MBTA Blue Line Archives - WalkMassachusetts

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

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

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

October 11, 2013

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

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

Dear Secretary Sullivan:

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

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

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

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

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

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

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

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

B. Access to the site via MBTA bus service

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

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

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

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

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

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

C. High Quality Design, Amenities and Year Round Maintenance

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

D. Pedestrian paths through the property

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

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

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

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

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

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

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

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

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

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

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

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

E. Boardman Street Overpass

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

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

Sincerely,

Wendy Landman Robert Sloane
Executive Director Senior Project Manager

Comments on the ENF for The Boston Garden project

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

Comments on ENF for Caesars Resort at Suffolk Downs

March 26, 2013

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

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

Dear Secretary Sullivan:

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

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

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

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

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

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

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

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

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

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

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

Sincerely,

Wendy Landman
Executive Director

Waterfront Square at Revere Beach Comment Letter

May 8, 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 Final Environmental Impact Report (FEIR) for Waterfront Square at Revere Beach, EOEA #14080

Dear Mr. Bowles:

WalkBoston is happy to submit comments on the Final Environmental Impact Report (FEIR) for Waterfront Square at Revere Beach. This project is a Transit-Oriented Development (TOD) that embodies many of the precepts of concentrated development and pedestrian improvements that the state and region have been working toward. For this reason, our comments focus on whether the TOD elements will work well for pedestrians using the MBTA Wonderland Station, the new uses to be built on the site and people accessing Revere Beach and adjacent properties. We are pleased that many of the concerns we raised in our previous comments have been addressed by the FEIR, however (as discussed below) we continue to have some specific concerns.

We continue to be impressed that the project is being made possible by the joint efforts of the proponent and several public agencies owning property within the site. The public agencies – the MBTA and the Department of Conservation and Recreation have agreed to become part of the project to further the development goals of better, more intensive uses of their lands and increased use of the existing MBTA Blue Line terminus at Wonderland Station. Unfortunately, one site – the Seaside Site – has not been included in the development, even though it stands at the mid-point of the site and thus prevents contiguous development.

Summary of comments:

• Pedestrian connections to adjacent parcels should be explored.
• All crosswalks should have pedestrian signals timed to afford safe crossings.
• Pedestrian access on the ground level of the South Parking Garage seems to include potential hazards for pedestrians due to the need to cross bus lanes to reach the rail station
• Pedestrian crosswalks are sparse along Ocean Avenue.
• Pedestrian ramps at the Wonderland Station seem to be replaced by elevators and a stair. Does the new plan still include ramps?
• The Transit Plaza may have significant use by pedestrians linking train and bus trips, and should include generous walkways covered for weather protection.
• All bus-rail riders are required to cross above the rail tracks on one leg of their journey. Is there a way to explore all at-grade access between buses and trains on only one side of Wonderland Station?

Many WalkBoston concerns have been addressed by the FEIR. These include:

• Pedestrian access to the Transit Plaza above the roof level of the Wonderland Transit Station will be accomplished as part of the South Garage construction in Phase I. These elevators will be available for movement between the rail and bus stations and each level of the parking garage. A similar elevator will be added in Phase II between the east side of the rail station and the Transit Plaza level.
• The proponent is committed to constructing a pedestrian bridge connecting the site to the beachfront, and has committed to long-term maintenance and repair of the bridge.
• Sidewalks located along Route 1A on both sides of the street will be retained and improved as routes for local residents to walk to the station and the businesses or offices on the site.
• Sight lines and pedestrian connections pass through the proposed Transit Plaza and the pedestrian bridge from the site to the beachfront.
• These sight lines and pedestrian connections also reach to the future Revere stop on the commuter rail line west of Route 1A, through the large parking lot at Wonderland Park, now used for daytime commuter parking (and a future development site).
• The site has connections to regional trails and paths – beachfront and the north-south Border to Boston trail which connects to the Northern Strand Community Trail (aka Bike to the Sea Trail).
• The crosswalk at Route 1A and the access to the MBTA South Parking Garage is moved to the north side of the intersection. Nearly 400 people cross here daily according to August 2008 counts. At the north side of the intersection, pedestrians will be able to have a traffic signal cycle and not be at risk to the many right turning vehicles entering the South Garage site.

There are certain remaining concerns that are raised by our review of the FEIR:

• Alternatives should be explored to connect the Transit Plaza with adjacent parcels such as the Water’s Edge Apartments south of the Transit Plaza. Such a connection might be beneficial to this project because it could attract additional walkers to and through the site, either to the MBTA station or the beachfront.
• The Seaside Site, a parcel surrounded by this project but not included in these plans, is largely ignored. Pedestrian connections between this site and the north and south parts of this project and to the MBTA station and parking garages seem sketchy at best.
• A new crosswalk is planned at the intersection of Shawmut Street and the vehicular connection to the MBTA North Parking Garage. When the crosswalk is constructed, pedestrians should be provided with an adequate traffic signal interval to cross the street safely.
• Pedestrian circulation on the west side of the Transit Plaza at the entrance to the Blue Line station is shown in some detail in Figure F-2. The proposed Phase I South Parking Garage on MBTA property has a covered bus terminal directly adjacent to the Blue Line platform for easy pedestrian transfer between bus and rail services. The first floor of the Garage also houses kiss-and-ride and garage ramps. Pedestrian access between the drop-off lanes and the rail station appear to require crossing the bus lanes, and may be unsafe.
• Improvement of the pedestrian environment along Ocean Avenue is needed. Curb cuts for parking access along Ocean Avenue dominate the environment and only 6 widely separated crosswalks connect the site and the beachfront park.
• Existing pedestrian ramps at Wonderland Station provide pedestrian access up and over the station, independent of elevators. However, the ramps appear to be removed as part of the Phase II construction of the Transit Plaza and replaced by a monumental stairway. Will new construction include a physical replacement of the pedestrian ramps? If so, where will they be located in respect to the Transit Plaza, the MBTA train station and the MBTA bus station?
• The plan calls for elevators to be constructed on both sides of Wonderland Station to allow alighting riders to go up and over the station to reach either connecting buses or parking facilities. At the Transit Plaza level, peak period pedestrian movements may be significant, and may require generous connections between elevators, stairs and ramps. Perhaps these Transit Plaza pedestrian connections could be covered to protect transit riders from severe weather conditions? How many elevators are planned to accommodate peak hour pedestrian traffic between travel modes and the Transit Plaza? What volume of peak hour pedestrian traffic is expected?
• Can MBTA operating plans for arriving Blue Line trains at Wonderland Station be modified to reflect access to connecting buses? Currently, both inbound and outbound bus access takes place on the outbound side of the transit station, giving a direct at-grade route for alighting passengers to walk to buses, but requiring inbound pedestrians to climb up and over the station to the inbound tracks. In this proposal, future inbound access to rail from arriving buses will be at-grade on the inbound side of the transit station, and require outbound passengers to cross up and over the tracks to the outbound buses. Is it possible that arriving trains could be routed to the inbound side of the station, where they would have the same cross-platform access to buses without using stairs, ramps or elevators? Is it possible that this change in train routing could obviate the need to construct a Transit Plaza elevator on the east side of the tracks?

Thank you for the opportunity to comment on the Final Environmental Impact Report (FEIR) for Waterfront Square at Revere Beach. We hope our comments on the FEIR are incorporated into your requirements for the next phase of design and permitting documents. Please contact us for any clarification or additional comments that would be useful.

Sincerely,

Wendy Landman
Executive Director

Robert Sloane
Senior Planner