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