April 18, 2017

Matthew Beaton, Secretary
Executive Office of Energy and Environmental Affairs (EEA)
ATTN: Alex Strysky, MEPA Office 100 Cambridge Street, Suite 900
Boston MA 02114

Brian Golden, Director
Boston Planning and Development Agency
ATTN: Michael Rooney
One City Hall Square
Boston, MA 02201-­‐1007

RE: Comments on the DEIR/DPIR for the Back Bay/South End Gateway Project
MEPA: #15502

Dear Sirs:

WalkBoston has reviewed the DEIR/DPIR for Back Bay/South End Gateway Project. We are concerned about this project because of its impacts on rail and bus transportation, walking and biking. With the latest submission of plans for the project, we continue to see serious issues with pedestrian access into, through and around the site. These are described below.

1. Inappropriate relocation of the layover site for the Route 39 bus
   The proposal states that the layover site for the Route 39 bus will be located “off-­‐site.” Back Bay Station is one end of this bus route, which is one of the busiest in the MBTA system, serving Back Bay, the Fenway and Jamaica Plain. Buses congregate here and wait until schedules require them to return to the main route.The proposal for Route 39 is to remove it entirely from the streets directly connected to Back Bay Station, and to truncate the route before it connects with the Orange Line or the commuter rail/Amtrak services. Reducing the convenience of connections between Route 39 and other portions of the MBTA system will result in negative impacts on transit riders that should be avoided. We urge the City and MEPA to require the proponent to bring Route 39 back to the station. A possible layover site is Trinity Place (between Stuart and St. James Streets). The re-­‐routing of the 39 bus route to this layover location could provide a reasonable drop-­‐off and pick-­‐up solution on Stuart Street, which will have direct pedestrian access in Back Bay Station for bus riders.
2. Sidewalks that surround the site
   Sidewalks along the Dartmouth Street side of the project, where foot traffic is already heavy and likely to increase due to the new development, have been widened to a minimum of 13 feet, as shown in Fig, 3.8b. Sidewalks along Stuart Street are to be a minimum of 11 feet, as shown in Fig, 3.8c, perhaps reflecting the proponent’s projection of likely foot traffic on this side of the site. Along Clarendon Street, sidewalks range from 9 to 15 feet, as shown in Fig. 3.8d; it is not entirely clear if the 9’ width is a result of the footprint of the proposed residential building.Sidewalks may not be sufficiently wide, especially if street trees, planters or bicycle parking are also accommodated in the width otherwise available for pedestrians.A large public plaza is proposed at the Clarendon Street intersection to replace the existing forecourt to the east entrance to the station. Here sidewalks are very wide and the plaza offers generous open space. Much of this plaza appears to be for passive use to people walking by, although there is a retail space provided in one corner that, if used as a restaurant, might result in tables on the outdoor plaza.We are pleased to see that the principal entrance to Back Bay Station on Dartmouth Street is enhanced by the addition of major new entrances framed by the arch and a design that focuses on providing continuity of the sidewalk and interior surfaces to unite them and welcome users. An enlarged Dartmouth Street crosswalk that is 60 feet wide along the site’s frontage will be centered on the new entrance. Taxi zones are provided both north and south of the main entrance.We are pleased that the proponents have increased sidewalk widths by comparison to the earlier proposals.
3. Movement on sidewalks around the perimeter of the project
   The project site is in a pedestrian-­friendly portion of the city. There are more people walking along and crossing the perimeter streets than there are drivers using these same streets. For example, looking at the existing condition pedestrian volumes counted between 8:00 and 9:00 AM in 2016 in Figure 4.6a, we note that there are 2,253 people crossing Dartmouth in front of Back Bay Station, 1,264 walkers crossing on the east walk of the Stuart Street/Dartmouth Street intersection, 1,098 pedestrians crossing Stuart Street at Trinity Place, and 1,646 pedestrians crossing Stuart Street at Clarendon Street. A total of 1,071 pedestrians crossed the garage driveway on Clarendon Street during this period.Meanwhile, in the same period, Dartmouth Street handles 486 cars northbound and 703 cars southbound. Stuart Street handled 784-­1,057 vehicles in this period and Clarendon Street handled 503-­625 vehicles.Although there are 15 different projections of vehicular traffic under alternative futures, there are no projections at all of pedestrian traffic. There are, however, projections of pedestrian level of service at selected intersections. See Table 4.12.3 page 4-­126. The accompanying text states that PLOS doesn’t change between Existing, No-­build and Build Conditions because walk times and cycle lengths will not change. Is this a valid conclusion without he benefit of projecting future pedestrian volumes?Based on the data that was provided, it appears that there are about three times as many pedestrians as there are cars during peak hours.
4. Movement across the sidewalk – Dartmouth Street
   In order to improve access to the proposed parking garage, the proponent has proposed changing Turnpike access patterns and partially shifted vehicle access and egress away from Stuart and Clarendon Streets and provided a new exit onto Dartmouth Street. These changes directly affect pedestrian safety at the principal pedestrian access to Back Bay Station.As shown on the proponent’s plans, the proposed vehicular exit from the garage is in an inappropriate location on Dartmouth Street. The exit ramp will pose a hazard for pedestrians on this portion of Dartmouth Street, where thousands of people (see numbers in Section 3 above) are walking during peak hours. This location is an especially busy and important place for pedestrians walking to, through and making connections to transit.Shifting the location of Turnpike access so significantly by removing a major access point to the westbound Turnpike in the midst of Back Bay and requiring all drivers to use alternative access on Huntington Avenue does not make sense for this part of the City. This does not seem an appropriate choice in the context of Boston’s adoption of Vision Zero and the City’s declaration in GoBoston 2030 that Boston will “prioritize the movement of people over cars.”
   WalkBoston does not believe that it is in the interest of public safety and convenience to shift existing vehicular access so that it results in a garage exit ramp in a congested pedestrian zone. An alternative to this garage exit ramp should be developed.
5. Movement across the sidewalk -­Clarendon Street
   On the Clarendon Street side of the property, there are multiple garage entrances and exits as there are today, and the sidewalk needs very careful treatment to protect pedestrians. The proposal to add a bulb out to shorten the Clarendon mid-­‐block pedestrian crossing is a good idea. As noted above, WalkBoston believes that Clarendon Street is a better location for garage and Turnpike access than the proposed Dartmouth Street garage exit and circuitous Turnpike access.The new plaza on the Clarendon Street side of the property has been designed with a drop-­‐off lane that doubles as a route for delivery and service vehicles for the residential and retail occupants of the structure. The drop-­‐off lane occupies what appears to be about 40% of the plaza, and raises the question of whether it needs to be this size.If the space is being used primarily for vehicular needs – drop-­offs, taxis, deliveries, service, and potential bus storage – that colors the manner that the design might take for the plaza. If, on the other hand, some of the vehicular needs could be transferred to the street – perhaps with some widening to accommodate the intended use. Getting rid of the drop-­off lane would considerably improve the potential for this plaza to be genuinely pedestrian-­friendly, and open it to other retail uses that would enhance the productivity and attractiveness of this end of the property.
6. The station area concourse
   We are gratified that the proponent enlarged the proposed waiting area, rather than transforming it into a retail facility. However, we continue to be concerned about the redesign 4 of the concourses to narrower passageways lined by many retail facilities. New retail activity will increase in the number of pedestrians to accommodate on the narrowed concourses. The relocation of the commuter rail and Amtrak ticket offices to a new location at a substantial distance from either the waiting area or the entrances to the rail platforms seems ill-­‐advised. The proposed new location is deeper within the station area, much closer to the east entrances than to the likely more important west entrances. It is also indistinguishable from adjacent retail stalls that may or may not have relevance for rail travelers. The proposed layout is occurring during a period of reduction in the number of small retail businesses in many locations, including central Boston and the Back Bay. Active ticket offices in a central location may be more important to bolster other retail outlets, and benefit the management and rental of retail stalls throughout the station area.
7. Construction on the rail station platforms
   The proposal calls for use of the station platforms for supports for the new high-­‐rise building being built in the Station East portion of the project. These new obstructions narrow the platforms for waiting or alighting passengers and add complexity in an environment where moving to or from access points is already complicated. This is true of both the Orange line platform, serving both directions for subway passengers and the southernmost railway platform serving commuter rail passengers to and from the south and southwest, including Providence, New York, Washington and the entire eastern seaboard.Using the existing rail platforms for construction of these supports will obstruct passenger traffic during construction as well as after completion. Designs should be carefully integrated with existing obstructions such as columns to minimize interference with passenger traffic flow.

We are very concerned about the changes proposed for the station, the bus layover facility, the vehicle circulation, sidewalks and interior passageways. We would appreciate your consideration of our comments and look forward to your responses to them. Please feel free to contact WalkBoston with questions you may have.

Sincerely,

Wendy Landman                                               Bob Sloane
Executive Director                                             Senior Project Manager

Cc City Council President Michelle Wu
City Councilor Josh Zakim
Ellis South End Neighborhood Association
Bay Village Neighborhood Association
Neighborhood Association of Back Bay