Category: Comment Letter

Comments on Sullivan Square/Rutherford Avenue Design Project 3/31/17

March 31, 2017

Deputy Commissioner James Gillooly
Boston Transportation Department, 7th floor
1 City Hall Square
Boston, MA 02201

Re: Sullivan Square/Rutherford Avenue Design Project (SS/RA Design Project)

Dear Deputy Commissioner Gillooly,

WalkBoston has been engaged in and following the planning and design of Sullivan Square/Rutherford Ave. for many years. We have consistently and persistently noted that the redesign of the streets and roadways for this part of Boston should reflect what the people of Charlestown, Somerville and Everett deserve as a hub for walking and transit, and should create opportunities for the redevelopment of what has long been a neglected, dysfunctional and unsafe auto-centric wasteland.

We strongly believe that an at-grade street system with opportunities for at-grade redevelopment of parcels (that do not require air rights or decks) presents the greatest opportunity to create a sense of place, answer the long-term transportation needs of this dense urban location, provide for safe mobility for all street users and allow for climate resilient designs.

Over the last decade transportation planners and engineers across the United States have come to understand that adding roadway capacity in multi-‐modal, dense urban environments simply means that more people will drive their cars and fill up the roads. We’ve learned from years of mistakes that building large roads that look and feel like highways through communities encourages high speed traffic, attracts more vehicular traffic and traffic congestion, cuts off parts of neighborhoods.

The roadway, transit and sidewalk network at the heart of the Boston metro area should meet the multi-‐modal needs appropriate to the land uses and neighborhoods that surround the roadway network. With I-‐93 directly adjacent to Sullivan Square and Rutherford Avenue, this part of the region already houses a regional road system that serves longer distance travelers.

Slowing traffic down on Rutherford Ave and keeping regional traffic off of local roads will better protect Main St, Bunker Hill St and Medford St. the local streets are 1-lane in each direction, with parking on both sides, and a number of traffic lights. It is counter-‐intuitive to think that anyone might navigate off of Rutherford Ave and onto these streets in order to go faster. Waze and other similar tech services will always show drivers the fastest routes – if Rutherford Ave is faster than I-93, Waze will route even more drivers through Charlestown.

The City’s new plan, Imagine Boston 2030 states the case that WalkBoston is making here: Sullivan Square has the potential to be “a walkable job and housing center with access to quality transit,” and goes on to note that this would require that “strategic infrastructure investment, potentially including open space, would be needed to address congestion and flooding vulnerability in Sullivan Square and nearby areas.”

The many comments that the City will receive about the project will provide both detailed technical and moving personal information about the project and its impacts on the Charlestown community. To put the project in a larger context, WalkBoston has reviewed the City’s plans for transportation (GoBoston 2030), resilience (Climate Ready Boston), and long range planning (Imagine Boston 2030). The table below puts the SS/RA in the context of the goals that these plans set for the City. We believe that the goals clearly point to the surface option as the right choice for the project.

If the City carries both options to further levels of refinement, we ask that several technical assessments be included:

1. Estimated number and severity of total traffic crashes for the entire roadway system from the Mystic River to Austin Street for each mode: pedestrians, bicycles, transit users and vehicles. We believe that the crash statistics cited on page 29 of the 2/28/17 slide show do not represent an accurate picture of the impacts of the project designs on all crashes. (see note below)

2. Measure the total land area devoted to roadway surface and “unbuildable” air rights parcels in each alternative.

3. Measure the longest distances that are not traversable by pedestrians between intersections: (1) from the bank of the Mystic River at Alford Street to the first pedestrian crossing, (2) from northern D Street south toward Baldwin Street), (3) north from Austin Street.

4. Estimate the walking travel time from the corner of Main and Bunker Hill Street to Sullivan Square Station.

5. Provide construction and fifty-‐year operation/maintenance cost estimates for each proposal.

6. Describe in detail how vehicles using a Rutherford Ave tunnel will be slowed to 25-‐30 mph when they emerge onto the surface portions of Rutherford Ave.

Let’s not put the design of Sullivan Square/Rutherford Ave on the wrong side of history. We don’t want to build new streets with underpasses that are “relics” before they are built.

Thank you for your consideration.

Best Regards,

Wendy Landman
Executive Director

Cc Chris Osgood, Chief of Streets, Transportation and Sanitation
Commissioner Gina Fiandaca, Boston Transportation Department
William Conroy, Project Manager Boston Transportation Department
Tad Read, Boston Planning and Development Agency
Peter Furth, Northeastern University
Amy Branger, Liz Levin, Emma Rothfeld Yashar, WalkBoston Board members and advocates from Charlestown

Note: Peter Furth provided WalkBoston with the following information about the cited crash statistics. “They are using Highway Safety Manual’s general 42% reduction in crash rate when an at-‐grade intersection is converted to a grade-‐separated interchange. It’s obvious, but worth emphasizing: a grade separated interchange is NOT what’s proposed for Sullivan Sq; what’s proposed is a flyunder, akin to a flyover. The HSM has no data on flyover / flyunder conversions. They are making a logical leap by using a reduction that comes from complete grade separation. On the slide they write “*Applies to Underpass Movements Only,” meaning they intend to apply that reduction only to cars who will use the underpass. However, that suggests that a flyunder will leave all the other traffic unaffected. That is not proven (there is no data), and moreover, there are good reasons to expect that crash rate will go *up* for the other traffic. One reason is that the only traffic removed by the flyunder is thru traffic; all the turning traffic, which carries higher crash risk, remains, and furthermore will be concentrated. More importantly, the space required for the flyunder structure forces the at-‐grade intersection to have an unfavorable geometry, with the left turn lanes that flank the underpass separated from each other in a way that results in interlocking left turns, which are less efficient and (probably) less safe. Nobody would ever lay out an intersection that way if they weren’t constrained by the structure of the flyover / flyunder. That change could have an unfavorable safety effect that erases the gains enjoyed by thru cars that get to bypass the intersection.”

Comments on the Seaport Square NPC, MEPA 14255-3/24/17

March 24, 2017

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

Gary Uter
Boston Planning and Development Agency
One City Hall Square
Boston, MA 02201

Re: Comments on the Seaport Square NPC, MEPA 14255

Dear Mr. Beaton and Mr. Uter:

WalkBoston is pleased to submit comments on the revised Seaport Square project in the South Boston Seaport District.

We applaud the developer’s broad and thoughtful approach to creating a walkable and pedestrian focused sense of place. In particular, the new walking connection to Summer Street; the extensive, interesting and continuous connection to the harbor via Harbor Way; and the fact that the development is at the same grade with the rest of the Seaport District provide great opportunities to help transform the district into a lively part of the City.

Our comments are focused on several detailed design and management issues that we believe should be further considered as the project moves toward final development and implementation.

We are very pleased that the proponent is providing an additional entrance to the Courthouse Silver Line station. This will provide weather-protected access to transit and provide very convenient transit access for people walking in the area. We urge the developer to ensure that safe crosswalks are provided to the Silver Line station on Northern Avenue and on the nearby intersecting streets - Marina Park Drive and Boston Wharf Road - two cross streets that are not precisely aligned with one another. The crosswalks should serve desire lines for walkers going to or from the station.
Several of the key pedestrian crosswalks that will serve the project require further attention to pedestrian safety.

The lane widths shown on Figures 1-35 and 1-36 show that Congress Street and East Service Road will have overly wide 12’ and 15’ travel lanes. The un-‐signalized pedestrian crosswalk on Congress Street is 70’ wide and we believe that substantial safety measures are needed to make this a safe place for pedestrians, in particular because many of the vehicles using this street will be coming from or heading toward I-90, a situation that causes drivers to think that they are in a higher speed situation. Among the measures that should be considered are: addition of a traffic signal, narrowing the lanes and the crossing distance, and addition of a raised crossing.
The diagrams of other streets show 10.5 – 11’ foot lanes. We urge the proponent to work with the City to shrink all lanes to 10’ or 10.5,’ which the City’s Complete Streets Guidelines suggest as a reasonable width for an urban street.
At the edge of the project, a crossing of Summer Street to connect Seaport Square with the BCEC is absolutely essential. This crosswalk must be fully protected by a traffic signal. We believe that a gracious and safe pedestrian crossing of Summer Street will be important to the financial success of Seaport Square in addition to fulfilling the needs for a walker-‐centric design.
No signals are provided for five pedestrian crossings of Northern Avenue. While this may be viewed as a slow-‐moving street, great care should be taken with the design to ensure that all the crossings are safe for pedestrians, with minimal crossing distances and street designs and parking management that ensure that pedestrians waiting to cross can be seen by approaching motorists.
It is noteworthy that signalized crossings are added along Seaport Boulevard at pedestrian crossings between Farnsworth Street and the Harbor Shore Drive pedestrian way, between Thompson Street and Fan Pier Boulevard, and at the important pedestrian crossing where the Summer Street–to-‐harbor pedestrian way intersects the Seaport Boulevard and also leads to the new entrance to Courthouse Station on the Silver Line.

The shadow conditions in the project area suggest that the proponent will need to make special provisions to make the pedestrian zones comfortable during colder parts of the year. The developer might look to some of the work highlighted by WinterCities (http://wintercities.com/home/about/) for ideas on this topic.
The proposed design for Seaport Boulevard as shown in Figure 1-6 does not yet accomplish the goals for a truly walkable urban district. Except for a partially widened median strip, the roadway appears to have few distinctions from the existing conditions. Among the measures that should be considered for Seaport Boulevard are:

Narrow lanes and frequent raised crossings to slow traffic
Pedestrian scale lighting
Activated ground floor uses to give a sense of place for people walking along the street • Pedestrian wayfinding
We also urge the proponent to consider whether a widened median is a desirable design feature to be continued throughout the project area. The landscaping with rocks, grasses and sculptures might truly make the boulevard distinctive. Landscaping features could also be added on the sidewalks, making the walking experience more pleasant.

All of the design features noted above could help shift the street from its existing character as an auto-centric roadway to one that is attractive and safe for pedestrians.

The proponent should consider walking conditions and amenities on the edges of the project as well as the center – people will be walking everywhere and the NPC is focused very heavily on the central Harbor Way. We urge that the many other streets be carefully planned as well.
Because the project is so large and will create a significant portion of the Seaport District’s character, it seems to have the potential to provide a pedestrian and land use environment that can serve a diverse and multi-‐generational population. We urge the developer to pay attention to the mix of uses, shops and restaurants and their pricing so that they are attractive to all members of the greater Boston community.
Bicycle accommodations shown in the NPC do not seem to represent Boston’s current thinking about the need to provide low stress bicycle facilities. While this is not WalkBoston’s area of expertise, we believe that it is very important for the Seaport District to accommodate bicycles as well as possible.

For example, Figure 3-13, Transportation Circulation Plan, shows bicycle lanes on Northern Avenue, Seaport Boulevard and Boston Wharf Road, without indicating connections to the City’s planned bicycle routes on Congress Street, Summer Street, the Northern Avenue Bridge, the Evelyn Moakley Bridge, and Seaport Boulevard east of East Service Road. Potential north-‐south connections between these main routes are ignored. Possible bicycle lanes on Sleeper Street, Fan Pier Boulevard, Marina Park Drive or other connecting streets are not indicated.
Bicycle lanes on Seaport Boulevard are shown in ways the City is no longer supporting. Figure 1-6 shows bicycle lanes adjacent to moving traffic, while the City is now working to provide protected bicycle lanes (between parked cars and the sidewalk) on arterials.
The crosswalk on Summer Street will also be used by cyclists on the Summer Street cycle tracks. Cyclists will be interested in crossing the street as they access the proposed development – particularly the critical and focal pedestrian path between Summer Street and the harbor. Special provision for cyclists should be included to preserve the safety of pedestrians throughout this potentially densely used walkway.

Thank you for the opportunity to provide comments on the project, and would be pleased to answer any questions that our comments raise.

Sincerely,

Wendy Landman
Executive Director

Cc Yanni Tsipis, WS Development
Jonathan Greeley, BPDA
Vineet Gupta, Boston Transportation Department
Patrick Sullivan, Seaport TMA

115 Winthrop Square PNF Comment Letter

January 20, 2017

Casey Hines, Senior Project Manager
Boston Planning and Development Agency
Boston City Hall
One City Hall Square
Boston, MA 02201

Re: 115 Winthrop Square PNF

Dear Ms. Hines:

WalkBoston is Massachusetts’ leading pedestrian advocacy organization. We have reviewed the Project Notification Form for this project and believe that it will provide benefits to the economic strength and vitality of downtown Boston by replacing a dilapidated parking garage that has blighted the Winthrop Square neighborhood for decades. We also believe that there are several issues that require further evaluation and improvement.

1. The Great Hall that has been proposed has the potential to be an exciting gathering place that attracts people from both downtown and Boston’s neighborhoods. We urge that the Great Hall be open to the public 18 hours a day, 52 weeks a year and that it be given programming that goes well beyond a food and shopping court. The ground floor of the building (both as part of the Great Hall and also adjacent to the Great Hall) should have rooms and spaces for talking, working or observing. Programs to encourage use of the space will be essential. The proponent should clarify the plan for activating this space, including the types of programs and the agency or individuals who will be assigned the task of programming and managing the space. We urge the Proponent to provide a description of the mix of uses, the cost to users
(for events that are open to the public), and the anticipated intensity of programming that is to be provided in the Great Hall.

2. Because of its prominent, strategic location, the Great Hall will also be a walking connection between Federal and Devonshire Streets that adds to Downtown’s rich tradition of publicly accessible lanes and alleys. The balance between circulation space and usable public space should be carefully studied and described.

3. Wind studies of the building should identify its impacts on pedestrians using adjacent streets and sidewalks. Wind may also be a factor in the design of the Great Hall, where pedestrians and users of the space should be protected from gusts or periodic and protracted winds around the building.

4. Pedestrian scale lighting should be designed to enhance the usefulness and attractiveness of both interior and exterior portions of the building with attention to creation of a sense of place, traffic safety at street crossings and personal safety.

5. We urge the Proponent to explore building shapes, heights and orientations to reduce or eliminate shadow impacts on the Common and Public Garden.

6. We also urge the City and the Proponent to work with the many organizations and individuals who are deeply concerned that the project will set a precedent that allows shadow impacts on the Common and Public Garden. Prior to approval of the project, the City should describe permanent and binding protections for the Common and the Public Garden from further shadow impacts.

Thank you very much for your consideration of our comments.

Sincerely,

Wendy Landman
Executive Director

Cc: Senator William Brownsberger
Senator Joseph Boncore
Representative Jay Livingstone
Representative Aaron Michlewitz
Representative Byron Rushing
City Council President Michelle Wu
Elizabeth Vizza, Friends of the Public Garden
Howard Kassler, Neighborhood Association of the Back Bay
Patricia Tully, Beacon Hill Civic Association
Greg Galer, Boston Preservation Alliance
Todd Lee, LightBoston
Kathleen MacNeil, Millennium Partners
Cindy Schlessinger, Epsilon Associates

Comments on General Electric Headquarters Project SEIR 15547

January 20, 2017

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

Re: General Electric Headquarters Project SEIR 15547

Dear Secretary Beaton,

WalkBoston submitted comments on the EA for this project in September, 2016. We made a
number of suggestions about specific improvements that we believe the Proponent might make
themselves, or work with the City to secure, in order to assure comfortable and safe access to and
through the site.

We believe that the GE Headquarters will add vitality and opportunity to the Fort Point Channel neighborhood and to Boston. But, we feel that there is considerable work still required to improve access to the site for the vast majority of employees and visitors who will be arriving on foot.

Necco Street: It appeared to us from the drawings provided in the EA that the sidewalk was to be widened to 12’ in some areas, but narrowed to allow for vehicular drop-off at the main entrance.
The response in Comment 8.4 was that the designs would in keeping with the guidelines of Boston Complete Streets, which calls for a minimum of 8’ wide sidewalks in Downtown Commercial or Mixed-use Districts. Based on further conversations with the project team we are reassured that
the sidewalk at the entrance will largely meet that minimum standard. We hope that the proponent will also:

• Ensure that the narrower portions of the sidewalk not be encumbered with street
furniture or signage and thus remain unobstructed for walkers; and
• Create the pull-outs for vehicle drop-off in locations that are offset from the building
entrances so that there is ample space for people entering and leaving the buildings.

Necco Street Crosswalk: In Comment 8.7 we asked if there would be a crosswalk from the
Headquarters Building to the Necco Street Parking Garage. The following response was provided that does not answer the question: “The project incorporates substantial sidewalk improvements and pedestrian ramping to accommodate ADA compliant crossings.” Since the garage is likely to attract many people going to the GE building, a crosswalk aligned with its single entrance would seem to be appropriate

Accessible Routes to the Site: Comments 8.8, 8.9, 8.10 and 8.11 asked that the Proponent work
with the City and with other property owners in the neighborhood to improve the walking route
from South Station to the site via Summer Street, particularly for people with disabilities who will
not be able to use the stairway that connects Summer Street to the Harborwalk and then to the
main entrance of this project. The response provided in the EA was, ”The Proponents cannot
orchestrate improvements off the Project Site.”

WalkBoston’s comments were made because along the direct route from the Proponent’s main entrance to Summer Street there is no complete or accessible sidewalk. With a projected 70% mode share of walk and transit trips (which are thus also walking trips) this issue deserves careful attention. We believe that GE is very interested in working to remedy this situation in concert with the City and with its new neighbors. We urge GE to work with the City to solve this accessibility
problem before construction is completed on the Headquarters.

We look forward to working with GE and the City to ensure that pedestrians find a safe, accessible and inviting environment on and around GE’s Headquarters.

We appreciate your consideration of our comments and your responses to them.

Please feel free to contact WalkBoston with questions you may have.

Sincerely,
Wendy Landman
Executive Director

Cc Peter Cavanaugh, GE Project Manager
Elizabeth Grob, VHB Project Manager
Chris Osgood, Boston Chief of Streets

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Comment on EENF for The Office and Research Center and the Residences at Assembly

November 23, 2016

Matthew Beaton, Secretary
Executive Office of Energy and Environmental Affairs
Attn: MEPA Office
Analyst: Holly Johnson
100 Cambridge Street, Suite 900
Boston, MA 02114

RE: EENF for The Office and Research Center and the Residences at Assembly – MEPA #15595

Dear Mr. Beaton,

WalkBoston is a 501©(3) non-profit, pedestrian advocacy organization that makes walking safer and easier in Massachusetts. We have reviewed the EENF and offer the comments below.

The Office and Research Center and the Residences at Assembly is located on a 9-acre site at 5 Middlesex Avenue, Somerville, in close walking proximity to Assembly Station and to existing residential areas of East Somerville. It is planned to become an integral feature of the massive developments already taking shape in Assembly Square. Phase 1 of the proposed Project includes a 188-room hotel, and a 147-unit residential building with 6,000 sf of retail space on the ground floor. Later phases will include offices and residential units. The total space to be constructed within the site may reach 2,000,000 sq ft.

We are concerned that the proponent has not offered significant changes to the walking environment, except on its own site. The nearby Kensington Underpass, one of two connections between residential Somerville and the many worksites and attractions, should become its focus for improvements. The proponent has suggested a U-turn that would complicate pedestrian crossings at the underpass. The proponent should be required to develop improvements for pedestrians and vehicles at the underpass in an integrated way.

Recognizing the advantages of being located in the large Assembly Square complex of developments, the proponent notes that walking and bicycling through Assembly Square and on the paths along the Mystic River will be encouraged. The proponent also emphasizes the access provided to the site by public transportation not only at the new Orange Line rapid transit station, but also on bus lines located nearby on Route 38 and on Broadway in East Somerville. Access to public transit gives significant advantages to the proponent’s proposed complex of both office and residential units that can take advantage of the transportation services concentrated in the environs.

The proponent’s plan includes on-site pedestrian facilities and a plaza in the center of the development. The proponent vows that improvements to pedestrian and bicycling facilities will ensure security and comfort for those walking and biking. Part of these improvements will be a significant wayfinding element that will direct site visitors and users toward significant destinations, show walking times, and including public transportation services. The proponent also hopes to link the fabric of this new district to neighboring East Somerville.

The Assembly Square complex has already established pedestrian facilities throughout the property and highlights the riverside park and paths that make up a substantial pedestrian network. The proponent’s site will be able to take advantage of those improvements and link into them at appropriate locations.

The basic link between this site and East Somerville is the neglected underpass of I-93 at Kensington Street, which has not been updated since the construction of the highway. The proponent should take a leading role in the upgrading of this underpass, to bring to life the proponent’s laudable goal of a more appropriate connection into the surrounding community. Improvements to the underpass would bring about:
1. Improved pedestrian connections from East Somerville into the Assembly Square shopping area to reach proliferating new shopping, entertainment and work locations.
2. Improved pedestrian connections from the East Somerville neighborhoods to the new Orange Line rapid transportation station at Assembly Square.
3. A wayfinding network for pedestrians finding their way into and through the complex set of developments at Assembly Square.
4. Improved pedestrian connections both from Assembly Square as well as the East Somerville neighborhoods to the public transportation routes along Route 38, where bus stops are closer than the Assembly Square Orange Line Station.
5. Clear routes for access from Assembly Square to the major grocery store as well as commercial and public sites such as the library along Broadway in East Somerville.
6. A walking route for residents of East Somerville and people in Assembly Square for recreation and healthy daily activities.
7. Implementation of major goals of the City of Somerville’s “Somervision” program which looks to increase active and alternative transportation options, reduce congestion and promote workplace- and business-based policies and incentives to encourage changes in more choice and to expand bike, pedestrian and public transit use.

Improving the Kensington Underpass by itself is insufficient to protect users. The underpass, which connects East Somerville to Assembly Square near the intersection of McGrath Highway, Fellsway, Route 38 and the I-93 southbound onramp, has two at-grade street crossings where pedestrians must cross heavily traveled routes. The two crossings have painted crosswalks and pedestrian-actuated yellow flashing warning lights. More detailed analysis should be undertaken to assess the current levels of safety for people crossing at this location. Projections of future pedestrian traffic should be undertaken to analyze whether what level of additional safety measures might be appropriate.

Of special concern is the proposal by the proponent of this project that there should be a U-turn that would allow traffic from Assembly Square and this project to use the westbound service road along I-93 (called Bailey Road) to reach a point where it could u-turn into the eastbound service road near Route 28 to provide better access from Assembly Square to I-93 southbound. This would, according to the proponent help by “allowing vehicles to bypass two signals, thereby alleviating congestion.” The U-turn would provide, in essence, a fourth option for exiting the complex and reaching I-93 southbound.

However, with the addition of this U-turn, people trying to cross at the Kensington Underpass crosswalk will always be faced with oncoming traffic at both eastbound and westbound service roads leading into and out of the U-turn. The addition of traffic to the two service roads is a problem for the pedestrians using existing Kensington underpass should be analyzed in terms of any improvements that may be made to increase its use.

Several options might be explored to alleviate this difficulty. One would be to reduce both service roads on either side of I-93 to one lane, so that drivers would not be tempted to bypass a driver who is yielding to a pedestrian in the crosswalk. That option might be sufficient to retain the un-signalized crosswalk.

We appreciate your consideration of our comments.

Best regards,

Bob Sloane
Senior Planner

Brendan Kearney
Communications Manager

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