June 9, 2020

Kathleen A. Theoharides, Secretary of Environmental Affairs
100 Cambridge Street, Suite 900
Boston, MA 02114
Attn:  Alex Strysky, MEPA Unit

Chris Osgood, Chief of Streets
Public Works Department
Boston City Hall
Boston, MA 02201
Attn: Para Jayasinghe, City Engineer

Re:       MEPA Project 16194 – Northern Avenue Bridge Replacement Project

Dear Secretary Theoharides and Chief Osgood:

We are writing to provide comments on the ENF for the Northern Avenue Bridge (NAB) Replacement Project. This is a project with a 30-year history which has included many internal City deliberations as well as many public processes, both within and outside those managed by the City. While we are pleased that the City is now seeking to bring the project planning to closure, we strongly disagree with the City’s choice of a bridge design that includes regular vehicle use that impinges on the use and safety of the bridge by people walking and biking, and does not provide the traffic benefit that the City says is the reason for including buses on the bridge.

While the design includes substantial space for use by pedestrians, much of that space would not be built until the unfunded and unscheduled Phases 2 and 3 of the project are built. Bicycles are relegated to shared lanes with buses. The lack of clarity about how pedestrians, bikes and buses will circulate raise many safety and operational concerns.

The scale and cost of the bridge has grown enormously simply to accommodate 110 shuttle buses/day. In addition to the lack of transportation efficacy and the design problems discussed below, we believe that the project is simply too big and too expensive. A smaller bridge that serves people walking and biking, and provides access for emergency vehicles, could provide the benefits and urban enhancements that both the public and the City desire.

While the loss of the Old Northern Avenue Bridge and the design of a new Northern Avenue Bridge raise many historic and contextual design issues, we are confident that the comments of our fellow advocates with specific historical and urban design expertise will speak to those issues, and we leave that task to those able commenters.

Our comments are organized as follows:

1. Decision regarding the modes to be served by the bridge
2. Funding and budget for the project
3. Walking and biking designs as described in the ENF
4. Public process

Decision regarding the modes to be served by the bridge

The City has determined that the bridge will carry pedestrians, bicycles, emergency vehicles and “transit”, which has never been clearly defined by the city, but thus far seems to include private buses and shuttles utilized by businesses located in the Seaport District. . We believe that the decision to serve these private vehicles  is the wrong choice, and that this wrong choice has in turn led to a wide variety of problems with the selected alternative.

• Will the inclusion of a bus lane on the bridge provide transportation benefits to the public?

There has been widespread and consistent public support for pedestrian, bicycle and emergency vehicle access. It is worth noting that of the online public comments regarding the project, 68% of the respondents preferred a bike/ped/emergency bridge option and only 1 person called for allowing general traffic on the bridge. The remaining 31% of comments didn’t reference a mobility preference.

• Will the inclusion of a bus lane reduce congestion?

As the City has stated in the ENF (page 6) ”… the intent of the project is (to) re-open the bridge for public enjoyment, provide additional means of pedestrian access across Fort Point Channel, provide a dedicated bus lane to reduce traffic congestion in Downtown Boston, and provide an alternate route for emergency vehicles if the need arises.”  This statement of purpose seems to be the City’s justification for selecting a large and very expensive bridge rather than a smaller and less expensive alternative, that serves only  pedestrians, bicycles and emergency vehicles. However, the transportation analysis provided by the City’s consultants – AECOM Memo: Northern Avenue Bridge Reconstruction – Mobility Analysis (November 13, 2018) makes the following conclusion: (P 16)   “The overall level of service for all study area intersections remains consistent between the No Build and all concepts analyzed in 2035 PM peak hour as previously shown on Table 5. The intersections of Seaport Boulevard and Atlantic Avenue and Seaport Boulevard and Purchase Street continue to operate at LOS “F”, and would remain congested under all concepts analyzed.”

Thus, the City’s own transportation analysis concluded that putting buses on the bridge does not reduce congestion. 

Having been closed to vehicular traffic since 1997, the downtown Boston side of the NAB ends at a one-way roadway lacking direct access to the entrance of I-93, completed as part of the central artery in Big Dig which opened up many years later. Thus, the utility for vehicular traffic traveling from the Seaport into downtown will be extremely limited and cause further disruption in travel demand due to congestion and redundancy (forced increase in VMT from driving around the block to get to the entrance). Therefore, having motorized vehicle traffic travel from and utilize the NAB will not fit into the existing fabric of the street network.

When asked about this mismatch between the stated purpose for the project and the lack of efficacy shown by the data during the MEPA “Site Visit” call, City Engineer Para Jaysinghe suggested that the City was planning for “unknown volumes” for the next 75 years. The standard practice for transportation studies is to use the time frames actually evaluated (2035).

• Is the inclusion of a bus lane on the bridge a reasonable financial decision?

The ENF states that the bridge would carry 110 buses/day (at a generous occupancy factor of 25 people/bus this equals 2,750 people/day). The very wide bridge now proposed at a cost of $100 million (for Phase 1, Phases 2 and 3 have not yet been costed out) is at least twice as costly as a bridge that could very comfortably accommodate walkers, cyclists and emergency vehicles. As stated in City presentation from the Mobility and Traffic Evaluation Workshop: “Most people on NAB will be walking; 70 to 90% of trips are by foot across all concepts.”

• Will any public transit make use of the bus lane?

There has been no indication that any MBTA public buses will use the bridge, and the MBTA’s study of improvements to its bus networks and routes does not include any use of a Northern Avenue bus lane. Thus, as we understand it today, a bus lane on the NAB would only serve private shuttle buses serving employees in the Seaport District. Over the years many advocates for better bus service have urged the MBTA and the City to look at the feasibility of an exclusive Congress Street bus lane from South Boston to North Station – a route that could provide significantly more direct and efficient service for both MBTA and private shuttles. We do not believe that this bridge should be built to accommodate buses unless the MBTA and the City can demonstrate that there is a clear benefit to public transit, and the MBTA identifies which specific routes will run over the bridge when it has been completed.

We urge the City to select a design to accommodate walking, biking and emergency vehicles and to delete accommodation of other vehicles.

Funding and budget for the project

• How much will the bridge cost?

The cost information provided at the June 3, 2019 community meeting showed a range in cost from a “basic” 12-foot wide bridge for $40 million to a “contextual” 56-foot wide bridge for $110 million. The contextual bridge now being proposed is more than 100-feet wide (at the center of the span) and thus could be guesstimated to cost well in excess of $150 million for Phase 1. The public needs to be informed about the actual estimated cost of Phases 1, 2 and 3 of the entire bridge.

• How will the bridge be funded?

Appendix C of the Massachusetts Historical Commission PNF (included as Attachment 5 to the ENF) provides a funding summary that shows $46m in City funding; $10m in Federal funding; and $2m in private funding – for a total of $58m in allocated funding. This would seem to indicate a gap in sufficient funding for the bridge in the range of 50-$100m for Phase 1 of the project. The City needs to disclose its funding plan for all phases of the project to prove the feasibility of the design that has been shared with the public.

• Is this the moment in time to spend a lot of money on this project?

The combined Federal and private funds for the bridge comprise less than 10% of the overall cost of the bridge as it is currently designed. This means that the City will need to contribute significant funds to complete even the first phase of the bridge at a point of great economic uncertainty locally and globally. There is significant risk that the City will be unable to finance the completion of the bridge through Phase 3. Additionally, the City already has enough dedicated funds, $46m, to build a basic 12 ft bridge as described at the June 2019 NAB Task Force meeting (see above).

Walking and biking designs as described in the ENF

As laid out above, we strongly disagree with the City’s choice of a design alternative that includes vehicle use (other than emergency vehicles) on the bridge. However, we feel compelled to also comment on the specific design of the bridge as shown in the ENF because it has so many problematic design features for people walking and biking. While we understand that the designs are not expected to be complete at this point in the project, the lack of attention to simple operational and safety questions raises doubts about the project design. If the City continues to pursue this preferred alternative we request that each of the design issues raised below be answered in the response to comments on this ENF. In addition, we recommend designing any bikeway and pedestrian facility using the NACTO, Boston Complete Streets, MassDOT, and FHWA design standards to have a low level of traffic stress (LTS by Furth) and high level of local access (by MAPC) rating.

1. The pedestrian//bike/bus interaction at the Seaport side of the bridge seems to show the bus lane taking up the entire entrance area onto the bridge with a pedestrian ramp entering directly into the bus lane. All of the pedestrian access onto and off the bridge is in the area shown as a bus lane. How will this area be designed to ensure the safety of people walking and biking? The plan shows shuttle buses directly adjacent to people walking/biking; paint is not an appropriate or safe separation or protection for pedestrians and cyclists on a new bridge.
2. On the downtown side of the bridge the buses would cross the heavily traveled Atlantic Avenue sidewalk into the congested Atlantic Avenue vehicular traffic without a traffic signal to provide them with a break in traffic. How will bus movement be managed to ensure that the buses do not inch up to the travel lane and block the sidewalk while waiting to turn right onto Atlantic Avenue?
3. How will pedestrian connections between the new bridge and the Harborwalk be designed on both sides of the Channel and how will the connection on the Seaport side of the bridge impact the operations and attractiveness of the Barking Crab restaurant and the Envoy Hotel? The new bridge is itself planned to be a new part of the Harborwalk, but these connections which have complicated vertical and alignment design challenges have not been described in the ENF. Specifically, how does the bridge gain enough height to pass over the water 8′ higher than it is now? Is there a long ramp from Northern Avenue near the courthouse? Is that ramp steep enough to affect walkers trying to use it?  Does the existing Harborwalk at the Courthouse connect under the new bridge to the part of the Harborwalk that parallels the Fort Point Channel? Will the new bridge allow this connection?
4. On the downtown side of the bridge, it appears that service access to the Coast Guard Building and the Hook Lobster site are to be provided through the pedestrian, bike and bus zones of the bridge. How would this work? Would service vehicles (or any other vehicles) be allowed to turn right from Atlantic Ave into the bus lane and pedestrian zone?
5. Bus/Bike Lane – The functionality of bus/bike lanes prioritizes bus travel, but do provide some safety benefits for bikes in places where buses were already operating in the roadway space and the only other option bikes have is to ride in dangerous, high speed vehicular traffic. For example, after the bus/bike project was implemented on Washington St, bikes now have the option of riding in a less congested space, which they share with buses, hence reducing the potential for conflicts and ultimately crashes. While the bus/bike lane provides some protection, we feel that it is not enough for the following reasons: 

   – Since the Northern Ave Bridge has not allowed vehicles for many years and it is being designed from scratch, adding an additional layer of bus traffic (transit) without proper space for segregation for bikes and pedestrians only increases the exposure to conflict and risk.

   – In a 12’ bus/bike lane, buses will travel at a much greater speed than cyclists and will want to overtake cyclists, which becomes stressful and can cause potential conflicts. The cyclist is forced to rely on the decision-making of bus drivers behind them. The cyclist is also usually traveling slower, causing the bus driver to reduce their speed and accept the delay from being “stuck” behind the cyclist. This conflict may cause aggressive behavior, which can promote overtaking movements due to impatience from the delay.

   – The ENF states there the number of vehicle trips per day will be 110 bus trips (potential for occasional emergency vehicles). Within a 12-hour period, for example from 8 AM – 8 PM, frequency will be approximately 10 buses per hour, or 1 bus every 6 minutes. This pushes the limit of the NACTO recommendations for a safe shared bus/bike facility. If there is more frequent vehicle transportation in the future, the bus lane should definitely not be designed to be shared with cyclists. Overtaking a cyclist leaves too much room for human error, especially in the confined space of 12’ wide lane.

   – Finally, other bus/bike lanes in Boston are shared with MBTA buses whose drivers get specific and detailed training on sharing a lane with bikes. We understand that the Northern Avenue bridge bus lane would be for private shuttles and have no reason to believe that these drivers know how to safely share and pass cyclists.

6. Air quality – As we now understand in a more visceral way than before COVID19, air quality matters to health. We share concerns that were expressed at the last public meeting about air pollution from diesel fumes, given the proximity of pedestrians and cyclists to the bus travel lane.Future Design Considerations – In the current 25% design, there are two spans (ribbons) each 24’ wide. One side is a pedestrian only zone and the other includes a bus/bike lane (12’), an unprotected bike lane (6’), and a pedestrian walkway (6’). The plan is designed to keep bikes separate from the pedestrian side, by signing that they ride in or adjacent to bus/shuttle traffic. However, we do not believe this design is realistic given that we can expect tourists and people who are new to the bridge to ride in whatever space is furthest from vehicles, and who also will want to visit the ocean side of the bridge. We suggest separating all bike facilities completely from vehicular facilities, and providing a bike lane with clear ocean views. If the purpose of this bike lane is to be a recreational bike path, which we support, then we suggest designing bike lanes for people to ride 2 abreast which demands that the lanes be 7.5-8 feet wide.
7. Future Design Considerations – In the current 25% design, there are two spans (ribbons) each 24’ wide. One side is a pedestrian only zone and the other includes a bus/bike lane (12’), an unprotected bike lane (6’), and a pedestrian walkway (6’). The plan is designed to keep bikes separate from the pedestrian side, by signing that they ride in or adjacent to bus/shuttle traffic. However, we do not believe this design is realistic given that we can expect tourists and people who are new to the bridge to ride in whatever space is furthest from vehicles, and who also will want to visit the ocean side of the bridge. We suggest separating all bike facilities completely from vehicular facilities, and providing a bike lane with clear ocean views. If the purpose of this bike lane is to be a recreational bike path, which we support, then we suggest designing bike lanes for people to ride 2 abreast which demands that the lanes be 7.5-8 feet wide.

Public process

Over the past two years, we have raised concerns about the public process on numerous occasions — and LivableStreets raised these issues formally and repeatedly as an official NAB task force member.

The City of Boston established a NAB task force as a means of utilizing the abundant knowledge the City of Boston has to offer, to direct the process for turning the Northern Avenue Bridge into an iconic destination that improves mobility, strengthens resiliency, and honors history. Unfortunately, this process was mismanaged and flawed from the onset.

Though the Task Force process had been framed as transparent and open to the public, there was limited discussion of public comment and often blatant disregard for public consensus.  At each task force meeting, while there was a short amount of time allotted to public comment, there appeared to be no method for incorporating those comments into the process for decision making. Additionally, while there was a tool for providing online comment, there was no discussion about how to incorporate those comments into the process.

Similarly, public meetings for the project were problematic. Ahead of the June 2019 public meeting, Stacy Thompson of LivableStreets, along with several other task force members expressed strong concerns and reservations about the approach the City was taking, which appeared to be purposefully obstructive of public feedback. Stacy also followed up with Chief Osgood, the consulting team and the chairs of the committee outlining her direct concerns in writing. None of the feedback was acknowledged or incorporated into the meeting.

In advance of the May 6, 2020 meeting for this project, we again directly expressed our concerns to the project team and Chief Osgood, that it was inappropriate to even hold public meetings of this nature while the State’s stay-at-home advisory related to COVID 19 was in place. BTD’s decision to hold the meeting was in direct contradiction to the policies of other city of Boston departments such as the BPDA which  stated that, “to ensure that the public process is equitable to all”, it would not be holding virtual public meetings for Article 80 projects or planning studies at this time. This inconsistency between agencies is concerning and needs to be addressed.

We would be pleased to speak with the MEPA Office or the City of Boston about our comments.

Best regards,

Stacey Beuttell, WalkBoston

Stacy Thompson, LivableStreets Alliance

Becca Wolfson, Boston Cyclists Union

Cc:        Mayor Marty Walsh
Congressman Stephen Lynch
State Senator Nick Collins
State Representative David Biele
City Councilors – Kim Janey, Annissa Essaibi-George, Michael Flaherty, Julia Mejia, Michelle Wu, Lydia Edwards,
Ed Flynn, Frank Baker, Andrea Campbell, Ricardo Arroyo, Matt O’Malley, Kenzie Bok, Liz Breadon
Tammy Turley, Chief Regulatory Division, U.S. Army Corps of Engineers
Harborfront Neighborhood Alliance
Northern Avenue Bridge Task Force members – Rick Dimino, Sara McCammond, Kathy Abbott,
Dennis Callahan, Carol Chirico, Senator Nick Collins, Handy Dorceus,
Councilor Michael Flaherty, Councilor Ed Flynn, Gregory Galer, Susan Goldberg, Susanne Lavoie, Representative Stephen Lynch, Richard Martini, Bud Ris, Patrick Sullivan,
Stacy Thompson