November 30, 2018­­­

Stephanie Pollack
Secretary of Transportation
State Transportation Building
10 Park Plaza
Boston, MA 02116

Matthew Beaton
Secretary of Energy and Environmental Affairs
Saltonstall Building, 100 Cambridge St #900
Boston, MA 02114

Re: Comments on the findings of the Independent Review Team for the Throat portion of the I-90 Allston Interchange Project

Dear Secretary Pollack and Secretary Beaton:

As advocates for people walking, running, meandering and biking on the paths along the Charles River, we have reviewed the two documents prepared by the Independent Review Team (IRT) on the I-90 Throat area of the I-90 Allston Interchange Project. We have followed the IRT work closely, and appreciate the Team’s ability to deal with time constraints and the complexities of the project while including direct contacts with members of the I-90 Task Force.

The original options for the Throat area have been successfully updated and improved by the IRT. We recommend that they be discarded from further consideration. Whether those options are discarded or not, issues remain that must be resolved prior to MassDOT’s selection of a preferred alternative to carry into the Final Environmental Impact Report (FEIR).

Issues to resolve before choosing a preferred alternative

A. Good pedestrian and bicycle access for the heavily used Paul Dudley White (PDW) path on the Boston side of the river must be maintained throughout the multi-year construction period. The reports state that a replacement is ‘to be determined.’ Here are some possibilities:

1. A temporary boardwalk in the river.
   • A boardwalk in the Throat would be short – roughly 1800’ long.
   • A boardwalk could maintain access for bikes and pedestrians close to the existing route of the PDW path.
   • Temporary paths can be used in the wider segments of the riverfront at each end of the Throat.
   • The design of a temporary boardwalk would need to be attentive to safety. Wooden boardwalks are often slippery and difficult for users.
2. Limited fill in the river to support temporary paths.
   • Fill would be relatively minor – a narrow strip roughly 1800’ long.
   • Fill would be coordinated with the mandated ecological improvements to the river’s edge.
3. Alternatives that detour all walking and biking to the Cambridge side of the river are not adequate. However, improvements must be made to encourage some shifts to the Cambridge path.
   • For walkers and bicyclists coming from the Cambridge path, connections on the Boston side of the river between the Mass Ave Bridge and the riverfront use a steep and narrow ramp that connects only to the downstream sidewalk and bike lane. It is not possible to safely cross Mass Ave at the entry to the ramp.
   • The walking and biking connections across the BU Bridge in Cambridge are difficult, and the path on the downstream side of the bridge is inadequate and unsafe for all users.
4. A significant wayfinding system is needed to provide safe temporary routings.

B. All options must include ecological restoration of the banks of the river, between the BU and the River Street Bridges, to repair the neglected, unattractive, degraded and eroded bank. Ecological restoration would:

1. Provide additional parkland, integrated with it and expanding upon the areas in the current options.
2. Protect the river bank from further degradation by stabilizing the eroded edge.
3. Restore aquatic habitat for the fish run for alewives, blueback herring and American shad, as they return to the river each year to spawn.
4. Reduce stormwater runoff discharging to the river via overland flows and outfalls, including the 13 outfalls along Soldiers Field Road in the Throat Area.
5. Provide flood resilience, control and storage capacity for precipitation-based inland flooding.
6. Provide a solid footing for construction of improvements at the river’s edge, including a new PDW path or a new SFR.
7. Develop landscape strategies and designs that provide Section 4(f) mitigation.
8. Remove invasive species, dead trees and replant with native vegetation.
9. Help plan for the riverfront parkland, a water-dependent use under Chapter 91.
10. Help meet historic requirements for the Charles River Basin Historic District included in Section 106 of the National Historic Preservation Act and Massachusetts Historical Commission review.
11. Comply with the Article 97 no net loss policy that requires replacement of parkland that is to be taken by the Project.

C. Mitigation for the impacts of each option must be provided prior to MassDOT’s selection of a preferred alternative. The full implications of each option cannot be known without exploration of how the impacts of each are to be treated.
In addition, the provisions for treating impacts will vary by option, with some being more attractive than others. Showing what mitigation can do to each option will help with the process of making and justifying a choice:

1. Physical improvements intended as mitigation for impacts from highway construction must be provided close to the site of the impacts.
   • The IRT documents suggest that the addition of parkland 1,000 feet upriver will mitigate the loss of historic parkland in the Throat. Many Task Force members disagree with that conclusion.
   • Replacing parkland within the Throat area is a valuable and necessary element of mitigation to replace parkland taken by highway uses.

2. Mitigation can make some options more attractive than others.
   • For example, if the riverbank restoration requires the addition of fill to the river edge, that fill can serve as an extension to the narrow strip of riverfront parkland and integrate with it either as landscaped edging or as a grassy area for exploration, sitting, walking and picnicking.
   • A wider park is a major element of mitigation for localized impacts from highway construction.
3. Mitigation for each option is required by the federal legislation that governs the use of Section 4F (for parks) and Section 106 (for historic resources).
   • It seems likely that the analysis required by Section 4F and Section 106 will result in an exploration of alternatives to discern the least harmful alterations to the 20^th century parkway (a highway bounded by two landscaped strips of land) that this project will be removing.
   • It is important to integrate the work done by Sasaki on pathways along the riverbank to meet the “all possible planning” requirements of Section 4F.

Choosing a preferred alternative

The following comments and questions are offered to help MassDOT select a preferred alternative for the Throat:

A. The Hybrid Variant Option

We are drawn to this option because it is more respectful of the need for improvements along the river’s edge than the other options, providing space for riverbank restoration, dual paths, and landscaping that will enhance the riparian environment and improve the quality of the park for all park users and non-motorized commuters along the river. However, the IRT report has developed the option only in brief outline form. The basic elements of the proposed option must be retained as they form the basis for its attractions.

1. The dimensions of the riverfront park, as shown by the Independent Review Team on page 219 of the report, must be retained to provide an adequate park width throughout the Throat area.
   • The total dimension of the riverfront park is 42’ between the edge of the river and the wall of the Westbound Turnpike boat section.
     • The goal of two separated paths – one 10’ wide for bicyclists and one 10’ wide for walkers/runners – have been included.
     • A 16’ landscaped buffer is between the edge of the bicycle path and wall of the Westbound Turnpike boat section. This portion may also be used to fulfill many of the stormwater and resiliency goals of the project.
     • A 2’ buffer lies between the river’s edge and the walking path and a 4’ buffer between the bicycle and walking paths.

2. These dimensions are in danger of being diminished as MassDOT and FHWA resolve questions about adding more shoulder space to the Turnpike.
   • An additional 2’ for a breakdown lane on right side of both WB and EB cross-sections of the Turnpike would take 4’ away from the 16’ landscaped buffer.
   • An additional 2’ for a breakdown lane on both sides of the WB and EB cross-sections of the Turnpike would take a total of 8’ away from the 16’ landscaped buffer.
   • Other roadway dimension issues may still emerge – all widenings of the highway elements of the project will diminish the 16’ landscaped buffer.

3. If more space is required for highway elements this must be provided without diminishing parkland.
   • Make use of additional land on the south side of the project area. BU has been very helpful on the development of solutions that do not include a Turnpike viaduct and the use of BU property appears to be an integral part of both the at grade and the Hybrid options. The IRT report highlights other opportunities to use BU property. See “Maximum Potential Encroachment on Boston University Property” (Figure 6.1, p. 190 IRT Report).
   • Restoring and enlarging the degraded and unstable river bank, which could add some land that would serve as a landscaped buffer between the paths and the water sheet of the river.
   • The possibility of placing Soldiers Field Road above the eastbound, as opposed to the westbound, lanes of the Turnpike is intriguing and opens the possibility that the park-like setting might be significantly widened and potentially enhanced. We look forward to analysis of the possibility.

4. Footbridges to connect the riverfront park and its walking and cycling paths with the community must be provided as an integral part of the project over the Turnpike, Soldiers Field Road and the rail lines.
   • Access for non-motorized travelers between the community and the river is severely limited. The existing footbridge over Storrow Drive just behind the chapel on BU’s campus is not ADA compliant and does not include any bicycle access. The next access is Massachusetts Avenue, a half mile east, or the proposed New Cambridge Street a half mile west. None of these locations can directly serve all users or people coming on foot or by bicycle from Packard’s Corner or Brookline.
   • A bicycle and pedestrian bridge has been proposed for a location at the end of Agganis Way, where it currently overlooks the rail lines. Agganis Way already connects to Commonwealth Avenue and a link to the proposed West Station could be readily made from that location and would serve BU students, South Allston and Allston Center, the northernmost neighborhoods of Brookline, bordering Commonwealth Avenue for nearly a mile.
   • An additional bicycle and pedestrian bridge connection has been proposed to connect the riverfront to Commonwealth Avenue near the BU Bridge. An exact location for this proposal has not been defined, but it would serve the area’s many walkers and bicyclists who are currently cut off from the river’s path network.

5. The Hybrid Variant includes the reconstruction of the Little Grand Junction railroad bridge as an integral portion of the project, which would allow the straightening of the riverside Paul Dudley White Path, and removal of the boardwalk that intrudes into the river under the BU Bridge where it complicates and impacts boating activities.
   • This bridge is not a contributing element to the Charles River Basin Historic District, as claimed in the DEIR, according to DCR.
   • Elimination of the boardwalk under the BU Bridge, made possible by rebuilding this bridge, is a high priority among boaters.

6. A method of attenuating sound must be included to dampen noise impacts from the Westbound Mass Turnpike on the surroundings including:
   • The IRT addendum report describes the possibility of a noise wall between the boat section and the paths in the riverfront parks, which diminishes the width of the park.
   • Other options must be explored.

B. The At-Grade Option

The At-Grade option remains a viable possibility and must be retained as an important alternative to continue analyzing because of the superior profiles the fully at grade options achieve in the essential Aggasis to Charles River Basin pedestrian and bicycle connection, in comparison with the highway profile required to clear the elevated Soldiers Field Road element of the Hybrid Variant. We have reviewed this option in prior comments submitted about the DEIR.

1. The At-Grade option removes the viaduct and creates a more livable environment for the BU West Campus and the surrounding neighborhoods. A thorough investigation of ways to make the option more acceptable would have included adding more land from the BU campus to make the right-of-way wider and remove the option from its intrusion onto the river bank, where construction permits become difficult.
2. The At-Grade option described in the IRT report is difficult to support. The paths and parkland are much too narrow. We suggested frequently that the Paul Dudley White paths could be constructed either on a boardwalk or on limited fill at the river’s edge. These options have not been explored, yet we think they would have been successful in meeting goals related to riverbank restoration, water quality, parkland and the riverfront paths. We suggest that they are still worth looking at to solve problems related to the river’s edge.
3. Extensive design and environmental studies that describe the visual, accessibility, noise and air quality conditions for walkers and bicyclists are needed for the option that includes walkways suspended or cantilevered above Soldiers Field Road. The option remains interesting because it offers a high-level connection to potential pedestrian and bicycle bridges to Commonwealth Avenue.

C. The Highway Viaduct (HV) Option

We have reviewed this option in prior comments submitted for the DEIR. In view of the numerous objections to this option, we do not think that any Turnpike viaduct replacement option should be carried forward. These objections include:

1. It is a barrier to an essential pedestrian and bicycle connection between Commonwealth Avenue and the river paths, as needed to provide a complete walking and biking network and as requested by the surrounding neighborhoods of Allston and Brookline.
2. It cannot remove the horizontal curve on the Turnpike adjacent to the Commonwealth Avenue Bridge.
3. During construction it cannot maintain two track service on the Worcester commuter rail line, thus negatively impacting riders from the Western corridor, and forcing spillover traffic onto local streets.
4. The new HV option, at the tightest section of the Throat, has very difficult construction design issues where the Grand Junction is rising, because limited space is available for the Turnpike to hover over Soldiers Field Road.
5. Boston University has generously offered space for widening the Throat for all purposes, but not if the Viaduct is to be rebuilt.
6. The Houghton Spur, an early reason for rebuilding the viaduct, is to be abandoned.
7. It does not include replacement of the Grand Junction bridge, a critical component of rail service into Cambridge, and would, if replaced, allow straightening and widening the Paul Dudley White Path and removing the boardwalk under the BU Bridge.

We believe that the next phase of comparison of plans should compare two options:

1. A Hybrid combined with a Sasaki plan to make the necessary further improvements.
2. A fully At-Grade combined with a Sasaki plan to achieve the necessary further improvements.
   This would fulfill the commitment by the Secretary to make each plan as good as it can be before making a final decision on which plan, including its necessary mitigation, should be included in the FEIR.

We have worked long and hard together on this project during the past 4 1/2 years. Now that we are getting closer to the decision among the options, we hope that MassDOT’s choices will reflect the opinions of the Task Force and the many hundreds of comments that have been shared by the public and elected officials.

Thank you for your attention to our concerns.

Sincerely,

Wendy Landman, Executive Director, WalkBoston
Galen Mook, Executive Director, MassBike
Laura Jasinski, Executive Director, Charles River Conservancy
Stacey Thompson, Executive Director, Livable Streets
Becca Wolfson, Executive Director, Boston Cyclists Union
Josh Fairchild, President, TransitMatters
Emma Walters, Executive Director, Allston Village Main Streets
Anthony D’Isidoro, President, Allston Civic Association
Jason Desrosier, Mgr, Community Building, Allston-Brighton Community Development Corporation

I-90 Task Force Members and Allston Residents

Jessica Robertson, Harry Mattison, Paola Ferrer