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Comments on the Expanded Environmental Impact Report for Two Brookline Place

By WalkMassachusetts | January 22, 2010

January 22, 2010

Secretary Ian Bowles
Executive Office of Energy and Environmental Affairs MEPA Office
100 Cambridge Street, Suite 900
Boston, MA 02114

RE: Comments on the Expanded Environmental Impact Report for Two Brookline Place, Brookline, MA
EOEA #14522

Dear Secretary Bowles:

WalkBoston appreciates the opportunity to provide comments on the Expanded Environmental Impact Report for Two Brookline Place in Brookline. The proposal calls for construction of an 8- story building with space for medical and general office space. The site is a part of the Gateway East Development Area, for which the town has prepared a Public Realm plan, which, of course includes sidewalks throughout the area.

We are concerned about several of the details of the proposal and request that they be given further attention during upcoming work on the project. They are:

Pedestrian islands. Generous, large pedestrian refuge islands should be provided at the intersections where Route 9 crosses Washington/High Street, Pearl Street, Brookline Avenue and the proposed new crossing linking the bicycle and pedestrian paths inside the Emerald Necklace. After completion of the proposed development, Route 9 will remain a 6-8 lane boulevard, which is too wide for many pedestrians to cross within one sequence of traffic signal changes. A refuge will provide a safe place for pedestrians to wait for the next opportunity to cross traffic lanes legally and without jaywalking.

Intersection mitigation. It appears that only a few of the nearby intersections will be provided with mitigation of traffic impacts from the proponent’s project. Two locations cited in the document are Brookline Avenue and Pearl Street and Brookline Avenue and Washington Street. Pedestrian crosswalks and signal phases at these two intersections are critical to the overall success of the project and integral to the proposed pedestrian network in the Gateway East Public Realm Plan. On Washington Street large pedestrian refuge islands should be provided for the pedestrian crosswalk, and a pedestrian refuge island is also desirable on Pearl Street (but has not been singled out as an element of the Gateway East Public Realm plan).

Truck/pedestrian conflict. The loading zone for Two Brookline Place and the principal access point into the garage are both located on the portion of Pearl Street nearest Washington Street. The nearby new street intersection at Pearl/Juniper and Washington Streets may encourage pedestrians to use this portion of Pearl Street as they seek out the relatively short route between residential areas and direct access to the MBTA station. Pedestrians and trucks may come into conflict on this section of Pearl Street, depending on the frequency of the use of the loading zone and the vehicular traffic diverted to use the Pearl Street/Washington Street intersection. Conflicts between vehicles and pedestrians may also occur. Both of these issues should be addressed as the design moves forward.

Encouraging walking. Walking should be encouraged with good on-line walking directions, provision of area maps and through encouragement programs as an integral part of the proponent’s TDM program for local residents, workers and patients.

Thank you for the opportunity to comment on the Two Brookline Place Project.
Please feel free to contact us for any clarification or additional comments that you may need.

Sincerely,

Wendy Landman
Executive Director

Robert Sloane
Senior Planner

Environmental Notification Form (ENF) Alewife Brook Greenway MEPA #14431

By WalkMassachusetts | June 29, 2009

June 29, 2009

Secretary Ian Bowles
Executive Office of Energy and Environmental Affairs 100 Cambridge Street, Suite 900
Boston, MA 02114

RE: Environmental Notification Form (ENF) Alewife Brook Greenway
MEPA # 14431

Dear Secretary Bowles:

WalkBoston is pleased to review the Alewife Brook Greenway Environmental Notification Form (ENF). We have found the proposal extremely interesting, as it expands the off-road network of trails and walkways that are so important to metro arearesidents for transportation and recreation. The ENF details improvements that will be made for both pedestrians and bicyclists on a corridor between Alewife Brook MBTA Station and the Mystic Valley Parkway that leads through Cambridge, Somerville and Arlington, and has connections to the Minuteman Pathway, the Linear Park/Community Path route into Somerville, the Mystic River parklands and future paths into Belmont and Watertown.

This is an extremely important piece of the regional trail network. We are happy to endorse its construction and even happier to realize that it may be constructed relatively rapidly as part of the national stimulus construction agenda.

In our review, we noted a few concerns of importance to pedestrians:

1. The proposed network does not provide for fully separated bicycle and pedestrian paths.
In two segments of the proposed improvement (1. Between the Mystic Valley Parkway and Broadway; and 2. between Henderson Street and Massachusetts Avenue) there appears to be a partial separation of bicycle and pedestrian paths. By contrast, there is only a single path between Broadway and Henderson Street and between Massachusetts Avenue and the MBTA Alewife Station. This will result in an effective capacity of two 10’-wide paths in the areas of separated paths and only one 10’-wide path in the other parts of the corridor. We are concerned about the safety of pedestrians in portions of the corridor where the capacity is limited. In those areas, consideration should be given to a wider cross-section on the path to accommodate potential demand.

2. The proposal does not indicate whether there will be signage to can foster safe walking. Pedestrian safety in mixed walking and cycling traffic can be an issue of concern, depending on the volume of traffic that uses the paths. While we would prefer separate facilities that are clearly designated as such, it does not appear to be feasible throughout the entire corridor. We therefore suggest that signing and warnings be provided to make the route safe for all users. This might include, for example:

Lane separation lines for the north and south directions.
Signs warning pedestrians to stay to the right of the path.
Signs advising cyclists to ring a warning bell as they approach pedestrians from behind.
Route signs designating a cyclist trail along the paths that abut Alewife Brooke Parkway.

3. The Boardwalk parallel to Alewife Brook Parkway has the potential for becoming a bottleneck, as it accommodates all path traffic in a narrow corridor. The boardwalk overlooks and is cantilevered over the river in the section extending north of Henderson Street and is one of the most accessible portions of the pathways for nearby residents. It is also close to Dilboy Field, which has occasional special sports events. If the boardwalk accommodates both pedestrians and cyclists and is closely fenced on both sides, it has the potential for becoming heavily used and potentially unsafe for people on foot. Would it be possible to widen the boardwalk to at least 12 feet in this location?

4. Seating and observation areas should be maximized.The path promises to be a very pleasant route. Many people will want to sit occasionally along the route, and children, among others, will be interested in closely examining the stream.

5. For the security of people who are using the path lighting may be appropriate. Lighting of the paths would extend their usefulness to walkers and cyclists in evening hours and in fall and winter.

6. Crosswalks may be needed in several locations. Near the Dilboy Park baseball diamonds, a fence opening and curb ramp have been provided that appear designed to help people cross Alewife Brook Parkway. The addition of a crosswalk in this location would be appropriate. Other crosswalks should be examined to cross Alewife Brook Parkway at Massachusetts Avenue, at Matignon Road, at Powder House Boulevard (two curb ramps), and at Broadway. For continuity of the path network, a Mystic Valley Parkway crosswalk should be considered at the north end of this project.

Thank you for giving us the opportunity to provide comments on the ENF. Please let us know if you have any questions or need further detail.

Sincerely,

Wendy Landman
Executive Director

Robert Sloane
Senior Planner

Cc Dan Driscoll, DCR Bicycle and Pedestrian Planner

Route 181 Reconstruction Comment Letter

By WalkMassachusetts | November 18, 2008

November 18, 2008

Frank A. Tramontozzi, P.E.
Chief Engineer Massachusetts Highway Department
10 Park Plaza
Boston, MA 02116

RE: Route 181 Reconstruction and Minor Widening project in Belchertown, MA
Project File No. 604433

Dear Mr. Tramontozzi:

WalkBoston is the Commonwealth’s leading advocate for pedestrians and safe walking. We work throughout the state – encouraging walking, supporting pedestrian improvements and sponsoring walks. We have extensive experience in helping residents and local governments with pedestrian issues, safe routes to schools and safer street crossings and sidewalks.

We appreciate the opportunity to comment on the proposed reconstruction and minor widening of Route 181 in Belchertown and are pleased to have been notified by MHD about the project. We are commenting because we think there may be ways to further enhance pedestrian safety.

As we have seen in the plans, the project focuses on Route 181 between its intersection with Maple Street (the town center) and the Belchertown-Palmer town line. The reconstructed road will have two 11-foot wide travel lanes and 4-foot wide shoulders. The project will include safety improvement measures such as bicycle accommodation; sidewalk reconstruction; enhanced roadway drainage; improved sight distance in some areas; and installation of guardrail, pavement markings and signage.

We are concerned about pedestrian access in the Route 181 corridor for these reasons:

1. Safe Routes to Schools. WalkBoston is involved with a number of communities across the state in providing walking programs and encouragement, along with planning for physical improvements that could better accommodate children walking to school. In Belchertown, sidewalks connect to both the Center School on Rte 181 north of Maple Street and the Cold Spring School on Rte 181 at Old Springfield Road. Pedestrians going to schools are accommodated along Rte 181 by sidewalks between Maple Street and by a sidewalk between Old Springfield Road to a point about 2000 feet south on Rte 181. These sidewalks should be maintained and, if rebuilt, should be maintained at 4’ or 5’ clear walking width. Poles, signs or other impediments should not be located within the clear walking width.

2. Continuous sidewalk on at least one side of the street. Sidewalks are available on both sides of the street between Maple Street and Old Springfield Road and along only one side of Rte 181 to a point about 2000 feet south of Old Springfield Road. Sidewalks should extend outward for at least 1 mile from schools, assuming there are residences where students might live within that radius. Along Rte 181 south of Old Springfield Road and within 1 mile from the Cold Spring School, there appear to be residences that might warrant extending the sidewalk beyond the 2000’ length.

3. Crosswalks. Along Rte 181, crosswalks are provided at the intersection of Rte 181 and Maple Street and Rte 181 and Old Springfield Road. There is a single intersection with Rte 181 at Fuller Street that does not presently have a crosswalk. Consideration should be given to installation of crosswalks at the Fuller Street intersection, in addition to repainting the crosswalks at the two existing intersections.

4. Detailed design. Sidewalks already in place along Rte 181 should be reconstructed if possible – largely to bring them to a standard width. Care should be taken to assure that any widening of Rte 181 does not narrow sidewalk widths. Where possible, sidewalks should be separated from the roadway by a minimum of 4’ to provide greater safety and comfort for walkers along this relatively high speed road.

Thank you for the opportunity to comment on this project. We look forward to working with you and welcome any questions you may have.

Sincerely,

Wendy Landman
Executive Director

Bob Sloane
Senior Project Manager

Cc: MABPAB
MHD Commissioner Luisa Paiewonsky

Comments on Cambridge Discovery Park EOEA #13312 Final Environmental Impact Report

By WalkMassachusetts | November 7, 2005

November 7, 2005

Secretary Steve Pritchard
Executive Office of Environmental Affairs Attn: MEPA Office
100 Cambridge Street, Suite 900 Boston, MA 02114

RE: Cambridge Discovery Park, EOEA #13312 Final Environmental Impact Report

Dear Secretary Pritchard,

We were pleased to review the Final Environmental Impact Report for the Cambridge Discovery Park. It is gratifying when a project proponent makes considerable effort to comply with EOEA’s certificate.

EOEA’s DEIR certificate called for identification of pedestrian sidewalks, footpaths and bicycle facilities for the proposed development. As shown in the plans provided in the FEIR, the proponent indicates that they will construct all of their off-site pedestrian improvements as part of Phase I of the project, thus making these facilities available to help set non-auto commuting patterns.

The Proponent has agreed to take on significant responsibilities for constructing pedestrian pathways in and near the site. Especially noteworthy is the commitment by the proponent to construct and maintain a path through DCR’s Alewife Reservation on land lying between the proponent’s project and Alewife Station. This path will be wide, well-lighted for pedestrian safety, and maintained in all weather by the proponent.

The proponent has also agreed to take responsibility for improvements to the intersection of the EB Route 2 off-ramp and the entrances to the MBTA’s Alewife Garage. This intersection is of critical importance to pedestrians because several pedestrian pathways – both existing and proposed – will intersect: the Minuteman Bicycle and Pedestrian Path, the new pedestrian path from the proponent’s site through DCR’s Reservation, and the proposed Fitchburg cut-off pathway from Belmont. All three of these routes currently lead pedestrians through an unsignalized intersection that has heavy peak-hour traffic adjacent to the MBTA station. The improvements to be provided by the proponent are a major step in making the intersection safe for pedestrian access to the MBTA Alewife Station.

We remain concerned about maintenance of the sidewalks from the proponent’s site to the Alewife MBTA Station via the Route 2 off-ramp. Although sidewalks exist and may be improved by the proponent, WalkBoston is concerned that this pedestrian route may not be adequately maintained because of the overlapping responsibilities of governmental organizations and the proponent’s position that future developments by abutting landowners should bear incremental or additional costs for maintenance of this walkway. The lack of existing development on abutting land should not relieve the proponent of responsibility for maintaining the sidewalk until such time that another developer is on the scene and an agreement for sharing responsibility is reached.

The DEIR Certificate called for the creation of a pedestrian access master plan that takes a longer-range look at the area and develops a future pedestrian path network. The FEIR does not include this long- range plan. We request that it be added, and that it include three elements that would improve pedestrian access this site:

The proponent has agreed to make a contribution of $400,000 toward the design and construction of a footbridge (which would be constructed by others) over the Little River to the south bank multi- use paths. Since a plan for this footbridge is being actively pursued, it would be useful to know how paths from the proponent’s property would access it, even if the information must be tentative or diagrammatic. Possible locations for the bridge or paths are not shown on the maps.
The existing footbridge over Route 2 is not included or discussed in the planning for the site, even though it is noted on FEIR maps. All of the FEIR pedestrian facility maps (Exhibits 5-8, 5-9, 5-10, and 5-11) show the existing footbridge over Route 2. In addition, one of the maps (Exhibit 5-13) shows a bus stop on the north side of Route 2 that will require connection via the footbridge to the site. We wonder whether there are other pedestrian connections to the footbridge that should also be shown on a long-term plan for the area, such as through Thorndike Field in Arlington; or paths connecting the footbridge over Route 2 with the Minute Man Bike/Pedestrian Path. If such paths exist or are planned, it would be useful to show them on a long-term plan for the area to indicate options for people walking to the site from the Arlington side of Route 2. Again, the connections could be tentative or diagrammatic. The benefit of an Arlington footpath to the bridge would be to provide a shorter route to get to the proponent’s site and avoid a route that requires walking to the Alewife MBTA Station and backtracking to get to the site.
A pedestrian connection to the site from the west through Belmont via Frontage Road and Acorn Park Drive has been briefly mentioned as a longer-term goal. This should also be a part of the master plan for pedestrian facilities in the area. As part of this investigation, consideration might also be given to a sidewalk parallel to the south side of Route 2.

Thank you for the opportunity to comment on this project.

Sincerely,

Wendy Landman
Executive Director

Target Distribution Center Westfield Comment Letter

By WalkMassachusetts | November 7, 2005

November 7, 2005

Secretary Steven Pritchard
Executive Office of Environmental Affairs
Attn: MEPA office
100 Cambridge Street, Suite 900
Boston, MA 02114

RE: Target Distribution Center Westfield, MA Final Environmental Impact Report EOEA No. 13361

Dear Secretary Pritchard:

WalkBoston advocates for pedestrian safety, improved facilities, and programs to encourage walking throughout Greater Boston, and takes an active role in promoting pedestrian interests statewide. We offer our comments on the proposed Target Distribution Center in Westfield, MA that is projected to have approximately 860 employees and to generate 6,460 vehicle trips/day. The project site is located on Route 202 and just off Routes 10/202 approximately 4 miles from the city’s center.

Providing access for all modes is now a requirement in state law for new and reconstructed state roads and is being fully incorporated in the new MassHighway Design Manual to be published in January 2006. Access by foot and by bicycle is fundamental to the state’s smart growth policies and programs. We are also concerned Westfield may not address the needs of pedestrians, even when these needs could logically be part of the transportation mitigation of local commercial development.

In examining this FEIR, WalkBoston finds that pedestrian access and its relationship to transit and transportation demand management is given little consideration by the proponent, despite MEPA’s clear guidelines in the February 14, 2005 Certificate on the proponent’s DEIR. The Certificate reads as follows:

Transit: The FEIR should update its inventory of public transit bus services in the project area. The proponent should work with local officials to identify bus connections and potential shuttle bus services from activity nodes and residential areas to the project site.

Pedestrian and Bicycle Facilities: The DEIR described where sidewalks currently exist in the area. The FEIR should identify the proposed pedestrian (sidewalk) and bicycle facility improvements included with this project. Unless the proponent can obtain a letter from the City of Westfield or MHD stating that a sidewalk is unnecessary, I recommend a sidewalk along the site frontage on North Road (Route 202) and Falcon Drive. 2

Transportation Demand Management (TDM) Strategies: The FEIR should examine the full range of potential TDM strategies.

Comments offered by the Executive Office of Transportation (EOT) and the Pioneer Valley Planning Commission (PVPC) also express the need to address bus service and pedestrian facilities:

EOT – The site design should include transit amenities including a bus turnout and bus shelters to further encourage transit usage. The site design should identify sidewalk and/or pedestrian access between the building and the PVTA drop-off area. Bicycle and pedestrian routes in the vicinity of the site should be identified as well. And bicycle lockers and shower facilities should be provided to encourage pedestrians and bicyclists.

PVPC – The DEIR acknowledges the potential for public transit service serving the proposed development using the Pioneer Valley Transit Authority (PVTA) Blue 23 bus route. While the proponent has committed to work with the PVTA to develop transit service for the site, no information was provided in the DEIR on how pedestrians would access the proposed new on site bus shelter. Consequently we’d urge that the FEIR provide additional information addressing the actual location of the proposed bus stop as well as depict and explain and show how pedestrian access will be provided from the Target development to this new bus stop.

The FEIR does not respond adequately to these requests. No details are provided on proposed pedestrian and bicycle facility improvements for the project, either in the plan or in the text. It says only: “The appropriate and safe pedestrian amenities on site, including necessary parking lot crosswalks, lighted pedestrian travel ways, and the like are being considered for the final design of the site.” (from Section 2.8.2, p. 2-48; repeated in Response EOT .08, Appendix B, p. 8-4 and Response PVPC.03, Appendix B, p. 8-9). This is not a sufficient commitment to pedestrian access.

WalkBoston believes that policy direction is needed to determine how pedestrian access should be addressed by this (and other) project(s). The absence of existing pedestrian facilities is not an indication that they are not needed. WalkBoston suggests clear and careful consideration to determine an appropriate approach. Among the possible choices are the following:

a. Over time, perhaps with state EOEA or MHD assistance, the city will provide sidewalks on at least one side of all major roads that provide access to employment.

b. Over time, working with local municipalities and EOEA, MHD will provide sidewalks on at least one side of major state highways near urban and suburban employers.

c. The city or MHD will request all major employers to construct sidewalks from their building’s employee entrances to the sidewalks that parallel major local roads or state highways. The city, MHD or the employer will then construct bus stops and sidewalks to connect to employer-constructed on-site sidewalks.

d. In the vicinity of new development, the city or MHD will require project proponents to construct sidewalks along roadways connecting to transit and schools.

e. The city or MHD will leave most, if not all, of the decisions regarding sidewalks along state highways or local roads near new development to project proponents.

WalkBoston believes that MHD and the City of Westfield should provide clear policy direction to the project proponent about their responsibilities for pedestrian access. At that point, a variety of options exist for pedestrian accommodation. EOEA, in its DEIR Certificate, has taken a position that sidewalks should be provided along North Road (Route 202) and Falcon Drive, unless the City or MHD waives the requirement. The certificate also calls for public transit bus services to the project site, and for the identification of nearby bus stop locations and their relationship to sidewalks providing access to the employee entrance to the site. Since many of the vehicular improvements to be provided as mitigation measures for the project are off-site, it is reasonable to also require off-site pedestrian mitigation measures. Among the options for pedestrian access are the following:

1. A sidewalk along North Road (Route 202) – From the FEIR, it appears that the proponent has designed an auto access road that parallels North Road (Route 202) through most of the site. A sidewalk could be constructed along this road. To avoid security problems, the sidewalk could be located outside the perimeter fencing and adjacent to North Road (Route 202). This sidewalk would provide the first step toward EOEA’s ultimate goal of providing a sidewalk along the full length of North Road (Route 202) in the city.

2. A sidewalk along Falcon Drive – From the FEIR, it appears that the proponent owns very little property along Falcon Drive. However, placing a sidewalk within its property could become part of EOEA’s long-range vision for sidewalks along the full length of Falcon Drive.

3. A sidewalk from the site to North Road (Route 202) – From the FEIR, a pedestrian sidewalk to North Road (Route 202) seems possible along the side of the building adjacent to employee parking, presumably connecting to the employee entrance to the distribution center building. Figure 1-3 FEIR Proposed Conditions Plan (p. 1-6) and Figure 1-5 FEIR Operations Plan (p. 1-10) show auto access directly from North Road (Route 202) This access gate is approximately 2000 feet from the intersection of North and Southampton Roads. It is labeled “emergency vehicle access and gate.” This access gate could also serve pedestrians.

4. A sidewalk from the site to a bus stop – Bus travel to the site should be encouraged through clear routes and signage and direct, well-marked paths for pedestrians between transit stops and the pedestrian entrance to the proponent’s building. The FEIR notes that the Pioneer Valley Transit Authority Blue 23 weekday and Saturday bus routes pass the site on North Road (Route 202) and also on Southampton Road (Routes 10 and 202). Yet the FEIR contains no indication that workers may arrive by transit or estimates of transit’s potential for serving employees coming to or leaving the site. Nor does the FEIR specify where transit stops and sidewalks might be best located to serve employees, or even from which direction or gate the riders would come.

The bus rider’s pedestrian access from Southampton Road is particularly daunting. If bus-riding employees must access the site from a bus stop on Southampton Road and walk via Southampton Road/Falcon Drive to the Target Warehouse employee entrance, they must walk over 4,000 feet. In addition, without sidewalks, walking along these routes is potentially dangerous. This would deter even the most dogged bus-rider/pedestrian.

By contrast, a bus stop near the North Road emergency access/gate that is connected via sidewalk to the employee entrance to the distribution center could be less than 400 away from the entrance. With this option, bus stops for riders coming from either direction could be established on the two sides of North Road, with a walkway from the bus stops through the North Road emergency vehicle access/gate and up to the employee entrance. For security purposes, access for people on foot through the North Road emergency vehicle access/gate could be provided by electronic gate control mechanisms. Analysis of this possibility has not been included in the FEIR and should be provided during the next steps of the environmental permitting process. In addition to a bus stop and appropriate sidewalks, a protected pedestrian crossing of North Road should be reviewed. Such review should include the examination of a pedestrian-activated signal.

5. Improvements along Southampton Road (Routes 10/202) – Local comments mentioned the need for sidewalks for school and day care students attending classes in three buildings located along Southampton Road. It seems appropriate to provide new sidewalks along those portions of Southampton Road that are to be improved as part of the project’s mitigation program.

In the long run, sidewalks will need to be constructed wherever there are students who could walk to their schools from homes or bus stops. Indeed, the state is now involved in an extensive Safe Routes to Schools program that will lead to a greater demand for new or improved pedestrian and bicycle facilities for children to use in going on foot or by bike to their school buildings. They should be included in this project.

Finally, WalkBoston suggests that draft commitments for the Section 61 findings (Section 7.0 of the FEIR) should contain pedestrian and bicycle facilities.

Thank you for the opportunity to comment on the FEIR for the Target Distribution Center in Westfield. We hope that our concerns about pedestrians can be addressed as you examine the proposal and as it moves toward implementation.

Sincerely,

Ann Hershfang Wendy Landman
Advocacy Committee Chair Executive Director

Cc Astrid Glynn, Office of Commonwealth Development Tom Cahir, Executive Office of Transportation Tim Brennan, Pioneer Valley Planning Commission