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Comments on the MGM Springfield DEIR

January 31, 2014

Secretary Richard K. Sullivan, Jr.
Executive Office of Energy and Environmental Affairs (EEA)
100 Cambridge Street, Suite 900
Boston MA 02114

RE: Comments on the MGM Springfield Draft Environmental Impact Report
EEA #15033

Dear Secretary Sullivan:

WalkBoston has reviewed the Draft Environmental Impact Report for the MGM Springfield proposal and offers the comments below.

Within the DEIR, there are some changes in the dimensions of the plan. The proposal now includes a somewhat smaller, 501,108 square feet casino resort that includes retail/restaurant uses and banquet facilities in addition to gaming space. Adjacent to the casino will be a somewhat smaller 250‐room hotel, 54 residential units, and an expanded, 159,397 SF retail and entertainment center to be known as Armory Square. A somewhat smaller, 3,740 space on-site multi-level parking garage will be provided. In most cases, these alterations to the plan do not appear to affect volumes or paths for walkers.

The ENF Certificate provided by Secretary Sullivan called out additional analysis to be included in the DEIR, and specified that the proponent was to meet with WalkBoston about our comments on the ENF. The Secretary’s Certificate included this language:

“I strongly encourage the proponent to consult with WalkBoston during the preparation of the DEIR to identify opportunities to enhance the development of pedestrian access to and within the site as well as incorporation of safe pedestrian access for off-site roadway improvements.”

The proponent did meet with us to discuss the project, and were very forthcoming about the pedestrian components of the project. In our discussion we covered many of the ideas that now appear in the DEIR and have solidified the commitment to serving walkers in the project plans and designs.

Secretary Sullivan’s Certificate on the ENF mentioned some specific aspects to be explored further in the DEIR. These are important and form the basis of our comments on the DEIR:
1. Existing and proposed traffic signals.
2. Consistency with a Complete Streets design approach.
3. Existing and proposed connections for pedestrians.
4. A commitment to making improvements to increase the use of walking routes.

1. Existing and proposed traffic signals.
We are pleased to note that the DEIR calls for updating pedestrian signal equipment at the study area intersections around the site.

We note that two mid-‐block crossings with refuge islands and flasher assemblies are proposed – one on State Street and the other on Union Street ‐ both roughly half way between Main Street and East Columbus Avenue and located at the exterior of the proponent’s site.

Another mid-block crossing is noted in the DEIR that allows for a mid-block crossing to reach a bus stop. This crossing is located on Main Street at Howard Street, and represents a response to one of WalkBoston’s recurring concerns ‐ that transit riders should not be required to walk to corner locations to reach a bus stop if the stop is mid-block. Instead, crosswalks should be added to provide safe and convenient walking routes for transit users.

We encourage the efforts of the proponent to provide a diagonal pedestrian crossing at the intersection of Main and State Streets, where a direct connection to the Mass Mutual Convention Center may be of significant use. We hope that the City of Springfield will work with the proponent to establish this crossing.

The proponent vows to upgrade pedestrian push buttons to MUTCD standards at all locations where new signals will be installed as part of this project or the mitigation efforts that result from the construction of the project. Upgrades of pedestrian push buttons are very welcome as are any other forms of enhancements for pedestrians crossing streets on the perimeter of the project.

2. Consistency with a Complete Streets design approach.
The proponent has been mindful of the design of streets on the perimeter of the project. In particular, the width of sidewalks has been discussed and the design now provides positive benefits to walkers.

For example, sidewalks on Main Street, according to several of the maps, vary in width from 10.5’ to 18.’ On the widest sidewalks, there is the promise of added pedestrian amenities, such as benches, pedestrian level lighting landscaping and other streetscape improvements. The designs of the narrowest sidewalks should be carefully considered to provide a clear walk zone of at least 5 feet, with no obstructions, such as trees or benches, intruding on that width.

We note that the pedestrian network evaluation preceding design has led to proposed improvements to sidewalk pavement conditions, sidewalk widths, crosswalks, and compliance with current accessibility standards.

One of the requirements of a complete streets approach to street design is adequate provision for buses, bus stops and transit riders. In central Springfield, including Main Street along the east boundary of the site, heavy bus traffic (including four major PVTA bus routes) serves downtown employers and merchants and ordinarily occupies a lane that can be shared with bicycles, but should otherwise be retained for exclusive use by buses.

In addition to the PVTA bus routes, a proposed downtown trolley line will connect the casino site to rail and bus service in the vicinity of Union Station, about ½ mile north of this site. The trolley line makes the connection efficiently, and will encourage transit use by casino employees and patrons.

3. Existing and proposed connections for pedestrians.
The proposal includes several connections for pedestrians into the large complex, particularly along Main Street. The proponent has made progress is the design of the proposed Armory Plaza at the south edge of the casino building by providing a car-free area that combines the open space surrounding the old, restored Armory building with the relatively small but useful open space of DaVinci Park. The use of the Plaza may be combined with the uses in the adjacent Armory Marketplace building and may host civic events and a farmers’ market.

A new pedestrian attraction is the provision of a landscaped plaza atop the casino building. This plaza is completely removed from vehicular traffic and provides a quiet space where people may walk or sit.

A pedestrian connection already exists between the site and the Connecticut River pedestrian and bicycle trail. An existing at-grade crossing at the foot of State Street allows pedestrians to move between the proponent’s site and the trail. It is anticipated that this connection will be used as a way to get from the site to the nearest open space. Lighting under I-91 at State Street will help open the area to pedestrians by making it more legible and safe.

A similar pedestrian connection exists at Union Street, where the walkway link that passes under I-91 allow pedestrians to reach the Naismith Basketball Hall of Fame. The distance is relatively short and is eminently walkable. The connection will be improved by the proposed lighting to be placed under I-91.

4. A commitment to making improvements to increase the use of walking routes.
The proponent’s site is central to the Springfield urban area and will become an integral part of downtown as it is developed. Within the site, there are many places to walk that may require little effort to get patrons to explore. Each entrance/exit to the site should have wayfinding signs to assist walkers and encourage them to walk to destinations within and outside the entertainment complex. The signs should indicate where to find locations such as the center of the casino, the hotel, the outdoor plaza, shops and theatres on the south side of the site, Former Armory, Armory Square Marketplace, the rooftop landscaped plaza, and the main entrances to the parking garage.

Outside the casino complex, there are many attractions in downtown Springfield, and wayfinding signs that guide walkers should include: the Mass Mutual Convention Center, Union Station/Main Bus Depot, Dr. Seuss Sculpture Garden, Springfield Museums, the Civic Center, Springfield Armory, and nearby parks.

Signs should also indicate how to find the riverside attractions including views of the river and the Connecticut River Pedestrian and Bicycle Trail and the Naismith Basketball Hall of Fame.

Wayfinding signs should include walking times to reach destinations. Pedestrians do not think in terms of miles, and minutes required to take a walk are much more effective in conveying the effort that might be involved. Walkers may think little of having to walk ten minutes, but recoil at the prospect of walking ½ mile, even though the distances are the same.

Specific wayfinding signs that should include walking information as well as vehicle and bicycle information are:
• Signs along West Columbus Avenue on the river-facing side of the site,
• Signs on Union Street at the edge of the project, and
• Signs along the East Columbus Avenue side of the site.

Wayfinding can be enhanced with local walking maps that help people find their way around the site and its environs.

We 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,

Robert Sloane
Senior Project Manager

Comments on the DEIR for Caesars Resort At Suffolk Downs, MEPA #15006

October 11, 2013

Secretary Richard K. Sullivan, Jr.
Executive Office of Energy and Environmental Affairs (EEA)
Attn: Deirdre Buckley
100 Cambridge Street, Suite 900
Boston MA 02114

RE: Comments on the DEIR for Caesars Resort At Suffolk Downs, MEPA #15006

Dear Secretary Sullivan:

WalkBoston has reviewed the DEIR for a Caesars Resort at Suffolk Downs. The DEIR documents walking improvements that the proponent will undertake as part of the plan and we are generally pleased with the proposals. We offer comments below to supplement the current proposal with further improvements.

The scale of the site proposed for this project is noteworthy. The existing roadway extends nearly a mile through the L-shaped site between Route 1A and Winthrop Avenue, and the site is roughly 3,000’ north-south and east-west. Opportunities for integration with the existing community are substantial, as the site is bounded by industrial uses on the west side, by residential neighborhoods on both the north and south sides, and by the combination of the MBTA Blue Line, Bennington Street and the Belle Isle marsh on the east side. The urban setting of the project sets the stage for planning elements to allow the development to relate physically and operationally to the surrounding community.

Recognizing the scale of the site, its urban location, and the number of people anticipated to be present each day, the proponent has made efforts to shift trips away from private vehicles and toward public transportation. This is in keeping with the recently announced MassDOT statewide goal of tripling the share of walking, bicycling, and transit travel in Massachusetts. Reducing auto dependence would also reduce the environmental impacts of the development and help preserve capacity on the adjacent highway network. In addition, encouraging greater use of active travel options – walking and biking – will help the development achieve some positive public health effects. We believe that there are additional measures that could be taken to further reduce auto trips and have described several opportunities in our comments.

The details of the development plan offer evidence of some innovative thinking that has created opportunities for walkers on the site. For example, the introduction of water-catching swales on parking lots creates an opportunity to construct parallel walkways that are more pleasant ways of walking through open parking areas. Our comments are organized into those affecting access to and through the site and the pathways that help people get where they want to go within the site.

A. Access to the site via MBTA rapid transit service.

The Blue Line forms one boundary of the site, and has two stations near the proposed project – Beachmont Station and Suffolk Downs Station. Most of the Blue Line users are expected to use the Suffolk Downs Station.

This is reflected in the proposed walkways, bikeways and shuttle bus services to be constructed at that location. No improvements are proposed at Beachmont Station. The proponent has estimated that 15% of daily trips to and from the site will be made via the Blue Line. A total of 4,00o on-site employees are projected, and 40% of these employees, or 1,600 people, are expected to use public transit daily. In addition, 11% of the 23,674 to 32,992 daily casino visitors (2,614 – 4,086 people) are expected to use the Blue Line for access. Since there is no current MBTA bus service to the site, all of the public transit users – some 4,000 to 6,000 people per day – are expected to access the site via the Suffolk Downs Station, which in recent years has handled daily traffic of roughly 1,000 riders.

In recognition of this major impact on the use of rapid transit by employees and visitors to this site, the Suffolk Downs Blue Line Station will be upgraded by the proponent to handle anticipated transit and foot traffic. Elevators will be added on both sides of the tracks to make the station fully accessible and convenient for people wanting to cross the tracks between Bennington Street and the site. We offer several suggestions regarding the MBTA station and the access it provides to the site:
1. A new plaza in front of the station should encourage access for all users, using a design that provides adequate space for walkers, bicyclists and shuttle bus users.
2. The connection into Orient Heights should be enhanced and the proponent should work with neighborhood residents to design a connection that encourages safe and pleasant walking to the station.
3. The shuttle bus shelter proposed near the plaza should have signage that includes both bus and walking information, including the estimated walking time from the station to the casino and other facilities in the proposed development.
4. Walkways between the station and on-site buildings should be attractive, safe and conducive to walking. Separate paths for pedestrians and bicycles are an important and positive design feature. This separation should be made very clear to users, through a significant landscaped buffer strip and wayfinding signs that clearly indicate the separation. Different textures or colors of surface pavement, slightly different elevations, or decorative pathway curbs could all help signify which path belongs to pedestrians. Walkway lighting could also be designed to distinguish pedestrian lighting from the roadway/bikeway lighting.
5. East Boston Greenway connections should be thoroughly explored. The Belle Isle Marsh lies across Bennington Street from the main entrance to Suffolk Downs MBTA Station. Plans show a path along the marsh edge connecting to the existing East Boston Greenway, and the proponent has agreed as part of a consent decree with the US EPA to fund a new boardwalk at Belle Isle Marsh to improve public access and protect natural resources within the marsh. In the short term, the path and the boardwalk should be considered concurrently and include a link to the Suffolk Downs Station. Pedestrian access improvements on Bennington Street could include moving the existing crosswalk now located at Leverett Street 200 feet north to align with the main station entrance and the route of the Greenway at the edge of the marsh. This would allow an extension of the Greenway into the proponent’s site, where significant new open space with paths and nature trails could expand and extend the Greenway network to Route 1A and to Winthrop Avenue.
6. Future Greenway connections should be considered. The East Boston Greenway, if extended through the proponent’s site to Route 1A, could eventually be extended to link with walkways on the opposite side of Route 1A along Chelsea Creek in Revere, where open spaces are cited in the DEIR as possible future projects.

B. Access to the site via MBTA bus service

The DEIR includes a proposal for MBTA bus service within the site, including a stop on Tomesello Drive near the entrance to Casino Area II, but bus service on Route 1A is not addressed in the DEIR. MBTA bus service should be more completely examined, as it could significantly affect access to the site from throughout the region. In addition, it could affect internal site pathways – their alignments, construction standards and levels of potential use.

1. MBTA bus service within the site has not been detailed to explain off-site routings and their consolidated or separate connections into the site. Such bus service might supplement private carriers such as the anticipated dedicated charter buses and shuttles from Logan airport, nearby business districts and other major tourist, cultural and travel venues in Boston, Revere, and the surrounding region. MBTA bus service should be more clearly explained as a possible option, including potential routes that might be devoted to accessing the casino/racetrack on this site from a variety of locations.

2. MBTA bus service along Route 1A should be more thoroughly explored. Currently, MBTA service on Route 1A consists primarily of express buses which run between Salem, Lynn and Boston or the airport. Route 1A may also be an appropriate route for bus service that serves this site and could affect the attractiveness of public transit options.

3. Future Route 1A bus service might stop near the site’s principal entrance at Tomesello Drive. Bus stop locations would need to be closely coordinated with proposed traffic signals at Route 1A and Tomesello Drive because pedestrians would cross Route 1A using this signal. It is likely that a separate pedestrian phase at the signal would be needed.

4. Route 1A bus stops at Tomesello Drive should be connected to all pedestrian paths leading to the casino and racetrack. A primary, well-marked pedestrian path is essential and should be located on the same side of Tomesello Drive as a bus stop. It should be well designed, attractive to walkers, safe, well lit, and signed to reassure visitors that they are on the right track. Ideally, the pedestrian path should be separated from the bicycle path. Distances in time might be added to encourage walking along this route. It is about a 10-minute walk from Route 1A to the entrance to Casino II.

5. Late night MBTA transit service should be considered to serve both patrons and staff. This may require subsidies by the proponent to support increased transit service that would not otherwise be provided by the MBTA, such as late night Blue Line service or bus shuttles from Downtown Boston. Late night service would help shift workers and patrons away from private vehicles.

C. High Quality Design, Amenities and Year Round Maintenance

WalkBoston assumes that the proponent will commit to providing the levels of landscaping, lighting, security, snow shoveling and maintenance needed to make transit riders, pedestrians and bicyclists feel invited, safe and comfortable year-round. Because the site is so large, and the length and number of pathways and sidewalks are so substantial, this will require a serious commitment of resources. WalkBoston believes that this investment is needed to ensure that the proponent’s projection that 15% of trips to the site will occur via the Blue Line. As noted above, we urge the proponent to also investigate the potential to shift additional trips to public buses.

D. Pedestrian paths through the property

WalkBoston is pleased to see the attention paid to walking paths through the property. Each of the paths are discussed below.

1. The path between Suffolk Downs MBTA Station and the South Plaza is the site’s prime example of walking/biking path separation. Separate paths are preferred by both walkers and bikers and should be considered for the other paths on the site. The path follows a new street called Blue Line Road that will provide access for the shuttle bus between transit and the casino and other facilities. The physical layout includes a 23’ roadway, with an 8’ two-way bikeway immediately adjacent to it. An 8’ two-way walkway is separated from the bikeway by a 6’ wide greenway and from the horse track by an 18’ landscaped buffer and fenced grassy area.

2. The path along the edge of the racetrack connects directly with the station path described above and provides one part of a connection that traverses the entire site from south to north, on a route that follows the edge of the racetrack, past the apron, the paddock for parading horses and the grandstand. It connects to the Sales Creek Path and the path leading along the edge of the North Parking Lot and to Winthrop Drive at north edge of the project site. This long attractive walking route could potentially be of significant use as a recreation trail. However, the DEIR calls for ‘controlled’ use of the path, and the degree to which public access will be allowed should be explained in detail.

3. Possible pedestrian connections to Orient Heights. The edge of the proponent’s site is separated from Orient Heights by a steep grade along most of its southern boundary. However, at one location, near the point where Tomesello Drive currently makes a 90- degree turn, the grades of Tomesello Drive and Waldemar Avenue coincide. If the residents of Orient Heights are interested, the project proponent should explore new pedestrian access at this location to provide a connection into the South Parking Lot which would allow pedestrians to walk via on-site pedestrian paths and sidewalks between Orient Heights and the Suffolk Downs facilities and the shopping area along the west side of Tomasello Drive.

4. Path connections meet at the South Plaza, where there is a major entrance into the casinos. This is where the path from the Suffolk Downs MBTA station and from the South Parking Lot connect with the Winter Garden entrance and the link between the casino areas and the North Plaza. The plaza is proposed to be a shaded space with adjacent activities such as a sidewalk café. It has a good model – the Lincoln Center grove of trees – and affords a place to walk, with ample sitting areas where people can wait to meet others arriving at the south entrance, or take an outdoor break from other activities. The South Plaza is also called out as a location for active events. A description of the possible events should be provided, as they may affect the layout and pedestrian use of the plaza.

5. The path between the Route 1A site entrance and Casino Area II is a handsome entrance amenity for the site. It will become especially important if bus service and bus stops are added at Route 1A. The total distance from Route 1A to the entrance to Casino Area II is approximately 2,400’ – about a 10-minute walk. At the moment there are two paths proposed, passing through areas to be extensively landscaped around restored water areas. The paths could readily become parts of the East Boston Greenway.
However, the alignment of the walks may need attention for walker safety. The current location of the walks, though parallel to Tomesello Drive, is some 50’ away from it. This distance may be too far for walkers to feel safe. Many designers suggest that pedestrians should be visible from the roadway and that they should be able to reach the roadway in case of an emergency. A more suitable distance, predicated on safety, should be explored.
It may also be useful to explore if both of these walkways through this pleasant green area are essential. One walkway, located along the desire line of people expected to use it between the bus stops on Route 1A and the casinos, may be all that is needed. The proposed bollard lighting system sounds promising and should be help provide maximum safety for walkers.

6. Paths from Route 1A lead to the plaza/main entrance to Casino Area II where significant vehicular access is proposed. Four lanes serve the entry point and there are direct connections into the underground parking beneath Casino II for this valet parking area. At this entry point, a large roof above the vehicle lanes (called a porte cochere) provides weather protection. Because many vehicles, including taxis, will arrive on each of the four lanes, it will be important to know how pedestrians will be able to safely walk between their cars and the entrance to the casino. (This area is similar to the drop off and pick up area at airport terminals, where many pedestrians are required to walk across a number of lanes of arriving and departing vehicles.)
An additional question concerns direct access for people arriving from Route 1A or from the MBTA Station on foot. The current plan includes an indirect route for the approaching walkway rather than a more direct route. People who have walked from Route 1A should not be asked to walk several hundred feet out of their way when they can see the entrance clearly ahead of them.

7. Paths along Tomesello Drive north of the casino area are proposed for the west side of Tomesello Drive as far as the traffic circle entrance to the parking garage and North Plaza. On the east side of Tomesello Drive, paths are shown from Route 1A all the way to Winthrop Ave. The path on the east side is separated from the road by an 8’ buffer; on the west side it is not clear whether a buffer is provided. The paths are 14’ wide and are twoway shared bike-ped facilities. A planted 6’ wide slope separates the path from the parking bays north of the parking garage. Overhead lighting is designed to provide illumination that differs between the roadway and the path.
The proponent should consider whether the proposed path on the west side of Tomesello Drive is essential for access to any part of the site, and whether it will see much use.

8. Path connections at the North Plaza will serve significant numbers of visitors who will enter both casinos via this large square. The plaza provides access for all bus and limo shuttle services at a scale that indicates that many buses are anticipated. At the north end of the plaza there is a weather-protected drop-off location where individual drivers can access Casino Area I and the racetrack. Access to Casino Area II is provided at the south end of the plaza through the Winter Garden.
The North Plaza is approximately 500 feet long and 200’ wide, encompassing 2.2 acres. It is laid out with two lanes of traffic surrounding it (suggesting a one-way pattern of traffic movement) with adjacent sidewalks for loading and unloading visitors to the sidewalks adjacent to the casino entrances. Vehicular access into and out of the plaza is provided by four lanes of traffic that connect the plaza and the large parking garage to Tomesello Drive. No pedestrian paths are provided along these routes.
The plaza is designated as an event space and viewing area, which is still undefined. The side of the plaza abutting the Grandstand and Casino Area I appears to have the widest sidewalk leading directly into the casinos. This is where many of the bus and shuttle services are likely to discharge and pick up passengers. On the opposite side of the plaza is the large parking garage. Rather undefined sketches show the first floor of this garage as a future retail area.
It will be important to design the North Plaza so that pedestrians have a pleasant and safe walking experience. Especially important will be the provision of visual interest for the very tall and lengthy facades and the provision of landscaping to provide walkerfriendly scale and materials. To clearly separate pedestrians from vehicles, safety improvements such as bollards, seating areas between the line of trees, and different treatments of sidewalk surfaces should be considered. To make the area more interesting for walkers entering the casinos, the west wall of the Grandstand facing this long sidewalk might considered for the installation of art or information diagrams or posters.
It is also important to ensure that air circulation systems diminish the accumulation of exhaust fumes from the many vehicles in the plaza.

9. Paths to and through the parking structure should be detailed. A second-level walkway connects the garage directly into Casino Area II, but access from the garage to Casino Area I and the racetrack involves crossing the busy North Plaza at crosswalks. These crosswalks should be designed for the safety of walkers passing through the traffic bringing visitors to the site.

10. The path between the North Plaza and the North Parking Lot is a long, straight walkway serving users of the 1,468 parking spaces. A tree-lined path connects all of the site’s activities to the shopping area west of Tomasello Drive. As a unique on-site feature, transverse swales across the parking lot are planned to direct storm water runoff into the underground drainage system. It is unclear if these swales will be landscaped. As currently planned, there are four transverse swale areas laid out to separate every three or four rows of parking and to collect runoff through their permeable surfaces. For each of these transverse swale areas, the opportunity exists to create shaded walking paths along each swale. A similar opportunity may exist at the South Parking lot.

11. The Sales Creek Path is approximately 800 feet long, and extends from the racetrack diagonally to Tomesello Drive on a route that parallels an original waterway. This route affords the proponent an opportunity to use the creek as a focus of landscaping to provide screening at the edge of the North Parking Lot, and create a shaded place to walk. It might be possible to extend the landscaping along the creek up to Tomesello Drive on both sides of the street, and use the creek as a major feature that designates the entrance into the site.

E. Boardman Street Overpass

A path along the proposed Boardman Street overpass should be constructed to replace the existing sidewalk that parallels Route 1A between Boardman Street and the site entrance. A buffer strip between the sidewalk and the overpass would be desirable, as the overpass is likely to be very busy. Connections into existing adjacent open space and the new sidewalk might be considered in consultation with residents of Orient Heights.

We 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 Robert Sloane
Executive Director Senior Project Manager

Comments on the Expanded Environmental Notification Form for Wynn Everett

July 12, 2013

Secretary Richard K. Sullivan, Jr.
Executive Office of Energy and Environmental Affairs (EEA)
Attn: Anne Canaday
100 Cambridge Street, Suite 900
Boston MA 02114

RE: Comments on the EENF for Wynn Everett, MEPA #15060

Dear Mr. Sullivan:

WalkBoston has reviewed the Expanded Environmental Notification Form for Wynn Everett, a resort proposed to include 2.9 million square feet of development along the west side of Lower Broadway (Route 99) in Everett, with frontage on the commuter rail line and an existing embayment of the tidal Mystic River. The proposal includes 3,490 structured parking spaces, and waterfront features that include a harbor walk and water transportation docking facilities. Principal access to the site is from two proposed intersections with Lower Broadway.

Traffic is significant: there will be an additional 29,384 new vehicles trips on a Friday, and 35,754 new vehicle trips on a Saturday, with the largest peak-hour volumes occurring on Friday and Saturday evenings. To accommodate this traffic, a new signalized intersection with Lower Broadway is to be constructed, connecting with an on-site boulevard. Lower Broadway is to be widened to allow two southbound right turns into the boulevard. Northbound left turns will be handled by a widening of Lower Broadway or a jughandle using Bow Street that would allow vehicles to turn to the south and enter the site.

A secondary service drive is contemplated that will intersect Lower Broadway north of the site. The intersection of this drive with Lower Broadway is also anticipated to be signalized.

Transit access will be provided at the Sullivan Square MBTA Station, 1.2 miles from the site. Transit stations at Wellington and Assembly Square are each 0.8 miles from the site, but currently have indirect pedestrian routings to the proposed resort. Shuttle buses to all subway stations have been proposed.

Our comments center on pedestrian access into and within the site. We are basically concerned that the location of the site and its considerable distance from centers of population and regional transit stations will result in motor vehicles providing the majority of the access to the site. Despite that concern, we have reviewed the proposal for individual improvements in pedestrian access associated with the project.

Off-site access to and from the proposed resort

Lower Broadway was recently reconstructed by the state as part of its enhancements to State Route 99, which included the addition of new bicycle lanes in both directions and the narrowing of existing sidewalks to permit expansion for other transportation modes. The proponent should detail the ways in which sidewalks will be upgraded for pedestrian access into the site. Sidewalk access should extend at least as far as the MBTA Sullivan Square Station, which will require the proponent to deal with that portion of the sidewalk within the City of Boston.

A new commuter rail station being investigated by the City of Everett on the commuter rail line that is adjacent to this site. To make this proposal a realistic option, the proponent should detail the ways in which rail connections to the site will be integrated with the resort, including major pedestrian routes into the heart of the site. A brief mention was made of an existing underpass; perhaps this could be upgraded to provide a connection to both sides of the track.

The new intersections with Lower Broadway for both the major boulevard access and the service access should be carefully planned to include safety measures for pedestrian crossings. This should include pedestrian phase timing at these and other signalized intersections constructed or modified as part of the proposal.

A potential connection between the site and the City of Somerville could be provided by access over the Amelia Earhart Dam. This connection would lead to both the new Assembly Square MBTA Station and to the Somerville/Charlestown Mystic River path network.

Riverfront access

The proposal envisions an extension of the Mystic River trail system from this site to the west. This extension involves going under the elevated commuter rail line along the River to reach Gateway Park and other open spaces planned for the banks of the Malden River. This will extend parks in appropriate riverside locations and in accordance with local and regional park planning.

One of the uses of the proposed trail system to the west is suggested to be a connection to allow access to and from the MBTA Wellington Station. This station is nearly a mile away, and it may be difficult to attract transit riders to use the trail, as access to it involves walking in open spaces where walkways are not readily visible from the street. The proponent should investigate making this walkway safe for access to its site with improved signage and lighting.

A portion of the embayment along the Mystic River is located inside the City of Boston and is occupied in part by public agencies. The proponent should explore with these agencies the potential for riverside access for pedestrians, in effect extending the Mystic River pathway network closer to Sullivan Square.

We look forward to the details of these and other elements of the plan. We 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,

Robert Sloane
Senior Project Manager

Comments on ENF for Caesars Resort at Suffolk Downs

March 26, 2013

Secretary Richard K. Sullivan, Jr.
Executive Office of Energy and Environmental Affairs (EEA)
100 Cambridge Street, Suite 900 Boston MA 02114

RE: Comments on ENF for Caesars Resort at Suffolk Downs – EEA #15006

Dear Secretary Sullivan:

WalkBoston has reviewed the ENF for Caesars Resort at Suffolk Downs. We find agreement with the general design, as it seems directed toward providing safe facilities for pedestrians. A number of design details should be more closely investigated as part of the DEIR. Our comments about those details follow.

Underlying Assumptions
Many of the patrons and staff of the casino complex and racetrack will arrive on foot from transit stations or parking lots. Thus walking should be a significant element of the project design, coordinated with vehicular routes to minimize potential conflicts. Walking, transit and bike use should be maximize d in keeping with the Commonwealth’s goal of tripling the share of walking, biking and transit use. Access to and from the two MBTA stations and the Route 1A bus lines, and access between distant parking locations and the casinos and the racetrack are the primary routes to be addressed. Walking access between the site and adjacent residential areas should also be addressed.

Good information about the projected volumes of pedestrians (and bicycles) should inform the design and size of facilities.
For example, the ENF states that most employees will come to the site via public transportation. While not explicitly stated, we would anticipate that nearly all would walk from the MBTA stations into the site (unless shuttle service is provided). Because the Suffolk Downs Station is considerably closer to the proposed buildings than Beachmont Station, it will likely attract more users. The walkway from the station into the site should be designed to accommodate the anticipated volume of walkers (and bicyclists if they will use the same route) and the projected volumes should be included in the DEIR.

Overall Design Issues to be addressed
• The design of walkways and walk routes should be attractive, include high quality landscaping, and feel inviting both day and night, winter and summer. Designs should include:
– A network of short distance walkways to encourage people to walk on site.
– Lighting for safety, using designs that do not spill into residential areas or obscure the night sky
– Safety and security especially given late night operations for employees and patrons, where there are fairly long walks such as the one to the Suffolk Downs MBTA station
– Benches
– Smooth surfaces on all walkways
– Year round maintenance including snow shoveling
– Shade while walking to the casinos and hotels
– In New England, inclement weather is inevitable, suggesting the possibility of providing shelters or coverings along walkways, or alternative means of reaching destinations, such as a shuttle bus service
– Wayfinding for pedestrians – Signage should be employed as fully as possible to help pedestrians find their routes within this very large site. Signs would also encourage the use of MBTA bus routes and subway facilities, and should be used to designate access points in the event an on-site bus shuttle service is provided. Other off-site locations of interest should be included, such as the Belle Isle Marsh Reservation, Revere Beach and potentially the Target/Super Stop and Shop complex , the racetrack’s horse barns and other sites that might improve the experience of nearby residents as well as patrons of the casinos, the racetrack, and the hotels.
– Parking lots should be designed attractively, with trees and with defined walking paths that are separated from moving vehicle areas within the lots

• Multi-use path design.
The paths on the site that are walking/biking multi-use paths should provide appropriate widths to allow for safe shared use. MassDOT standards (Mass Highway Department Project Development and Design Guide, 2006), call for multi-use paths to be 10—14 feet wide to accommodate both pedestrians and bicycles, and for wider facilities if substantial volumes of foot and bike traffic are anticipated.

Tomasello Way/Rte 1A intersection and Tomasello Way Design
• Bus service
Bus service along Rte 1A is already substantial. Routes along the roadway connect Salem Center, Marblehead and Peabody Square to Haymarket and Downtown Crossing – 6 bus routes in total. Well-designed and highly-visible bus stops, along with weather-protecting shelters, should be included in the revamping of the intersection of the Tomasello Way/Rte 1A intersection.
• Signals and crosswalks
In keeping with the intersection’s importance as the front door of the proposed development, the intersection will need to be fully signalized for safety for all users, including pedestrians who will be crossing Rte 1A to and from the new bus stops and shelters. In the re-signalization of the intersection, pedestrian count-down signals should be employed.
• Access between the intersection and the on-site facilities
The proposal includes a major pedestrian way leading from the intersection of Tomasello Way and Rte 1A into the main entrance to the casinos, the racetrack and the hotels. It appears to be useful and attractive, but it must be made safe for walkers and is worthy of significant improvements to make it safe. According to the preliminary drawings, the walkway will be located in the median strip of the rebuilt south portion of Tomasello Way. This is a formal design that could be handsome, but it results in a strip of walkway in the median that could be difficult for walkers to access, because it requires them to cross roadways on both ends of the walkway – near Rte 1A and at the casino/racetrack entrances, as well as at intermediate locations in between – five crosswalks in all. A better solution might be to have the pedestrian way located on the south side of Tomasello Way, with more direct access across the street at a point where the walkway is closest to the casino. This would reduce potential pedestrian/vehicle conflicts along the full length of this stretch of Tomasello Way.
• Amenities along Tomasello Way
Pedestrians walking via Tomasello Way have a relatively long walk between Rte 1A and the site (roughly equivalent to 3-4 city blocks). The preliminary drawings show lines of trees that will be very appropriate to make a pleasant walk. Seating along the way would also make the route more attractive and allow people to rest as they make their way to the casinos or the racetrack.
• A sidewalk connecting Tomasello Way and Waldemar Avenue in Orient Heights
A wholly new but short on-site sidewalk connecting Tomasello Way and Waldemar Avenue would allow Orients Heights residents to reach the bus stops at the intersection of Rte 1A and Tomasello Way, and to be able to walk to the casinos or the racetrack.
• A roadway connecting Tomasello Way to Waldemar Avenue in Orient Heights
Consideration of a sidewalk connecting Tomasello Way and Waldemar Avenue should include examination of a future road connection as well. A new, relatively short street to link Tomasello Way to Waldemar Avenue could reduce problems at the intersection of Waldemar Avenue and Route 1A near the Tomasello Way entrance to the site because it would allow Orient Heights access to be diverted to the Tomasello Way entrance to the site. The connection could include options for improving the safety of nearby residents:
– Waldemar Avenue could become a dead-end street before reaching Rte 1A; or
– It could be made one-way inbound toward the residences; or
– It might be connected to Vallar Road if gradients are favorable.

The continuation of Tomasello Way to the Suffolk Downs MBTA station
A driveway currently exists along the proponent’s property line between the Rte 1A entrance to the site and the small turnaround space in front of Suffolk Downs T station. The west half of this route has been covered above. However, the future of the east half of the driveway is unclear, even though it could be used for vehicular and pedestrian traffic as part of the larger plan. An explanation should be provided as to:
– Whether this driveway will become an access roadway providing service both to the south entrance to the casino, and to the Suffolk Downs MBTA Station.
– Whether this driveway will be extended to connect into the local roadways of Orient Heights, such as Waldemar Avenue, Walley Street and Bonito Square. This connection could relatively easily reach Bennington Street as well, and could become a major route for vehicles entering or leaving the site.
– Whether an improvement is planned for the pedestrian component of the service plaza at the MBTA Station.
– What the pedestrian connections along this roadway will become, as it provides a major walkway between the MBTA station and the casinos and hotels. This connection might also be used to enhance direct access from neighborhood walkways into the station.

Pedestrian access from off-site locations
• Pedestrian access between Orient Heights and a potential Route 1A bus stop at Boardman Avenue.
A partial interchange is proposed for the intersection of Boardman Avenue (Route 145) and Route 1A. The proposal calls for a northbound overpass above Rte 1A to pass over the turning between Rte 1A and Boardman Avenue. The overpass design and focus of turning traffic at the intersection suggests some difficult crossings for pedestrians from Orient Heights. Bus stop access for pedestrians should be explored as part of the proposed partial interchange. It may be possible to link Boardman Street access to the bus stop at Tomasello Way.
• Pedestrian access between Orient Heights and the Target/Super Stop and Shop complex
The ENF notes that walkers from Orient Heights need to cross the Suffolk Downs site to get to the shopping complex located near the intersection of Tomasello Way and Furlong Drive, which are important businesses for Orient Heights residents to use. Data support-ing this suggestion would be useful. The multi-use path along Tomasello Way will improve this walk. From a pedestrian point-of-view, the suggested location of the walkway on the east side of Tomasello Way results in pedestrians from Orient Heights crossing at least 6 streets on route to the shopping complex, unless they follow the alternative walking route that hugs the buildings. The proponent should examine whether the walkway could be moved to the west side of Tomasello Way to reduce the number of crossings. Pedestrians walking along Tomasello Way should also be protected from walking through either of the two roundabouts at the approach to the hotels and casinos. Roundabouts are not very safe for pedestrian because of the potential conflicts with turning vehicles.
• Pedestrian access between Crescent Heights and the Target/Super Stop and Shop complex
Residents of the Crescent Heights neighborhood at the north edge of the site could also reach the shopping area via the Tomasello Way walkway.
• Racetrack walkway to the Target/Super Stop and Shop complex
The plan includes a walkway between the racetrack and the Target/Super Stop and Shop via the edge of the northern parking lots. The intersection of this walkway and Tomasello Way should be moved slightly to align with the front entrance to the shopping complex. The volume of foot traffic at this intersection may be low, but further exploration may suggest the need for a traffic signal with WALK signals.

Potential shuttle bus service
Shuttle buses should be considered to help people get around and to provide options during inclement weather. Options for shuttle bus stops include main entrances to the casino and race track, the Suffolk Downs and Beachmont MBTA stations, bus stops on Route 1A at Tomasello Way, the bus stop on Winthrop Avenue, and for access to the more remote parking areas. Facilities to support shuttle bus service may include the addition of a turnaround area in front of Suffolk Downs MBTA Station and a u-turn on Tomasello Way just short of Route 1A. Shuttles may also be useful to serve future night transit service on the Blue Line and elsewhere.

Local Community Benefits – pedestrian improvements at other locations
The ENF includes suggestions that certain improvements outlined by the Lower North Shore Traffic Study of 2000 could be included as part of the mitigation for the construction of this facility. Although no detail has been supplied on these locations, they appear to include intersections at Route 16 at Winthrop Avenue/Harris Street, the vicinity of the Beachmont MBTA Station in Revere, in the vicinity of Route 16/Route 1A/Bell Circle in Revere, and, in East Boston, at Bennington & Saratoga Streets at Orient Heights MBTA station and Boardman St. in East Boston. Many of these improvements have been requested by the affected communities and will need to be detailed in further submittals to show potential impacts on pedestrians.

We appreciate your consideration of our comments and your responses to them. Please feel free to contact WalkBoston with any questions you may have.

Sincerely,

Wendy Landman
Executive Director