October 9, 2020

Director Brian Golden
Boston Planning and Development Agency
Attn via email: Ebony DaRosa

Secretary Kathleen A. Theoharides
Executive Office of Energy and Environmental Affairs
Attn via email: Alexander Strysky

Re: The Pinnacle at Central Wharf (Harbor Garage Redevelopment)

Dear Secretary Theoharides and Director Golden:

WalkBoston is Massachusetts’ leading pedestrian advocate. We frequently provide comments on major public and private development and infrastructure projects, with a focus on how those projects serve and affect people walking, biking and taking transit.

The redevelopment of the Harbor Garage has been under discussion for many, many years with major public disagreement about the appropriate scale and mix of uses that the project should comprise. We will not specifically weigh in on those issues because the Municipal Harbor Plan has now set the stage to allow a very large mixed-use development. And while a number of commenters will raise public process issues, broad public benefit issues and questions about the timing of required design and use standards as they apply to the timing and design of this project we look to others to provide detailed and focused attention on these issues.

Our comments focus on a more detailed and fine-grained set of concerns about the ways in which people walking, biking and taking transit to, through and next to the project will be affected.

From a site planning perspective, we believe that the current proposal has a better footprint and urban design than earlier development concepts. Improvements to the sidewalks, landscaping and scale of the pedestrian areas around the site will  contribute to a more comfortable and attractive streetscape than the existing conditions surrounding the garage. However we do have significant concerns.

Garage and loading access

Our significant and consequential comment is that garage access and egress should be removed from Atlantic Avenue in order to provide an acceptable site plan that will be safe for people walking and biking along Atlantic Avenue. 

The building site presents a complicated puzzle for the circulation of people and vehicles because all four sides of the site are public facing, each with its own personality and constituency.

Atlantic Avenue

• Over many years, the advocacy community has invested an enormous amount of time and energy to establish and preserve the integrity of a wide and pedestrian-friendly sidewalk along Atlantic Avenue, both as a core walking route for thousands of people every day and as a component of the Rose Kennedy Greenway. We remain committed to maintaining the preeminence of this walking route. Atlantic Avenue’s significant pedestrian volumes can only be expected to grow in the coming years.

Milk Street

• Milk Street is the primary connection from Downtown and the Greenway to the Aquarium,  serves millions of visitors every year, and will be part of the Aquarium’s planned Blueway. Special attention to this walking link to the harbor is an essential component of the site’s redevelopment.

Harbor Walk

• The Harbor Walk is the City’s waterfront front door and pedestrian corridor with critical public realm and resiliency functions and serving thousands of walkers every day. As one of Boston’s most loved and important pedestrian assets and spaces, the Harbor Walk deserves great attention to design, programming and management.

East India Row

• East India Row provides access to both the project site and the Harbor Towers residential development. It is used by both pedestrians and vehicles as a key link between Atlantic Avenue and these sites.

Vehicle Access

As currently configured and programmed, vehicle access into the garage for most of the garage users and all of the building deliveries will require vehicles to cross the Atlantic Avenue sidewalk. Access via this garage entrance will be for all passenger vehicles for office, retail, Aquarium and public parking, and for all loading (residential, office, retail). Egress across the sidewalk will serve all loading (residential, office, retail). As shown on the plans in the PNF, the driveway serving the garage entryway looks almost as wide as Milk Street.

According to the PNF (Table 2-7), during the morning peak hour there will be 292 vehicle trips turning across the Atlantic Avenue sidewalk – or about 5 vehicles/minute. The pedestrian data provided in Figure 2-7B indicates that under existing conditions approximately 700 pedestrians walk along Atlantic Avenue during the morning peak hour – or about 12 people/minute. The volume of vehicles turning across this busy sidewalk, without traffic signals to provide a safe time for pedestrians to walk along the sidewalk, is comparable to the right turn volumes of 238 vehicles from Seaport Boulevard onto Atlantic Avenue during the weekday PM peak hour (see Figure 2-6B), and the pedestrian volume walking along Atlantic Avenue of 738 people is also comparable. (PM pedestrian trips along Atlantic Avenue at the project site are even higher than AM trips, so a shift from garage access to garage egress would create even greater conflict.)

Bike volumes in the Atlantic Avenue bike lane are approximately 60-80 bikes/peak hour under existing conditions.

The PNF does not include projected walking and biking volumes (it does include those projections for vehicle trips). Given the rising numbers of walking and biking trips that we are seeing across downtown Boston, we request that these projections be included in the Draft EIR and PIR.

No specific information is provided about the number of loading trips that will enter and leave the building across the sidewalk. This information should also be provided in the Draft EIR and PIR.

In addition to the safety hazards of vehicles turning across people walking and biking, we also believe that vehicles exiting (and possibly entering) the garage will queue up across the sidewalk as they wait to enter the travel lanes along Atlantic Avenue (or potentially as they wait to enter the garage itself).

We do not believe that a garage and/or loading entrance into the project site should be allowed on Atlantic Avenue because it would require vehicles to turn across the sidewalk and bicycles traveling along Atlantic Avenue. We ask the City to require a shift of garage access to East India Row where it will impact far fewer people walking and biking, and where it will not negatively impact one of Boston’s premier walking routes. 

Aquarium and Harbor Towers Parking Long-Term and During the Construction Period

Because the site will continue to provide parking for the Aquarium (as required under the Municipal Harbor Plan) and also for the Harbor Towers, as well as serving the Project’s commercial, retail and residential occupants, it is not realistic to ask that the garage use on the site be eliminated. However, we urge the Proponent, the City, the Aquarium and Harbor Towers to re-examine the amount of parking included and reduce it to the greatest extent possible.  Additionally, we urge the developer to explore the feasibility of repurposing any reduction  of parking into maximizing the number of onsite affordable housing  units.. As the City is in the midst of revising its maximum allowable parking regulations, this Project should at a minimum adhere to these new lower limits. Any reduction in total vehicle trips into the site will reduce the Project impacts on people walking and biking as well as its contributions to traffic and greenhouse gas emissions.

We understand that publicly available parking spaces are needed for the Aquarium to maintain its operations – and especially in light of the financial hardship caused by the ongoing COVID-19 pandemic, it is critical to insure the Aquarium’s healthy operations when the Harbor Garage is out of service. Given that the City and the Proponent will be working closely with the Aquarium to develop a parking plan for the approximately 3-year construction period when there will be no parking at the site,  we believe it would be valuable to explore if any of the short-term parking mitigation sites may serve as a better long-term parking solution than building 500 new parking spaces.

Site Design, Operations and Management Comments

• Pedestrian circulation around and through the development site
• Site grade in relation to the surrounding waterfront
• Public programming to support a lively public realm and welcome a diverse set of visitors
• Shadow, wind and microclimate
• Coordination with existing and future waterfront resiliency efforts that will affect people walking

Pedestrian circulation around and through the development site

Pedestrian circulation around the building, on the site and through the building seems to provide attractive pedestrian routes and easy access to all the public spaces within the development. The Proponent has noted that a variety of sidewalk, accessibility and landscape improvements will be made to enhance the walking environment.

We could not find a description of whether the diagonal interior pedestrian passage through the building would be open to the public 24/7.  We ask that the Proponent describe the operating plans for this pedestrian circulation in the next filing.

Relationship between the raised grade of the proposed site plan and the surrounding waterfront

The document provides a description of the proposed grade changes to raise the site level above projected water levels in future years, but it is not clear to the lay reader how the transition between this site and adjacent sites will affect the experience of people walking on this site or adjacent sites. Please include a detailed description and diagrams in the next project filing.

Public programming to support a lively public realm and welcome a diverse set of visitors

While the document provides several sentences describing the Proponent’s intent to provide site programming worthy of this important site and significant development, very little detail is included. We ask that the following questions be addressed in the next filing.

• How will the Proponent ensure that people of all races, ethnicities and income groups feel welcome and included in both the interior and exterior spaces of the project?
• What low and no-cost activities will be provided?
• What will be the annual budget for programming of public activities on the site and how many years of programming will the Proponent provide?
• Will there be children’s programming to align with Aquarium? Will the Aquarium have the opportunity to provide (and be compensated) for such programming?
• How will the Proponent enliven the site during winter months?

Wind, shadow, and microclimate

We are pleased that the developer has explicitly worked to design a building façade/skin that is intended to reduce the wind impacts of the building and we look forward to seeing the wind studies that will be provided in future filings.

A project of this scale will have unavoidable shadow impacts on the streets, sidewalks and open spaces around it and this project is no exception.

Given the hope that this project will invite many people to enjoy the waterfront, we urge the developer to look in detail at ways to create comfortable outdoor spaces that are sheltered from the existing windiness of the waterfront; are shaded in the summer; and take full advantage of the sun in colder months. We suggest that the design team look at best practices for creating human-friendly microclimates on the site. This could mean spray stations for the summer, seating with solid legs and backs and wind protection for the winter, and different orientations to take advantage of the sun at every season. We look forward to learning more about the designs in the next filings.

Coordination with existing and future waterfront resiliency efforts that will affect people walking

The development plan meets the City’s resiliency guidance for the development site itself. We ask that the developer formally commit to working with the City and with other waterfront property owners and managers to ensure that public access to the HarborWalk will be safe and attractive over the long term as sea levels rise.

Thank you for the opportunity to comment on this significant new project. WalkBoston would be pleased to answer any questions about our comments and to meet with City or development team staff.

Sincerely,

Stacey Beuttell
Executive Director