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EENF 1265 Main Street Waltham Comment Letter

By WalkMassachusetts | February 15, 2011

February 15, 2011

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

RE: Expanded Environmental Notification Form (EENF)
1265 Main Street
Waltham, MA
MEPA # 14681

Dear Mr. Sullivan:

WalkBoston is the Commonwealth’s leading advocate for pedestrians and safe walking. We work throughout the state – encouraging walking, advocating for pedestrian improvements and working for design improvements. We have extensive experience helping residents and local government with pedestrian issues, safe routes to school and safer street crossings.

We have reviewed the EENF for 1265 Main Street, Waltham (formerly The Commons at Prospect Hill), a proposed mixed-use retail and office redevelopment at the site of the former Polaroid buildings.

The project at 1265 Main Street includes approx. 1.28 million sf of mixed office/retail uses in the proposed redevelopment. Phase I of the proposal will use existing buildings formerly occupied by Polaroid along Route 128 to accommodate these uses. Parking for retail and office uses will be shared to provide maximum and successive use of auto storage areas. Phase II of the proposal calls for new buildings scattered around the site.

WalkBoston’s concerns focus on the fact that walking and pedestrians facilities do not appear to be a major component of the project, although the project is frequently called “pedestrian-friendly” in the document. Pedestrian accommodations are listed on p. 92 of the EENF as being primarily along or connected with the residential areas facing Main Street. Plans for the reconstruction of Main Street will surely include sidewalk replacement and widening. Sidewalk connections within the site and between buildings are not discussed, with the exception of the Wayside Trail, which will accommodate pedestrians in addition to cyclists.

WalkBoston is concerned that some opportunities may be lost which could help make walking a part of the project’s benefits. These opportunities are concentrated in six areas:
1. Pedestrian access into the development site
2. Pedestrian connections to transit routes
3. Pedestrian access along the corridor of buildings
4. Pedestrian access along Wayside Trail
5. Pedestrian access into Prospect Park
6. Pedestrian access into Berry Farm

Each of these opportunities is considered below:

1. Pedestrian access into the development site is apparently to be incorporated into three proposed vehicular access routes into the site from Main Street on the south side of the site. The three access routes are Tower Road, the extension of Cutting Lane, and a new roadway that skirts the existing residential community along Hill Road to connect into Main Street at a new location. No access is provided from the north.

2.
• The principal accessways into the western part of the site appear to be along Tower Road on the western edge of the site and the extension of Cutting Lane which goes up the middle of the site. Tower Road connects between all buildings to be reused as part of Phase I. The extension of Cutting Lane connects only to the first two buildings of the former Polaroid site, providing major existing pedestrian access points into the buildings.
• Tower Road is already a major facility for access to the site and is likely to retain its importance as part of Phase I of this development. The proposal calls for two lanes of entering traffic on Tower Road, which suggests it will be carrying a major load of traffic in the future. It connects into the parking areas only indirectly. As such, Tower Road does not appear to be the most appropriate site for major pedestrian access into the site.
• Pedestrian access into the development site is not indicated in the graphics of this proposal. However, the logical location for pedestrian access may be along the proposed new roadway between Main Street and the eastern half of the site. This road is proposed to be located on a new right-of-way that leads to the north part of the site. It provides access to an existing building near the south boundary of Prospect Park which (we assume) will be retained as part of this development. Sidewalks can be created on one or both sides of this new roadway to give access to the existing building if it is to be retained.

3. Pedestrian access to transit from the development site is discussed only vaguely in the EENF. Transit for people working on site and for visitors should be more thoroughly discussed as the project moves forward.
• Transit lines along Main Street will continue to serve this development. At present there is one bus shelter located about one-quarter of the way from Tower Rd/Stow St. to Cutting Lane. Future connections to the transit services along Main Street should be closely connected to the principal pedestrian access within the site. As mentioned above, the future axis could be along the extension of Cutting Lane. If that is the principal on-site sidewalk, it suggests that the bus shelter and stop be relocated to be closer to that axis. Since this portion of Main Street is proposed to be widened and reconstructed, the new bus shelter can become part of that improvement.
•The proponent has expressed a willingness to add a bus route within the site. A new line would be a welcome addition to the access to the site. The proponent should consider where stops will be located on site and whether there should be shelters at those locations.

3. A pedestrian access corridor through the site would be very useful. The proposed development consists of a row of buildings parallel to Route 128/95. This single axis of buildings suggests a prime location for such a corridor.
• The extension of Cutting Lane is on an alignment that appears to be appropriate for pedestrian access to all of the buildings proposed to be activated by Phase I construction. Although there is no continuous roadway for vehicles on the east side of all the buildings, sidewalks and safe pedestrian facilities can readily be provided along this axis. This is particularly appropriate since some of the recommended pedestrian facilities are already in place outside the existing buildings, providing access to existing and proposed parking on the east side of the buildings.
• The pedestrian access corridor would seem to be more efficiently and pleasantly located along the extension of Cutting Lane rather than Tower Road.
• Pedestrian connections will need to be provided across the major parking lot located at the north end of the existing major complex of buildings on the site. This parking lot can be developed with safe pedestrian walkways across it to connect between all buildings on the site.
• The Low Impact Development (LID) for Stormwater Design, calls for underground water storage facilities beneath parking lots. Specifically an underground stone reservoir is planned for the parking lot that is located between buildings. A long-range view of the grouping of buildings might include a building on the site of the parking lot. This in turn would tie the pedestrian portions of the site closer together, and not require pedestrians to walk across a parking lot for access to the buildings. Is it possible to design the underground water storage facility to permit construction of a future building above it?

4. Pedestrian access to the Wayside Trail is welcome. The proponent has generously volunteered to construct a portion of the Wayside Trail along the former railroad right-of-way that passes through this property. The trail is proposed for use by pedestrians as well as bikes. The use of the existing right of way meshes well with state-wide planning effort for this trail.
• On site, all street/trail intersections should be carefully protected. If traffic signals cannot be provided, traffic calming measures should be considered. Signing should be plentiful to warn motorists of the crossings by pedestrians and bikes.
• Additional consideration should be given to the most appropriate location where the trail can safely cross Main Street. If the trail is located within the rail right-of-way, it will reach Main Street in the vicinity of either Cutting Lane or the new access road that skirts the Hill Road residential area. A traffic signal at either location would allow for safe crossings of Main Street. Alternatively, the trail could extend to Stow Street/Tower Road and cross at the signal proposed for that location, although the traffic at the Tower Road/Stow Street/Main Street intersection is expected to be relatively heavy. • If Main Street is to be widened as part of this project, it may be appropriate to incorporate the Wayside Trail as an integral element in the design of Main Street between the Hill Street residential area and Route 128/95. It might become a facility parallel to Main Street but somewhat separated from it. The trail could be on either side of Main Street, depending on the design. It is important to provide a sufficient width to make this portion of the trail spacious for all users – a minimal sidewalk will not suffice.

5. Pedestrian access into Prospect Park is critical. One of the beauties of this site is the extensive background of nearby adjacent public parkland. People working on the site or visiting will be able to see the park and should be provided with options for walking or jogging in it. • Direct access to the parking is cut off by the Low impact Development (LID) for Stormwater Design, which calls for water quality swales to control runoff from nearby steep land. The proposal calls for 2 water storage areas in what appears to be the southeast corner of Prospect Park. These water storage areas are proposed to be bounded by a new site access road, which will ultimately connect to Route 128/95. Pedestrian access through these sites appears to be difficult but not impossible. Perhaps a landscaped walkway could connect between the park and the buildings lined up along Route 128/95. Consideration of this connection would add significantly to the amenities of the site. • Signing on walkways would be appropriate to lead walkers from business areas into the park’s trails and potential jogging routes. Signs could also lead people from major parking areas and from site roadways into the park. • Use of the trails and walkways within the park should be encouraged through signage, promotion among employers on the site, and by sharing maintenance responsibilities between the City and the proponent.

6. The proponent will donate Berry Farm area to the city as part of this project. Pedestrian access into Berry Farm open space could result from this project. This will expand and greatly enhance the availability and accessibility of open space in the area.
• A direct trail or walkway connection between the proposed Wayside Trail and Berry Farm should be considered. There appears to be a physical connection between the main portion of the farm and the former rail right-of-way. This “leg” of Berry Farm should be used to construct an entranceway into the farm. An area directly adjacent has been designated for parking for Berry Farm. This means that people can drive to both the park and the trail and have access from this site.

Thank you for the opportunity to comment on this EENF. Please feel free to contact us for clarification or additional comments.

Sincerely,

Wendy Landman
Executive Director

Riverwalk Redevelopment Lawrence Comment Letter

By WalkMassachusetts | April 24, 2009

April 24, 2009

Secretary Ian Bowles
Executive Office of Energy and Environmental Affairs, MEPA Office
100 Cambridge Street, Suite 900
Boston, MA 02114

RE: Comments on the Expanded Environmental Notification Form (EENF) for the Proposed Riverwalk Redevelopment in Lawrence.

EOEA #14389

Dear Secretary Bowles:

Thank you for the opportunity to comment on the Expanded Environmental Notification Form (EENF) for the Proposed Riverwalk Redevelopment in Lawrence. We are pleased to see redevelopment where it can bring significant economic benefits, and especially where it affords the opportunities for new or expanded pedestrian facilities. Our understanding is that the project is looking for a Phase I waiver to allow initial demolition and construction of relatively modest buildings. These initial moves set the stage for the larger Phase II.

Riverwalk is located on the banks of the Merrimack River, but is separated from the river by a strip of land owned privately and occupied principally by a very wide municipal easement, consisting of a large sewer pipe, covered by a wide granite slab. This strip of land has long been planned by the City to be a pedestrian walkway along the Merrimack, and its existing design condition lends itself well to this purpose.

We are concerned that the Riverwalk project may be turning its back on the City’s proposed riverfront pedestrian improvements. The project as shown in this document could be substantially improved to ameliorate this situation. We suggest the following improvements:

One driveway in the project now occupies much of the waterfront side of this property on the north. This driveway appears to be designed primarily for truck access to one existing building (the Cotton Mill) and one proposed structure (the proposed commercial building of 3 stories.) It will be a lost opportunity if the site’s entire river frontage becomes pavement to serve this truck access. Consideration should be given to relocating most of the truck access further into the site interior. While trucks will continue to need access to the redeveloped Cotton Mill, it is on the east side of the site and can be accommodated by a service road connection that leaves options open for further use of the river frontage of the site.
If truck access were removed from most of the river frontage of the site, more benign pedestrian-oriented use could be made of this advantageous waterfront location. Parkland could be added, and if a large commitment of outdoor space can be made, it can provide amenities for employees and visitors to existing and proposed buildings on a scale that is difficult to find in other cities.
If parkland could be provided along the riverfront, the layout of the site might be reconsidered to focus all of the buildings toward the river, its views and its amenities. In practice this would suggest that pedestrian walkways be added between all the site’s buildings and the water’s edge. For example, walkways across the large parking lot might be provided and emphasized with landscaping to provide a major pedestrian connection between the river and the Wood Mill. We understand that sidewalk access from the Cotton Mill to the river already exists on the east side of the site. River access from all proposed new buildings should also be provided through the use of a sidewalk network that connects to all parts of the site and its buildings. In some cases, this may mean that the sidewalks might have a dedicated right-of-way that is not located alongside a new street.
Where roadways are proposed on the site, they should include sidewalks, and most of the proposal indicates that to be the case. However, along the frontage of the Wood Mill (included in Phase II), no sidewalks are provided. As the project moves into more detailed design, truck and pedestrian access will be clarified. At that point, sidewalks should be provided to the principal entrance on the parking lot side of the Wood Mill.

Thank you for the opportunity to comment on the EENF for the Proposed Riverwalk Redevelopment. Please contact us for any clarification or additional comments that you may need.

Sincerely,

Wendy Landman Robert Sloane
Executive Director Senior Planner

Plymouth Rock Studios Comment Letter

By WalkMassachusetts | January 3, 2009

January 3, 2009

Secretary Ian A. Bowles
Executive Office of Energy & Environmental Affairs
Attn: MEPA Office, Deidre Buckley
100 Cambridge Street, Suite 900
Boston, MA 02114

Chairman Marc Garrett
Plymouth Planning Board
Plymouth Town Hall
11 Lincoln Street
Plymouth MA, 02360

RE: Comments on the Expanded Environmental Notification Form for Plymouth Rock Studios in Plymouth EOEA # 14345

Dear Mr. Bowles & Mr. Garrett,

WalkBoston appreciates the opportunity to provide comments on the Expanded Environmental Notification Form for Plymouth Rock Studios (PRS) in Plymouth. We applaud the developer for proposing extensive on site pedestrian circulation. PRS has the potential to be an important economic engine for the lower South Shore region.

While the PRS proposal provides a number of pedestrian facilities, some changes to the design could further improve the pedestrian experience.

Greater attention to the needs of pedestrians could be given to the Studio Amenities Zone. This particular area of the site is very auto-oriented, and it would benefit walkers if the buildings were closer together and linked with sidewalks, and all sidewalks should be directly tied into the site’s recreation paths.
The recreation path along the project’s new access drive crosses and re-crosses the roadway. While these crossings are provided via bridges to avoid conflicts, a pathway that stays to the west of the access drive seems to be more straightforward. Although wetland B is close to the roadway, given the available buffer area, the recreation pathway could be designed to hug the west side of the roadway.
Pedestrian access to the bungalow housing units could be improved by adding a paved path to connect the cul-de-sac to the recreation pathway and the access drive/ring road.
Pedestrian access near the ten single-family home sites on Long Pond Road could be improved by adding a wooded walking trail.
The applicant should explore making a short off-site trail connection to the west, connecting the PRS Campus to Bump Rock Road.
The applicant should explore making better use of the existing shared use path that is being retained in the Studio Amenities Zone by integrating it and connecting it to the 2 proposed recreation paths as a looped walking or jogging route for use by the residents of PRS.
The existence of a Zone I Aquifer and associated buffer should not prohibit the enhancement of this existing shared use path, perhaps using permeable paving. MassDEP permits passive recreation uses within Zone I, such as walking, jogging or bicycling.
The proposed recreation path will connect to existing hiking trails on the adjacent townowned conservation land. The applicant should be asked to provide additional details on how these pedestrian amenities interconnect and complement each other.
Most of the pedestrian trips made daily on the PRS campus will not be able to take advantage of the full pedestrian network. Assuming a majority of the 4,190 proposed parking spaces experience daily turnover, at least 2,000 pedestrian trips a day will be made between parking lots and structures and the various buildings on the PRS campus. Given the propensity for pedestrian and auto conflicts in the loosely-structured driving situations that parking lots provide, and the large number of foot trips that PRS drivers make in accessing their cars, we believe it is paramount for pedestrian safety that a footpath system be established throughout the parking lots. The provision of sidewalks and designated walkways through the parking areas, signage and directional markings, could be combined with the required parking lot plantings that are designed to reduce the heat island effect.

The PRS proposal includes amenities and offers some attractive mitigation that will enhance the pedestrian experience. We trust that the Secretary’s certificate and local project approvals will condition these improvements to ensure that they are built. We recommend that the following proposed improvements and mitigation be conditioned in project approvals:

a. Proposed traffic calming along the area of Long Pond Road, north of Clark Road. At this time, only a commitment to explore such work exists. Traffic calming along this stretch of Long Pond Road will ultimately be very important for the pedestrian experience, as the measured 85th percentile speeds in this location were well above the speed limit.
b. The proposed modern roundabout at the intersection of Clark Road and Long Pond Road. Although it was not included with the Expanded ENF, (and is proposed by others), its existence is critical to the local roadway system if PRS is to be built. The project proponent should ensure that pedestrians and bicyclists are very carefully considered in the design of the new roundabout and all sidewalks and paths leading to it.
c. Pedestrian crossings where the project’s new access road meets Clark Road. Pedestrians traveling along Clark Road and crossing the project’s signalized multi-lane access drive should be able to walk safely and efficiently. The project’s roadway and turning lanes should be kept to minimal widths where they intersect Clark Road.
d. Sidewalks along all internal roadways. These sidewalks, as proposed on page 6-101 of the Expanded ENF, are an important pedestrian amenity and their installation is essential.
e. Details on the placement and type of bicycle accommodations, including weather protected secure storage locations. The installation of bicycle improvements is essential, and would be in keeping with the proponent’s proposed credits in the LEED Project-Wide Credit Summary, Table 5.2.1 of the Expanded ENF.
f. The recreation path from Clark Road, past the Plymouth South School Complex and through the project will provide a significant amenity as proposed, and could connect 3 through the Crosswind Golf Club to Forges Field Recreational Complex, helping to realize the vision for the “Wishbone Trail” in the Plymouth Open Space Plan.

Thank you for the opportunity to comment on the PRS Enhanced Environmental Notification Form. We look forward to seeing the next phase of project design and permitting submissions.

Please feel free to contact us for clarification or additional comments.

Sincerely,

Wendy Landman Robert Sloane
Executive Director Senior Planner

Nahant Beach Rehabilitation Comment Letter

By WalkMassachusetts | July 15, 2008

July 15, 2008

Secretary Ian Bowles
Executive Office of Energy and Environmental Affairs
100 Cambridge Street, Suite 900
Boston, MA 02114

RE: Expanded Environmental Notification Form (EENF) Rehabilitation of Nahant Beach Reservation, City of Lynn/Town of Nahant
MEPA # 14268

Dear Mr. Bowles:

We have reviewed the EENF for the Rehabilitation of Nahant Beach Reservation. As the Commonwealth’s leading advocate for pedestrians and safe walking, we have a responsibility to note projects that affect large groups of pedestrians within the state.

We commend the Department of Conservation and Recreation for their sensitive consideration of the needs of pedestrians who use the beach facilities. The work that has been done will lead to positive improvements in both rehabilitation of the facilities and upgrading to accommodate modern needs and concerns.

The retention and upgrade of the dune-top path that runs the full length of the Reservation will assure access for relatively long-distance walkers while providing a pleasant view and walk experience. New sidewalks within the parking lots and parallel to the Parkway will certainly make the lots safer for pedestrians, making for a pleasant experience for walkers who are being discouraged from taking informal paths across the dunes.

The plan has only one drawback: a fragment of a walk along the Lynn Harbor side of the Reservation is intriguing because it would offer a novel experience for walkers along a distinctly different side of the beach. Financing may prevent current upgrading of the walkway, but, over the long-term, we hope the addition of the harborwalk along the full length of the Reservation will become possible. Perhaps the steps involved in improving the Lynn Harbor side of the Reservation might be designed to accommodate (or not preclude) upgrade of the walkway along the harbor.

Thank you for this opportunity to comment on the Nahant Beach Reservation project. Please feel free to contact us if further questions arise.

Sincerely,

Wendy Landman
Executive Director

Meadow Walk at Lynnfield EENF Comment Letter

By WalkMassachusetts | October 10, 2007

October 10, 2007

Secretary Ian Bowles
Executive Office of Energy and Environmental Affairs
100 Cambridge Street, Suite 900
Boston, MA 02114

RE: Expanded Environmental Notification Form (EENF) Meadow Walk at Lynnfield
MEPA # 09800

Dear Mr. Bowles:

We have reviewed the EENF for Meadow Walk at Lynnfield, a proposed mixed-use retail, office and residential redevelopment of a portion of the Sheraton Colonial Golf course in Lynnfield and Wakefield. We are pleased that walking is being encouraged as a major organizing feature of the development – a worthy initiative. We are commenting because of the immense potential for incorporating extensive pedestrian access in mixed-use suburban development throughout Massachusetts.

The proposed Meadow Walk at Lynnfield comprises 395,000 SF of retail space, 80,000 SF of office space and 200 housing units of which 40 are allocated to the Lynnfield Initiative for Elders (LIFE). It includes 3,438 parking spaces and will increase the number of vehicle trips generated by the site from 644 to 19,079 per day. The retail/office components of the development are designed to be a traditional Main Street where frontage is lined with retail outlets, and on-street parking and pedestrian amenities are key design elements.

The scale of the development is sprawling. Most of the buildings appear to be 1 story in the retail areas, with 2-story exceptions (shown in renderings of the central open space.) Buildings taller than 2 stories are included in the residential areas.

Summary of comments:

 The development appears to be primarily an outdoor mall, without roofed pedestrian walkways and with a street where an enclosed walkway inside a standard mall might ordinarily appear. Notwithstanding some token nods to pedestrians, the overall site is characterized by vast parking lots, relatively high-speed roadways around the lots, visibility from a major highway, and traffic that is dispersed around the site.
 Of the roughly 2 miles of roadway to be constructed, one half mile is truly pedestrian-friendly, while one mile serves solely vehicular traffic and another half mile serves the back side of the retail/office structures with little physical separation of pedestrian and vehicular movements.
 If pedestrian friendliness is to be a major selling point of the development, a great deal of adjustment should be made to the current design to incorporate elements more specifically encouraging to pedestrians.

Overall site plan

 A high density of uses in the center of the development, tapering toward the perimeter, does not appear as a guiding feature of the plan. High density encourages walkability.
 The proposed development rigorously separates land uses. The retail/office uses are separated from the residential uses and open spaces. Uses are not mixed within single structures (except perhaps for offices). Residences are not planned above stores or offices, though that would encourage walking.
 The street network could benefit from full integration of the interior Main Street with parking service streets and from street connections to the residential area.
 The existing Boston Sports Club building and Sheraton Hotel, which are to remain on the site, have not been integrated in any way with the proposed development. 
The comparably-scaled Mashpee Commons on Cape Cod offers a useful contrast in pedestrian friendliness. A similar development of 250,000 SF of retail space with 90 stores, Mashpee Commons has residential uses above many retail outlets, creating walkability as a major feature. Its circulation plan emphasizes the creation of traditional city blocks, multi-story structures that hold both retail and residential uses, 2 main streets with connections to minor streets that lead to all parking lots, some very smallscale stores, and mid-block meeting places and walkways. Westwood Station, being planned at Rte 128/I 95, has 1000 residential units above or adjacent to retail.

Relationship to Traditional Neighborhood Development Planning
The development adopts many of the current concepts about traditional neighborhood developments without full embrace of them. In particular, it has these distinctions:

 A roadway solely for vehicles extends around the perimeter of the site for approximately one mile, and the interior pedestrian-friendly street is roughly a half-mile in length. The interior street is paralleled by a street on the other side of the retail/office structures that is also about a half mile long but with few pedestrian friendly features.
 Transit service does not connect directly into the site and is not within walking distance.
 Proposed pedestrian access ways are tied to streets. All pedestrians must enter the site at locations where vehicles also enter. Pedestrian circulation is entirely along the sidewalks next to the streets. No off-street pedestrian walkways for circulation or for access to the site or nearby open space areas are provided.
 Additional pedestrian access to the site could be added on the Walnut Street frontage of the site owned by the project proponent. Without this access, pedestrians arriving via Walnut Street must enter near the Rte 128 ramps, a location with heavy traffic volumes.
 On-street parking is permitted only on the Main Street, (making the sidewalks safer with the protection of a row of cars separating pedestrians from the roadway) and not on either the perimeter street or access ways into parking lots.
 The location of the site next to a protected environmentally sensitive site suggests the possibility of pedestrian walkways or jogging paths for recreation at the site perimeter. These paths might link to the Sheraton Hotel via the bridge over the Saugus River.

The retail/office components

 The roadway network for the retail and office elements consists of a perimeter road, with access into parking lots from 14 separate intersections. Five short streets connect the parking lots and the Main Street.
 The project’s retail elements are organized around the spine of a traditional Main Street. The Main Street seems to serve a minimal circulation purpose, as it is a closed loop within the overall project, connected primarily at an entrance location to the Rte 128/I-95 access points for the project.
 The interior street is gently curved – a nice touch.
 The proportion of street frontage with active commercial uses that encourage walking may be limited because all of the stores will have entries facing both the street and the parking lots. Retail operations are unlikely to be able to support window displays or store-related activities on two street frontages of each site.
 All buildings appear to be designed for large-scale uses – perhaps big box stores that swallow up frontage unless broken up by smaller stores.
 Small structures do not appear to be included, but encouraging participation of small entrepreneurs can encourage outdoor browsing and pedestrian activity. 
Parking seems to be excessive. The 3,438 parking spaces for the development contrast with Mashpee Commons with less that half that number.
Open space in the retail/office area is limited to the small central square while open space outside the perimeter road is relatively lavish, because of abutting wetland. 
The interior shopping street should have a dense tree canopy to encourage walking.
Design standards for sidewalk and path construction were not provided. In some instances, greater widths will provide more public space and greater levels of activity.

The residential components
Residential units include luxury housing (160 units) and the LIFE component (40 units) wholly separated from retail/office uses by the perimeter street. This results in:

 The retail and office mall comes close to the residential units at the only part of the site without vast parking capacity on the mall side. Even here, pedestrians must cross the parking lots in front of the residential buildings before crossing the street into the mall.
 The residential access road (a part of the perimeter road around the site) is about 1500 ft long between parking access points and has only two access points into the residential parking lots. This layout suggests it may become a relatively high-speed roadway with hazards for walkers. Two pedestrian crosswalks are provided to cross this street at the luxury apartments. No crosswalks are indicated for the LIFE buildings.
Residential buildings could be grouped to reduce the impact on this environmentallysensitive location. Grouping would allow residential structures to be at a greater distance from the wetlands, while retaining the pleasant views.
There should be direct pedestrian access between the residential and retail/office uses. (Sidewalks are not always shown on the plans.) The possibility of a more direct connection might result in locating the residences inside the perimeter roadway where they can be more immediately adjacent to the retail/office uses.

Thank you for the opportunity to comment on this document, which offers great promise for improvements for pedestrians in a suburban setting. Please feel free to contact us for clarification or additional comments.

Sincerely,

Robert Sloane
Senior Planner