June 17, 2016

Matthew Beaton, Secretary
Executive Office of Energy and Environmental Affairs (EEA)
ATTN: MEPA Office
100 Cambridge Street, Suite 900
Boston MA 02114

Brian Golden, Director
Boston Redevelopment Authority
One City Hall Square
Boston, MA 02201-1007

RE:  Comments on the ENF and the PNF for the Back Bay/South End Gateway Project MEPA: #15502

Dear Sirs:

WalkBoston reviewed the ENF and PNF for Back Bay/South End Gateway Project.

We are very interested in this project, which is superbly located to be served by public transportation, walking and biking. However, we have concerns about pedestrian access into, through and around the site which we would like to see addressed in the next project submissions. These are:

1. Relocation of the layover site for the Route 39 bus
The proposal states that the layover site for the Route 39 bus will be located “off-site.” Back Bay Station is one end of this bus route, which is one of the busiest in the MBTA system, serving Back Bay, the Fenway and Jamaica Plain. Buses congregate here and wait until schedules require them to return to the main route.This bus route is too important to the MBTA system and its many riders to shift the layover site to another location which could lead to a major change in the frequency of bus service. A layover location must be found nearby.

2. Sidewalks that surround the site
Sidewalks along Stuart and Clarendon Streets have been designed at minimum widths for their functions. The MassDOT Design Guide calls for sidewalks in busy downtown areas of cities to be between 12 and 20 feet in width. These guidelines should be generously incorporated into the planning for this project.  The City’s Complete Streets Guideline Manual suggests that 8 feet is a minimum but prefers a width of ten feet.

This is particularly important for the Dartmouth Street side of the project. Foot traffic on Dartmouth Street is already heavy and likely to increase, due to the new development and to moving the principal entrance to the station to the center of this frontage. The plan calls for a portion of the Dartmouth Street frontage to be as narrow as 8 feet at one point, and 13 feet otherwise. The 8’ foot width, which appears along a planned ADA ramp into the first-floor retail area, is not adequate for this location. Perhaps this width could be expanded by moving the ADA ramp into the retail area of the building or by selectively eliminating portions of the drop-off/taxi lane which extends from the station entrance to Stuart Street. Alternatively, perhaps a thoughtful reduction of the number of trees and their placement might be appropriate to widen the clear width of the walkway.

3. Garage exit on Dartmouth Street
One of the unfortunate consequences of the design for re-use of the Garage East and West portions of this project is the potential use of Dartmouth Street as one of the exits from the on-site garage. This appears to result from redesign of the existing garage which currently has two entrance and exit ramps.

The proposed new parking facility removes two the existing garage access ways – those leading in and out of the garage in drums connecting with Trinity Place. It retains the existing entrance and exit ramps on Clarendon Street. The design calls for no new entrance ramps. However, it calls for a new exit ramp that requires removal of the Turnpike on-ramp. If the Turnpike ramp is retained, the proponent maintains that there is a need for a replacement exit onto Dartmouth Street.

The proposed exit ramp onto Dartmouth Street is deeply consequential for pedestrian traffic. It is difficult to imagine a more inappropriate design than the insertion of a major vehicular exit from the garage onto the Dartmouth Street sidewalk, the primary pedestrian access route to and from Back Bay Station. Certainly there must be a better place to provide a garage exit than this, possibly by retaining one of the drums could be retained for exiting traffic directly onto Trinity Place.

4. The station area concourse
Back Bay Station was designed as a large arched hall, flanked on both sides by hallways leading to ticket and waiting areas. Each platform has its own stairways, escalators and /or elevators connecting the platform to the station concourse. Train platforms are split, with the Worcester/Amtrak Chicago line platforms near the north edge of the station concourse, and the New York/Amtrak Washington platforms near the south edge. Access to the Orange Line platform is directly in the center of the station, under the arched portion of the station structure. On either side, outside the arched hall, two wide concourses connect through the block between Dartmouth and Clarendon Streets.

Within the large arched hall, pedestrian movement is presently blocked for concourse movement by a fence that surrounds the major access stairways and escalators to and from the Orange Line. The proposal calls for a removal of some of this blockage and relocation of the two principal concourse pathways between Dartmouth and Clarendon Streets into the arched hall. The present concourses, outside the arched hall, are then repurposed for retail and other facilities.

The relocation or shrinking of the passenger concourses and repurposing the space occupied by the old ones raises a concern as to whether the new routes are sufficiently wide to handle projected growth in passenger volumes. Although it is uncertain what projections of passenger volumes might show, according to the project proponent, the station already handles 30,000 passengers per day. The MBTA currently maintains there are 36,000 Orange Line passengers here, plus 17,000 commuter rail passengers. Amtrak may constitute an additional 2000 passengers. New projections of traffic should be undertaken to determine likely future volumes of people using the station.

With the knowledge of the likely future traffic of patrons of the Orange Line, the commuter rail lines and Amtrak, the plan must provide good access to and egress from the following locations:

– The Dartmouth Street entrance
– The Orange Line station (two stairways, escalators, one elevator)
– The underpass beneath Dartmouth Street to the Copley Place mall (one stairway)
– The commuter and Amtrak rail lines west toward Worcester and ultimately Chicago (two stairways, one elevator) serving 15 stations and communities
– The commuter and Amtrak rail lines that generally go south and follow the east coast to Providence, New York and Washington D.C. (two stairways, two escalators, one elevator) serving 47 stations and communities
– The proposed new passageway to Stuart Street and into the Garage West office structure
– Ticket machines for passes and Charlie cards for the subway lines.
– Amtrak ticket offices
– Commuter rail ticket offices
– Restrooms for the entire station concourse area
– Food and retail outlets proposed for the concourse level
– Food and retail proposed for the second level
– Food and retail outlets proposed for the third level
– Waiting areas including seating for passengers traveling by rail
– The existing and new parking garages in the Garage West/East areas
– The new residential building in the Station East area at the Clarendon Street end of the project

All but the last two of these movements take place primarily in a compressed space that extends about 100’ from the main entrance on Dartmouth Street into the station. The proposal significantly diminishes this portion of the existing concourse, serving the movements listed above and lowering the space of the waiting area from 9,225 square feet (41 bays each roughly 15 feet square) to 6,075 square feet (27 bays, each roughly 15 feet square. It calls for eliminating the principal existing waiting area and replacing it with a large food service facility. All waiting passengers will be moved to backless benches located in busy pedestrian passageways, including the major entrance to the building. The proposal also calls for diminishing the size of the concourse by narrowing the existing passageways between Dartmouth and Clarendon Street and replacing them with retail space. It calls for new entrances to the proposed second and third levels in the midst of the existing waiting area. The proposal moves the ticketing area away from the waiting area and into new space along the proposed new passageway, where queuing to purchase tickets (now possible in the waiting area) will compete with pedestrian movement. It is hard to imagine that all these activities can be accommodated in the space planned.

A new design should be undertaken to accommodate the growing number of pedestrians and waiting passengers as well as patrons of food and retail outlets who may choose to sit in this busy space. The existing waiting area should not be removed but instead enlarged to accommodate anticipated future use. Ticketing space should be provided close to passenger access areas. Access to and from the second and third levels should be moved away from the waiting area and into the space that is gained by closing the existing concourse passageways. Retail areas adjacent to the passenger waiting area should be scaled back to remove potential blockage of clear and very visible access to and from the stairways leading to transportation facilities below the concourse. Benches for rail passengers should not be relegated to busy portions of the concourse, especially where they might interfere with pedestrian traffic through the concourse.

5. Construction on the rail station platforms
The proposal calls for use of the station platforms for supports for the new high-rise building being built in the Station East portion of the project. These new obstructions narrow the platforms for waiting or alighting passengers and add complexity in an environment where moving to or from access points is already complicated. This true of both the Orange line platform, serving both directions for subway passengers and the southernmost railway platform serving commuter rail passengers to and from the south and southwest, including Providence, New York, Washington and the entire eastern seaboard.

Using the existing rail platforms for construction of these supports will obstruct passenger traffic during construction as well as after completion. Designs should be carefully integrated with existing obstructions such as columns to minimize interference with passenger traffic flow.

We are very concerned about the changes proposed for the station, the bus layover and the sidewalks and interior passageways. We would 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
Executive Director