FEIR Archives - WalkMassachusetts

Letter to Review Team on Restoration of the River Edge

From: WalkBoston, Charles River Conservancy, Charles River Watershed Association

To: MassDOT – officials, staff, consultants Review Team on the I-90 Allston Interchange Improvement Project

Date: August 15, 2018

Re: Charles River – Restoration of the River Edge

On behalf of three organizations committed to the protection of the Charles River and its parklands, public access and pathways, and environmental health we jointly request that MassDOT fulfill its responsibilities to this invaluable resource by analyzing and developing options for the ecological restoration of the severely degraded and eroded riverbank in the I-90 Interchange Project area – from the BU Bridge to the River Street Bridge. This Project directly impacts the Charles River Basin , its parkland, ecology, water quality, and overall resiliency; dealing with those impacts is integral to the Project.

A study by MassDOT in advance of the FEIR should include re-establishment of a more natural edge, bank restoration, stormwater management, and increased floodplain connectivity and storage for resiliency. It should explore at least one alternative that creates better habitat and provides flood storage through the use of fill material in the river to accomplish these objectives. We ask that between now and when the FEIR is produced, a detailed analysis of alternatives, carried out in a collaborative manner, be developed so that results can be incorporated in the FEIR.

The DEIR did not adequately consider the need to restore the river bank, improve the park, and improve water quality. The DEIR has chiefly dealt with these impacts by trying to avoid them on the theory that permitting for the Project would be more difficult if river edge improvements are included. We are convinced that the contrary is true: a serious examination of these improvements would enlist substantial support from organizations, municipalities, and agencies committed to restoring environmental quality in this area – support that will be important to obtaining required approvals.

Restoration of this area requires attention to a number of issues and several important state and federal requirements, including:

1. Protect the river bank from further degradation and restore aquatic and riparian habitat. Much of the existing bank is degraded and eroding, eliminating fish habitat. The Charles is an important fish run for alewives, blueback herring and American shad, migratory fish that return to the river each year to spawn.

2. Provide parkland and improve safe walking and biking conditions as part of multi-modal improvement called for in MassDOT’s Project “purpose and need” statement and under Article 97.

3. Reduce stormwater runoff discharging to the river via overland flows and outfalls, including the 13 outfalls along Soldiers Field Road in the Throat Area. Both MassDOT and DCR have regulatory obligations to comply with phosphorus limits established in the state’s Lower Charles River Basin Nutrient Total Maximum Daily Load (2007).

4. Provide flood resilience, control and storage capacity for precipitation-based inland flooding within the context of current and expected climate change impacts.

5. Develop landscape strategies and designs that provide Section 4(f) mitigation. Removing invasive species, dead trees and replanting with native vegetation, in addition to incorporating green infrastructure, should be integral to the study.

6. Plan for the riverfront parkland, which is a water-dependent use under Chapter 91.

7. Meet historic requirements for the Charles River Reservation in the Charles River Basin Historic District included in Section 106 of the National Historic Preservation Act and Massachusetts Historical Commission review.

8. Comply with the Article 97 no net loss policy that requires replacement of parkland that is to be taken by the Project.

One example of how an alternatives analysis could address these issues is the environmental assessment and recommendations prepared for the North Shore Riverfront Ecosystem Restoration Project in Pittsburgh, PA. It provides extensive river edge improvements, including a natural bank, new pathways, landscaped parklands, connected floodplain, and wetlands. It was developed jointly by local environmental organizations and local, state and federal agencies, including the US Army Corps of Engineers. (https://www.lrp.usace.army.mil/Portals/72/docs/ProjectReviewPlans/N%20Shore%20Riverfront%20DP R%20MSC%20Approved%20for%20Release.pdf?ver=20160524161651743)

We are committed to working cooperatively with you in this process in order to evaluate the options and to achieve results in an expedited and cost-effective manner to restore and enhance this area of the Charles River and the Basin parklands.

We look forward to your response.

Wendy Landman, Executive Director, WalkBoston
Laura Jasinski, Executive Director, Charles River Conservancy
Margaret VanDusen, Deputy Director and General Counsel, Charles River Watershed Association

Please join WalkBoston, the Charles River Conservancy and the Charles River Watershed Association at a “Throat” Walk, September 12, 5:30 PM. We will meet at “BU Beach” behind the Marsh Chapel.

Images from Environmental Assessment of North Shore Riverfront, Pittsburgh

Comments on the Supplemental Information Document for the Back Bay/South End Gateway Project

October 5, 2017

Brian Golden, Director
Boston Planning and Development Agency
ATTN: Michael Rooney
One City Hall Square
Boston, MA 02201-1007

RE: Comments on the Supplemental Information Document for the Back Bay/South End Gateway Project dated August 18, 2017

Dear Mr. Golden:

WalkBoston has reviewed the documents for Back Bay/South End Gateway Project many times. Although the proponent has made efforts to address some of the issues we raised in our prior comments, we continue to have concerns about the project impacts to the extremely busy pedestrian environment around the project area, and to several of the design elements suggested by the proponent.

We have reviewed the letter submitted by South End resident Ken Kruckemeyer and would like to concur with his comments and his very thoughtful suggestions about how to remedy some of the problems that he describes.

Possible garage exit ramp across the Dartmouth Street sidewalk adjacent to the Station
We remain vitally concerned about the possibility of an exit ramp from the project garage onto Dartmouth Street into the heaviest pedestrian traffic in the area. Back Bay Station Orange Line, Commuter Rail and Amtrak service presently serves approximately 64,000 passenger trips (alighting and boarding) each day. Many more pedestrians are simply walking by the site, arriving on buses, via cabs and in automobiles. The MBTA, MassDOT, and all people concerned with the continued economic vitality of the Boston area and a more sustainable transportation system, hope that this number will rise significantly over the coming decades. The Back Bay/South End Gateway Project must be designed and managed in such a way that the transit and transportation functions of the station are enhanced.

WalkBoston does not think that a project design that includes a garage exit ramp that requires cars to cross the Dartmouth Street sidewalk is acceptable. Putting the interests of drivers above those of the tens-of-thousands of pedestrians who use this sidewalk is not an appropriate use of public space. Given the intensity of sidewalk use, and the overlap of peak transit and garage use, we do not believe that the ramp can be designed and/or managed acceptably. Asking pedestrians to wait while single cars exit the garage is not a reasonable solution.

We are very concerned about the changes proposed for the station, the bus layover and the sidewalks and interior passageways, but we believe the exit ramp onto Dartmouth Street is a potentially disastrous step to take in such a congested area. We urge the BPDA to recommend that further consideration of the project as presently designed be delayed until this issue is resolved favorably with no garage ramp exiting across the Dartmouth Street sidewalk.

We would 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
Executive Director

Cc Secretary of Transportation Stephanie Pollack City Council President Michelle Wu City Councilor Josh Zakim Ellis South End Neighborhood Association Bay Village Neighborhood Association Neighborhood Association of Back Bay Ken Kruckemeyer

Comments on the FEIR for the Back Bay/South End Gateway Project MEPA: #15502

August 11, 2017

Matthew Beaton, Secretary
Executive Office of Energy and Environmental Affairs (EEA)
ATTN: Alex Strysky, MEPA Office
100 Cambridge Street, Suite 900
Boston MA 02114

Brian Golden, Director
Boston Planning and Development Agency
ATTN: Michael Rooney
One City Hall Square
Boston, MA 02201-1007

RE: Comments on the FEIR for the Back Bay/South End Gateway Project
MEPA: #15502

Dear Sirs:

WalkBoston has reviewed the FEIR for Back Bay/South End Gateway Project. While we appreciate the proponent’s efforts to address some of the issues we raised in our DEIR/DPIR comments, we continue to have concerns about the project impacts to the extremely busy pedestrian environment around the project area, and to several of the design elements suggested by the proponent.

Per our own quick review of MBTA data, Back Bay Station Orange Line, Commuter Rail and Amtrak service presently serves approximately 64,000 passenger trips (alighting and boarding) each day. Many more pedestrians are simply walking by the site, arriving on buses, via cabs and in automobiles. The MBTA, MassDOT, and all people concerned with the continued economic vitality of the Boston area and a more sustainable transportation system, hope that this number will rise significantly over the coming decades. The Back Bay/South End Gateway Project must be designed and managed in such a way that the transit and transportation functions of the station are enhanced.

Our key comments and concerns are as follows.

1. Possible garage exit ramp across the Dartmouth Street sidewalk adjacent to the Station
The project proponent and MassDOT support, and are eagerly awaiting, the decision of the FHWA about the closing of an I-90 on-ramp which would allow the project to locate the garage exit elsewhere.

WalkBoston does not think that a project design that includes a garage exit ramp across the Dartmouth Street sidewalk is acceptable. Putting the interests of drivers above those of the tens-of-thousands of pedestrians who use this sidewalk is not an appropriate use of public space. Given the intensity of sidewalk use, and the overlap of peak transit and garage use, we do not believe that the ramp can be designed and/or managed acceptably. Asking pedestrians to wait while single cars exit the garage is not a reasonable solution.

We urge MEPA to recommend that further consideration of the project as presently designed be delayed until this issue is resolved favorably with no garage ramp exiting across the Dartmouth Street sidewalk.

2. Route and layover location for Bus 39
The proponent seems to have reached a reasonable set of recommendations for much of the routing of Bus 39. However, in order to provide accessible and weather protected transfers for people wishing to use the Orange Line, Commuter rail or Amtrak services, the route should include a stop at Back Bay Station on both its inbound and outbound routes. This is particularly important because the Green Line is not fully accessible for people with disabilities and people with strollers.

The FEIR does not provide any details about layover for the Route 39 buses, a critical issue to keep this very busy route operating with reasonable service levels.

Until these questions are resolved, we do not believe that the transportation planning for the project has been adequately addressed and request that the proponent be directed to work
with the MBTA and the City of Boston to find fully workable solutions.

3. Dartmouth Street Sidewalk
The width of this critical sidewalk – critical because of its role as a major element of the Back Bay transportation system that serves well in excess of 70,000 pedestrian trips/day – is
constrained by the introduction of a wide furnishing zone and the filling in of the walking area in the weather-protected arcade beneath the station arcade and the existing garage overhang.
We urge the proponent to continue to modify the sidewalk plan so as to maximize the walking area. A 13-foot sidewalk (at the station) and a 17-foot sidewalk at the new commercial frontage (where the existing garage is located) are each narrower than the existing sidewalk and are not adequate in this location. The arcade could be kept open to walkers, the first floor of new commercial building could be set back, and the large planters shown should be removed (especially important along this street frontage where people will be getting picked up and dropped off).

4. Pedestrian Bridges across Stuart Street and Trinity Place (outside the project site)
We urge the proponent to delete the pedestrian bridges (other than the one internal to their site) as unnecessary and deleterious to the active street life that makes Boston a walkable and lively City. We disagree with the proponent’s contention that “the pedestrian bridge(s) will …further enhance transit access, pedestrian safety, and neighborhood connectivity.” In fact we believe that such bridges diminish all of these characteristics.

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
Executive Director

Cc Secretary of Transportation Stephanie Pollack
Laura Brelsford, MBTA Assistant General Manager, System-Wide Accessibility
City Council President Michelle Wu
City Councilor Josh Zakim
Ellis South End Neighborhood Association
Bay Village Neighborhood Association
Neighborhood Association of Back Bay
Ken Kruckemeyer

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Comments on the DEIR/DPIR for the Back Bay/South End Gateway Project

April 18, 2017

Matthew Beaton, Secretary
Executive Office of Energy and Environmental Affairs (EEA)
ATTN: Alex Strysky, MEPA Office 100 Cambridge Street, Suite 900
Boston MA 02114

Brian Golden, Director
Boston Planning and Development Agency
ATTN: Michael Rooney
One City Hall Square
Boston, MA 02201-‐1007

RE: Comments on the DEIR/DPIR for the Back Bay/South End Gateway Project
MEPA: #15502

Dear Sirs:

WalkBoston has reviewed the DEIR/DPIR for Back Bay/South End Gateway Project. We are concerned about this project because of its impacts on rail and bus transportation, walking and biking. With the latest submission of plans for the project, we continue to see serious issues with pedestrian access into, through and around the site. These are described below.

Inappropriate relocation of the layover site for the Route 39 bus
The proposal states that the layover site for the Route 39 bus will be located “off-‐site.” Back Bay Station is one end of this bus route, which is one of the busiest in the MBTA system, serving Back Bay, the Fenway and Jamaica Plain. Buses congregate here and wait until schedules require them to return to the main route.The proposal for Route 39 is to remove it entirely from the streets directly connected to Back Bay Station, and to truncate the route before it connects with the Orange Line or the commuter rail/Amtrak services. Reducing the convenience of connections between Route 39 and other portions of the MBTA system will result in negative impacts on transit riders that should be avoided. We urge the City and MEPA to require the proponent to bring Route 39 back to the station. A possible layover site is Trinity Place (between Stuart and St. James Streets). The re-‐routing of the 39 bus route to this layover location could provide a reasonable drop-‐off and pick-‐up solution on Stuart Street, which will have direct pedestrian access in Back Bay Station for bus riders.
Sidewalks that surround the site
Sidewalks along the Dartmouth Street side of the project, where foot traffic is already heavy and likely to increase due to the new development, have been widened to a minimum of 13 feet, as shown in Fig, 3.8b. Sidewalks along Stuart Street are to be a minimum of 11 feet, as shown in Fig, 3.8c, perhaps reflecting the proponent’s projection of likely foot traffic on this side of the site. Along Clarendon Street, sidewalks range from 9 to 15 feet, as shown in Fig. 3.8d; it is not entirely clear if the 9’ width is a result of the footprint of the proposed residential building.Sidewalks may not be sufficiently wide, especially if street trees, planters or bicycle parking are also accommodated in the width otherwise available for pedestrians.A large public plaza is proposed at the Clarendon Street intersection to replace the existing forecourt to the east entrance to the station. Here sidewalks are very wide and the plaza offers generous open space. Much of this plaza appears to be for passive use to people walking by, although there is a retail space provided in one corner that, if used as a restaurant, might result in tables on the outdoor plaza.We are pleased to see that the principal entrance to Back Bay Station on Dartmouth Street is enhanced by the addition of major new entrances framed by the arch and a design that focuses on providing continuity of the sidewalk and interior surfaces to unite them and welcome users. An enlarged Dartmouth Street crosswalk that is 60 feet wide along the site’s frontage will be centered on the new entrance. Taxi zones are provided both north and south of the main entrance.We are pleased that the proponents have increased sidewalk widths by comparison to the earlier proposals.
Movement on sidewalks around the perimeter of the project
The project site is in a pedestrian-friendly portion of the city. There are more people walking along and crossing the perimeter streets than there are drivers using these same streets. For example, looking at the existing condition pedestrian volumes counted between 8:00 and 9:00 AM in 2016 in Figure 4.6a, we note that there are 2,253 people crossing Dartmouth in front of Back Bay Station, 1,264 walkers crossing on the east walk of the Stuart Street/Dartmouth Street intersection, 1,098 pedestrians crossing Stuart Street at Trinity Place, and 1,646 pedestrians crossing Stuart Street at Clarendon Street. A total of 1,071 pedestrians crossed the garage driveway on Clarendon Street during this period.Meanwhile, in the same period, Dartmouth Street handles 486 cars northbound and 703 cars southbound. Stuart Street handled 784-1,057 vehicles in this period and Clarendon Street handled 503-625 vehicles.Although there are 15 different projections of vehicular traffic under alternative futures, there are no projections at all of pedestrian traffic. There are, however, projections of pedestrian level of service at selected intersections. See Table 4.12.3 page 4-126. The accompanying text states that PLOS doesn’t change between Existing, No-build and Build Conditions because walk times and cycle lengths will not change. Is this a valid conclusion without he benefit of projecting future pedestrian volumes?Based on the data that was provided, it appears that there are about three times as many pedestrians as there are cars during peak hours.
Movement across the sidewalk – Dartmouth Street
In order to improve access to the proposed parking garage, the proponent has proposed changing Turnpike access patterns and partially shifted vehicle access and egress away from Stuart and Clarendon Streets and provided a new exit onto Dartmouth Street. These changes directly affect pedestrian safety at the principal pedestrian access to Back Bay Station.As shown on the proponent’s plans, the proposed vehicular exit from the garage is in an inappropriate location on Dartmouth Street. The exit ramp will pose a hazard for pedestrians on this portion of Dartmouth Street, where thousands of people (see numbers in Section 3 above) are walking during peak hours. This location is an especially busy and important place for pedestrians walking to, through and making connections to transit.Shifting the location of Turnpike access so significantly by removing a major access point to the westbound Turnpike in the midst of Back Bay and requiring all drivers to use alternative access on Huntington Avenue does not make sense for this part of the City. This does not seem an appropriate choice in the context of Boston’s adoption of Vision Zero and the City’s declaration in GoBoston 2030 that Boston will “prioritize the movement of people over cars.”
WalkBoston does not believe that it is in the interest of public safety and convenience to shift existing vehicular access so that it results in a garage exit ramp in a congested pedestrian zone. An alternative to this garage exit ramp should be developed.
Movement across the sidewalk -Clarendon Street
On the Clarendon Street side of the property, there are multiple garage entrances and exits as there are today, and the sidewalk needs very careful treatment to protect pedestrians. The proposal to add a bulb out to shorten the Clarendon mid-‐block pedestrian crossing is a good idea. As noted above, WalkBoston believes that Clarendon Street is a better location for garage and Turnpike access than the proposed Dartmouth Street garage exit and circuitous Turnpike access.The new plaza on the Clarendon Street side of the property has been designed with a drop-‐off lane that doubles as a route for delivery and service vehicles for the residential and retail occupants of the structure. The drop-‐off lane occupies what appears to be about 40% of the plaza, and raises the question of whether it needs to be this size.If the space is being used primarily for vehicular needs – drop-offs, taxis, deliveries, service, and potential bus storage – that colors the manner that the design might take for the plaza. If, on the other hand, some of the vehicular needs could be transferred to the street – perhaps with some widening to accommodate the intended use. Getting rid of the drop-off lane would considerably improve the potential for this plaza to be genuinely pedestrian-friendly, and open it to other retail uses that would enhance the productivity and attractiveness of this end of the property.
The station area concourse
We are gratified that the proponent enlarged the proposed waiting area, rather than transforming it into a retail facility. However, we continue to be concerned about the redesign 4 of the concourses to narrower passageways lined by many retail facilities. New retail activity will increase in the number of pedestrians to accommodate on the narrowed concourses. The relocation of the commuter rail and Amtrak ticket offices to a new location at a substantial distance from either the waiting area or the entrances to the rail platforms seems ill-‐advised. The proposed new location is deeper within the station area, much closer to the east entrances than to the likely more important west entrances. It is also indistinguishable from adjacent retail stalls that may or may not have relevance for rail travelers. The proposed layout is occurring during a period of reduction in the number of small retail businesses in many locations, including central Boston and the Back Bay. Active ticket offices in a central location may be more important to bolster other retail outlets, and benefit the management and rental of retail stalls throughout the station area.
Construction on the rail station platforms
The proposal calls for use of the station platforms for supports for the new high-‐rise building being built in the Station East portion of the project. These new obstructions narrow the platforms for waiting or alighting passengers and add complexity in an environment where moving to or from access points is already complicated. This is true of both the Orange line platform, serving both directions for subway passengers and the southernmost railway platform serving commuter rail passengers to and from the south and southwest, including Providence, New York, Washington and the entire eastern seaboard.Using the existing rail platforms for construction of these supports will obstruct passenger traffic during construction as well as after completion. Designs should be carefully integrated with existing obstructions such as columns to minimize interference with passenger traffic flow.

We are very concerned about the changes proposed for the station, the bus layover facility, the vehicle circulation, sidewalks and interior passageways. We would 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 Bob Sloane
Executive Director Senior Project Manager

Cc City Council President Michelle Wu
City Councilor Josh Zakim
Ellis South End Neighborhood Association
Bay Village Neighborhood Association
Neighborhood Association of Back Bay

Comments on FEIR for Government Center Garage

October 24, 2014

Secretary Maeve Vallely Bartlett
Executive Office of Energy and Environmental Affairs (EEA)
Attn: MEPA Office EEA #14069
100 Cambridge St., Suite 900
Boston MA 02114

RE: Comments on the Final Environmental Impact Report for the Redevelopment of the Government Center Garage, MEPA #15134

Dear Secretary Vallely Bartlett:

WalkBoston has reviewed this document to identify potential implications for pedestrians. We offer the following comments.

Sidewalk Widths

The FEIR contains detailed drawings of sidewalk widths at all locations, and WalkBoston believes that the widths are completely adequate, except as noted below at the outer bus bays facing the Greenway. On map B.2 – Conceptual Improvement Plan, Bus Bays #4, 5, and 6 are shown with sidewalks that are only 8.5 feet wide, compared with those of Bus Bays #1, 2, and 3, which have 15 foot sidewalks without encroachments. Bays 4, 5, and 6 also appear to have a line of windbreaks that encroach on the 8.5’ width. No benches are shown, but the text response to our DEIR comments states that, “Additional measures, such as windbreaks and seating areas will also be incorporated into the reconfigured Haymarket Bus Station area.” The relatively narrow sidewalk coupled with windbreaks and potentially benches as well, could make the sidewalk uncomfortably narrow and crowded at Bays 4, 5, and 6. We urge the proponent to consider a modest re-distribution of space to provide wider sidewalks at these bus stops.

Truck loading bays

WalkBoston continues to be concerned about loading docks that require trucks to back from the major adjoining streets into the building. Two of these streets are major access ways into Central Artery (I-93) and will require very careful operation to be safe for both pedestrians and other vehicles. Clear and enforced management should stipulate that they will not be used, except in emergencies, during daytime working and peak travel times.

Cut-ins on sidewalks

Cut-ins proposed on three sides of the East Parcel and two sides of the West Parcel should also be managed to reduce conflicts with pedestrians as loading and unloading occurs from vehicles. Management of the site should ensure that use of the cut-ins for deliveries (not for guest or resident drop off) is minimized during busy portions of the day or evening.

Thank you for the opportunity to comment on this important project. Please feel free to contact us if there are any questions.

Sincerely,

Robert Sloane
Senior Planner