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