MEPA Archives - WalkMassachusetts

Channelside DEIR/DPIR comments

August 20, 2021

Secretary Kathleen A. Theoharides
Executive Office of Energy and Environmental Affairs
Attn via email: Alex Strysky (alexander.strysky@state.ma.us )

Director Brian Golden
Boston Planning and Development Agency
Attn via email: Aisling Kerr (Aisling.Kerr@boston.gov)

Re: Channelside DEIR/DPIR comments

Dear Secretary Theoharides and Director Golden:

WalkBoston, LivableStreets Alliance, Boston Cyclists Union, FPNA and MassBike are submitting our joint comments on the Channelside Project regarding transportation within and to the development site.

We have focused our comments on the broad and underlying transportation conditions that will impact the existing and future neighborhood as well as the residents and workers who will occupy the proposed 1.4 million SF development that is undergoing review. While we have detailed comments on several aspects of the proponent’s site design and proposed mitigation, these are issues that later project phases could address.

We are pleased that the proponent has fully embraced the idea of Transit Oriented Development (TOD) and Complete Streets designs, and has provided travel projections for the project that predict a net total of 4,633 trips generated by the site of which 4,089 are walking, biking and transit trips – an impressive 88% of all trips! We also applaud the plan to redevelop what currently is non-permeable parking lot pavement into a park and pathway system which will help control the impacts of tidal flooding along the channel.

However, we are disappointed and concerned that the DEIR/DPIR devotes so little analysis of future conditions and, more specifically, how these thousands of trips will be served. Section 4.4 Transportation Build (2028) Condition of the document devotes (excluding maps and tables) ½ page to bike accommodation, 2 pages to transit, and 0 pages to walking (this notwithstanding that both walking and transit mode shares will depend on pedestrian facilities – including especially walking access from South Station and Broadway Station). And we are disappointed the project team is seeking to “not overburden” a transit system which currently does not serve this area sufficiently, instead of actively increasing capacity and service in advance of the rapid growth expected at Channelside. This development cannot be “Transit Oriented” without providing for increased transit usage.

Unfortunately, the DEIR/DPIR is following the precedent of several prior development projects in the Seaport, South Boston and Fort Point Channel neighborhoods, by focusing on this project in isolation of the rapid transformation that is occurring around it. Given the growth of these neighborhoods over the course of the last two decades, continuing to review all development projects in the area as single projects and not more holistically as a large agglomeration of projects that together require significantly better transit, walking and biking conditions to work well for its residents, workers, visitors and businesses, risks the future success of this, and many other projects in the area.

Continuing down this piecemeal development planning path is unsustainable for the neighborhood and the City, and places undue burden on individual developments to solve problems that may include their project yet go beyond their boundaries. This parcel at 244-284 A Street is a crucial connection to a network of safe bicycling and walking routes that flow throughout the city, and needs to be incorporated into a vision of a connected, sustainable, and safe waterfront trail and harborwalk that includes all of the City’s waterfront neighborhoods.

We ask that MEPA require the City of Boston (along with MassDOT, the MBTA and Massport) to complete, fund and begin the implementation of the South Boston Transit Study prior to advancing the permitting of new projects. We believe that without such action the proponent’s project (along with existing and other new development projects) will choke the neighborhood with traffic, provide insufficient transit service, not include an accessible sidewalk system (both within the development zone and connecting to South and Broadway Stations), and lack safe bicycle facilities connected to a larger network for those most vulnerable on our roads.

We have included below excerpts from the MEPA and BPDA Scopes for the project that we believe call for an analysis of how all trips (auto and non-auto) trips will be managed and provided for. We do not think that the DEIR/DPIR answers these scope items.

MEPA Scope

Trip Generation
The DEIR should fully describe and document existing and proposed pedestrian and bicycle facilities, transit operations and roadway and intersection conditions within the study Area. (page 9)
The TIA should describe the project’s anticipated transportation impacts and identify appropriate mitigation measures. The Proponent should indicate a clear commitment to implement proposed mitigation measures and describe the timing of their implementation, including whether measures are implemented based on phases of the project or occupancy levels. (Page 10)
Multimodal Facilities
It should describe all existing and proposed pedestrian facilities, including sidewalks, crosswalks, bicycle paths and bicycle parking spaces, located within the study area. The DEIR should review the regional pedestrian and bicycle network, evaluate the safety and capacity of the network and describe potential measures to enhance connections between the site and other locations and routes. (page 9)

BPDA Scope

“Melcher Street will be another important pedestrian connection for the site and its high volume of transit users connecting to South Station. Pedestrian safety and accessibility improvements are needed and a priority for the City and community. The Proponent should commit to working with the city to design and construct improvements to Melcher Street from A Street to Summer Street.” (Page 26)
“Additional transit service and connectivity was identified as needed on A Street in the South Boston Seaport Strategic Transit Plan [and the South Boston Dorchester Avenue Transportation Plan]. “The Proponent should provide shuttle service on A Street that connects to Broadway Station and South Station. Ideally, this would be in partnership with other corridor stakeholders such as State Street Bank that currently provides shuttle service on A Street that connects to South Station. New and efficient shuttle stop locations will need to be determined through consultation with the City.” (Page 26)

A private shuttle service should not be the primary solution for the lack of transit access in the area. In addition to completing the long awaited South Boston Transit Study, the City should study the potential implementation of BRT on Congress Street, connecting to North Station. Additionally the MBTA is currently in the process of a system-wide bus network project. Now is an opportune time to work with the MBTA to determine the current and future transit needs for the neighborhood and to build the necessary street infrastructure to accommodate that bus service (i.e. bus lanes, new bus stops, ADA accessible sidewalks).

Sincerely,

Stacey Beuttell, WalkBoston Executive Director
Stacy Thompson, LivableStreets Alliance Executive Director
Becca Thompson, Boston Cyclists Union Executive Director
Tom Ready, FPNA
Galen Mook, MassBike Executive Director

Cc Senator Nick Collins
Representative David Biele
Boston City Councilor Ed Flynn
Boston City Councilor Michael Flaherty
Greg Rooney, Commissioner, Boston Transportation Department
Jamey Tesler, Secretary, MassDOT
Steve Poftak, General Manager, MBTA
Joel A. Barrera, Massport, Director of Strategic and Business Planning
Patrick Sullivan, Seaport TMA, Executive Director
David Gibbons, Executive Director, MCCA
Rick Dimino, President and CEO, ABC

WalkBoston Comments on MEPA Regulatory Review 3-31-21

While the text is pasted below, we recommend clicking here to view this letter as the full PDF – images and tables were embedded in letter which did not render properly below.

March 31, 2021

Secretary Kathleen A. Theoharides
Executive Office of Energy and Environmental Affairs

Attn: MEPA-regs@mass.gov Dear Secretary Theoharides:

WalkBoston appreciates the opportunity to provide comments on the MEPA Regulatory Review effort. As you are aware, we frequently provide comments on projects that are submitted for MEPA review and feel that this step in the Massachusetts regulatory system is vital for maintaining the quality of the environment in the state, and that issues are often surfaced that result in project changes that are beneficial in many areas of environmental quality.

Our comments on the regulations themselves are focused on the transportation requirements of the process. For clarity, where we have pasted text directly from the MEPA forms or regulations the text is shown highlighted in a text box.

Project Notification Form (Page 2)

Summary of Project Size Existing Change Total & Environmental Impacts

Vehicle trips per day Parking spaces

TRANSPORTATION

We suggest that the summary table be modified to reflect all modes of travel to ensure that project proponents and all reviewers are thinking about the range of transportation demands that projects will generate. In turn, as discussed later in this letter, the review thresholds should be redefined to include transit trips as well as vehicle trips and parking spaces.

This will also address the issue that, in asking for Vehicle trips per day (based on the ITE Trip Generation Manual), the availability and use of other non-auto modes of transportation, including car-pooling/ride-sharing, transit, walking and biking, is not acknowledged or included quantitatively in the PNF. By “adjusting” the ITE trips, all person trips (i.e. the total demand for travel) are accounted for.

Further, we suggest that the form should also ask for peak hour vehicle and transit trips, as in some locations peak hour trips are a better indication of impact than daily trips. We understand that this may require some new modeling tools that make better estimates of non-vehicle trips, but we believe that this is an appropriate step for Massachusetts to be taking with respect to transportation thinking. The reporting of trip generation in the ENF table should include the following:

TRANSPORTATION

Daily Vehicle trips
Peak Hour* Vehicle trips
Daily Transit trips
Peak Hour* Transit trips
Daily Walking trips
Daily Bicycle trips
Parking spaces

* Typically, the peak hours would be weekday commuter peaks but can include other periods or weekends for some land uses such as Retail, Recreation, Entertainment etc.

(Page 16)

TRANSPORTATION SECTION (TRAFFIC GENERATION)

Please delete the qualification phrase “Traffic Generation” from the title – this section is about all transportation modes.

We recommend deleting this question as a threshold question. If a project does not require state permits, but does meet the review thresholds due to the numbers of vehicle trips and transit trips, the proponent should still be required to complete the traffic multi-modal transportation impact questions on the form. The environmental impacts of the transportation demands generated by the project do not disappear if no state permits related to state-controlled roadways are required.

II. Traffic Impacts and Permits

Title – replace “Traffic” with “Transportation” to encompass all transportation modes.

Question identification – please correct the lettering system so that there is only one question per letter. The questions are presently shown as A, B, C, D, C, D, E.

I. Thresholds / Permit

B. Does the project require any state permits related to state-controlled roadways? ___ Yes ___ No; if yes, specify which permit:

A. Describe existing and proposed vehicular traffic generated by activities at the project site:

Number of parking spaces Number of vehicle trips per day ITE Land Use Code(s):

Existing _______ ________ ________

Change ________ ________ ________

serving the site? Change

     ________
     ________
     ________

T otal _______ ________ ________

T otal ________ ________ ________

B. What is the estimated average daily traffic on roadways

Roadway
1. ___________________

2. ____________________ 3. ____________________

Existing ________ ________ ________

C. If applicable, describe proposed mitigation measures on state-controlled roadways that the project proponent will implement:

D. How will the project implement and/or promote the use of transit, pedestrian and bicycle faciliti and services to provide access to and from the project site?

The table in Section A should be modified to include daily transit as well as vehicle trips, and peak hour trips by vehicles and transit. The peak hour trips should be appropriate for the land use of the project (e.g. M-F commuting for office use, and Saturday for retail, etc.).

While daily vehicle and transit trips are useful proxies for the scale of transportation impacts and as general thresholds, we believe that projected peak hour trips are a better indicator of potential impacts by each mode. We suggest therefore that the impacts called for in Section B should be based on peak hour trips assigned to the roadway network and the transit network.

Similarly, we suggest that Section C should be modified to include proposed mitigation measures on all transportation infrastructure that the project proponent will implement.

Please add detail to Section D on transit, walking and biking – for example by adding the following questions.

– Are sidewalks provided along all road frontages of the project?
– Are sidewalks provided along all roadways within the project site?
– Are bike facilities provided on all of the roads around the site?
– Are bike facilities provided on all of the roads within the site?
– Provide a map showing where the nearest transit facilities are provided.
– Are sidewalks and bike facilities available to get to the nearest transit?
– Do sidewalks within the project site connect to the local sidewalk/trail network or
other sidewalks?

(Page 17)

TRANSPORTATION SECTION (ROADWAYS AND OTHER TRANSPORTATION FACILITIES)

We suggest that the title be changed to “TRANSPORTATION SECTION (for Transportation Infrastructure Projects” to clarify the purpose of this section and the need to complete it.

Section 11.03 Review Thresholds, (6) Transportation

We urge that MEPA review the 3,000 adt threshold in order to look at two questions, both of which we believe are important to understanding how projects will affect the multi-modal transportation systems into which they fit.

(1) We believe that the threshold should include both vehicle and transit trips/day to reflect the importance of transit trips to the functioning of Massachusetts’ transportation systems. Congestion and capacity on some portions of our transit system are of greater importance than roadway congestion and capacity, so we urge that it be measured and included as a threshold. Further, the first or last part of a transit trips involves walking to arrive at, or depart from, a development, and are therefore important in considering the adequacy of the pedestrian infrastructure supporting the project.
(2) Is 3,000 the appropriate number of vehicle and transit trips generated that cause such a small impact on area transportation conditions that review beyond an ENF is not needed? Or, have conditions changed since that threshold was established (greater levels of development, greater awareness of the impacts of traffic on human health, water quality etc.) that a lower threshold should be established?

The number of parking spaces included in a project is a proxy for many potential impacts on the environment including transportation, use of land (about 8 acres of paving would be required for a 1,000-car surface parking lot), water quality, habitat, and others.

(a) ENF and Mandatory EIR.

6. Generation of 3,000 or more New adt on roadways providing access to a single

(a) ENF and Mandatory EIR.

7. Construction of 1,000 or more New parking spaces at a single location.

We recommend reducing the threshold for parking spaces to 500 spaces which still represents a very significant impact that should be reviewed in full through an EIR.

As a result of the new climate bill signed by Governor Baker this week, we will be looking to EEA and MEPA (and others) for guidance on how the new Climate Bill environmental justice requirements will address cumulative transportation impacts and not simply the new impacts that result from an individual project. We believe that the guidance may require significantly greater review of both impacts and mitigation measures.

Thank you for the opportunity to comment on these important regulations. We would be pleased to speak with the MEPA staff if they have any questions about our comments.

Best regards,

Stacey Beuttell, Executive Director
Wendy Landman, Senior Policy Advisor

Comments regarding the transportation model underlying project design and operational decisions

Re: Comments regarding the transportation model underlying project design and operational decisions

Dear FHWA Administrator McEwan and MassDOT Acting Director O’Dowd,

The I90 Allston Task Force met last night (December 11, 2019), the evening before today’s deadline for comments on the Allston I-90 NEPA Scoping Report.

The entire meeting (2+ hours) was consumed by a conversation about the model being used by CTPS (also to be used by MAPC on an additional study) to evaluate the requirements and impacts of the project. As became clear during the course of the presentation and Q&A, the assumptions about transit service that are built into the model will lead to results that point to very low use of West Station (45-60 minute headways during peak hours) and no use of the Grand Junction line (no service at all). The Task Force asked the project team for information about these assumptions a year ago because we were concerned about this issue and its potential impacts on the project review.

We ask that FHWA and MassDOT incorporate the meeting minutes of the Dec. 11 Task Force as WalkBoston’s comments about the Scoping Report because they reflect the serious questions needed to be answered about the basis on which project plans and designs will be made.

Most notably, if the model assumptions lead to results that show little to no use of West Station we fear that a number of decisions will be based on incorrect data:

West Station will be put at risk because it will show such low ridership use
Grand Junction components of the project will be at risk because there will seem to be no travel demand
Bus, walking and biking elements of the West Station area will seem to be of little use because West Station will be shown as having very low use
Sizing of roadway elements of the project (both highway and street elements of the project) will expand because almost all of the trips to be served will be modeled as vehicle trips – because such inadequate transit service has been baked into the model assumptions
West Station and the rail service included in the project assessment will be at odds with the MBTA’s own plans for regional rail as recently voted on by the FMCB – thus putting the MEPA and NEPA analysis at risk for not conforming with state and local plans
The I90 “Allston Multimodal Project” will be at odds with Massachusetts policies and goals regarding the reduction of GHG emissions because it will be premised on a vehicle-based transportation system – thus putting the MEPA and NEPA analysis at risk for not conforming with state and local plans

Thank you for the opportunity to provide comments, and for including the comments of the I90 Task Force in the project record.

Wendy Landman

WalkBoston Senior Policy Advisor and Task Force Member

WalkBoston and MassBike comments on Waltham High School MEPA #16097

November 26, 2019

Secretary of Energy and Environmental Affairs Kathleen Theoharides
Executive Office of Energy and Environmental Affairs (EEA)
Attn: MEPA Office, Page Strysky
100 Cambridge Street, Suite 900
Boston MA 02114

Dear Secretary Theoharides,

WalkBoston and MassBike have reviewed the MEPA filing #16097 for Waltham High School located at 554 Lexington Street in Waltham, MA.

We are concerned with changes to Lexington Street that are included in the environmental filing: in particular, a new design speed of 45 mph, the removal of bicycle lanes in order to add additional general travel lanes, and poor connectivity. The changes are at odds with the Waltham Complete Streets policy as well as the recommendations put forth in the Waltham Transportation Master Plan (TMP) from January 2017. As proposed, this project will make Lexington Street more dangerous for all Waltham residents, even motorists. The segment of Lexington Street where the changes are proposed is, in addition to an important north-south arterial for motorists, bicyclists and pedestrians, a residential street lined with single-family homes and their driveways where residents turn left across oncoming traffic, and pull in and out.

Three of our major concerns from the filing:

This project has set a new design speed limit of 45mph on Lexington Street near the new high school; the street previously varied between 40 mph, a 30 mph advisory speed, and 20 mph school zone. The AAA Foundation for Traffic Safety has found that the average risk of severe injury for a pedestrian struck by a vehicle reaches 10% at an impact speed of 16 mph, 25% at 23 mph, 50% at 31 mph, 75% at 39 mph, and 90% at 46 mph. The TMP noted that the Waltham Police Department identified speeding “as a significant issue” on Lexington Street. However, when a speed study was conducted for the high school project, the 85th percentile speed recorded was 41mph, leading to a new design speed set at 45mph. This does not mitigate the existing problem of speeding drivers on Lexington Street, but instead, legitimizes it. The purpose of this project should not be to maximize vehicle speed and throughput. On the contrary, the goal must be to create a safe access to the new high school for all modes and ages, especially the most vulnerable.
A community should be safe for residents to get around, whether by walking, cycling, using transit, or in a vehicle. That safety and comfort is impacted by the design of our streets and intersections. All existing elementary schools in Waltham currently participate in the Massachusetts Safe Routes to School Program, which encourages students and their parents to walk and bike to school, something they hopefully would continue through high school. Parents also need to feel comfortable allowing their children to walk or bike to school. Many students walking to and from school will have to cross Lexington Street. A speed limit of 45 mph is not consistent with safe crossing by pedestrians, yet Lexington Street has the opportunity to see more students walking and bicycling to school in the years to come: a proposed new K-8 public school may occupy the site of the existing high school. With additional vulnerable road users in this area, it is important to ensure that anyone driving on Lexington Street is doing it at a safe speed, and that safe and comfortable facilities are provided for vulnerable users. The City should consider expansion of the 20mph School Zone on Lexington Street to include all three schools, or through creating a 20 mph “Safety Zone,” which was established in 2016 under Mass General Law Chapter 90, Section 18B.
Existing bicycle facilities will be converted to shared-use lanes in order to accommodate turn lanes at the proposed intersections. This is not in accordance with the TMP recommended cross section for the Lexington Street Corridor, which included sidewalks and a consistent 6’ bike lane throughout the corridor on each side of Lexington Street, and has been implemented. Additionally, the TMP recommends any redesigns consult up-to-date design guidance. It is unlikely any guidance would pair an increased speed limit with the removal of bike lanes.
Lack of non-Lexington Street connections to the site. If the high school is to be constructed at the Stigmatine site, paths should be constructed connecting it with residential neighborhoods to its north, south and west. These neighborhoods are within easy walking and bicycling distance of the Stigmatine property, as long as connections are established, with an opportunity significantly to reduce traffic to the site from Lexington Street and demand for parking. The initial plans show only access via Lexington Street, but supplemental filings include letters from the Police and Fire Department that reference potential emergency access routes to Lincoln Street and Jericho Hill Road that could be used by people walking or bicycling. These should be investigated further, as they could be an important option for encouraging walking and bicycling to the site, while excluding cut-through motor traffic.

Potential solutions at the Stigmatine site are restricted by the additional problems that will be created on Lexington Street. We are hopeful that the city can consider more ways to use this project to back up the vision put forth in the TMP: “In addition to implementing physical improvements, easing today’s congestion and minimizing the congestion encountered in the future will require mode shift, smart land use planning, and mitigation on the state, City and private partnership level.”

We encourage the MEPA office to take a deeper look at this project: the impacts are serious enough that it may require an environmental impact report.

Thank you,

Brendan Kearney, Deputy Director, WalkBoston
Galen Mook, Executive Director, MassBike

Comment Letter RE: MEPA 16015 Mystic River Pedestrian and Bicycle Crossing

May 13, 2019

Kathleen Theoharides
Secretary of Energy and Environmental Affairs 100 Cambridge St., Suite 900
Boston, MA 02114

RE: MEPA 16015 Mystic River Pedestrian and Bicycle Crossing

Dear Ms. Theoharides:

WalkBoston has worked closely with other community and advocacy groups in support of this proposed bridge over the Mystic River. Because of its critical location at the junction of several lengthy riverside paths, it is of regional significance as a key element in the area’s network of pedestrian and bicycle thoroughfares – a system of facilities that WalkBoston has long supported. The critical nature of the connection is magnified by its potential service as a major walkway between a high traffic generating facility (the casino in Everett) and public transportation (the Assembly Station in Somerville). This new walkway will provide a three- minute walk to public transit (as opposed to a twelve-minute existing walk) and encourage a reduced amount of vehicular traffic in the area.

The Casino operators have supported the proposed bridge with investments of $2,000,000 to date, and have committed to help with further capital funding. We are grateful for this assistance and hope that this provision of private funding will encourage the state to fund a portion of the capital costs, giving the project a higher priority than it now has.

We were surprised that the proposed bridge width has been reduced from 15 feet to 12 feet. Given the impending opening of the casino, the bridge will see a great deal of use by cyclists and walkers who need to share the limited space. Nearly all other pedestrian bridges recently built or under construction by MassDOT exceed this reduced width, adopting a standard that is 14′ or wider. We urge you to adopt the more generous standard that reflects the design standards for 21st century bike and pedestrian bridges. When it is constructed, the bridge will be the only safe, off-road non-vehicular connection between North Shore communities and Boston.

Sincerely,

Stacey Beuttell
Deputy Executive Director