Category: Comment Letter

Comments on L Street Power Station Redevelopment South Boston ENF/Expanded PNF

July 7, 2017

Secretary of Energy and Environmental Affairs Matthew A. Beaton
Executive Office of Energy and Environmental Affairs (EEA)
Attn: MEPA Office, Alex Strysky
100 Cambridge Street, Suite 900
Boston MA 02114

Brian Golden, Director
Boston Planning and Development Agency
Boston City Hall
Boston, MA 02201

Re: EEA No. 15692, L Street Power Station Redevelopment, South Boston
ENF/Expanded PNF

Dear Secretary Beaton and Director Golden:

WalkBoston is pleased to see the proposal for a mixed use development of the large South Boston waterfront site that will include the re-use of the historically and architecturally interesting L Street Power Station. Putting this portion of the City back into a productive use that invites public access is a positive change for the City and for South Boston.

The overall site design will help to integrate this large parcel into the neighborhood, and create new opportunities for people to walk from East 1st Street to the waterfront and help to link the residential portions of South Boston into the site which was long cut off from the community by fences and other obstructions. The partial extension of the local street network onto the site and between and around new buildings proposed for the site seems appropriate in scale. With sidewalks that are sufficiently wide and landscaped, both community residents and people living on-site will be served by the new connections.

Our comments below are focused on questions that we hope the proponent will respond to in subsequent filings about the project.

1. Waterside Pedestrian and Open Space Environment
We understand that the new dedicated harborside freight corridor that will connect Summer Street to Massport’s Conley Terminal and remove heavy truck traffic from East 1st Street will provide very important, and long-desired improvements to the South Boston neighborhood. But this shift will also present challenges; the new harborside route will place an access barrier and significant truck traffic (with its accompanying noise and air pollution) between the development site’s primary open space and the harbor.
We urge the developer to consider creative ways to mitigate the truck route’s impact on the
open space. This could include grade changes that place the open space higher than the truck route (Figure 3.5b may hint at this); landscaping that both masks and frames views,
soundscapes to mask truck noise, and the addition of viewing platforms that allow open space users to gain unimpeded views of the water. There may also be ways to capitalize on the site’s industrial past and on-going use through interpretive elements. WalkBoston is concerned that without such special treatment the open space will not be very attractive to the public.
If possible, the proponent might also explore with Massport whether it would be possible to
schedule truck traffic so that is interferes less with daytime and weekend use of the open space.

2. Encouragement of walking and walking-transit trips
At the direction of the City, the proponent has used South Boston adjusted trip generation rates to develop trip tables for walking/biking, transit and vehicles. However, the site is at a
significant distance from other land uses that would seem to justify such significant numbers of walking trips, and to suffer from overused bus lines and significant distances to the Red and Silver Lines. Figure 5-1 illustrate the 5 and 10-minute walking zones, neither of which include a great many retail, job and civic land uses.
We urge the proponent to develop mitigation measures to make the development a more
realistically mixed mode project. These could include such things as: subsidies to the MBTA to provide more frequent bus service, or creation or partnering with other South Boston
developments to provide shuttle services to the Silver and/or Red Lines.

3. Bicycle facilities
The proponent mentions that Boston has flagged both East 1st Street and Summer Street for
protected bicycle facilities, however Figure 3.5a shows an on-street bike lane.
We urge the proponent to work with the City, and perhaps provide funding for, separated
bicycle facilities on both East 1st Street and Summer Street. The distance of the site from transit and a mix of retail, job and civic facilities will make bicycling a more likely mode of off-site trips than walking.

We look forward to working with the City and Redgate as the project plans are developed in greater detail.

Sincerely,

Wendy Landman
Executive Director

Cc Ralph Cox, Greg Bialecki, Megha Vadula, Redgate
Elizabeth Grob, VHB

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Comments on Beacon Street Redesign

June 30, 2017

Gina Fiandaca, Commissioner
Boston Transportation Department
1 City Hall Sq., Suite 721
Boston, MA 02201

Re: Beacon Street Redesign

Dear Commissioner Fiandaca,

WalkBoston strongly supports the re-design of Beacon Street to slow vehicular traffic and improve pedestrian safety. As the neighborhood expressed at the Public Meeting on June 12, 2017, the narrowing of the street will reduce the numerous traffic crashes, including pedestrian fatalities in the past several years. Moreover, the improvements will be implemented in the near term.

WalkBoston Supports Alternative 1, Option A
WalkBoston supports Alternative 1, the Preferred Design, which the neighborhood endorsed at the Public Meeting. This design calls for the removal of a travel lane, two one-way travel lanes, a bicycle lane and parking on both sides of the street. The buffer between the bike and parking lanes will not only increase bicyclist safety, but also make cycling more comfortable.

Alternative 1 has two options at the intersection of Massachusetts Avenue/Beacon Street. Of the two options, WalkBoston strongly supports Option A, which will retain the protected bike lane to Massachusetts Avenue and also preserve parking. Option B mixes bicycles and vehicles in order to provide a right hand turn for motorists. We believe the vehicle volumes do not necessitate this vehicular right turn and will be very dangerous for cyclists.

Traffic Signals Should Be Automatic with LPIs
Traffic signals in this downtown neighborhood should be automatic (no pushbuttons) and on throughout the 24-hour period (except when signals are in flashing mode). WalkBoston also understands that leading pedestrian intervals (LPIs) will be incorporated at all signalized locations. Finally, WalkBoston has noted that throughout the City, the concurrent green is on for a relatively short period of time. We request that the concurrent WALK remain throughout the concurrent vehicle green.

Increase Crossing Safety by Establishing No Right Turn on Red and Installing Tactical Medians
The City has installed No Right Turn on Red (NTOR) at intersections throughout the City where there are large volumes of pedestrians. We are pleased to see that the City is calling for NTOR at all intersections in this re-‐designed section of Beacon Street.

Medians or refuge Islands provide safety at intersections for crossing pedestrians. WalkBoston requests that the City consider temporary medians through paint and flex posts at all crossings.

Re-Assess Visitor and Resident Parking
At the Community Meeting many attendees asked that the City reassess the assigned parking, which was established in the 1980s. The City expressed interest in working with the neighborhood to assess how curb space is currently used, and how a balance can be found to meet current resident, visitor, and delivery needs.

In summary, WalkBoston strongly supports the Alternative 1, Option A Design and looks forward to working with the City to implement and evaluate the design. Thank you for consideration of our comments.

Sincerely,

Dorothea Hass
Sr. Project Manager

Letter to Mayor Walsh-Massachusetts Zero Coalition

May 17, 2017

Mayor Martin Walsh
City Hall
Boston, MA 02201

Re: Vision Zero

Dear Mayor Walsh:

When you announced the Vision Zero Action Plan in December 2015, we were proud to be your constituents. You demonstrated leadership when you stated:

“We know how to build safer streets. We know how to protect our most vulnerable road users, who are suffering disproportionately because of speeding traffic and distracted drivers. With this Action Plan, I am saying it’s time to act. It’s time to commit to eliminating fatal and serious traffic crashes from our daily experience.”

Which is why we were dismayed by your comments Wednesday afternoon on WGBH Radio.

On behalf of the Massachusetts Vision Zero Coalition we invite you to work with us to fully fund and implement Vision Zero in Boston. We ask that you join us on Friday morning at 8 AM for a moment of silence for victims of traffic violence on City Hall Plaza. On behalf of those victims, we also ask that you apologize for the comments you made on the air.

Our streets are in crisis.

In 2016, fifteen people died while walking on Boston’s streets; a record-‐breaking high for pedestrian fatalities. We are on track to see even higher numbers in 2017. Crashes overall are up. On average, at least two to three people walking are hit in a crash that results in an EMT call every day.

We need action from you and your administration, not victim-‐blaming. When you said on the air, “Pedestrians need to put their head up when they’re walking down the street, take your headphones off … you’ve got to understand, cars are going to hit you,” you were reiterating a narrative that doesn’t stand up to the crash data your administration collects.

Most of the people killed while walking were children or older adults. In 2016, of the 10 pedestrian victims whose ages we know, four were older than 60 and two were younger than 3 years old.

This Coalition and your constituents look to you for action.

A week ago, hundreds of people attended the City Council’s FY18 budget hearing for the Boston Transportation Department to call for increased resources to make streets safer for everyone. After 2 the hours of questions from the council and public testimony, it’s clear from all sides -‐ Boston is falling behind.

In your interview with WGBH, you said that the city is doing “everything we can,” but we know Boston is being eclipsed by peer cities in both resources and implementation. The City of New York spends about $20 per person on Vision Zero annually, and San Francisco spends $75 per person annually. Both cities have seen declines in overall traffic fatalities despite a troubling rise in fatal crashes nationwide. Boston is spending less than $5 per person, this is not enough.

Forty-seven neighborhood groups applied for Neighborhood Slow Streets, a signature program of Boston’s Vision Zero initiative. Your FY18 budget recommendation only provides resources to implement two to three in the coming year.

At the current rate of implementation it will take more than 20 years to respond to just the first round of applications. Safety should not be a privilege afforded to only some Boston neighborhoods.

We recognize that there are many competing budget priorities and that rapid change on our streets will cost money. This year we suggest drawing on the parking meter fund. In the long term, we are here to work with you to diversify and increase the revenue streams available for transportation, for example through increased parking revenues.

Simply put, the Massachusetts Vision Zero Coalition, and the thousands of people we represent, feel strongly that the 2018 transportation budget as currently proposed is insufficient to reduce the number of fatalities and serious crashes on our streets.

We hope you will take this opportunity to recommit to leading Boston as a Vision Zero city.

Thank You,

Vision Zero Coalition

CC: Boston City Council
Chief of Streets Chris Osgood
Transportation Commissioner Gina Fiandaca
Chief of Staff Dan Koh
Press
Public

Comments on Jamaica Pond: Parkman and Perkins Access Enhancement

May 8, 2017

Commissioner Leo Roy
Department of Conservation and Recreation
Office of Public Outreach
251 Causeway Street, Suite 600
Boston, MA 02114

Re: Jamaica Pond: Parkman and Perkins Access Enhancements

Dear Commissioner Roy:

WalkBoston is very pleased that Department of Conservation and Recreation (DCR) is designing safe pedestrian access to Jamaica Pond from adjacent developments and the larger communities of Brookline and Boston.

WalkBoston Supports the Proposed Signalized Crossings
As we stated at the Public Hearing on April 11, 2017 WalkBoston strongly supports a signalized crossing at Cabot Estates where residents have for years been pressing for a safe crossing to the pond.

We are pleased that the crossing at Parkman/Perkins will also be signalized and we echo what many others at the hearing said that there is no need for a slip lane at this intersection, and we request that the pork chop be eliminated. Typically, cars turn quickly at slip lanes, ignoring pedestrians.

WalkBoston Recommendations

Shorten traffic signal cycles to 70 seconds
Traffic signal cycle length will be 110 seconds according to the public presentation speakers. Pedestrians will not wait up to two minutes to cross a roadway. With this fact in mind, WalkBoston as well as other advocates such as Livable Streets is asking the City of Boston and state agencies such as DCR to develop shorter signal cycles of no more than 70 seconds. We are assuming from the presentation that the traffic signals are exclusive, but we would like to have the plans so we can review them.
Undertake additional traffic calming measures
Traffic often speeds on the Pond’s perimeter because there are few intersection streets. To slow traffic WalkBoston recommends lane widths be reduced from 11’ to 10’.
Utilize white reflectorized thermoplastic crosswalk markings of a ladder design.
The state standard of two parallel lines does not provide enough visual warning to motorists.
Enhance pedestrian access to the west side of Jamaica Pond.
The optional path is a pedestrian desire line and if constructed would addresses drainage and erosion.

WalkBoston is very pleased that these long-awaited access improvements are coming to fruition. We look forward to working with DCR on this and other vital pedestrian safety access projects throughout Greater Boston.

Sincerely,

Wendy Landman Dorothea Hass
Executive Director Sr. Project Manager

Comments on the DEIR/DPIR for the Back Bay/South End Gateway Project

April 18, 2017

Matthew Beaton, Secretary
Executive Office of Energy and Environmental Affairs (EEA)
ATTN: Alex Strysky, MEPA Office 100 Cambridge Street, Suite 900
Boston MA 02114

Brian Golden, Director
Boston Planning and Development Agency
ATTN: Michael Rooney
One City Hall Square
Boston, MA 02201-‐1007

RE: Comments on the DEIR/DPIR for the Back Bay/South End Gateway Project
MEPA: #15502

Dear Sirs:

WalkBoston has reviewed the DEIR/DPIR for Back Bay/South End Gateway Project. We are concerned about this project because of its impacts on rail and bus transportation, walking and biking. With the latest submission of plans for the project, we continue to see serious issues with pedestrian access into, through and around the site. These are described below.

Inappropriate relocation of the layover site for the Route 39 bus
The proposal states that the layover site for the Route 39 bus will be located “off-‐site.” Back Bay Station is one end of this bus route, which is one of the busiest in the MBTA system, serving Back Bay, the Fenway and Jamaica Plain. Buses congregate here and wait until schedules require them to return to the main route.The proposal for Route 39 is to remove it entirely from the streets directly connected to Back Bay Station, and to truncate the route before it connects with the Orange Line or the commuter rail/Amtrak services. Reducing the convenience of connections between Route 39 and other portions of the MBTA system will result in negative impacts on transit riders that should be avoided. We urge the City and MEPA to require the proponent to bring Route 39 back to the station. A possible layover site is Trinity Place (between Stuart and St. James Streets). The re-‐routing of the 39 bus route to this layover location could provide a reasonable drop-‐off and pick-‐up solution on Stuart Street, which will have direct pedestrian access in Back Bay Station for bus riders.
Sidewalks that surround the site
Sidewalks along the Dartmouth Street side of the project, where foot traffic is already heavy and likely to increase due to the new development, have been widened to a minimum of 13 feet, as shown in Fig, 3.8b. Sidewalks along Stuart Street are to be a minimum of 11 feet, as shown in Fig, 3.8c, perhaps reflecting the proponent’s projection of likely foot traffic on this side of the site. Along Clarendon Street, sidewalks range from 9 to 15 feet, as shown in Fig. 3.8d; it is not entirely clear if the 9’ width is a result of the footprint of the proposed residential building.Sidewalks may not be sufficiently wide, especially if street trees, planters or bicycle parking are also accommodated in the width otherwise available for pedestrians.A large public plaza is proposed at the Clarendon Street intersection to replace the existing forecourt to the east entrance to the station. Here sidewalks are very wide and the plaza offers generous open space. Much of this plaza appears to be for passive use to people walking by, although there is a retail space provided in one corner that, if used as a restaurant, might result in tables on the outdoor plaza.We are pleased to see that the principal entrance to Back Bay Station on Dartmouth Street is enhanced by the addition of major new entrances framed by the arch and a design that focuses on providing continuity of the sidewalk and interior surfaces to unite them and welcome users. An enlarged Dartmouth Street crosswalk that is 60 feet wide along the site’s frontage will be centered on the new entrance. Taxi zones are provided both north and south of the main entrance.We are pleased that the proponents have increased sidewalk widths by comparison to the earlier proposals.
Movement on sidewalks around the perimeter of the project
The project site is in a pedestrian-friendly portion of the city. There are more people walking along and crossing the perimeter streets than there are drivers using these same streets. For example, looking at the existing condition pedestrian volumes counted between 8:00 and 9:00 AM in 2016 in Figure 4.6a, we note that there are 2,253 people crossing Dartmouth in front of Back Bay Station, 1,264 walkers crossing on the east walk of the Stuart Street/Dartmouth Street intersection, 1,098 pedestrians crossing Stuart Street at Trinity Place, and 1,646 pedestrians crossing Stuart Street at Clarendon Street. A total of 1,071 pedestrians crossed the garage driveway on Clarendon Street during this period.Meanwhile, in the same period, Dartmouth Street handles 486 cars northbound and 703 cars southbound. Stuart Street handled 784-1,057 vehicles in this period and Clarendon Street handled 503-625 vehicles.Although there are 15 different projections of vehicular traffic under alternative futures, there are no projections at all of pedestrian traffic. There are, however, projections of pedestrian level of service at selected intersections. See Table 4.12.3 page 4-126. The accompanying text states that PLOS doesn’t change between Existing, No-build and Build Conditions because walk times and cycle lengths will not change. Is this a valid conclusion without he benefit of projecting future pedestrian volumes?Based on the data that was provided, it appears that there are about three times as many pedestrians as there are cars during peak hours.
Movement across the sidewalk – Dartmouth Street
In order to improve access to the proposed parking garage, the proponent has proposed changing Turnpike access patterns and partially shifted vehicle access and egress away from Stuart and Clarendon Streets and provided a new exit onto Dartmouth Street. These changes directly affect pedestrian safety at the principal pedestrian access to Back Bay Station.As shown on the proponent’s plans, the proposed vehicular exit from the garage is in an inappropriate location on Dartmouth Street. The exit ramp will pose a hazard for pedestrians on this portion of Dartmouth Street, where thousands of people (see numbers in Section 3 above) are walking during peak hours. This location is an especially busy and important place for pedestrians walking to, through and making connections to transit.Shifting the location of Turnpike access so significantly by removing a major access point to the westbound Turnpike in the midst of Back Bay and requiring all drivers to use alternative access on Huntington Avenue does not make sense for this part of the City. This does not seem an appropriate choice in the context of Boston’s adoption of Vision Zero and the City’s declaration in GoBoston 2030 that Boston will “prioritize the movement of people over cars.”
WalkBoston does not believe that it is in the interest of public safety and convenience to shift existing vehicular access so that it results in a garage exit ramp in a congested pedestrian zone. An alternative to this garage exit ramp should be developed.
Movement across the sidewalk -Clarendon Street
On the Clarendon Street side of the property, there are multiple garage entrances and exits as there are today, and the sidewalk needs very careful treatment to protect pedestrians. The proposal to add a bulb out to shorten the Clarendon mid-‐block pedestrian crossing is a good idea. As noted above, WalkBoston believes that Clarendon Street is a better location for garage and Turnpike access than the proposed Dartmouth Street garage exit and circuitous Turnpike access.The new plaza on the Clarendon Street side of the property has been designed with a drop-‐off lane that doubles as a route for delivery and service vehicles for the residential and retail occupants of the structure. The drop-‐off lane occupies what appears to be about 40% of the plaza, and raises the question of whether it needs to be this size.If the space is being used primarily for vehicular needs – drop-offs, taxis, deliveries, service, and potential bus storage – that colors the manner that the design might take for the plaza. If, on the other hand, some of the vehicular needs could be transferred to the street – perhaps with some widening to accommodate the intended use. Getting rid of the drop-off lane would considerably improve the potential for this plaza to be genuinely pedestrian-friendly, and open it to other retail uses that would enhance the productivity and attractiveness of this end of the property.
The station area concourse
We are gratified that the proponent enlarged the proposed waiting area, rather than transforming it into a retail facility. However, we continue to be concerned about the redesign 4 of the concourses to narrower passageways lined by many retail facilities. New retail activity will increase in the number of pedestrians to accommodate on the narrowed concourses. The relocation of the commuter rail and Amtrak ticket offices to a new location at a substantial distance from either the waiting area or the entrances to the rail platforms seems ill-‐advised. The proposed new location is deeper within the station area, much closer to the east entrances than to the likely more important west entrances. It is also indistinguishable from adjacent retail stalls that may or may not have relevance for rail travelers. The proposed layout is occurring during a period of reduction in the number of small retail businesses in many locations, including central Boston and the Back Bay. Active ticket offices in a central location may be more important to bolster other retail outlets, and benefit the management and rental of retail stalls throughout the station area.
Construction on the rail station platforms
The proposal calls for use of the station platforms for supports for the new high-‐rise building being built in the Station East portion of the project. These new obstructions narrow the platforms for waiting or alighting passengers and add complexity in an environment where moving to or from access points is already complicated. This is true of both the Orange line platform, serving both directions for subway passengers and the southernmost railway platform serving commuter rail passengers to and from the south and southwest, including Providence, New York, Washington and the entire eastern seaboard.Using the existing rail platforms for construction of these supports will obstruct passenger traffic during construction as well as after completion. Designs should be carefully integrated with existing obstructions such as columns to minimize interference with passenger traffic flow.

We are very concerned about the changes proposed for the station, the bus layover facility, the vehicle circulation, sidewalks and interior passageways. We would 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 Bob Sloane
Executive Director Senior Project Manager

Cc City Council President Michelle Wu
City Councilor Josh Zakim
Ellis South End Neighborhood Association
Bay Village Neighborhood Association
Neighborhood Association of Back Bay