April 10, 2009

Secretary Ian Bowles Executive Office of Energy and Environmental Affairs
100 Cambridge Street, Suite 900
Boston, MA 02114

RE: Final Environmental Impact Report (FEIR)
The Commons at Prospect Hill
MEPA # 13952

Dear Secretary Bowles:

Thank you for the opportunity to comment on the FEIR for The Commons at Prospect Hill in Waltham.

This plan is a roll-over from the SDEIR on which we commented in February, 2009. We note, since this is simply the roll-over of that document, changes have not been incorporated in the plan since that time. Thus, our comments on the SDEIR remain the same as when they were written.

We hope that the final design of the project will incorporate a greater measure of concern about the facilities that pedestrians need throughout the project, and that sufficient safety measures will be put into place to assure that pedestrians crossing streets or parking lots will be protected from the flood of autos that will be attracted by the project.

As you may know, we met with the proponent and had the opportunity of presenting our comments directly to the designers. It is entirely possible that we did not present our case understandably or make our suggestion sufficiently attractive to persuade the development team to place a greater emphasis on pedestrian activities throughout the site. However, we would also point out that 21st century standards of development are rapidly evolving toward greater emphasis on pedestrian-friendly and transit-accessible designs in all parts of the country. We find it disappointing that that is not the case with this project.

Thank you for the opportunity to comment on this document. Please let us know if you would like further clarification of our comments.

Sincerely,
Wendy Landman                                   Robert Sloane
Executive Director                                 Senior Planner

February 18, 2009

Secretary Ian Bowles
Executive Office of Energy and Environmental Affairs
100 Cambridge Street, Suite 900
Boston, MA 02114

RE: Supplemental Draft Environmental Impact Report (SDEIR)
The Commons at Prospect Hill
MEPA # 13952

Dear Secretary Bowles:

Thank you much for the opportunity to comment on the evolving plan represented in the SDEIR for The Commons at Prospect Hill in Waltham.

We are commenting this time to underscore our feeling that opportunities are being lost to create a development that could be a model for the 21st c. We are certain that proponents for The Commons at Prospect Hill could go further toward ensuring that walking (and bicycling and transit use) can be supported by the new development.

Summary of Comments
We note that the SDEIR has incorporated few, if any, adjustments to the proponent’s DEIR plan that reflect the comments raised by WalkBoston about that plan’s pedestrian circulation and safety needs and possible modifications to the physical layout of the project to encourage walking.

The following comments relate to pedestrian safety and circulation throughout the site. We have added suggestions that we think should be considered to make the development more attractive to pedestrians.

1. Pedestrian safety along the rail trail

•  Access to adjacent buildings. We continue to be concerned that there do not seem to be any places where pedestrians can access new buildings from the trail without crossing driveways or parking lots. A more extensive effort should provide routes that are safe for pedestrians moving within parts of the project. For example, access to Buildings 10 and 11, immediately adjacent to the rail trail, could be included and made attractive.
• Trail/site driveway crossings. Unprotected pedestrian crossings along the rail trail are not safe for walkers. The crossing of the rail trail at the East Driveway has the potential for being difficult to use and unsafe for each crossing. It seems insufficient to state that safety issues related to crossings will be dealt with at a later date. At the Central Driveway and at the Primary Driveway, crossings will be signalized, but extremely heavy site traffic is anticipated, and pedestrian phases must be built into the signalization of both intersections.

2. Pedestrians in the Main Street corridor

• The relatively high density of development proposed for the entrance areas near Main Street would suggest that a pedestrian-friendly precinct is especially important in this part of the site. However, the sidewalk along Main Street remains cramped and narrow, with insufficient space to accommodate both walking and bicycling.
• Snow storage in winter will further complicate pedestrian movement along this frontage. No provision is evident for snow storage along this perimeter.
• Extending the sidewalk partially u n der Building No. 9 would make it more useful as the major entry to the site that also must accommodate MBTA transit access and the rail-trail as it crosses the site. As the front door of the site, it should be extremely welcoming to all who arrive on foot, by transit and bike.

3. Pedestrians in the Lifestyle Center
The layout of the Lifestyle Center, comprised of Buildings 5,6,7,8 and 9, is unchanged from the DEIR. It remains a problem area that is largely unsupportive of safe and attractive pedestrian activity. About 180 parking spaces are planned to be the focus of the pedestrian-oriented Lifestyle Center area, and they separate all the buildings with double rows of parking and a traffic circle. These concessions to cars are made despite the existence of a very large parking garage, which will abut the parking lots at the heart of the Lifestyle Center – the traffic circle – adjacent to Building 6. To cope with these liabilities, we suggest:

•  Limiting parking on both sides of Lifestyle Center streets to parallel curb parking rather than diagonal parking, and narrowing the street in the regained space.
• Reserving a portion of the wide sidewalks on the Lifestyle Center streets solely for pedestrians, with outdoor cafes and other attractions to make it lively.
• Adding retail spaces on the ground level of the garage to enlarge the variety of business options in the Lifestyle Center and attract more pedestrian/customers.
• Connecting Building 9 more directly with the Lifestyle Center by providing sidewalks on both sides of the building all the way to Main Street, and by including retail facilities on the ground floor to attract more pedestrians and to make the walk more interesting.
• Connecting Building 3 more directly to the Lifestyle Center. Presently located immediately behind the parking garage, Building 3 is indirectly connected to the pedestrian network via walkways that wind between Building 6 and the parking garage. Whether Building 3 has retail, office or other occupants, it can be directly connected to the Lifestyle Center.
• Connecting Building 4 more directly to the Lifestyle Center. It is not far from Building 6 in the present plan, but inexplicably unconnected to the Lifestyle Center.

4. Pedestrians in the big box areas
The scale of the remaining development remains sprawling, with large 1-2 story retail structures surrounded by parking. This layout is not conducive to encouraging pedestrian trips. If buildings are to be so widely separated by parking lots, the proponent should make additional efforts to assure that these very lengthy walkways are pedestrian-friendly. Buildings 1, 2 and 11 are so large and so distant from the Lifestyle Center pedestrian ways that they may never become pedestrian destinations.

• Redesign sidewalks in the outlying areas to make them more direct. Navigating the sidewalks from the Lifestyle Center to Building 11, for example, requires following a formidable, very indirect route that few will follow.
• Redesign sidewalks leading to outlying large retail buildings to make them landscaped, green corridors with shelters, lights and wayfinding signs added. • Incorporate green walking corridors alongside partially open, functional drainageways inside the parking lots (also useable for snow storage).

5. Walkways in and connecting to the adjacent parks
The abutting Prospect Hill Park and the 20-acre Berry Farm parcel offer opportunities for recreational walkways linked to the development on this site.

• Connections between Prospect Hill Park, the Berry Farm and the Wayside Rail Trail should be added, perhaps at the east boundary of this site, where parking lots could be skirted.
• Hillside Road, an existing roadway through land owned by the city in Prospect Hill Park, will be abandoned and truncated as a result of this project. Hillside Road might become the corridor for a walkway within the park along the east side of the site – readily useable by all site occupants. An extension of Hillside Road further north on the site could be located within the buried power line corridor and could eventually extend to Third Street north of the site.
• Connecting a Hillside Road walkway with the rail trail would apparently involve using the sidewalk along the East Driveway. As an alternative, the City of Waltham might be interested in a Prospect Park corridor between Hillside Road and a yet-to-be planned trail system within the Berry Farm – ultimately connecting with the rail trail.

6. Intersections and the rail trail
The statewide rail trail through the site involves passage through very high density land uses and traffic. Because of this, considerable effort must be made to assure that children and others walking or riding along the rail trail are safe. Three difficult intersections on the site will be crossed by the trail at Primary Driveway, Central Driveway and East Driveway. Additional intersection crossings will be required within the new interchange to be constructed above Route 95/128. All intersections will be very heavily traveled. An extraordinary amount of effort will be required to assure that pedestrian safety at all of these intersections is made secure and convenient.

Thank you for the opportunity to comment on this document. Please feel free to contact us for clarification or additional comments.

Sincerely,
Wendy Landman                                 Robert Sloane
Executive Director                               Senior Planner