EEA – Page 3 – WalkMassachusetts

Comments on the DEIR for the Redevelopment of the Government Center Garage MEPA #15134

By WalkMassachusetts | July 11, 2014

July 11, 2014

Secretary Maeve Vallely Bartlett
Executive Office of Energy and Environmental Affairs (EEA)
Attn: Holly Johnson
100 Cambridge Street, Suite 900
Boston MA 02114

RE: Comments on the DEIR for the Redevelopment of the Government Center Garage MEPA #15134

Dear Secretary Vallely Bartlett:

WalkBoston reviews significant proposed development projects to provide comments about their impacts on pedestrians, and to suggest measures that may mitigate negative impacts or generally improve the projects for walkers.

We have reviewed the DEIR for the Redevelopment of the Government Center Garage and find exciting aspects of the project that will benefit walkers. These include:

Enhancement of a major pedestrian-transit hub
The East Parcel contains a high-volume transit hub with extensive pedestrian access. Access to the Orange and Green Line Haymarket Station access points will be maintained, as will access to the many MBTA bus services. Some of the difficult pedestrian crossings to the site will be improved by narrowing the width of the New Sudbury Street and thus the length of the crosswalks at its intersection with Congress Street.

The sidewalk through the East Parcel
The new pedestrian connection proposed for this project between Congress Street and Canal Street respects a traditional walking route between Downtown and North Station. This route will see more intensive use over the coming years as the significant developments at North Station and at this site occur, and the proposed design reflects the many circulation activities that are required of this parcel.

A new signalized intersection for Bowker Street
The proposed signalized intersection at New Chardon Street and Bowker Street is a welcome addition for pedestrians. The nearby intersection of New Chardon and Congress Street is skewed in such a way that the crossing is very long and is inconvenient for walkers going to the courthouse across the street. The new crosswalk makes the move much more convenient.

Improvements to on-site parking
As parking ceases to be the principal use of this site, the plan is much less auto-oriented. A reduction of number of available parking spaces reduces vehicles circulating around the site for access. This is accompanied by a reduction in the number of places where vehicles must cross sidewalks, enhancing pedestrian safety. The removal of garage access from New Chardon Street and its potentially busy sidewalks is a major pedestrian benefit of the proposal.

In addition to these project benefits, we also note several issues that need more attention.

Weather protection for walkers
The current garage has the unusual benefit of covering the bus waiting area and access to the transit station below, thus protecting walkers from rain and snow. Removing the garage and opening up the area for new development is beneficial to the project, and we believe that Figure 1.8 shows that the new structure will also provide cover for the bus station area. However, no cover for the subway entrance area is shown. The diagrams are less than clear on this point and we ask the developer to clarify how the bus waiting area and subway entrance areas will be designed and whether they will be covered.

Widths of sidewalks
Pedestrian improvements included in the project will improve safety at crosswalks and along the major streets. A note suggests that the current sidewalks widths are varied throughout the project, and are “rarely less than eight feet wide.” We trust that the standards for future sidewalk widths in this pedestrian-friendly project will be considerably wider and in keeping with the City’s complete street guidelines.

Services provided at the bus station
Six bus stops are proposed in the redesign of the bus station. Three of the stops will be in the area where they are now located, and three stops will be provided by a nominal widening at the side of the Central Artery Surface Road. The design and operation of the bus stops is critical for pedestrian safety and convenience. We ask that the proponent provide detailed diagrams and sketches of how this area will operate and ensure that bus patrons are well served by the new design.

Truck loading bays facing New Chardon Street
New Chardon Street is the major Downtown/North End access to and from the Central Artery (I-93). Four truck loading docks are proposed for the section of New Chardon between Congress Street and the on- and off-ramps leading to the I-93. The site plan suggests that trucks will back into these docks from the street travel lanes across the sidewalk on this side of the East Parcel. Unless use of the docks are restricted to the middle of the night it is difficult to comprehend how trucks backing into place across the sidewalk on a ramp to I-93 can be safely accommodated. We request that the proponent describe this element of the project in detail, including how pedestrian safety will be maintained.

Cut-ins on sidewalks
Cut-ins are proposed on three sides of the East Parcel and two sides of the West Parcel:
1. New Seabury Street near the Surface Artery
2. New Chardon Street near Canal Street
3. New Chardon Street near Bowker Street
4. Congress Street Near New Sudbury Street toward Leverett Circle
5. Congress Street near New Sudbury Street toward State Street

Although not well defined in the DEIR, a cut-in appears to be a pull out lane that reduces the width of the sidewalk to accommodate vehicles. The drawings in the DEIR show these indentations only vaguely but imply that a cut-in is a lane for vehicles separate from the adjacent thoroughfare but parallel to it.

The next stage of development of the project should include details of:

Why the cut-ins are needed in each of the five locations?
How they are proposed to be used (back-in, parallel movement, etc.)?
How they relate to, or potentially conflict with, all major adjacent pedestrian flows?
Design guidelines that include minimum widths for adjacent sidewalks or crosswalks, as well as bollards or other protections for walkers. We are concerned that the sidewalks seem quite narrow adjacent to some of the proposed cut-ins.

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

MGM Springfield Draft Environmental Impact Report EEA #15033

By WalkMassachusetts | February 20, 2014

January 31, 2014

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

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

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Comments on the DEIR for The Boston Garden, MEPA #15052

By WalkMassachusetts | November 8, 2013

November 8, 2013

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

Commissioner Thomas Tinlin
Boston Transportation Department
One City Hall Plaza
Boston, MA 02201

RE: Comments on the DEIR for The Boston Garden, MEPA #15052

Dear Secretary Sullivan and Commissioner Tinlin:

WalkBoston has reviewed the DEIR for the Boston Garden project. The proposal will improve the second largest pedestrian, transit and commuter rail interchange locations in the city. From WalkBoston’s perspective, one of project’s key challenges is handling the many daily pedestrian trips generated by subway and commuter rail riders, on-site workers and residents, and the large crowds generated by the TD Garden Arena.

The design of the 2.8 acre site includes a large office building, a hotel and a substantial residential building, comprising 1,870,000 square feet of new structure. The basement and first two levels of the building are predominantly retail. A lower level garage expands the existing below-grade parking facility by 800 spaces, for a total of 2075 in the complex.

The magnitude and importance of pedestrian access has prompted a number of comments and questions about the ways in which the proposed plan meets the needs of walkers both to and within the site. It is very important to distinguish between the site design, which is under the control of the developer, and the design of Causeway Street, which is under the control of the City. We believe that these two components must be designed to work well together, and our comments address both areas because it is not possible to separate them from a pedestrian perspective. For that reason we have addressed our comment letter to both MEPA and the City of Boston Transportation Department.

CONFUSION ABOUT PEDESTRIAN CROSSINGS OF CAUSEWAY STREET

The DEIR includes a design for Causeway Street that has been superseded because of the City’s receipt of a federal TIGER grant that will pay for the reconstruction of the street. As described to WalkBoston by several City staff members, the designs shown in the document are currently being modified by the City to incorporate cycle tracks instead of bicycle lanes and to possibly alter original alignments of lanes on the street. New designs will change the approved 25% design drawings for all pedestrian crossings on Causeway Street, and for vehicular accommodations on the street as well. The details of the proposed changes have not yet been shared, and WalkBoston will actively participate in review of the new design once it is presented. Rather than provide comments on the current design we have focused this letter on suggestions about elements we would like to see in the new design.

MAJOR PEDESTRIAN ISSUES

1. Projected pedestrian volumes into and out of the site exceed vehicular volumes.
The number of people who currently enter the rail and arena adjacent to the site is impressive. Per the MBTA Blue Book, there are 26,763 weekday commuter rail boardings at North Station, and 16,702 weekday entries into the Green and Orange Lines. In addition many more people use the transit lines, streets and sidewalks when an event is scheduled in the 19,000 seat TD Garden. North Station is the 2nd busiest transit station in the MBTA system (exceeded only by South Station). Causeway Street carried 14,800 vehicles per day in 2009, according to MassDOT.

2. Pedestrian crossings of Causeway Street are one of the most important issues to be explored.

a. Canal Street is the major pedestrian approach to the site.
Reflecting the significant anticipated growth in transit and pedestrian trips, a new pedestrian entrance to both the rail station concourse and the TD Garden is planned for the location where pedestrians will cross Causeway Street from Canal Street. Historically Canal Street served as the pedestrian route to North Station from the Downtown financial and retail districts, and in the planned design it will regain that prominence (Fig. 1-14.)
Walking along Canal Street is fostered by wide sidewalks and by the street’s slow speed, narrow travel lanes, corner bulb-outs and traffic signal designs. Pedestrians are encouraged to follow a walking route along Congress Street from the financial district and up Canal Street to North Station.
Retail property uses along the frontage of Canal Street have also changed over time and it now includes many uses catering to people attending sports events including bars and restaurants with large outdoor seating areas.
The private and public expenditures on Canal Street have emphasized it as the primary walking route, thus leaving Friend, Portland and Haverhill Streets much less used by walkers.

b. The design of the Canal Street entrance emphasizes its importance
“Champions Way,” is the grand entrance into the project from Causeway Street – directly aligned with Canal Street. It is approximately 50’ x 200’ (10,000 square feet), sized to handle large numbers of people accessing the site and lined with retail facilities to attract walkers. (Nothing of this nature is proposed for either the Friend Street or Haverhill Street approaches.)
About half of Champions Way will be open to the sky, and at the far end, near the rail concourse, is a ‘mixing bowl,’ where the entrance is divided into three parts leading to the Commuter Rail Station, the second-floor TD Garden and the below grade North Station subway station.
Interestingly, the proposed Champions Way has roughly the same dimensions as the Channel Gardens/Promenade leading into New York’s Rockefeller Center. The New York example spreads out into wide sidewalks at either end of the Promenade; here, that would be somewhat comparable to the wide sidewalk along Causeway Street and the expanse of the rail station concourse at the opposite end of the entrance court.
Other local comparisons are also apt. The Canal Street entrance is about one-half the length and roughly the same width as Yawkey Way, used as a pedestrian street for access to the 40,000-seat Fenway Park. South Station’s main entrance has roughly 6,500 square feet divided into two walkways and a row of escalators and small shops. The South Station vestibule also connects with relatively large open areas on both ends, a triangle of sidewalk in front of the station is about 9,300 square feet and a plaza for pedestrians on the opposite side of the street is an additional 17,500 square feet.

c. The new entrance to the site is more than a replacement of existing site entrances.
Walkers currently enter the TD Garden and rail station concourse via east doors facing the sidewalk along Legends Way and west doors facing the O’Neill Building path. This layout is reflected in current pedestrian access patterns with existing peak hour pedestrian traffic heaviest where Friend Street crosses Causeway Street, as commuters walk toward the western doors. The same pattern does not exist at the intersection of Haverhill and Causeway Streets, perhaps because walkers heading to the east entrance use the MBTA’s underground passage beneath Haverhill Street. Once the proposed new development is in place, the importance of the east and west entrances will diminish significantly and the new entrance at Canal Street will be the focus.

3. Projections of pedestrian activity on parallel streets do not seem to reflect the current design. Causeway Street intersects with four streets in front of the project site – Portland, Friend, Canal and Haverhill, and the distance between the streets is quite narrow. The intersections of Portland, Friend and Canal are three-way, and Haverhill St. is a four-way intersection. All have at least one crosswalk, and there are signals at Haverhill and Portland Streets. A brief analysis of each street is useful to explore their role in the pedestrian network leading to North Station. As noted above, Canal Street is the primary pedestrian route and the other streets have narrower sidewalks, fewer retail outlets catering to Garden event patrons, and more parking lots that reduce the quality of the pedestrian experience.

Portland Street, slightly west of the project site, serves relatively few pedestrians. Most walkers on this street may be heading toward the O’Neill Federal Building at the corner of Causeway and Merrimac Streets, and some may be heading toward the west entrance to the TD Garden and the rail station concourse, although the walking route is not direct.
Friend Street provided a more direct route to the west entrance of the TD Garden/Rail Station, but it crosses Causeway Street at a location that does not align with the O’Neill Building pathway, and the existing diagonal path across the project site will disappear with the new development.
Haverhill Street provides access to the Orange Line/Green Line station, and both sides of this 2-block street have been recently developed with large apartment buildings. However, many loading zones for the new buildings and vehicular entrances make the street less pedestrian-friendly than Canal Street.

4. Pedestrian volume projections may need re-examination.
Existing and projected pedestrian volumes for the four street crossings are provided in the document. Existing pedestrian volumes are highest in the weekday AM peak hour at Portland Street which would seem to stem from Commuter Rail passengers walking from North Station, exiting via the west door and walking toward downtown.
In future projections for the 2017 Phase I development, all pedestrian movements grow, but the largest growth is projected for Friend and Haverhill Sts. which lead only to the east and west entrances to the building. Canal Street traffic grows somewhat, but Haverhill Street projections for the AM peak hour grow to be 10 times larger than the existing pedestrian movement at that intersection. It is unclear if these volumes reflect a route using Haverhill Street’s underpass beneath Causeway St. and the sidewalk along Legends’ Way leading to the east doors of the rail station and the TD Garden. It seems unlikely that such high volumes could cross Causeway St. safely at grade.
For the 2028 full-build, pedestrian volumes grow again, but the pattern is difficult to understand: pedestrian numbers increase substantially at both Friend and Haverhill Sts., but change very little for Canal Street, despite the design’s clear emphasis on the new entrance focused on the traditional walking path from Downtown to North Station.
By contrast, vehicular traffic through the four intersections changes very little from existing levels, declines slightly for the 2017 Phase I, and rises again for the 2028 full-build.
We are puzzled by the projections and request that the proponent describe the volumes and their projected locations in detail.

5. The traffic signal program for Causeway Street needs re-examination.
If this development is to focus its principal entrance on Canal Street, and pedestrian traffic at that location is to increase, the intersection of Causeway and Canal Streets must be signalized for pedestrian safety. The DEIR deliberately fosters jaywalking at both Canal and Friend Streets: a logic of unsignalized intersections is stated in the report: “The unsignalized crossings of Causeway Street at both Friend Street and Canal Street operate at a pedestrian LOS F during the peak hours independent of the full build-out of the Project. Again, under actual operating conditions, pedestrians cross these locations in a platoon when a gap in traffic is afforded in at least one direction on Causeway Street thereby resulting in less pedestrian delay than predicted by the analysis model.”(DEIR page ES-7; pages 3-2 & 3-4; table ES-4)

PROPOSED SOLUTIONS
WalkBoston is excited about the pedestrian service this project will provide. To make the project more appealing and safe for walkers, we suggest the following steps that would more clearly recognize the important role of pedestrians in accessing this site:

THE CAUSEWAY STREET FRONTAGE OF THE SITE

1. Propose a hierarchy of pedestrian crossings on Causeway Street. Canal Street will be the most important pedestrian crossing of Causeway Street (on ground level) based on this design. Haverhill Street is the most important pedestrian crossing of Causeway Street (that passes underground) based on this design. Friend and Portland Sts. will be relatively lowvolume pedestrian crossings.
2. Think of Canal and Haverhill Sts. (and possibly Friend St. as one intersection to aid in finding pedestrian solutions. The block front distance between Haverhill Street and Canal Street is manageably short (about 120 feet). Friend St. is a bit further away from Canal St.
3. Signalize Canal/Haverhill Street at Causeway Street as a single coordinated traffic intersection. Portland St. could also readily be signalized. Friend St. does not necessarily need a traffic signal, if alternative pedestrian crossing locations can be encouraged and if sidewalk and street crossing designs discourage pedestrians from crossing at this location.
4. Build a level pedestrian crossing table for this intersection to slow traffic from both directions. The table should extend a total of at least 200’ from the MBTA headhouse area at Haverhill and Causeway Sts. to the west side of the intersection of Canal and Causeway Sts.
5. Try to attach Friend Street to this raised crossing, recognizing there will be some difficulties. Canal, Friend and Haverhill Sts. constitute the majority of pedestrian crossings 5 on Causeway St. and thus may be considered as a single unified crossing location. Friend Street might be included in the raised table, but issues arise. First, extending the platform to Friend Street doubles its length, potentially leading to the use of the street for storage of vehicles at signals that may interfere with large-volume pedestrian crossings. Second, an additional signal at Friend St. so close to the Canal/Haverhill signals complicates the vehicular signal patterns for the whole street. Third, much of the proposed truck service traffic into the site is located at a door between Friend and Canal Streets, perhaps causing conflicts with surface gradients of the proposed raised platform and adding turning movements into a pedestrian facility. Entrances and exits into this truck service area should take place only from westbound Causeway Street – thus, no left turns for eastbound access.
6. Permit no left turns to or from Causeway Street. Both Causeway Street westbound and Haverhill Street northbound can become vehicular entrances into the site’s parking garage, but exiting traffic from this ramp should only be permitted to turn left to find its way to the Central Artery or Keaney Square. Traffic exiting here and wanting to turn right should be encouraged to use the existing exit ramps at the rear of the building, where Nashua Street provides direct access to Storrow Drive, Route 28, and the entrances to the Central Artery bridge and tunnels.
7. Design the cycle track proposed for Causeway St. to minimize impacts on pedestrians. The alignment of cycle tracks should not interfere with pedestrian movement. Cycle tracks could be located in space where landscaping is proposed. Cycle tracks should be located together so that pedestrians know where to expect bicycles. Pedestrians should be informed of the existence of the cycle tracks through a combination of eye-level signs and painted warnings on the pavement. Bicycle signals and signs in both directions should be installed to warn of pedestrian crossings. Bicycles waiting for signals and thus stored on the raised pedestrian platform should be minimized. Curbing along the cycle track should disappear at the raised pedestrian platform at Canal/Haverhill Sts. to avoid mishaps and to comply with ADA regulations.
8. Design lanes for movement on Causeway St. carefully. Preliminary designs indicate four 10.5’ vehicular lanes, a 5’ cycle track in each direction (possibly combined), a median strip of 6’ located between the two cycle tracks, and restrictions on existing turning movements at both Canal and Friend Streets.

WITHIN THE SITE

1. Reflect by design the number of pedestrian movements anticipated in Champions Way.
Where Champions Way meets the entrances to the TD Garden and the rail station concourse, pedestrians will be passing through between:
• The Green and Orange Line subway stations and the Commuter Rail Station
• The Commuter Rail Station and TD Boston Garden
• The Green and Orange Line subway stations and TD Boston Garden
• Canal St. and the Commuter Rail Station
• Canal St. and TD Boston Garden
We are concerned about the dimensions of this complex entrance and especially the ‘mixing bowl’ near the entrance to the TD Garden and suggest a detailed analysis to explain its ability to fully, conveniently and safely handle the many pedestrian demands to be placed on it.
2. Reconsider the dimensions of the MBTA underground passageway between the ‘mixing bowl’ and the subway station to maximize pedestrian convenience, safety and service. It has a 90-degree turn at one location, along with an inconsistent width progressing through the site. Additional width may be essential at the 90-degree turn. The queue of pedestrians at the bottom of the escalators should have adequate space for waiting.
3. Add a stairway inside the ‘mixing bowl’ to avoid overcrowding of the escalator and elevators. A stairway would also offer an opportunity for people to exercise during their on-site walk from the subway to the Garden or the commuter rail concourse.
4. Provide generous space for pedestrian circulation in and around the first floor at Champions Way.
The DEIR design has two escalators, two stairways (leading upward only) and two elevators (leading downward only.) Space is provided on both sides for people walking through between Canal Street and the rail station concourse. It is important that these facilities and spaces are matched closely to anticipated pedestrian traffic. It may also be important to look forward to future pedestrian traffic to be certain that the spaces and facilities are able to handle projected demand. For example, escalator redundancy may be a consideration to assure that pedestrian traffic moves without impediments.

BEHIND THE SITE

1. Commit to financial aid for the construction of the Charles River Southbank
pedestrian/bicycle bridge over the MBTA tracks. This proposal has been on the agenda for a considerable time. It has been proposed to complete the various pedestrian/bicycle projects along the Charles River in the vicinity of North Station. It will benefit all of the users on the South Bank of the river, and will aid non-motorized traffic to reach the site of this project.

WAYFINDING
1. Signs and other indications of routings for pedestrians should be provided to aid walkers and to direct pedestrian traffic to certain entry points.

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 Wendy Landman
Senior Project Manager Executive Director

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

By WalkMassachusetts | October 11, 2013

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 ENF for The Boston Garden project

By WalkMassachusetts | June 11, 2013

June 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 ENF for The Boston Garden project, MEPA #15052

Dear Mr. Sullivan:

WalkBoston has reviewed the ENF for The Boston Garden project. We understand that the building project will be constructed on 2.8 acres of land fronting on Causeway Street and include:

WalkBoston is supportive of this development and considers it a critical location that requires close examination of pedestrian circulation, as it encompasses major pedestrian movements between regionally important city and suburban transit facilities and a major sports facility. In addition to pedestrians already using the site, the proposal will need to accommodate the movements of the new workers, guests and residents brought into the new buildings on the site as the project components are completed.

Our comments focus on pedestrian volumes to the site, circulation inside the grouping of new buildings and along the perimeter of the site, and the potential for improvements to the Charles River walkway behind North Station.

Pedestrian volumes to and from the site
Many residents of the region already pass through this site daily and for special events. The site is the location of commuter rail connections to the northern half of the metropolitan area, two major subway stations and the TD Boston Garden, home of the Bruins and Celtics professional sports teams. These pedestrian volumes need detailing and evaluation. Our review of the data led us to the following numbers:

In the morning, the combined total for arrivals by commuter rail coupled with patrons exiting the Green and Orange line subway station is thus a number that is around 43,000 2 pedestrians using the stations for transportation access or interconnections in and around the site. A similar number may exist for the afternoon use of the site.

These numbers have not been updated and are of course prior to the construction of office, hotel or residence buildings that will bring additional people to the site. In addition, the existence of the 19,600-seat TD Garden arena above the commuter rail station can create circulation difficulties when people attending events overlap with people leaving the city after work. With over 200 events each year at the TD Garden and limited on-site parking for event attendees, there are many opportunities for overlapping movements of large numbers of people moving into and through the site. It may be possible to have over 60,000 people on the site in the afternoon hours prior to a major event.

As preparatory steps for addressing environmental concerns surrounding this project, it will be important to closely examine the volumes of pedestrian traffic that move to and from the site each working day, and on days with special events in the TD Garden. Flows of pedestrian traffic that are deserving of special attention include movements between:

the Green and Orange Line subway stations and the Commuter Rail Station
the Commuter Rail Station and TD Boston Garden
the Green and Orange Line subway stations and TD Boston Garden
Canal St. (used by downtown workers on foot) and the Commuter Rail Station
Canal St. and TD Boston Garden • Canal St. and the Green and Orange Line subway stations

These pedestrian movements deserve to be counted and evaluated for trends that indicate potential future use of transportation facilities at this site. Pedestrians going to or from the new on-site buildings will also be moving between:

the commuter rail station and the new buildings on site
the subway stations and the new buildings on site
Canal St. and the new buildings on site

These potential movements should be projected and evaluated in conjunction with the pedestrian traffic already using the site.

Pedestrian circulation through the buildings on the site
Pedestrians currently move into and out of the TD Garden building by using the east and west entrances on Legends Way and on the O’Neill Building pedestrian way. Plans show the intention of moving much of the pedestrian access between the subway stations and the TD Garden/North Station building below ground level. This will provide protection from weather conditions for walkers and is conceptually a major improvement for all.

The brief current outline of the plan calls for a passageway built under the large office tower to handle all pedestrian movements and connections on the site, located on the first basement level and connecting (in an undefined manner) between the subway stations and the proposed major pedestrian passage, to be called Champions Row. Escalators and elevators will be needed to make the connection fully ADA accessible and to speed the large volumes of pedestrians to their destinations.

It is entirely possible that this connection can be designed to handle the 43,000 users of transportation facilities on-site very well. However, it is equally possible that the volume of pedestrian traffic will be such as to thwart the good intentions of the proponent of this project. There are several possibilities for additional capacity to handle pedestrians in this important location under the office tower:

1. Addition of an escalator- and elevator-served access point leading into the present east entrance to the TD Garden/commuter rail station building (very much like the existing head house, but with a direct, covered connection into the building.)
2. A passageway between the subway station and the TD Garden/commuter rail station building that connects in several potential ways (all underground):
• As a diagonal passageway between the MBTA undercrossing of Causeway Street and the proposed main stem of the project – Champion’s Row. This passageway should be sufficiently wide to handle the considerable traffic using it twice a day.
• A passageway under the office tower could support small commercial/retail establishments that can quickly serve people passing through to make their commutes or to attend a large event.
• A passageway could envisioned as a large food court or produce market serving all pedestrians passing through as well as those who will be working in or nearby after the new structures are built.
• All proposed principal passageways, including Champions Row, should be unobstructed by escalators or elevators that may impede pedestrian movements.

There may be a desire to connect other buildings or uses planned for the site into this major pedestrian facility under the tower of the office building. If so, a major connection across Champions Row leading into the underground pedestrian facility would be needed to provide access for all of these pedestrian connections and services while also providing access for the four levels of retail attractions that are anticipated for the site

. Based solely on its need to serve so many access points for pedestrians on the site, Champions Row could conceivably become a much more significant and grander element of the site. Champions Row has been located to be on a direct axis between Canal Street and the entrance to the commuter rail station/TD Garden building. Like the major axis of an enclosed shopping center, it also provides direct access to the surrounding transportation facilities and the TD Garden. Alternatively, it could become a part of an imposing railroad station with retail facilities surrounding it and even below it (like South Station, perhaps, grand but laid out as a small Grand Central Station). In either event, the space could become a local landmark and meeting place for residents, commuters and event attendees.

Pedestrian access on the perimeter of the site
Because the new facilities back up to the TD Garden, three sides remain to be served by sidewalks – along Causeway Street, Legends Way and the O’Neill Building pedestrian way.

1. Causeway Street
Wide sidewalks are planned in keeping with the city’s Crossroads Project plans for Causeway Street. Street furniture and trees will be added in keeping with this plan. On the site, the façades of the new buildings will be lined up with the O’Neill Building to present a uniform appearance along the streets. A number of small and large retail facilities will have access to and from the sidewalks, and access to the three large buildings planned for the site will also be focused on the Causeway Street sidewalk. The sidewalk will not be interrupted by access ramps into the on-site garage, as these ramps are being located at the edge of the site adjacent to the Central Artery, and will supplement the existing ramps that are located at the rear of the TD Garden Building.

However, the diagrams show a loading platform near the proposed hotel building that will interfere with pedestrian traffic on the sidewalk significantly. This loading platform is a potential hazard for pedestrians on the Causeway Street sidewalk, particularly if service trucks back into the site from the street.

To be fully supportive and attractive to pedestrians, the new buildings could be designed to attract and provide interest for passers-by, using strategies such as:
• Maximize the number of retail outlets facing the sidewalk by using narrow frontages for business facilities
• Introduce sidewalk cafes, restaurants or bars
• Provide canopies along the building frontage to protect walkers
• Avoid intimidating pedestrians by the overwhelming scale of proposed buildings. The proposed façade for the Causeway side of the site is about three blocks long, and has been broadly designed to be a uniform building of four stories topped by towers. The four-story building could be intimidating for pedestrians – it is a very large and long building. Its façade could be articulated to show connections with the streets of the area, as is currently diagrammed for the three large towers planned for the site that line up precisely with Canal Street and Friend Street. The four floors of the building complex that are designed for retail could also reflect these breaks while retaining the alignment with the O’Neill Building, either physically or by using varied building materials.

2. The pedestrian passageway at the O’Neill Bldg.
This walkway should be treated qualitatively as handsomely as the Causeway Street frontage. It has become a major entrance for pedestrians and will continue to provide major access to the commuter rail station and the TD Garden. It could also become more interesting for walkers, if cafes or other retail establishments were added. It has the advantage of the statue of Bobby Orr which is a dramatic addition of great interest to pedestrians using the site. A canopy for the length of the walkway would be of great service to the pedestrians using the walkway for access to the TD Garden/commuter rail building.

3. Legends Way
This street will be of limited use for pedestrians, except to provide access to the east entrance into the TD Garden/commuter rail station building. Access for users of MBTA’s The Ride will be retained. Opportunities for retail uses appear very limited, but should be considered. This is another location where a canopy could be of considerable use to passengers waiting for The Ride.

4. The Riverfront walkway along the Charles
At the rear of the commuter rail station, the tracks serving the terminal narrow down to enter two bascule bridges across the Charles River. At this location, Central Artery plans included a bridge on the North Bank crossing over the tracks, a bridge on the South Bank also over the tracks, and a bridge that would be cantilevered or attached to a bascule bridge. The North Bank Bridge is now completed and in operation. The bascule bridge walkway is in design. The South Bank Bridge remains to be designed and constructed.

As a positive improvement to the environment of this project and as mitigation for some of the anticipated impacts of its construction, the proponent and the MBTA have begun discussions of constructing the South Bank Bridge. This positive development is very exciting, as it would complete the major interconnection of Charles River walkways on both banks, along with connections into the downtown Boston Harborwalk and the Charlestown Navy Yard.

Construction of the South Bank Bridge will involve examination of the potential building methods within a narrowly defined space on both sides of the tracks. On the east side of the tracks a sidewalk follows the boundary of the MBTA trackage at the river’s edge to a dead end at the bascule bridge. This sidewalk may become an approach ramp for the South Bank Bridge. However, there are difficulties in constructing the bridge on the west side of the tracks that are likely to require significant work in examining possibilities. The rewards of designing and constructing this bridge will have regional impact because of its connection to metropolitan-scale pedestrian facilities.

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