Suffolk Downs Archives - WalkMassachusetts

Comments on the DEIR/DPIR for the Suffolk Downs Project, MEPA 15783

December 14, 2018

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 DEIR/DPIR for the Suffolk Downs Project
MEPA: #15783

Dear Secretary Beaton and Director Golden:

Thank you for the opportunity to review and comment on the Suffolk Downs project. We offer the following comments on the project’s pedestrian environment, which overall is well addressed.

The project offers generous walking opportunities

The heart of the proposal is a 15-acre park – the Central Common – with walkways surrounding the site and connecting into and through the open space it provides. The Common has been designed as a one-mile running/walking loop. The park has water features with one pond that can be used for skating and another elongated pond that connects into the nearby saltwater Belle Isle Inlet. The Common connects on either end to meeting and performance spaces on plazas leading to the two Blue Line stations.

Main Street, a second north-south walkway, also connects Beachmont and Suffolk Downs Blue Line stations. This street will have wide, landscaped walkways with setbacks to allow for sidewalk cafes and other such uses along its route.

A third walkway, the Active Linear Corridor, parallels Main Street and runs midblock between Main Street and Tomasello Drive. This pedestrian-only street is intended to provide a series of active play spaces for all ages. The proposal is an extraordinary experiment – a half-mile long area that gives nearby space for casual and active uses. Figure 3.37 lists the potential uses of the corridor as active play, jumping mounds, rolling course, flex turf, climbing health, ping pong and jungle gym. Many of these are likely intended for children.

An additional north-south community trail skirts Tomasello Drive and is shown as a two-way bike facility that follows a swale on the side of the property facing the gas tanks, coupled with a sidewalk on the opposite side of the street.

There are several cross streets that connect the four north-south walkways. They vary in scale and importance. Several contain landscaped walkways and add to the many opportunities for walking throughout the project area.

One concern we ask the developer to address with respect to this generously scaled set of pedestrian ways and open spaces is that the play areas along the Active Linear Corridor (with the exception of the block near Waldemar Avenue) are located within blocks intended to be developed not for housing, but office uses, where presumably there will be few children in nearby buildings. As development occurs within the project, the proponents should ascertain if the proposed Active Linear Corridor is located appropriately to serve the intended users who may be living in residences on-site. Active recreational facilities for small children might be more appropriate lining the loop road at the eastern edge of the proposed Common. This route directly serves the three residential areas near the proposed Beachmont Plaza, the Belle Isle Plaza and the “Panhandle” near Route 1A. This route would strengthen the opportunities for residents to use the Common and its central meeting places as well.

East Boston Greenway extension

WalkBoston encourages the proponents to seriously consider a connection to the East Boston Greenway. The existing East Boston Greenway ends at the Belle Isle Marsh, near the Suffolk Downs MBTA station but on the other side of Bennington Street from the station. There is a roadside path/sidewalk paralleling Bennington Street between the main entrance to the marsh reservation and the crosswalk to the Suffolk Downs transit station. This path is used two-way by both cyclists and pedestrians. Extending the path further north toward Revere Beach is not an easy task. The frontage of Bennington Street is spacious and possibly could be the location of an extended route until reaching Everard Street in Revere, where the Bennington route narrows down on the approach to the Beachmont station at Winthrop Avenue.

A potential alternative location for extending the East Boston Greenway that was suggested in the DEIR exists in the large tract of land between the MBTA rail tracks and the Suffolk Downs property line. This land is nearly 10 acres of unused space and has no buildings on it between the Suffolk Downs transit station and Washburn Avenue in Revere. Depending on ownership the tract might be made available. If owned by the MBTA, the property might become available to the developer, who could include a north-south path that would be available as a substitute for the Bennington Avenue route and link the property into the regional Greenway network as a principal route in the system.

Possible new walking connections into Orient Heights from the project site

A decision has been reached with neighborhood residents that vehicular access between the project site and Orient Heights will not be provided. Several walking issues should be addressed to overcome this lack of street connection.

Walley Street and the Suffolk Downs MBTA station
Walley Street, just off Waldemar Avenue, is the current road and pedestrian access point to the Suffolk Downs transit station for Orient Heights residents. This approach currently works for all access to the neighborhood, and the proposed development adjacent to it respects existing neighborhood preferences and adds no vehicular access to the existing site. Instead the proposal adds a new access route for vehicles and shuttle buses to drop off transit-riders from the new development as close as possible to the transit station; this connection appears to be a part of the proposed Belle Isle Plaza. It is a bit unclear how this new connection will meet with existing streets and paths, and the developer, the City of Boston and the MBTA will need to coordinate the proposed new access with the existing street and path layout.
South project boundary – Waldemar Avenue
A community path along the full length of the south project boundary (approximately ½ mile long) connects the bus stop on Route 1A with the Suffolk Downs MBTA station at Walley Street. This is a good walking connection for East Boston/Orient Heights residents, as it provides connections to transit in two directions. From the Suffolk Downs station to a location about halfway between the MBTA station and Route 1A, an on-site road (also called Waldemar Avenue) parallels the path. It will be lined with small residential buildings backing onto the path. The Waldemar Avenue/Tomasello Drive intersection is well located to connect pedestrians into Orient Heights via the sidewalks of the Orient Heights public housing project and especially via Crestway Road, a short street that links to Faywood Avenue and directly to the Manassah Bradley School.
Safe walking access to schools
The proponents include no discussion or description of schools and safe routes to schools. For any students who are attending nearby schools, walking to school should be safe and convenient. The proponents of the project should work with both the City of Boston and the City of Revere to assure safe passage for all students living in Suffolk Downs and using local schools.
WalkBoston suggests additional examination of the role of schools on the walking paths proposed for the development. Students attending the Bradley School from both Suffolk Downs and Orient Heights would be well served by a neighborhood connection to the proposed path network. In addition, we suggest looking at whether a playfield that includes active recreation uses could be located where Crestway Road meets Waldemar Avenue (Block 5 on Figure 3.7). A playfield located here could serve both the school and the new neighborhood at a logical intersection of the walkways that are such a positive element of the project.
For children living in the Boston portion of the Suffolk Downs neighborhood, access to schools in the Orient Heights neighborhood will be somewhat constrained because there is no vehicular access between the two neighborhoods, other than the route provided by going out from Waldemar Avenue onto Route 1A between Tomasello Drive and Boardman Street.
The closest Revere school is the Seacoast School, located on Bennington Street, which can be reached from Suffolk Downs only by an indirect route through the Beachmont transit station and by sidewalks for a further 1000 feet. The Garfield Elementary and Middle School is about 1500 feet north of Winthrop Avenue. Revere High School is located approximately one mile north of Winthrop Avenue.

Route 1A along the western border of the project area

WalkBoston has significant concerns about the proponent’s plans for the Route 1A corridor. Adding a third vehicular travel lane in each direction and increasing roadway capacity from 2,100 to 3,300 vehicles in each direction – an increase of 57 percent – threatens to undermine the ambitious transit-oriented development goals the proponent expresses elsewhere in the proposal. Increased vehicular traffic will also mean more greenhouse gas emissions and more risks to pedestrian and bicyclist safety. We question the need for more vehicular travel lanes on Route 1A between Furlong Drive and Boardman Street, as most southbound traffic on Route 1A will likely access and exit the project site via Route 145/Winthrop Avenue, rather than the proposed “super street” corridor. Similarly, because of the extensive footprint of the Tomasello Drive intersection with Route 1A, we assume that the proponents are anticipating that most of the northbound Route 1A traffic into the site will enter via Tomasello Drive and exit via the same intersection.

The proposal to add more vehicular travel lanes within the existing roadway footprint will also undermine pedestrian and bicycle accommodations along Route 1A. Adding lanes will likely require narrowing or eliminating the current highway median, which would otherwise provide an important pedestrian refuge at the new proposed crossings at Tomasello Drive and Furlong Drive. Absent such a refuge, pedestrians will be forced to cross six highway travel lanes at once, which increases safety hazards and diminishes connectivity between the project site and development and recreation opportunities along the Chelsea Creek. Adding travel lanes while maintaining a five-foot roadway shoulder also reduces the space available for truly safe and protected bicycle facilities. The current proposal for a narrow five-foot unprotected shoulder alongside fast-moving highway traffic does not provide any meaningful protections for cyclists.

Instead of the “super street” concept, we encourage the proponents to reconsider Route 1A as a truly multimodal transportation corridor, with no new travel lanes except those built as dedicated pull-offs for buses on both the northbound and the southbound sides of Route 1A. This will further advance the proponent’s vision for transit-oriented development, while also maintaining space for protected pedestrian facilities in the median of Route 1A. Dedicated bus pull-out lanes also provide for increased bus service. As part of such a plan, the proponent should commit to improved bus stop facilities along Route 1A, including benches and shelters. Pull-outs for bus lanes and bus stop facilities should be considered for replacement of the existing unsafe bus stops at Furlong Drive, the jug handle at the tank farm, Tomasello Drive and Boardman Street.

Pedestrian access to Route 1A bus connections

Existing conditions for pedestrians and bus riders on 1A are terrible. We are glad that there are proposals that provide safe access for pedestrians to bus stops on Route 1A, including new pedestrian crossings at Tomasello Drive and Furlong Drive. The principal users of bus services may be most concerned about access at Tomasello Drive. The existing Tomasello Drive intersection is proposed to be divided into two components – one for traffic entering Suffolk Downs from Route 1A and the other for traffic exiting Suffolk Downs onto Route 1A.

Pedestrians from both Waldemar Avenue and Suffolk Downs are affected in a dramatic way by this proposal, which would add a bus stop island for northbound buses on Route 1A, a pedestrian island between the travel lanes for traffic exiting the site onto Route 1A, and a right-turning slip lane for traffic entering the site from Route 1A. We encourage the project proponents to also consider a more conventional T design for this intersection, similar to what exists now.

Under the proposed new configuration, most pedestrians will approach the intersection on the south side of Tomasello Drive, as that is the path that connects to the residential areas in the “Panhandle” of Suffolk Downs, as well as the homes in Orient Heights. The bus stop on the Suffolk Downs side of Route 1A would be located directly adjacent to the Tomasello Drive exit lanes onto Route 1A. Getting to the bus stop would require passengers to cross the right-turning slip lane from Route 1A to reach the bus stop island. The crossing of the slip lane is likely to be more dangerous for pedestrians than other crossings, as traffic entering the site may not be stopped by the Route 1A signals. This should get more attention in final designs; one option would be to install a signal protecting pedestrians and a crosswalk.

Pedestrians crossing Route 1A are primarily bus passengers using southbound Route 1A bus services. They, too, are required to cross the potentially dangerous slip lane from Route 1A into Tomasello Drive, along with the southbound lane that serves traffic exiting from Tomasello Drive. Pedestrians would halt on the island between the travel lanes exiting the site and cross directly to the bus stop on the west side of Route 1A. This movement can be made concurrently with the signal phase allowing exiting traffic to move from Tomasello Drive onto Route 1A. Designers of the traffic flow for this intersection must consider the possibility that walkers cannot cross without a median break that affords refuge and safety for pedestrians who cannot cross in one signal phase.

Offsite mitigation for pedestrians and bicyclists

The project proponents outline an extensive program for offsite traffic mitigation in Section 6.10 of the DEIR, detailing numerous operational improvements for motor vehicles broken down by specific locations and intersections. Pedestrian and bicycle improvements are described only briefly and in largely general terms at the end of this section. We encourage the proponents to provide more detailed plans in the FEIR for pedestrian and bicycle improvements at the same locations and intersections they are prioritizing for offsite traffic mitigation.

Thank you again for this opportunity to comment on the proposals that affect pedestrians in the Suffolk Downs project.

Sincerely,

Wendy Landman
Executive Director

Cc:
Bob O’Brien, City of Revere

Page Czepina, MEPA Office

Tim Czerwienski, Boston Planning and Development Agency

Comments on Suffolk Downs redevelopment (EEA No. 15783)

January 25, 2018

Mayor Brian Arrigo
ATTN: Robert O’Brien, Director of Economic Development
City of Revere
281 Broadway
Revere, MA 02151

Secretary Matthew Beaton
ATTN: Page Czepiga, MEPA Analyst
Executive Office of Energy and Environmental Affairs
100 Cambridge Street, Suite 900
Boston, MA 02114

Director Brian Golden
ATTN: Tim Czerwienski, Project Manager
Boston Planning and Development Agency
One City Hall, Ninth Floor
Boston, MA 02201

RE: WalkBoston comments on Suffolk Downs redevelopment (EEA No. 15783)

Dear Mayor Arrigo, Secretary Beaton and Director Golden:

Thank you for the opportunity to comment on HYM Investment Group’s proposed redevelopment of the Suffolk Downs site in East Boston and Revere. WalkBoston looks forward to working with the City of Revere, EEA, BPDA, HYM, and other agencies and project stakeholders to help advance the proponent’s stated goal of “creating a vibrant, mixed-use walkable community.”

Leveraging connections between walkability and transit

The proponent’s Expanded Project Notification Form (EPNF) reflects a strong commitment in principle to walkability and multimodal transportation connectivity. The proposed Phase 1 project emphasizes new pedestrian connections at the Suffolk Downs Blue Line station on the MBTA, and the Master Plan project is similarly premised upon pedestrian access to and from the Blue Line at Suffolk Downs and Beachmont Stations. Overall the Suffolk Downs site is wellpositioned for walkable transit-oriented development, which is reflected in HYM’s high anticipated mode shares for walking and transit for the Master Plan project. (The projected mode shares for walking range from 10.9% for office uses to 19.6% for residential uses; the projected mode shares for transit range from 45.4% for residential uses to 54.7% for hotel uses.)

The Phase 1 project has a much lower projected transit mode share of 37.5%, as well as a 44.4% projected mode share for single occupancy vehicles. We are concerned that this will create significant auto dependency from the onset of this project that will affect the future Master Plan development as well. The proponent states that “while there will be emphasis to support a high proportion of alternative trip making by the Phase 1 Project, this more conservative mode share profile has been utilized given the Phase 1 buildings are being analyzed as a standalone project without the benefit of a mixed-use environment.” We urge the proponent to aim for more ambitious transit, walking and biking mode share goals for the Phase 1 development to maximize the site’s potential for transit-oriented development.

The proponent also anticipates over 54,000 new transit trips per weekday, including over 4,000 trips during the morning peak hour and over 5,000 trips during the evening peak hour. This number is very high relative to current Blue Line ridership levels. As part of their transit analysis for the Draft Environmental Impact Report (DEIR), HYM should detail how they arrived at this number and how Blue Line ridership will change as the Master Plan project is phased in over time. This analysis should be accompanied by the proponent also clarifying their plans to invest in capacity upgrades along the Blue Line as part of a broader package of Transportation Demand Management (TDM) strategies.

Exploring opportunities to reduce single occupancy vehicle trips and parking spaces

While the high projected transit mode share and ridership are positive attributes of this development proposal, the proponent still projects over 33,000 new vehicle trips per weekday, including over 3,000 trips during the morning peak hour and over 3,000 trips during the evening peak hour. This increased vehicular traffic has the potential to significantly affect congestion and pedestrian safety within the project site and along surrounding roadways. Given that vehicular access to the site is limited to just two intersections (Route 1A/Tomasello Way and Winthrop Avenue/Tomasello Way), the proponent should clarify how the project site and surrounding streets will handle this traffic in the DEIR. Significant mitigation measures will be necessary to address 33,000 new vehicles on already congested streets.

While HYM does not specify how many new parking spaces will be needed to accommodate these vehicles, WalkBoston calculates that between 10,800 and 16,200 new spaces will be necessary, depending on the development program and parking ratios used. (The proponent states that the following parking ratio ranges should adequately support the Master Plan project’s parking demand into the future: residential, 0.5 to 1.0 spaces per unit; office, 1.0 spaces per 1,000 SF; lab, 1.0 spaces per 1,000 SF; hotel: 0.5 spaces per room; retail: 0.5 spaces per 1,000 SF). We are encouraged by the relatively low proposed parking ratios for the residential units, as well as HYM’s broader recognition that auto trip rates are likely to decrease over time. The final residential parking ratio should be as close to 0.5 spaces per unit as possible and we look forward to reviewing HYM’s TDM plans as part of the DEIR. Any strategies and mitigation measures proposed must further enhance walkability, bikeability and transit access, while reducing single occupancy vehicle use and the associated need for parking.

Exploring opportunities for bus/shuttle connectivity and related pedestrian access

HYM notes that there are several MBTA bus lines (450, 459 and 119) along Route 1A and Winthrop Avenue within a half-mile walk of the project site, and that “there are opportunities to expand MBTA bus service into the project site and provide for internal site transportation/shuttle to further improve access to public transit” as the Master Plan project is built out. The proponent should further explore and detail these options as part of their TDM plans in the DEIR, as increased utilization of MBTA buses and/or shuttles can reduce single occupancy vehicle use. An analysis of bus/shuttle options should examine the potential for increased service on existing MBTA bus lines and associated changes in ridership, as well as the potential to service the neighborhoods surrounding the project site. The proponent should also clarify their plans for investing in such services, whether through funding the MBTA or their own shuttles.

Ensuring that pedestrians can safely and comfortably walk to and from bus/shuttle stops is critical to ensuring that these services will be utilized. Ideally bus/shuttle stops will be located within a quarter-mile of the project site to maximize their usage. We appreciate HYM’s commitment to improving sidewalks adjacent to the project site to meet ADA standards and to include street trees if feasible, as well as their acknowledgement of the need for mitigation measures and infrastructure improvements at the site’s primary vehicular access points (Route 1A/Tomasello Way and Winthrop Avenue/Tomasello Way). The proponent states that “geometric and traffic signal improvements will be recommended at both of these intersections to optimize traffic operations.”

Improvements at these locations must also address pedestrian safety and traffic calming. HYM plans to widen Tomasello Way and Route 1A as part of the Master Plan improvements, yet there are no crosswalks across Route 1A near the project site and the crosswalk across Tomasello Way at Route 1A is already 140 feet wide with minimal pedestrian refuge. Any signal and roadway upgrades at this location and near other shuttle/bus stops must provide safe pedestrian crossings and well-timed WALK signals that provide countdowns and leading pedestrian intervals. Long crossing distances should be reduced as much as possible using curb extensions, and pedestrian refuges should be created and enhanced to provide protected waiting areas. In extreme circumstances, the proponent might consider working with the MBTA to relocate bus stops to more pedestrian-friendly locations.

Creating a walkable project site that meets Complete Streets standards

In addition to leveraging pedestrian access to and from the Blue Line, the proponent has integrated walkability and pedestrian connectivity into many other aspects of their redevelopment proposal. These include creating a new interior street network on site that meets Boston Transportation Department’s (BTD) Complete Streets guidelines, developing a system of multi-use ADA-compliant paths and trails that connects to adjacent neighborhoods and regional path networks, and activating the public realm with open space amenities and extensive ground-floor retail. Creating streets, sidewalks and paths that accommodate road users of all abilities and travel modes is critical to developing more livable and walkable communities, so WalkBoston is pleased to see a commitment to these issues in the EPNF.

We look forward to seeing more detailed plans for the interior streets, paths, intersections and signals as part of the DEIR. The interior streets should be designed to ensure that vehicles follow a 20 mile per hour speed limit to maximize walking safety as well as walking and transit mode shares. They should also include additional measures for pedestrian safety and traffic calming, including narrow vehicular travel lane widths, frequent and well-marked crosswalks, and well-timed WALK signals that provide countdowns and leading pedestrian intervals. We encourage the proponent to maintain their current plans to not have vehicular access to the project site from Bennington Street or Waldemar Avenue, thus prioritizing multimodal connectivity and reducing the potential for increased local traffic.

Improving pedestrian safety throughout the project study area

The need for traffic mitigation is not limited to the immediate project vicinity and access points. To this end, HYM states that a mitigation program will likely focus on improvements to roadway geometry, traffic signals, and multimodal mobility along the broader Route 1A and Winthrop Avenue corridors, as well as Furlong Drive, the on-site roadway network, and other nearby intersections. The proponent also notes that many of the broader study area intersections are located within Highway Safety Improvement Program (HSIP) clusters and thus are potentially subject to Road Safety Audits (RSAs) per Massachusetts Department of Transportation guidelines. WalkBoston looks forward to reviewing a more detailed discussion of the Master Plan project mitigation phasing and recommendations for the timing of specific roadway improvement projects as part of the DEIR. We are also available to participate in future RSAs as needed. Once again, we encourage utmost consideration for pedestrian safety and traffic calming measures as part of any improvement packages.

Thank you again for considering these issues and feel free to contact us with any questions.

Sincerely,

Wendy Landman
Executive Director

Cc: House Speaker Robert DeLeo
Senate President Harriette Chandler
Senator Joseph Boncore, Transportation Co-Chair
Representative William Strauss, Transportation Co-Chair
Representative Adrian Madaro
Boston City Council President Andrea Campbell
Boston City Councilor Michelle Wu, Transportation Chair
Boston City Councilor Lydia Edwards, District 1
Revere City Council President Jessica Giannino
Revere City Councilor Steven Morabito, Economic Development and Planning Chair
Revere City Councilor Joanne McKenna, Ward 1
Becca Wolfson, Boston Cyclists Union
Stacey Thompson, LivableStreets Alliance
Andre Leroux, Massachusetts Smart Growth Alliance
Richard Fries, MassBike Marc Ebuña, TransitMatters
Chris Dempsey, Transportation for Massachusetts

Comments on the DEIR for Caesars Resort At Suffolk Downs, MEPA #15006

October 11, 2013

Secretary Richard K. Sullivan, Jr.
Executive Office of Energy and Environmental Affairs (EEA)
Attn: Deirdre Buckley
100 Cambridge Street, Suite 900
Boston MA 02114

RE: Comments on the DEIR for Caesars Resort At Suffolk Downs, MEPA #15006

Dear Secretary Sullivan:

WalkBoston has reviewed the DEIR for a Caesars Resort at Suffolk Downs. The DEIR documents walking improvements that the proponent will undertake as part of the plan and we are generally pleased with the proposals. We offer comments below to supplement the current proposal with further improvements.

The scale of the site proposed for this project is noteworthy. The existing roadway extends nearly a mile through the L-shaped site between Route 1A and Winthrop Avenue, and the site is roughly 3,000’ north-south and east-west. Opportunities for integration with the existing community are substantial, as the site is bounded by industrial uses on the west side, by residential neighborhoods on both the north and south sides, and by the combination of the MBTA Blue Line, Bennington Street and the Belle Isle marsh on the east side. The urban setting of the project sets the stage for planning elements to allow the development to relate physically and operationally to the surrounding community.

Recognizing the scale of the site, its urban location, and the number of people anticipated to be present each day, the proponent has made efforts to shift trips away from private vehicles and toward public transportation. This is in keeping with the recently announced MassDOT statewide goal of tripling the share of walking, bicycling, and transit travel in Massachusetts. Reducing auto dependence would also reduce the environmental impacts of the development and help preserve capacity on the adjacent highway network. In addition, encouraging greater use of active travel options – walking and biking – will help the development achieve some positive public health effects. We believe that there are additional measures that could be taken to further reduce auto trips and have described several opportunities in our comments.

The details of the development plan offer evidence of some innovative thinking that has created opportunities for walkers on the site. For example, the introduction of water-catching swales on parking lots creates an opportunity to construct parallel walkways that are more pleasant ways of walking through open parking areas. Our comments are organized into those affecting access to and through the site and the pathways that help people get where they want to go within the site.

A. Access to the site via MBTA rapid transit service.

The Blue Line forms one boundary of the site, and has two stations near the proposed project – Beachmont Station and Suffolk Downs Station. Most of the Blue Line users are expected to use the Suffolk Downs Station.

This is reflected in the proposed walkways, bikeways and shuttle bus services to be constructed at that location. No improvements are proposed at Beachmont Station. The proponent has estimated that 15% of daily trips to and from the site will be made via the Blue Line. A total of 4,00o on-site employees are projected, and 40% of these employees, or 1,600 people, are expected to use public transit daily. In addition, 11% of the 23,674 to 32,992 daily casino visitors (2,614 – 4,086 people) are expected to use the Blue Line for access. Since there is no current MBTA bus service to the site, all of the public transit users – some 4,000 to 6,000 people per day – are expected to access the site via the Suffolk Downs Station, which in recent years has handled daily traffic of roughly 1,000 riders.

In recognition of this major impact on the use of rapid transit by employees and visitors to this site, the Suffolk Downs Blue Line Station will be upgraded by the proponent to handle anticipated transit and foot traffic. Elevators will be added on both sides of the tracks to make the station fully accessible and convenient for people wanting to cross the tracks between Bennington Street and the site. We offer several suggestions regarding the MBTA station and the access it provides to the site:
1. A new plaza in front of the station should encourage access for all users, using a design that provides adequate space for walkers, bicyclists and shuttle bus users.
2. The connection into Orient Heights should be enhanced and the proponent should work with neighborhood residents to design a connection that encourages safe and pleasant walking to the station.
3. The shuttle bus shelter proposed near the plaza should have signage that includes both bus and walking information, including the estimated walking time from the station to the casino and other facilities in the proposed development.
4. Walkways between the station and on-site buildings should be attractive, safe and conducive to walking. Separate paths for pedestrians and bicycles are an important and positive design feature. This separation should be made very clear to users, through a significant landscaped buffer strip and wayfinding signs that clearly indicate the separation. Different textures or colors of surface pavement, slightly different elevations, or decorative pathway curbs could all help signify which path belongs to pedestrians. Walkway lighting could also be designed to distinguish pedestrian lighting from the roadway/bikeway lighting.
5. East Boston Greenway connections should be thoroughly explored. The Belle Isle Marsh lies across Bennington Street from the main entrance to Suffolk Downs MBTA Station. Plans show a path along the marsh edge connecting to the existing East Boston Greenway, and the proponent has agreed as part of a consent decree with the US EPA to fund a new boardwalk at Belle Isle Marsh to improve public access and protect natural resources within the marsh. In the short term, the path and the boardwalk should be considered concurrently and include a link to the Suffolk Downs Station. Pedestrian access improvements on Bennington Street could include moving the existing crosswalk now located at Leverett Street 200 feet north to align with the main station entrance and the route of the Greenway at the edge of the marsh. This would allow an extension of the Greenway into the proponent’s site, where significant new open space with paths and nature trails could expand and extend the Greenway network to Route 1A and to Winthrop Avenue.
6. Future Greenway connections should be considered. The East Boston Greenway, if extended through the proponent’s site to Route 1A, could eventually be extended to link with walkways on the opposite side of Route 1A along Chelsea Creek in Revere, where open spaces are cited in the DEIR as possible future projects.

B. Access to the site via MBTA bus service

The DEIR includes a proposal for MBTA bus service within the site, including a stop on Tomesello Drive near the entrance to Casino Area II, but bus service on Route 1A is not addressed in the DEIR. MBTA bus service should be more completely examined, as it could significantly affect access to the site from throughout the region. In addition, it could affect internal site pathways – their alignments, construction standards and levels of potential use.

1. MBTA bus service within the site has not been detailed to explain off-site routings and their consolidated or separate connections into the site. Such bus service might supplement private carriers such as the anticipated dedicated charter buses and shuttles from Logan airport, nearby business districts and other major tourist, cultural and travel venues in Boston, Revere, and the surrounding region. MBTA bus service should be more clearly explained as a possible option, including potential routes that might be devoted to accessing the casino/racetrack on this site from a variety of locations.

2. MBTA bus service along Route 1A should be more thoroughly explored. Currently, MBTA service on Route 1A consists primarily of express buses which run between Salem, Lynn and Boston or the airport. Route 1A may also be an appropriate route for bus service that serves this site and could affect the attractiveness of public transit options.

3. Future Route 1A bus service might stop near the site’s principal entrance at Tomesello Drive. Bus stop locations would need to be closely coordinated with proposed traffic signals at Route 1A and Tomesello Drive because pedestrians would cross Route 1A using this signal. It is likely that a separate pedestrian phase at the signal would be needed.

4. Route 1A bus stops at Tomesello Drive should be connected to all pedestrian paths leading to the casino and racetrack. A primary, well-marked pedestrian path is essential and should be located on the same side of Tomesello Drive as a bus stop. It should be well designed, attractive to walkers, safe, well lit, and signed to reassure visitors that they are on the right track. Ideally, the pedestrian path should be separated from the bicycle path. Distances in time might be added to encourage walking along this route. It is about a 10-minute walk from Route 1A to the entrance to Casino II.

5. Late night MBTA transit service should be considered to serve both patrons and staff. This may require subsidies by the proponent to support increased transit service that would not otherwise be provided by the MBTA, such as late night Blue Line service or bus shuttles from Downtown Boston. Late night service would help shift workers and patrons away from private vehicles.

C. High Quality Design, Amenities and Year Round Maintenance

WalkBoston assumes that the proponent will commit to providing the levels of landscaping, lighting, security, snow shoveling and maintenance needed to make transit riders, pedestrians and bicyclists feel invited, safe and comfortable year-round. Because the site is so large, and the length and number of pathways and sidewalks are so substantial, this will require a serious commitment of resources. WalkBoston believes that this investment is needed to ensure that the proponent’s projection that 15% of trips to the site will occur via the Blue Line. As noted above, we urge the proponent to also investigate the potential to shift additional trips to public buses.

D. Pedestrian paths through the property

WalkBoston is pleased to see the attention paid to walking paths through the property. Each of the paths are discussed below.

1. The path between Suffolk Downs MBTA Station and the South Plaza is the site’s prime example of walking/biking path separation. Separate paths are preferred by both walkers and bikers and should be considered for the other paths on the site. The path follows a new street called Blue Line Road that will provide access for the shuttle bus between transit and the casino and other facilities. The physical layout includes a 23’ roadway, with an 8’ two-way bikeway immediately adjacent to it. An 8’ two-way walkway is separated from the bikeway by a 6’ wide greenway and from the horse track by an 18’ landscaped buffer and fenced grassy area.

2. The path along the edge of the racetrack connects directly with the station path described above and provides one part of a connection that traverses the entire site from south to north, on a route that follows the edge of the racetrack, past the apron, the paddock for parading horses and the grandstand. It connects to the Sales Creek Path and the path leading along the edge of the North Parking Lot and to Winthrop Drive at north edge of the project site. This long attractive walking route could potentially be of significant use as a recreation trail. However, the DEIR calls for ‘controlled’ use of the path, and the degree to which public access will be allowed should be explained in detail.

3. Possible pedestrian connections to Orient Heights. The edge of the proponent’s site is separated from Orient Heights by a steep grade along most of its southern boundary. However, at one location, near the point where Tomesello Drive currently makes a 90- degree turn, the grades of Tomesello Drive and Waldemar Avenue coincide. If the residents of Orient Heights are interested, the project proponent should explore new pedestrian access at this location to provide a connection into the South Parking Lot which would allow pedestrians to walk via on-site pedestrian paths and sidewalks between Orient Heights and the Suffolk Downs facilities and the shopping area along the west side of Tomasello Drive.

4. Path connections meet at the South Plaza, where there is a major entrance into the casinos. This is where the path from the Suffolk Downs MBTA station and from the South Parking Lot connect with the Winter Garden entrance and the link between the casino areas and the North Plaza. The plaza is proposed to be a shaded space with adjacent activities such as a sidewalk café. It has a good model – the Lincoln Center grove of trees – and affords a place to walk, with ample sitting areas where people can wait to meet others arriving at the south entrance, or take an outdoor break from other activities. The South Plaza is also called out as a location for active events. A description of the possible events should be provided, as they may affect the layout and pedestrian use of the plaza.

5. The path between the Route 1A site entrance and Casino Area II is a handsome entrance amenity for the site. It will become especially important if bus service and bus stops are added at Route 1A. The total distance from Route 1A to the entrance to Casino Area II is approximately 2,400’ – about a 10-minute walk. At the moment there are two paths proposed, passing through areas to be extensively landscaped around restored water areas. The paths could readily become parts of the East Boston Greenway.
However, the alignment of the walks may need attention for walker safety. The current location of the walks, though parallel to Tomesello Drive, is some 50’ away from it. This distance may be too far for walkers to feel safe. Many designers suggest that pedestrians should be visible from the roadway and that they should be able to reach the roadway in case of an emergency. A more suitable distance, predicated on safety, should be explored.
It may also be useful to explore if both of these walkways through this pleasant green area are essential. One walkway, located along the desire line of people expected to use it between the bus stops on Route 1A and the casinos, may be all that is needed. The proposed bollard lighting system sounds promising and should be help provide maximum safety for walkers.

6. Paths from Route 1A lead to the plaza/main entrance to Casino Area II where significant vehicular access is proposed. Four lanes serve the entry point and there are direct connections into the underground parking beneath Casino II for this valet parking area. At this entry point, a large roof above the vehicle lanes (called a porte cochere) provides weather protection. Because many vehicles, including taxis, will arrive on each of the four lanes, it will be important to know how pedestrians will be able to safely walk between their cars and the entrance to the casino. (This area is similar to the drop off and pick up area at airport terminals, where many pedestrians are required to walk across a number of lanes of arriving and departing vehicles.)
An additional question concerns direct access for people arriving from Route 1A or from the MBTA Station on foot. The current plan includes an indirect route for the approaching walkway rather than a more direct route. People who have walked from Route 1A should not be asked to walk several hundred feet out of their way when they can see the entrance clearly ahead of them.

7. Paths along Tomesello Drive north of the casino area are proposed for the west side of Tomesello Drive as far as the traffic circle entrance to the parking garage and North Plaza. On the east side of Tomesello Drive, paths are shown from Route 1A all the way to Winthrop Ave. The path on the east side is separated from the road by an 8’ buffer; on the west side it is not clear whether a buffer is provided. The paths are 14’ wide and are twoway shared bike-ped facilities. A planted 6’ wide slope separates the path from the parking bays north of the parking garage. Overhead lighting is designed to provide illumination that differs between the roadway and the path.
The proponent should consider whether the proposed path on the west side of Tomesello Drive is essential for access to any part of the site, and whether it will see much use.

8. Path connections at the North Plaza will serve significant numbers of visitors who will enter both casinos via this large square. The plaza provides access for all bus and limo shuttle services at a scale that indicates that many buses are anticipated. At the north end of the plaza there is a weather-protected drop-off location where individual drivers can access Casino Area I and the racetrack. Access to Casino Area II is provided at the south end of the plaza through the Winter Garden.
The North Plaza is approximately 500 feet long and 200’ wide, encompassing 2.2 acres. It is laid out with two lanes of traffic surrounding it (suggesting a one-way pattern of traffic movement) with adjacent sidewalks for loading and unloading visitors to the sidewalks adjacent to the casino entrances. Vehicular access into and out of the plaza is provided by four lanes of traffic that connect the plaza and the large parking garage to Tomesello Drive. No pedestrian paths are provided along these routes.
The plaza is designated as an event space and viewing area, which is still undefined. The side of the plaza abutting the Grandstand and Casino Area I appears to have the widest sidewalk leading directly into the casinos. This is where many of the bus and shuttle services are likely to discharge and pick up passengers. On the opposite side of the plaza is the large parking garage. Rather undefined sketches show the first floor of this garage as a future retail area.
It will be important to design the North Plaza so that pedestrians have a pleasant and safe walking experience. Especially important will be the provision of visual interest for the very tall and lengthy facades and the provision of landscaping to provide walkerfriendly scale and materials. To clearly separate pedestrians from vehicles, safety improvements such as bollards, seating areas between the line of trees, and different treatments of sidewalk surfaces should be considered. To make the area more interesting for walkers entering the casinos, the west wall of the Grandstand facing this long sidewalk might considered for the installation of art or information diagrams or posters.
It is also important to ensure that air circulation systems diminish the accumulation of exhaust fumes from the many vehicles in the plaza.

9. Paths to and through the parking structure should be detailed. A second-level walkway connects the garage directly into Casino Area II, but access from the garage to Casino Area I and the racetrack involves crossing the busy North Plaza at crosswalks. These crosswalks should be designed for the safety of walkers passing through the traffic bringing visitors to the site.

10. The path between the North Plaza and the North Parking Lot is a long, straight walkway serving users of the 1,468 parking spaces. A tree-lined path connects all of the site’s activities to the shopping area west of Tomasello Drive. As a unique on-site feature, transverse swales across the parking lot are planned to direct storm water runoff into the underground drainage system. It is unclear if these swales will be landscaped. As currently planned, there are four transverse swale areas laid out to separate every three or four rows of parking and to collect runoff through their permeable surfaces. For each of these transverse swale areas, the opportunity exists to create shaded walking paths along each swale. A similar opportunity may exist at the South Parking lot.

11. The Sales Creek Path is approximately 800 feet long, and extends from the racetrack diagonally to Tomesello Drive on a route that parallels an original waterway. This route affords the proponent an opportunity to use the creek as a focus of landscaping to provide screening at the edge of the North Parking Lot, and create a shaded place to walk. It might be possible to extend the landscaping along the creek up to Tomesello Drive on both sides of the street, and use the creek as a major feature that designates the entrance into the site.

E. Boardman Street Overpass

A path along the proposed Boardman Street overpass should be constructed to replace the existing sidewalk that parallels Route 1A between Boardman Street and the site entrance. A buffer strip between the sidewalk and the overpass would be desirable, as the overpass is likely to be very busy. Connections into existing adjacent open space and the new sidewalk might be considered in consultation with residents of Orient Heights.

We 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 Robert Sloane
Executive Director Senior Project Manager

Comments on ENF for Caesars Resort at Suffolk Downs

March 26, 2013

Secretary Richard K. Sullivan, Jr.
Executive Office of Energy and Environmental Affairs (EEA)
100 Cambridge Street, Suite 900 Boston MA 02114

RE: Comments on ENF for Caesars Resort at Suffolk Downs – EEA #15006

Dear Secretary Sullivan:

WalkBoston has reviewed the ENF for Caesars Resort at Suffolk Downs. We find agreement with the general design, as it seems directed toward providing safe facilities for pedestrians. A number of design details should be more closely investigated as part of the DEIR. Our comments about those details follow.

Underlying Assumptions
Many of the patrons and staff of the casino complex and racetrack will arrive on foot from transit stations or parking lots. Thus walking should be a significant element of the project design, coordinated with vehicular routes to minimize potential conflicts. Walking, transit and bike use should be maximize d in keeping with the Commonwealth’s goal of tripling the share of walking, biking and transit use. Access to and from the two MBTA stations and the Route 1A bus lines, and access between distant parking locations and the casinos and the racetrack are the primary routes to be addressed. Walking access between the site and adjacent residential areas should also be addressed.

Good information about the projected volumes of pedestrians (and bicycles) should inform the design and size of facilities.
For example, the ENF states that most employees will come to the site via public transportation. While not explicitly stated, we would anticipate that nearly all would walk from the MBTA stations into the site (unless shuttle service is provided). Because the Suffolk Downs Station is considerably closer to the proposed buildings than Beachmont Station, it will likely attract more users. The walkway from the station into the site should be designed to accommodate the anticipated volume of walkers (and bicyclists if they will use the same route) and the projected volumes should be included in the DEIR.

Overall Design Issues to be addressed
• The design of walkways and walk routes should be attractive, include high quality landscaping, and feel inviting both day and night, winter and summer. Designs should include:
– A network of short distance walkways to encourage people to walk on site.
– Lighting for safety, using designs that do not spill into residential areas or obscure the night sky
– Safety and security especially given late night operations for employees and patrons, where there are fairly long walks such as the one to the Suffolk Downs MBTA station
– Benches
– Smooth surfaces on all walkways
– Year round maintenance including snow shoveling
– Shade while walking to the casinos and hotels
– In New England, inclement weather is inevitable, suggesting the possibility of providing shelters or coverings along walkways, or alternative means of reaching destinations, such as a shuttle bus service
– Wayfinding for pedestrians – Signage should be employed as fully as possible to help pedestrians find their routes within this very large site. Signs would also encourage the use of MBTA bus routes and subway facilities, and should be used to designate access points in the event an on-site bus shuttle service is provided. Other off-site locations of interest should be included, such as the Belle Isle Marsh Reservation, Revere Beach and potentially the Target/Super Stop and Shop complex , the racetrack’s horse barns and other sites that might improve the experience of nearby residents as well as patrons of the casinos, the racetrack, and the hotels.
– Parking lots should be designed attractively, with trees and with defined walking paths that are separated from moving vehicle areas within the lots

• Multi-use path design.
The paths on the site that are walking/biking multi-use paths should provide appropriate widths to allow for safe shared use. MassDOT standards (Mass Highway Department Project Development and Design Guide, 2006), call for multi-use paths to be 10—14 feet wide to accommodate both pedestrians and bicycles, and for wider facilities if substantial volumes of foot and bike traffic are anticipated.

Tomasello Way/Rte 1A intersection and Tomasello Way Design
• Bus service
Bus service along Rte 1A is already substantial. Routes along the roadway connect Salem Center, Marblehead and Peabody Square to Haymarket and Downtown Crossing – 6 bus routes in total. Well-designed and highly-visible bus stops, along with weather-protecting shelters, should be included in the revamping of the intersection of the Tomasello Way/Rte 1A intersection.
• Signals and crosswalks
In keeping with the intersection’s importance as the front door of the proposed development, the intersection will need to be fully signalized for safety for all users, including pedestrians who will be crossing Rte 1A to and from the new bus stops and shelters. In the re-signalization of the intersection, pedestrian count-down signals should be employed.
• Access between the intersection and the on-site facilities
The proposal includes a major pedestrian way leading from the intersection of Tomasello Way and Rte 1A into the main entrance to the casinos, the racetrack and the hotels. It appears to be useful and attractive, but it must be made safe for walkers and is worthy of significant improvements to make it safe. According to the preliminary drawings, the walkway will be located in the median strip of the rebuilt south portion of Tomasello Way. This is a formal design that could be handsome, but it results in a strip of walkway in the median that could be difficult for walkers to access, because it requires them to cross roadways on both ends of the walkway – near Rte 1A and at the casino/racetrack entrances, as well as at intermediate locations in between – five crosswalks in all. A better solution might be to have the pedestrian way located on the south side of Tomasello Way, with more direct access across the street at a point where the walkway is closest to the casino. This would reduce potential pedestrian/vehicle conflicts along the full length of this stretch of Tomasello Way.
• Amenities along Tomasello Way
Pedestrians walking via Tomasello Way have a relatively long walk between Rte 1A and the site (roughly equivalent to 3-4 city blocks). The preliminary drawings show lines of trees that will be very appropriate to make a pleasant walk. Seating along the way would also make the route more attractive and allow people to rest as they make their way to the casinos or the racetrack.
• A sidewalk connecting Tomasello Way and Waldemar Avenue in Orient Heights
A wholly new but short on-site sidewalk connecting Tomasello Way and Waldemar Avenue would allow Orients Heights residents to reach the bus stops at the intersection of Rte 1A and Tomasello Way, and to be able to walk to the casinos or the racetrack.
• A roadway connecting Tomasello Way to Waldemar Avenue in Orient Heights
Consideration of a sidewalk connecting Tomasello Way and Waldemar Avenue should include examination of a future road connection as well. A new, relatively short street to link Tomasello Way to Waldemar Avenue could reduce problems at the intersection of Waldemar Avenue and Route 1A near the Tomasello Way entrance to the site because it would allow Orient Heights access to be diverted to the Tomasello Way entrance to the site. The connection could include options for improving the safety of nearby residents:
– Waldemar Avenue could become a dead-end street before reaching Rte 1A; or
– It could be made one-way inbound toward the residences; or
– It might be connected to Vallar Road if gradients are favorable.

The continuation of Tomasello Way to the Suffolk Downs MBTA station
A driveway currently exists along the proponent’s property line between the Rte 1A entrance to the site and the small turnaround space in front of Suffolk Downs T station. The west half of this route has been covered above. However, the future of the east half of the driveway is unclear, even though it could be used for vehicular and pedestrian traffic as part of the larger plan. An explanation should be provided as to:
– Whether this driveway will become an access roadway providing service both to the south entrance to the casino, and to the Suffolk Downs MBTA Station.
– Whether this driveway will be extended to connect into the local roadways of Orient Heights, such as Waldemar Avenue, Walley Street and Bonito Square. This connection could relatively easily reach Bennington Street as well, and could become a major route for vehicles entering or leaving the site.
– Whether an improvement is planned for the pedestrian component of the service plaza at the MBTA Station.
– What the pedestrian connections along this roadway will become, as it provides a major walkway between the MBTA station and the casinos and hotels. This connection might also be used to enhance direct access from neighborhood walkways into the station.

Pedestrian access from off-site locations
• Pedestrian access between Orient Heights and a potential Route 1A bus stop at Boardman Avenue.
A partial interchange is proposed for the intersection of Boardman Avenue (Route 145) and Route 1A. The proposal calls for a northbound overpass above Rte 1A to pass over the turning between Rte 1A and Boardman Avenue. The overpass design and focus of turning traffic at the intersection suggests some difficult crossings for pedestrians from Orient Heights. Bus stop access for pedestrians should be explored as part of the proposed partial interchange. It may be possible to link Boardman Street access to the bus stop at Tomasello Way.
• Pedestrian access between Orient Heights and the Target/Super Stop and Shop complex
The ENF notes that walkers from Orient Heights need to cross the Suffolk Downs site to get to the shopping complex located near the intersection of Tomasello Way and Furlong Drive, which are important businesses for Orient Heights residents to use. Data support-ing this suggestion would be useful. The multi-use path along Tomasello Way will improve this walk. From a pedestrian point-of-view, the suggested location of the walkway on the east side of Tomasello Way results in pedestrians from Orient Heights crossing at least 6 streets on route to the shopping complex, unless they follow the alternative walking route that hugs the buildings. The proponent should examine whether the walkway could be moved to the west side of Tomasello Way to reduce the number of crossings. Pedestrians walking along Tomasello Way should also be protected from walking through either of the two roundabouts at the approach to the hotels and casinos. Roundabouts are not very safe for pedestrian because of the potential conflicts with turning vehicles.
• Pedestrian access between Crescent Heights and the Target/Super Stop and Shop complex
Residents of the Crescent Heights neighborhood at the north edge of the site could also reach the shopping area via the Tomasello Way walkway.
• Racetrack walkway to the Target/Super Stop and Shop complex
The plan includes a walkway between the racetrack and the Target/Super Stop and Shop via the edge of the northern parking lots. The intersection of this walkway and Tomasello Way should be moved slightly to align with the front entrance to the shopping complex. The volume of foot traffic at this intersection may be low, but further exploration may suggest the need for a traffic signal with WALK signals.

Potential shuttle bus service
Shuttle buses should be considered to help people get around and to provide options during inclement weather. Options for shuttle bus stops include main entrances to the casino and race track, the Suffolk Downs and Beachmont MBTA stations, bus stops on Route 1A at Tomasello Way, the bus stop on Winthrop Avenue, and for access to the more remote parking areas. Facilities to support shuttle bus service may include the addition of a turnaround area in front of Suffolk Downs MBTA Station and a u-turn on Tomasello Way just short of Route 1A. Shuttles may also be useful to serve future night transit service on the Blue Line and elsewhere.

Local Community Benefits – pedestrian improvements at other locations
The ENF includes suggestions that certain improvements outlined by the Lower North Shore Traffic Study of 2000 could be included as part of the mitigation for the construction of this facility. Although no detail has been supplied on these locations, they appear to include intersections at Route 16 at Winthrop Avenue/Harris Street, the vicinity of the Beachmont MBTA Station in Revere, in the vicinity of Route 16/Route 1A/Bell Circle in Revere, and, in East Boston, at Bennington & Saratoga Streets at Orient Heights MBTA station and Boardman St. in East Boston. Many of these improvements have been requested by the affected communities and will need to be detailed in further submittals to show potential impacts on pedestrians.

We appreciate your consideration of our comments and your responses to them. Please feel free to contact WalkBoston with any questions you may have.

Sincerely,

Wendy Landman
Executive Director