Channelside DEIR/DPIR comments
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