November 26, 2019

Secretary of Energy and Environmental Affairs Kathleen Theoharides
Executive Office of Energy and Environmental Affairs (EEA)
Attn: MEPA Office, Page Strysky
100 Cambridge Street, Suite 900
Boston MA 02114

Dear Secretary Theoharides, 

WalkBoston and MassBike have reviewed the MEPA filing #16097 for Waltham High School located at 554 Lexington Street in Waltham, MA. 

We are concerned with changes to Lexington Street that are included in the environmental filing: in particular, a new design speed of 45 mph, the removal of bicycle lanes in order to add additional general travel lanes, and poor connectivity. The changes are at odds with the Waltham Complete Streets policy as well as the recommendations put forth in the Waltham Transportation Master Plan (TMP) from January 2017. As proposed, this project will make Lexington Street more dangerous for all Waltham residents, even motorists. The segment of Lexington Street where the changes are proposed is, in addition to an important north-south arterial for motorists, bicyclists and pedestrians, a residential street lined with single-family homes and their driveways where residents turn left across oncoming traffic, and pull in and out.

Three of our major concerns from the filing:

1. This project has set a new design speed limit of 45mph on Lexington Street near the new high school; the street previously varied between 40 mph, a 30 mph advisory speed, and 20 mph school zone. The AAA Foundation for Traffic Safety has found that the average risk of severe injury for a pedestrian struck by a vehicle reaches 10% at an impact speed of 16 mph, 25% at 23 mph, 50% at 31 mph, 75% at 39 mph, and 90% at 46 mph. The TMP noted that the Waltham Police Department identified speeding “as a significant issue” on Lexington Street. However, when a speed study was conducted for the high school project, the 85th percentile speed recorded was 41mph, leading to a new design speed set at 45mph. This does not mitigate the existing problem of speeding drivers on Lexington Street, but instead, legitimizes it. The purpose of this project should not be to maximize vehicle speed and throughput. On the contrary, the goal must be to create a safe access to the new high school for all modes and ages, especially the most vulnerable.

   A community should be safe for residents to get around, whether by walking, cycling, using transit, or in a vehicle. That safety and comfort is impacted by the design of our streets and intersections. All existing elementary schools in Waltham currently participate in the Massachusetts Safe Routes to School Program, which encourages students and their parents to walk and bike to school, something they hopefully would continue through high school. Parents also need to feel comfortable allowing their children to walk or bike to school. Many students walking to and from school will have to cross Lexington Street. A speed limit of 45 mph is not consistent with safe crossing by pedestrians, yet Lexington Street has the opportunity to see more students walking and bicycling to school in the years to come: a proposed new K-8 public school may occupy the site of the existing high school. With additional vulnerable road users in this area, it is important to ensure that anyone driving on Lexington Street is doing it at a safe speed, and that safe and comfortable facilities are provided for vulnerable users. The City should consider expansion of the 20mph School Zone on Lexington Street to include all three schools, or through creating a 20 mph “Safety Zone,” which was established in 2016 under Mass General Law Chapter 90, Section 18B.

2. Existing bicycle facilities will be converted to shared-use lanes in order to accommodate turn lanes at the proposed intersections. This is not in accordance with the TMP recommended cross section for the Lexington Street Corridor, which included sidewalks and a consistent 6’ bike lane throughout the corridor on each side of Lexington Street, and has been implemented. Additionally, the TMP recommends any redesigns consult up-to-date design guidance. It is unlikely any guidance would pair an increased speed limit with the removal of bike lanes.

3. Lack of non-Lexington Street connections to the site. If the high school is to be constructed at the Stigmatine site, paths should be constructed connecting it with residential neighborhoods to its north, south and west. These neighborhoods are within easy walking and bicycling distance of the Stigmatine property, as long as connections are established, with an opportunity significantly to reduce traffic to the site from Lexington Street and demand for parking. The initial plans show only access via Lexington Street, but supplemental filings include letters from the Police and Fire Department that reference potential emergency access routes to Lincoln Street and Jericho Hill Road that could be used by people walking or bicycling. These should be investigated further, as they could be an important option for encouraging walking and bicycling to the site, while excluding cut-through motor traffic. 

Potential solutions at the Stigmatine site are restricted by the additional problems that will be created on Lexington Street. We are hopeful that the city can consider more ways to use this project to back up the vision put forth in the TMP: “In addition to implementing physical improvements, easing today’s congestion and minimizing the congestion encountered in the future will require mode shift, smart land use planning, and mitigation on the state, City and private partnership level.” 

We encourage the MEPA office to take a deeper look at this project: the impacts are serious enough that it may require an environmental impact report.

Thank you, 

Brendan Kearney, Deputy Director, WalkBoston
Galen Mook, Executive Director, MassBike