Category: Comment Letter

Comment Letter on American Rescue Plan Act (ARPA) Funding focusing on the areas of Economic Development: Transportation/Arts & Tourism/Climate/ Infrastructure

Comment Letter on American Rescue Plan Act (ARPA) Funding focusing on the areas of Economic Development: Transportation/Arts & Tourism/Climate/ Infrastructure

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September 9, 2021

Joint Committee on Ways and Means and the House Committee on Federal Stimulus and Census Oversight

To: Senator Michael J. Rodrigues, Chair Shared with Erin Walsh at Erin.Walsh@mahouse.gov

RE: WalkBoston Comments on American Rescue Plan Act (ARPA) Funding focusing on the areas of Economic Development: Transportation/Arts & Tourism/Climate/ Infrastructure

Dear Senator Rodrigues and Committee Members:

WalkBoston is Massachusetts’ primary pedestrian advocacy organization, working across the Commonwealth to make it safer and easier for people to walk for all activities of daily living such as access to transit, school and jobs. The COVID-19 pandemic gave stark evidence that walkable neighborhoods and communities are critical to physical and mental health, to reducing isolation and to the resilience of all Massachusetts residents and their neighborhoods.

As recent research has shown, “Creating walkable environments with greenspace can help combat chronic and infectious disease pandemics” (L. Frank; Treating two pandemics for the price of one: Chronic and infectious disease impacts of the built and natural environment).

We urge the Senate to ensure that ARPA funds are used to help improve walkability and greenspace in communities and neighborhoods that were disproportionately affected by COVID-19.

The key components of the transportation system that support walking include:

  • Speed management. We need measures to control, and often reduce, speeds on Commonwealth roadways so that they are safe for all roadway users. During the initial months of the pandemic, there was dangerous speeding on roadways across Massachusetts. MassDOT’s ongoing initiative to create tools and measures to set and manage safe speeds on all MassDOT roadways (other than limited access highways) needs the support and encouragement of the legislature to ensure its success, and then to provide the funds to bring those same measures to municipal roads as well.
  • Safe connections to transit. As we learned during the pandemic, essential workers are more dependent on transit than many others. We need fully accessible transit and bus stops throughout Massachusetts, including safe street crossings and sidewalk connections to adjacent neighborhoods. These are crucial to a transit system that works for everyone.
  • More local funding to repurpose public space. The overwhelmingly popular MassDOT Shared Streets and Spaces program that was introduced in response to the pandemic has demonstrated that municipalities are interested and ready to rethink how they use their streets to enable more and safer outdoor recreation, commerce, community activities, and mobility.
  • Chapter 90 and Complete Streets. Chapter 90 funds have been traditionally used to build and maintain municipal roads without requirements that sidewalks and crosswalks be included. We suggest that the Committee review this standard and consider including Complete Streets measures within Chapter 90, similar to those requirements set by the legislature for MassDOT roadways.
  • DCR Parkways. DCR’s recently released (and long delayed) Parkway Master Plan clearly demonstrates that immediate action is needed to vastly improve safety for people bicycling and walking. Parkways are cultural and historic landmarks and should remain fully integrated components of parks and open spaces, used and enjoyed by people for walking, rolling, and riding as originally intended. With a commitment to accelerated improvement in partnership with MassDOT, parkways should remain under DCR’s purview. We urge the legislature to set funding and regulatory standards for DCR as follows:
    • Adopt MassDOT’s Complete Streets guidelines as their default design standard for all parkways; ○ Utilize MassDOT crash portal data to implement quick-build improvements on the most dangerous parkway roads and intersections within the next 12 months;
    • Align its parkway speed limits with local speed limits, especially in municipalities where the default speed has been reduced to 25 miles/hour or less;
    • Provide DCR with the budget needed to complete the recommendations in the DCR Parkway Master Plan;
    • Require DCR to set measurable goals to reduce the number of serious and fatal crashes on DCR roadways and report publicly and annually on progress toward these goals; and
    • Require DCR to add analysis and recommendations for several key parkways currently missing from the plan.

Thank you for the opportunity to comment.

Stacey Beuttell
Executive Director, WalkBoston

Channelside DEIR/DPIR comments

Channelside DEIR/DPIR comments

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August 20, 2021

Secretary Kathleen A. Theoharides
Executive Office of Energy and Environmental Affairs
Attn via email: Alex Strysky (alexander.strysky@state.ma.us )

Director Brian Golden
Boston Planning and Development Agency
Attn via email: Aisling Kerr (Aisling.Kerr@boston.gov)

Re:  Channelside DEIR/DPIR comments

Dear Secretary Theoharides and Director Golden:

WalkBoston, LivableStreets Alliance, Boston Cyclists Union, FPNA and MassBike are submitting our joint comments on the Channelside Project regarding transportation within and to the development site. 

We have focused our comments on the broad and underlying transportation conditions that will impact the existing and future neighborhood as well as the residents and workers who will occupy the proposed 1.4 million SF development that is undergoing review. While we have detailed comments on several aspects of the proponent’s site design and proposed mitigation, these are issues that later project phases could address.

We are pleased that the proponent has fully embraced the idea of Transit Oriented Development (TOD) and Complete Streets designs, and has provided travel projections for the project that predict a net total of 4,633 trips generated by the site of which 4,089 are walking, biking and transit trips – an impressive 88% of all trips! We also applaud the plan to redevelop what currently is non-permeable parking lot pavement into a park and pathway system which will help control the impacts of tidal flooding along the channel.

However, we are disappointed and concerned that the DEIR/DPIR devotes so little analysis of future conditions and, more specifically, how these thousands of trips will be served. Section 4.4 Transportation Build (2028) Condition of the document devotes (excluding maps and tables) ½ page to bike accommodation, 2 pages to transit, and 0 pages to walking (this notwithstanding that both walking and transit mode shares will depend on pedestrian facilities – including especially walking access from South Station and Broadway Station). And we are disappointed the project team is seeking to “not overburden” a transit system which currently does not serve this area sufficiently, instead of actively increasing capacity and service in advance of the rapid growth expected at Channelside. This development cannot be “Transit Oriented” without providing for increased transit usage.

Unfortunately, the DEIR/DPIR is following the precedent of several prior development projects in the Seaport, South Boston and Fort Point Channel neighborhoods, by focusing on this project in isolation of the rapid transformation that is occurring around it. Given the growth of these neighborhoods over the course of the last two decades, continuing to review all development projects in the area as single projects and not more holistically as a large agglomeration of projects that together require significantly better transit, walking and biking conditions to work well for its residents, workers, visitors and businesses, risks the future success of this, and many other projects in the area. 

Continuing down this piecemeal development planning path is unsustainable for the neighborhood and the City, and places undue burden on individual developments to solve problems that may include their project yet go beyond their boundaries. This parcel at 244-284 A Street is a crucial connection to a network of safe bicycling and walking routes that flow throughout the city, and needs to be incorporated into a vision of a connected, sustainable, and safe waterfront trail and harborwalk that includes all of the City’s waterfront neighborhoods.  

We ask that MEPA require the City of Boston (along with MassDOT, the MBTA and Massport) to complete, fund and begin the implementation of the South Boston Transit Study prior to advancing the permitting of new projects. We believe that without such action the proponent’s project (along with existing and other new development projects) will choke the neighborhood with traffic, provide insufficient transit service, not include an accessible sidewalk system (both within the development zone and connecting to South and Broadway Stations), and lack safe bicycle facilities connected to a larger network for those most vulnerable on our roads.

We have included below excerpts from the MEPA and BPDA Scopes for the project that we believe call for an analysis of how all trips (auto and non-auto) trips will be managed and provided for. We do not think that the DEIR/DPIR answers these scope items.

MEPA Scope

Trip Generation

The DEIR should fully describe and document existing and proposed pedestrian and bicycle facilities, transit operations and roadway and intersection conditions within the study Area. (page 9)

The TIA should describe the project’s anticipated transportation impacts and identify appropriate mitigation measures. The Proponent should indicate a clear commitment to implement proposed mitigation measures and describe the timing of their implementation, including whether measures are implemented based on phases of the project or occupancy levels. (Page 10)

Multimodal Facilities

It should describe all existing and proposed pedestrian facilities, including sidewalks, crosswalks, bicycle paths and bicycle parking spaces, located within the study area. The DEIR should review the regional pedestrian and bicycle network, evaluate the safety and capacity of the network and describe potential measures to enhance connections between the site and other locations and routes. (page 9)

BPDA Scope

“Melcher Street will be another important pedestrian connection for the site and its high volume of transit users connecting to South Station. Pedestrian safety and accessibility improvements are needed and a priority for the City and community. The Proponent should commit to working with the city to design and construct improvements to Melcher Street from A Street to Summer Street.”  (Page 26)

“Additional transit service and connectivity was identified as needed on A Street in the South Boston Seaport Strategic Transit Plan [and the South Boston Dorchester Avenue Transportation Plan]. “The Proponent should provide shuttle service on A Street that connects to Broadway Station and South Station. Ideally, this would be in partnership with other corridor stakeholders such as State Street Bank that currently provides shuttle service on A Street that connects to South Station. New and efficient shuttle stop locations will need to be determined through consultation with the City.” (Page 26) 

A private shuttle service should not be the primary solution for the lack of transit access in the area. In addition to completing the long awaited South Boston Transit Study, the City should study the potential implementation of BRT on Congress Street, connecting to North Station. Additionally the MBTA is currently in the process of a system-wide bus network project. Now is an opportune time to work with the MBTA to determine the current and future transit needs for the neighborhood and to build the necessary street infrastructure to accommodate that bus service (i.e. bus lanes, new bus stops, ADA accessible sidewalks). 

Sincerely,

Stacey Beuttell, WalkBoston Executive Director
Stacy Thompson, LivableStreets Alliance Executive Director
Becca Thompson, Boston Cyclists Union Executive Director
Tom Ready, FPNA
Galen Mook, MassBike Executive Director

Cc Senator Nick Collins
Representative David Biele
Boston City Councilor Ed Flynn
Boston City Councilor Michael Flaherty
Greg Rooney, Commissioner, Boston Transportation Department
Jamey Tesler, Secretary, MassDOT
Steve Poftak, General Manager, MBTA
Joel A. Barrera, Massport, Director of Strategic and Business Planning
Patrick Sullivan, Seaport TMA, Executive Director
David Gibbons, Executive Director, MCCA
Rick Dimino, President and CEO, ABC

Fenway Project PNF Comment Letter

Fenway Project PNF Comment Letter

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July 21, 2021

Aisling Kerr, Project Manager

BPDA via email Aisling.Kerr@boston.gov

Re: Fenway Project PNF

Dear Ms. Kerr:

WalkBoston has reviewed the PNF for the Fenway Project with respect to its impacts and benefits for people walking and using transit.

We are very pleased that the proponent is proposing significant improvements to the walking environment in the Fenway neighborhood and giving detailed attention to the needs of people walking, taking transit and bicycling. The proposed transformation of Jersey Street into a pedestrian-only space will provide an exciting new way to experience Fenway Park (on non-game days) and add amenities for residents and visitors to the Fenway neighborhood. We support the proponent’s plans to modify the street system in and around the multi-site project in order to create more space for pedestrians and for people enjoying what will essentially become a new open space in the neighborhood.

Overall we believe the project will benefit pedestrians on the streets and sidewalks of the Fenway. We urge the proponent to continue working with WalkBoston and other advocates and with the City of Boston to refine several elements of the design as the project proceeds.

  • Sidewalk/Bus stop/Bike interactions – The project includes re-designed streets (in particular Brookline Ave.) with new protected bike lanes. We urge the proponent to continue working with WalkBoston, the Boston Disabilities Commission, the MBTA’s Office of Systemwide Accessibility, the Boston Transportation Department and the bicycle advocacy community to ensure that the designs meet the needs of all sidewalk, transit and street users.
  • Transit operations – In order to achieve the mode shares that the proponent, the residents of the Fenway, the employers in the area, the City and all of us interested in reducing GHG emissions hope for, the operations of the many bus routes in the neighborhood will need careful attention to ensure that they are enhanced by the changes in the street system and urban design.
  • Paving surfaces – Some of the sketches shown suggest paving stones or other materials. We ask that all paving materials be fully accessible and comfortable for all people walking or using mobility assistance. We also ask that the proponent take into account the needs of providing good snow clearance on all of the sidewalks and also that they commit to providing such clearance.
  • Sense of welcome for all – The redesign and re-purposing of Jersey Street and all of the city blocks included in the project presents exciting opportunities for walkability. It also presents some challenges to ensuring that the spaces and places are not managed or curated in ways that could feel privatized or exclusive and less than fully welcoming to people of all races, incomes and ages. We urge the proponent to work with diverse community groups and individuals from a variety of Boston neighborhoods to ensure that the sense of welcome includes everyone.

Thank you for the opportunity to provide comments.

Sincerely,

Wendy Landman

Senior Policy Advisor

Comment Letter on Support for S.2277/H.3413 in order to increase regional transit accessibility in the Commonwealth – A pedestrian’s perspective

Comment Letter on Support for S.2277/H.3413 in order to increase regional transit accessibility in the Commonwealth – A pedestrian’s perspective

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July 30, 2021
Joint Committee on Transportation

To: The Honorable William Straus, House Chair & The Honorable Joseph Boncore, Senate Chair

RE: Support for S.2277/H.3413 in order to increase regional transit accessibility in the Commonwealth – A pedestrian’s perspective

Dear Chairs Straus and Boncore,

Thank you for allowing public testimony on this critical and timely piece of legislation. Regional transit is integral to mitigating the climate crisis and connecting communities hardest hit by the pandemic to essential resources to help us become a healthier, more sustainable Commonwealth. We must act now to ensure Regional Transit Authorities (RTAs) have access to stable, sustainable funding to improve and expand upon service to meet communities’ needs.

WalkBoston works in communities across the Commonwealth to build safer, more accessible pedestrian infrastructure to help ensure that people of all ages, abilities and incomes can comfortably access economic opportunities, connect to their communities, and reach other essential destinations. However, people can only get so far on foot. To achieve true mobility justice, we must adequately fund public transit and expand services to reach the communities that need it most. 

The benefits of investing in RTAs will be felt throughout the state but especially in communities at the frontlines of the climate crisis, the ones least served by public transit options. In Gateway Cities and other historically underinvested communities in particular, car-dominated infrastructure and vehicle emissions continue to harm frontline communities by polluting the air, producing a heat island effect, and creating unsafe roads that claim hundreds of lives every year. Robust regional transit services will make our state healthier, safer, more climate resilient, and create much-needed economic opportunity. 

RTAs are a lifeline to residents in over 250 communities beyond the reach of the MBTA, including essential workers who have relied on RTA service throughout the pandemic, and a disproportionate number of people with very low incomes, older adults, and people with disabilities. Chronic underinvestment and limited technical support have made it challenging for the RTAs to maintain stable service level and make sustainable improvements to service. We must pass S.2277/H.3413 to increase accessibility of regional transit for the 55% of Commonwealth residents who live in an RTA service area.

WalkBoston stands ready to work with the Legislature to strengthen our regional transit system and urges you to report S.2277/H.3413 favorably out of this committee without delay. Every Massachusetts resident should have the freedom to get to their daily destinations in an affordable and accessible way, and should not be deprived of that freedom because of underinvestment by the Commonwealth. 

Thank you again for the ability to submit testimony. Please reach out with any questions.

Sincerely,

Ayesha Mehrotra
Program Associate, WalkBoston

Comments on Re-Imagining Massachusetts’ Post-Pandemic Transportation System

Comments on Re-Imagining Massachusetts’ Post-Pandemic Transportation System

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Comments to Senate Committee on Re-Imagining Massachusetts Post-Pandemic Resiliency

Dear Senator Hinds and Committee Members:

WalkBoston is Massachusetts’ primary pedestrian advocacy organization, working across the Commonwealth to make it safer and easier for people to walk for all activities of daily living such as access to transit, school and jobs. The COVID-19 pandemic gave stark evidence that walkable neighborhoods and communities are critical to physical and mental health, to reducing isolation and to the resilience of all Massachusetts residents and their neighborhoods.

In light of the pandemic, we have learned that key components of the transportation system to support walking should include:

  • Speed management. We need measures to control, and often reduce, speeds on Commonwealth roadways so that they are safe for all roadway users. During the initial months of the pandemic, there was dangerous speeding on roadways across Massachusetts. MassDOT’s ongoing initiative to create tools and measures to set and manage safe speeds on all MassDOT roadways (other than limited access highways) needs the support and encouragement of the legislature to ensure its success, and then to bring those same measures to municipal roads as well.
  • Safe connections to transit. As we learned during the pandemic, essential workers are more dependent on transit than many others. We need fully accessible transit and bus stops throughout Massachusetts, including safe street crossings and sidewalk connections to adjacent neighborhoods. These are crucial to a transit system that works for everyone.
  • More local funding to repurpose public space. The overwhelmingly popular MassDOT Shared Streets and Spaces program that was introduced in response to the pandemic has demonstrated that municipalities are interested and ready to rethink how they use their streets to enable more and safer outdoor recreation,
    commerce, community activities, and mobility.
  • Chapter 90 and Complete Streets. Chapter 90 funds have been traditionally used to build and maintain municipal roads without requirements that sidewalks and crosswalks be included. We suggest that the Committee review this standard and consider including Complete Streets measures within Chapter 90, similar to those requirements set by the legislature for MassDOT roadways.
  • DCR Parkways. DCR’s recently released (and long delayed) Parkway Master Plan clearly demonstrates that immediate action is needed to vastly improve safety for people bicycling and walking. Parkways are cultural and historic landmarks and should remain fully integrated components of parks and open spaces, used and enjoyed by people for walking, rolling, and riding as originally intended. With a commitment to accelerated improvement in partnership with MassDOT, parkways should remain under DCR’s purview. We urge the legislature to set funding and regulatory standards for DCR as follows:
    • Adopt MassDOT’s Complete Streets guidelines as their default design standard for all parkways;
    • Utilize MassDOT crash portal data to implement quick-build improvements on the most dangerous parkway roads and intersections within the next 12 months;
    • Align its parkway speed limits with local speed limits, especially in municipalities where the default speed has been reduced to 25 miles/hour or less;
    • Provide DCR with the budget needed to complete the recommendations in the DCR Parkway Master Plan;
    • Require DCR to set measurable goals to reduce the number of serious and fatal crashes on DCR roadways and report publicly and annually on progress toward these goals; and
    • Require DCR to add analysis and recommendations for several key parkways currently missing from the plan.

Thank you for the opportunity to comment.

Stacey Beuttell
Executive Director, WalkBoston
405 Waltham Street, Suite 309
Lexington, MA 02421
617-367-9255