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Renaissance Village Comment Letter

By WalkMassachusetts | July 10, 2009

WalkBoston appreciates the opportunity to provide comments on the Environmental Notification Form (ENF) for the Renaissance Village project in Brockton. The project is a 40-R mixed use project of 6 stories, including 308 residential units, commercial and retail space, and a 460-space parking garage.

The project is located in an urban setting that occupies one full city block of downtown Brockton. It is readily accessible on foot to the Brockton commuter rail station, one of three serving the city. It will be a good addition to the city by helping to establish downtown as a place to live as well as work or shop.

Read the full letter here:
WalkBoston-CommentENF-RenaissanceVillage-Brockton

Hamilton Canal District Comment Letter

By WalkMassachusetts | June 6, 2008

June 6, 2008

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

RE: Environmental Notification Form (ENF)
Hamilton Canal District, Lowell
MEPA # 14241

Dear Mr. Bowles:

We have reviewed the ENF for the Hamilton Canal District in Lowell, a proposed mixed-use retail, office and residential redevelopment in the historic canal district near downtown. We are pleased that walking and pedestrian facilities are major organizing features of the development. We are commenting because details of this worthy project may need further analysis to serve the needs of pedestrians throughout the city.

WalkBoston is the Commonwealth’s leading advocate for pedestrians and safe walking. We work throughout the state encouraging walking, advocating for pedestrian improvements and working for design improvements. We have extensive experience helping residents and local government with pedestrian issues, safe routes to school, and safer street crossings.

Project description
The proposed Hamilton Canal District is located adjacent to downtown Lowell and is bounded on the south and west by Thorndike/Dutton Street, a major arterial into downtown Lowell with relatively heavy traffic. The north boundary of the site is immediately adjacent to the National Park Service Visitor Information Center on Market Street. The development is separated into three parts by the Middlesex, Pawtucket and Hamilton Canals which spread through the site. Considerable vacant land remains where factories were demolished. The few on-site historic buildings will be retained, rehabilitated or rebuilt as parts of larger structures.

The proposal comprises 11 new buildings on 13 acres with 50,000 SF of ground level retail space, 420,000 SF of office space, 600 new housing units and 1800 new parking spaces. Components are designed to blend with the historic city: frontage is lined with retail outlets and on-street parking and pedestrian amenities are key design elements. Building heights will range from 6 to 15 stories, with the tallest structures adjacent to the open space along the canals. A new trial court building is located south of Jackson Street.

A trolley line now arcs through the National Park sites along Dutton Street at the edge of the site. The trolley will be realigned to pass directly through the site over new bridges and right-ofway. The ultimate goal for the trolley is a further off-site extension to the Gallagher Transportation Center’s buses and commuter trains to Boston.

We believe that there are five issues that need more detailed exploration:
1. Sidewalk widths and surfaces
2. Canal crossings
3. Signage and wayfinding
4. Access to transit
5. Conflicts with vehicular traffic

Issue 1: Sidewalk widths and surfaces
A rule of thumb for a minimum clear sidewalk width is 5.’ A minimum of 8’ clear width is preferable in commercial areas. The proposed “Street Types,” as detailed by diagrams for this project do not always meet this standard.

Sidewalk widths of 7’ to 10’ should be adequate, but these widths are frequently diminished because of lights and signs located on the sidewalk.
On Street Types 1B, 1C, 2B, sidewalks are 6’ wide, but include space for light poles and other streetside elements. As these intrusions into the width of the sidewalk will be centered 20” from the curb line, the remaining clear width of the sidewalk will be 4’ – possibly a little less. This does not allow for wheel chairs or baby carriages to smoothly pass each another or other walkers or for people to walk comfortably side by side.
Street Type 3B permits only a 4’ wide sidewalk on one side. This width is not acceptable for foot traffic, as there are intrusions for railings.
Most of the canalside paths are the responsibility of the National Park Service. The NPS standards for sidewalk widths appear to be somewhat more generous than those designed by the developer and/or the City of Lowell. What happens when the two systems must be integrated, as, for example, where connections between canal paths require walkers to cross the bridges over the Pawtucket and Hamilton Canals?
How will bicycles be accommodated in the project area? It is not clear whether some of the paths are intended to be multi-purpose, and designed or signed for use by cyclists.
Walkway surfaces will be made of scored concrete with broom finish. Care should be taken that walkers are not forced to use cobble- or brick-paved surfaces along any part of their routes through the development. All “tree ways” abutting the sidewalks should be crossed by smooth sidewalks at intersections.

Issue 2: Canal crossings
Six bridges and one trestle over the canals will be rebuilt or rehabilitated; two bridges and the trestle are solely for pedestrian use, and the bridge at the Swamp Locks serves only pedestrians and the trolley. The trestle, with rail removed, will be rehabilitated as part of the canalside pedestrian path network and constructed separately from this project.

The two Hamilton Canal pedestrian bridges appear to connect through the Appleton Mills buildings. Are both bridges part of the pedestrian network? Will walkers have access into and through the buildings?
The reconstructed bridge at the Swamp Locks will offer a spectacular view of the locks and waterfall at the center of the site. Will the bridge (Street Type 1C) have a wide sidewalk where visitors may stand to view the locks and the waterfall? Will the bridge have extra width to accommodate the continuation of 10’ wide canalside paths?
Will the trolley bridge over the Merrimack Canal also be available for pedestrian crossings? If not, how will pedestrian access be controlled?

Issue 3: Signage and wayfinding
Central to the use of a new pedestrian network are wayfinding directions and signage for pedestrian pathways.

The central axis of the development will connect the NPS Visitor Center to the Swamp Locks, a highly desirable destination for visitors to the site. Will there be wayfinding signage or pavement markings along this route to help walkers get to the attraction?
Wayfinding is also essential for the large canalside pedestrian network envisioned for the site. Does the proposed plan include wayfinding on these pedestrian ways, especially in locations where continuation of the path involves turns to cross a bridge?

Issue 4: Access to Transit
We hope that transit will play an important role in connecting visitors and employees to this project and other parts of downtown. Shuttle bus services may be provided through or near the project. Ultimately the trolley will connect downtown Lowell to the Gallagher Transportation Center’s buses and trains.

Will trolley construction be phased into an early stage of development? Can shuttle services be routed through the project for service until the trolley is constructed?
Will pedestrians be able to reach the Gallagher Center on foot?

Issue 5: Conflicts with vehicular traffic
Through movements by vehicles are minimized by an indirect routing via a large “S” curve on a single street connecting Broadway and Revere Street. Several pedestrian issues remain:

Jackson Street at the south edge of the development site now serves the large Jackson- Appleton-Middlesex (JAM) parking garage and is being extended to Thorndike/Dutton Street. Where Jackson intersects Revere Street, monitoring will be necessary to determine if traffic and pedestrian signals are warranted.
The intersection of Jackson Street and Thorndike/Dutton Streets will need to be made safe with traffic signals and countdown pedestrian signals, as it is the replacement for a longplanned pedestrian overpass above Thorndike Street.
The intersection of Broadway and Thorndike/Dutton Streets will become a primary access point to this development, connecting to a new on-site parking garage and other new underground parking. The intersection may warrant countdown pedestrian signals.

Thank you for the opportunity to comment on this document, which offers great promise for pedestrians. Please feel free to contact us for clarification or additional comments.

Sincerely,

Wendy Landman Robert Sloane
Executive Director Senior Planner

Meadow Walk at Lynnfield EENF Comment Letter

By WalkMassachusetts | October 10, 2007

October 10, 2007

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

RE: Expanded Environmental Notification Form (EENF) Meadow Walk at Lynnfield
MEPA # 09800

Dear Mr. Bowles:

We have reviewed the EENF for Meadow Walk at Lynnfield, a proposed mixed-use retail, office and residential redevelopment of a portion of the Sheraton Colonial Golf course in Lynnfield and Wakefield. We are pleased that walking is being encouraged as a major organizing feature of the development – a worthy initiative. We are commenting because of the immense potential for incorporating extensive pedestrian access in mixed-use suburban development throughout Massachusetts.

WalkBoston is the Commonwealth’s leading advocate for pedestrians and safe walking. We work throughout the state – encouraging walking, advocating for pedestrian improvements and working for design improvements. We have extensive experience helping residents and local government with pedestrian issues, safe routes to school, and safer street crossings.

The proposed Meadow Walk at Lynnfield comprises 395,000 SF of retail space, 80,000 SF of office space and 200 housing units of which 40 are allocated to the Lynnfield Initiative for Elders (LIFE). It includes 3,438 parking spaces and will increase the number of vehicle trips generated by the site from 644 to 19,079 per day. The retail/office components of the development are designed to be a traditional Main Street where frontage is lined with retail outlets, and on-street parking and pedestrian amenities are key design elements.

The scale of the development is sprawling. Most of the buildings appear to be 1 story in the retail areas, with 2-story exceptions (shown in renderings of the central open space.) Buildings taller than 2 stories are included in the residential areas.

Summary of comments:

 The development appears to be primarily an outdoor mall, without roofed pedestrian walkways and with a street where an enclosed walkway inside a standard mall might ordinarily appear. Notwithstanding some token nods to pedestrians, the overall site is characterized by vast parking lots, relatively high-speed roadways around the lots, visibility from a major highway, and traffic that is dispersed around the site.
 Of the roughly 2 miles of roadway to be constructed, one half mile is truly pedestrian-friendly, while one mile serves solely vehicular traffic and another half mile serves the back side of the retail/office structures with little physical separation of pedestrian and vehicular movements.
 If pedestrian friendliness is to be a major selling point of the development, a great deal of adjustment should be made to the current design to incorporate elements more specifically encouraging to pedestrians.

Overall site plan

 A high density of uses in the center of the development, tapering toward the perimeter, does not appear as a guiding feature of the plan. High density encourages walkability.
 The proposed development rigorously separates land uses. The retail/office uses are separated from the residential uses and open spaces. Uses are not mixed within single structures (except perhaps for offices). Residences are not planned above stores or offices, though that would encourage walking.
 The street network could benefit from full integration of the interior Main Street with parking service streets and from street connections to the residential area.
 The existing Boston Sports Club building and Sheraton Hotel, which are to remain on the site, have not been integrated in any way with the proposed development. 
The comparably-scaled Mashpee Commons on Cape Cod offers a useful contrast in pedestrian friendliness. A similar development of 250,000 SF of retail space with 90 stores, Mashpee Commons has residential uses above many retail outlets, creating walkability as a major feature. Its circulation plan emphasizes the creation of traditional city blocks, multi-story structures that hold both retail and residential uses, 2 main streets with connections to minor streets that lead to all parking lots, some very smallscale stores, and mid-block meeting places and walkways. Westwood Station, being planned at Rte 128/I 95, has 1000 residential units above or adjacent to retail.

Relationship to Traditional Neighborhood Development Planning
The development adopts many of the current concepts about traditional neighborhood developments without full embrace of them. In particular, it has these distinctions:

 A roadway solely for vehicles extends around the perimeter of the site for approximately one mile, and the interior pedestrian-friendly street is roughly a half-mile in length. The interior street is paralleled by a street on the other side of the retail/office structures that is also about a half mile long but with few pedestrian friendly features.
 Transit service does not connect directly into the site and is not within walking distance.
 Proposed pedestrian access ways are tied to streets. All pedestrians must enter the site at locations where vehicles also enter. Pedestrian circulation is entirely along the sidewalks next to the streets. No off-street pedestrian walkways for circulation or for access to the site or nearby open space areas are provided.
 Additional pedestrian access to the site could be added on the Walnut Street frontage of the site owned by the project proponent. Without this access, pedestrians arriving via Walnut Street must enter near the Rte 128 ramps, a location with heavy traffic volumes.
 On-street parking is permitted only on the Main Street, (making the sidewalks safer with the protection of a row of cars separating pedestrians from the roadway) and not on either the perimeter street or access ways into parking lots.
 The location of the site next to a protected environmentally sensitive site suggests the possibility of pedestrian walkways or jogging paths for recreation at the site perimeter. These paths might link to the Sheraton Hotel via the bridge over the Saugus River.

The retail/office components

 The roadway network for the retail and office elements consists of a perimeter road, with access into parking lots from 14 separate intersections. Five short streets connect the parking lots and the Main Street.
 The project’s retail elements are organized around the spine of a traditional Main Street. The Main Street seems to serve a minimal circulation purpose, as it is a closed loop within the overall project, connected primarily at an entrance location to the Rte 128/I-95 access points for the project.
 The interior street is gently curved – a nice touch.
 The proportion of street frontage with active commercial uses that encourage walking may be limited because all of the stores will have entries facing both the street and the parking lots. Retail operations are unlikely to be able to support window displays or store-related activities on two street frontages of each site.
 All buildings appear to be designed for large-scale uses – perhaps big box stores that swallow up frontage unless broken up by smaller stores.
 Small structures do not appear to be included, but encouraging participation of small entrepreneurs can encourage outdoor browsing and pedestrian activity. 
Parking seems to be excessive. The 3,438 parking spaces for the development contrast with Mashpee Commons with less that half that number.
Open space in the retail/office area is limited to the small central square while open space outside the perimeter road is relatively lavish, because of abutting wetland. 
The interior shopping street should have a dense tree canopy to encourage walking.
Design standards for sidewalk and path construction were not provided. In some instances, greater widths will provide more public space and greater levels of activity.

The residential components
Residential units include luxury housing (160 units) and the LIFE component (40 units) wholly separated from retail/office uses by the perimeter street. This results in:

 The retail and office mall comes close to the residential units at the only part of the site without vast parking capacity on the mall side. Even here, pedestrians must cross the parking lots in front of the residential buildings before crossing the street into the mall.
 The residential access road (a part of the perimeter road around the site) is about 1500 ft long between parking access points and has only two access points into the residential parking lots. This layout suggests it may become a relatively high-speed roadway with hazards for walkers. Two pedestrian crosswalks are provided to cross this street at the luxury apartments. No crosswalks are indicated for the LIFE buildings.
Residential buildings could be grouped to reduce the impact on this environmentallysensitive location. Grouping would allow residential structures to be at a greater distance from the wetlands, while retaining the pleasant views.
There should be direct pedestrian access between the residential and retail/office uses. (Sidewalks are not always shown on the plans.) The possibility of a more direct connection might result in locating the residences inside the perimeter roadway where they can be more immediately adjacent to the retail/office uses.

Thank you for the opportunity to comment on this document, which offers great promise for improvements for pedestrians in a suburban setting. Please feel free to contact us for clarification or additional comments.

Sincerely,

Robert Sloane
Senior Planner

Target Distribution Center Westfield Comment Letter

By WalkMassachusetts | November 7, 2005

November 7, 2005

Secretary Steven Pritchard
Executive Office of Environmental Affairs
Attn: MEPA office
100 Cambridge Street, Suite 900
Boston, MA 02114

RE: Target Distribution Center Westfield, MA Final Environmental Impact Report EOEA No. 13361

Dear Secretary Pritchard:

WalkBoston advocates for pedestrian safety, improved facilities, and programs to encourage walking throughout Greater Boston, and takes an active role in promoting pedestrian interests statewide. We offer our comments on the proposed Target Distribution Center in Westfield, MA that is projected to have approximately 860 employees and to generate 6,460 vehicle trips/day. The project site is located on Route 202 and just off Routes 10/202 approximately 4 miles from the city’s center.

Providing access for all modes is now a requirement in state law for new and reconstructed state roads and is being fully incorporated in the new MassHighway Design Manual to be published in January 2006. Access by foot and by bicycle is fundamental to the state’s smart growth policies and programs. We are also concerned Westfield may not address the needs of pedestrians, even when these needs could logically be part of the transportation mitigation of local commercial development.

In examining this FEIR, WalkBoston finds that pedestrian access and its relationship to transit and transportation demand management is given little consideration by the proponent, despite MEPA’s clear guidelines in the February 14, 2005 Certificate on the proponent’s DEIR. The Certificate reads as follows:

Transit: The FEIR should update its inventory of public transit bus services in the project area. The proponent should work with local officials to identify bus connections and potential shuttle bus services from activity nodes and residential areas to the project site.

Pedestrian and Bicycle Facilities: The DEIR described where sidewalks currently exist in the area. The FEIR should identify the proposed pedestrian (sidewalk) and bicycle facility improvements included with this project. Unless the proponent can obtain a letter from the City of Westfield or MHD stating that a sidewalk is unnecessary, I recommend a sidewalk along the site frontage on North Road (Route 202) and Falcon Drive. 2

Transportation Demand Management (TDM) Strategies: The FEIR should examine the full range of potential TDM strategies.

Comments offered by the Executive Office of Transportation (EOT) and the Pioneer Valley Planning Commission (PVPC) also express the need to address bus service and pedestrian facilities:

EOT – The site design should include transit amenities including a bus turnout and bus shelters to further encourage transit usage. The site design should identify sidewalk and/or pedestrian access between the building and the PVTA drop-off area. Bicycle and pedestrian routes in the vicinity of the site should be identified as well. And bicycle lockers and shower facilities should be provided to encourage pedestrians and bicyclists.

PVPC – The DEIR acknowledges the potential for public transit service serving the proposed development using the Pioneer Valley Transit Authority (PVTA) Blue 23 bus route. While the proponent has committed to work with the PVTA to develop transit service for the site, no information was provided in the DEIR on how pedestrians would access the proposed new on site bus shelter. Consequently we’d urge that the FEIR provide additional information addressing the actual location of the proposed bus stop as well as depict and explain and show how pedestrian access will be provided from the Target development to this new bus stop.

The FEIR does not respond adequately to these requests. No details are provided on proposed pedestrian and bicycle facility improvements for the project, either in the plan or in the text. It says only: “The appropriate and safe pedestrian amenities on site, including necessary parking lot crosswalks, lighted pedestrian travel ways, and the like are being considered for the final design of the site.” (from Section 2.8.2, p. 2-48; repeated in Response EOT .08, Appendix B, p. 8-4 and Response PVPC.03, Appendix B, p. 8-9). This is not a sufficient commitment to pedestrian access.

WalkBoston believes that policy direction is needed to determine how pedestrian access should be addressed by this (and other) project(s). The absence of existing pedestrian facilities is not an indication that they are not needed. WalkBoston suggests clear and careful consideration to determine an appropriate approach. Among the possible choices are the following:

a. Over time, perhaps with state EOEA or MHD assistance, the city will provide sidewalks on at least one side of all major roads that provide access to employment.

b. Over time, working with local municipalities and EOEA, MHD will provide sidewalks on at least one side of major state highways near urban and suburban employers.

c. The city or MHD will request all major employers to construct sidewalks from their building’s employee entrances to the sidewalks that parallel major local roads or state highways. The city, MHD or the employer will then construct bus stops and sidewalks to connect to employer-constructed on-site sidewalks.

d. In the vicinity of new development, the city or MHD will require project proponents to construct sidewalks along roadways connecting to transit and schools.

e. The city or MHD will leave most, if not all, of the decisions regarding sidewalks along state highways or local roads near new development to project proponents.

WalkBoston believes that MHD and the City of Westfield should provide clear policy direction to the project proponent about their responsibilities for pedestrian access. At that point, a variety of options exist for pedestrian accommodation. EOEA, in its DEIR Certificate, has taken a position that sidewalks should be provided along North Road (Route 202) and Falcon Drive, unless the City or MHD waives the requirement. The certificate also calls for public transit bus services to the project site, and for the identification of nearby bus stop locations and their relationship to sidewalks providing access to the employee entrance to the site. Since many of the vehicular improvements to be provided as mitigation measures for the project are off-site, it is reasonable to also require off-site pedestrian mitigation measures. Among the options for pedestrian access are the following:

1. A sidewalk along North Road (Route 202) – From the FEIR, it appears that the proponent has designed an auto access road that parallels North Road (Route 202) through most of the site. A sidewalk could be constructed along this road. To avoid security problems, the sidewalk could be located outside the perimeter fencing and adjacent to North Road (Route 202). This sidewalk would provide the first step toward EOEA’s ultimate goal of providing a sidewalk along the full length of North Road (Route 202) in the city.

2. A sidewalk along Falcon Drive – From the FEIR, it appears that the proponent owns very little property along Falcon Drive. However, placing a sidewalk within its property could become part of EOEA’s long-range vision for sidewalks along the full length of Falcon Drive.

3. A sidewalk from the site to North Road (Route 202) – From the FEIR, a pedestrian sidewalk to North Road (Route 202) seems possible along the side of the building adjacent to employee parking, presumably connecting to the employee entrance to the distribution center building. Figure 1-3 FEIR Proposed Conditions Plan (p. 1-6) and Figure 1-5 FEIR Operations Plan (p. 1-10) show auto access directly from North Road (Route 202) This access gate is approximately 2000 feet from the intersection of North and Southampton Roads. It is labeled “emergency vehicle access and gate.” This access gate could also serve pedestrians.

4. A sidewalk from the site to a bus stop – Bus travel to the site should be encouraged through clear routes and signage and direct, well-marked paths for pedestrians between transit stops and the pedestrian entrance to the proponent’s building. The FEIR notes that the Pioneer Valley Transit Authority Blue 23 weekday and Saturday bus routes pass the site on North Road (Route 202) and also on Southampton Road (Routes 10 and 202). Yet the FEIR contains no indication that workers may arrive by transit or estimates of transit’s potential for serving employees coming to or leaving the site. Nor does the FEIR specify where transit stops and sidewalks might be best located to serve employees, or even from which direction or gate the riders would come.

The bus rider’s pedestrian access from Southampton Road is particularly daunting. If bus-riding employees must access the site from a bus stop on Southampton Road and walk via Southampton Road/Falcon Drive to the Target Warehouse employee entrance, they must walk over 4,000 feet. In addition, without sidewalks, walking along these routes is potentially dangerous. This would deter even the most dogged bus-rider/pedestrian.

By contrast, a bus stop near the North Road emergency access/gate that is connected via sidewalk to the employee entrance to the distribution center could be less than 400 away from the entrance. With this option, bus stops for riders coming from either direction could be established on the two sides of North Road, with a walkway from the bus stops through the North Road emergency vehicle access/gate and up to the employee entrance. For security purposes, access for people on foot through the North Road emergency vehicle access/gate could be provided by electronic gate control mechanisms. Analysis of this possibility has not been included in the FEIR and should be provided during the next steps of the environmental permitting process. In addition to a bus stop and appropriate sidewalks, a protected pedestrian crossing of North Road should be reviewed. Such review should include the examination of a pedestrian-activated signal.

5. Improvements along Southampton Road (Routes 10/202) – Local comments mentioned the need for sidewalks for school and day care students attending classes in three buildings located along Southampton Road. It seems appropriate to provide new sidewalks along those portions of Southampton Road that are to be improved as part of the project’s mitigation program.

In the long run, sidewalks will need to be constructed wherever there are students who could walk to their schools from homes or bus stops. Indeed, the state is now involved in an extensive Safe Routes to Schools program that will lead to a greater demand for new or improved pedestrian and bicycle facilities for children to use in going on foot or by bike to their school buildings. They should be included in this project.

Finally, WalkBoston suggests that draft commitments for the Section 61 findings (Section 7.0 of the FEIR) should contain pedestrian and bicycle facilities.

Thank you for the opportunity to comment on the FEIR for the Target Distribution Center in Westfield. We hope that our concerns about pedestrians can be addressed as you examine the proposal and as it moves toward implementation.

Sincerely,

Ann Hershfang Wendy Landman
Advocacy Committee Chair Executive Director

Cc Astrid Glynn, Office of Commonwealth Development Tom Cahir, Executive Office of Transportation Tim Brennan, Pioneer Valley Planning Commission

Lowe’s of Hadley Comment Letter

By WalkMassachusetts | June 7, 2005

The Lowe’s of Hadley project is a proposal to add a significant retail facility situated on Route 9 in a suburban setting that is typical of those found throughout the state. We have reviewed the proposal and commented on it because of the importance of its planning concepts to pedestrians and to all of us who live and work in Massachusetts.

Read the full letter here:
WalkBoston-CommentENF-Lowes-Hadley