Category: Comment Letter

Comments on Haverhill Walkway

September 15, 2014

Secretary Maeve Vallely Bartlett
Executive Office of Energy and Environmental Affairs (EEA)
Attn: Anne Canaday
100 Cambridge St., Suite 900
Boston MA 02114

RE: Comments on the Environmental Notification Form for the Haverhill Boardwalk Project
MEPA# 15238

Dear Secretary Vallely Bartlett:

WalkBoston has reviewed the ENF and we offer the following comments about its impacts on walkers.

The proposed project is quite small – about 450 feet long and 16-17 feet wide with wood decking for the boardwalk, totaling about 46,200 square feet (about 1.1 acres). It is part of the city’s long-range plan for a walkway loop around the downtown portion of the riverbanks, accessed via paved parking areas and public alleys that are adjacent to occupied buildings in downtown Haverhill.

When completed, the boardwalk will link to already-completed walks and become part of a 1,200 foot long walkway. It will also be part of a longer-range Merrimack River Walkway connecting to other cities. In this riverside setting, the project will include utility work, piles for boardwalk support, lighting on the boardwalk deck, benches and planting boxes and two stairways on the riverside floodwall to accommodate a future residential gangways and dock systems in the river.

The size of the project cannot reflect the extraordinary amount of diligence and patience it takes to build small increments of a larger plan. We applaud the city for its work in constructing this facility, and wish it well in further efforts to build the pathway.

We do have a few concerns that we hope can be addressed as the project moves forward.

• The design appears to call for on-land piles that raise the walkway about 7 feet above grade. Since the walkway is some 16-17 feet wide, we wonder about the space under the walkway. The space may become worrisome if it is left open for easy access, and if no alternative uses can be found for it. Is there a plan for enclosure of the space under the walkway to keep it safe and secure and to minimize maintenance problems that might arise?

• We wonder how this small portion of the path will help to encourage people to use the new and existing riverfront walkway until the full pathway can be constructed. The city should explore ways of marketing the boardwalk while the full project still lies in the future.

• Our understanding of the project is that it will connect to an existing walkway on its west end that has ramps leading toward the grade of Merrimack Street. There appears to be no such connection on the east end. We found a reference to a “Merrimack Place landward access stairway” on page 7 of the ENF, but saw no plans of how it would be sited in relation to the walkway. Will the elevated walkway – some 7’ above grade level and still elevated at Merrimack Place –have stairway or ramp access at its east end?

Thank you for the opportunity to comment on this interesting and important project.

Sincerely,

Robert Sloane
Senior Planner

Comments on the Final Environmental Impact Report for the Wynn Everett Development, MEPA# 15060

August 8, 2014

Secretary Maeve Vallely Bartlett
Executive Office of Energy and Environmental Affairs (EEA)
Attn: Anne Canaday
100 Cambridge St., Suite 900
Boston MA 02114

RE: Comments on the Final Environmental Impact Report for the Wynn Everett Development MEPA# 15060

Dear Secretary Vallely Bartlett:

WalkBoston has reviewed this document, in keeping with what we have done for other projects across the state, looking for potential mplications for pedestrians as a result of the proposal. We offer the following comments.

Access to the site as a pedestrian
The Final Environmental Impact Report (FEIR) for the Wynn Everett Development includes changes in the program between the DEIR and the FEIR. Changes that were introduced reduce the square footage devoted to the hotel, retail space, and convention services and enlarge the gaming areas, food/beverage service areas, entertainment/nightclub areas and support areas. Total square footage of the development has risen from 2,619,234 to 3,038,695 square feet. A total of 3,200 slot machines and 160 gaming tables are proposed, along with a 504-room hotel. The number of parking spaces under the complex has been increased and will house 3,700 cars on-site and 800 off-site.

• The use of public transportation is not encouraged by the present plan. Arrivals by vehicle are emphasized. The project is estimated to generate 9,424 vehicle trips on a Friday. Fewer people will arrive by public transportation – estimate at 3,265 public transportation person trips and 1,454 additional trips if water transportation is provided. (it is unclear where the water transportation riders go if water transportation is not provided, and this analysis should be provided if the proponent does not contractually commit to providing water transportation service.)

• Estimates of the use of public transportation conclude that capacity on public transportation is available, suggesting that more use of public transportation could be encouraged. Bus routes that serve the site generally have excess capacity (although estimates are that use will exceed capacity of Routes 104 and 109 outbound at certain times. Given the capacity available, there are no suggestions of making greater use of bus services on Alford Street at the site entrance or of enhancing capacity on Routes 104 and 109. Orange Line riders are also projected to be accommodated by available capacity. Shuttle service to the site from the Orange Line Sullivan Square Station is proposed, and, if adequately promoted, may at some point in the future result in more patrons arriving by public transportation.

• Walk-in traffic is not encouraged by the present plan. Walk-ins to the site include public transportation riders as well as nearby residents or employees. We are concerned that the pedestrian access may be unattractive to walkers. Sidewalks along both sides of the entrance drive are not afforded the lavish landscaping and improvements that surround paths along the water. Walk-in customers are not anticipated from the west side of the tracks, though a potential route is to be provided.

• A portion of the riverside might be used for additional pedestrian access. Immediately adjacent to this property, and also along the Mystic River, are lands owned and occupied in part by public agencies that front on Route 99. The proponent should explore with these agencies the potential for riverside access for pedestrians, in effect extending the Mystic River pathway network closer to Sullivan Square and making the walking routes much more attractive. The riverside route could be an attractive alternative for walkers to reach the proponent’s property away from the heavy traffic on Route 99.

The on-site paths are major links in the East Coast Greenway/Northern Strand/Bike to the Sea rail trail.
Although the proposal does not encourage access by pedestrians, it does include a very good proposal to extend the on-site walkways into the adjacent Gateway Park. Plans are in place for a regional multi-purpose path between downtown Boston and the New Hampshire state line. Called the Borders to Boston Trail, this route is 28 miles long and traverses 8 communities. Everett has constructed a portion of the path that is currently the southern end of the trail. A link across the Mystic River is required to access Boston. One proposal was to construct a pedestrian bridge over the Mystic River between Everett and Somerville. The engineering study done for this connection resulted in a finding that there was no feasible crossing at this location at an acceptable cost.

The alternative to a new and costly bridge is a connection directly through the proponent’s site. The route would connect Gateway Park’s riverside paths through the proponent’s site, where the route would link with bike paths and sidewalks along Alford Street to gain access into Boston. As it becomes a link in a major-north-south bicycle and pedestrian route, it will need careful attention to design details in the path proposed by the proponent. For a multipurpose path of this importance, a clear width of 10’ may be inadequate to accommodate likely numbers of walkers, joggers and cyclists. The route across the site should be investigated to assure that potential users of the site’s waterfront will not be adversely affected by the multi-purpose path. Access at the Alford Street intersection should also be investigated to assure safety for pedestrians and cyclists who may be crossing to get to the site.

Off-site improvements
The proponent has committed to improve several roadways near the site. Alford Street will clearly be in need of improvements because of impacts from this proposal. Alford Street will also need appropriate pedestrian signal equipment (automatic WALK signals during times of day when pedestrians will be present, countdown signals, leading pedestrian indicators, and signal heads at each intersection). Refuge islands at the street centerline should be considered. Crosswalks will need fresh zebra striping, possible curb extensions and potential addition of in-street crosswalk “yield to pedestrian” signs.

Thank you for the opportunity to comment on this important project.

Sincerely,

Wendy Landman Robert Sloane
Executive Director Senior Planner

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Comments on the Supplemental Draft Environmental Impact Report for the Mohegan Sun Development MEPA# 15006

August 8, 2014

Secretary Maeve Vallely Bartlett
Executive Office of Energy and Environmental Affairs (EEA)
Attn: Holly Johnson
100 Cambridge St., Suite 900
Boston MA 02114

RE: Comments on the Supplemental Draft Environmental Impact Report for the Mohegan Sun Development MEPA# 15006

Dear Secretary Vallely Bartlett:

The proposal included in the Supplemental Draft Environmental Impact Report makes some changes to the components of the Mohegan Sun Development and slightly alters pedestrian access to the site. Construction will include 965,000 sq ft of gross floor area, providing space for 5,000 gaming positions, 450-500 hotel rooms, 44,000 sq ft of meeting/entertainment space and 100,000 sq ft of retail space. Parking for 4,200 cars will be located beneath the structure, with an additional 270 cars on surface but below the first floor of the building.

Pedestrian entry into the site takes place at the two corners of the site, with a southwest corner entrance devoted to people arriving by private vehicles, and a northeast corner entrance devoted to people arriving by public transit (bus and subway), tour buses and walking from the surrounding area. Most of our comments focus on the building’s external design, and the ways in which people find access to and from the building.

1. Access to the site – the balance between transit and driving
Although this casino site is much better served by public transportation than any of the other proposed sites in Massachusetts, access by private vehicle may be encouraged because of the extremely large number of on-site parking spaces. We urge the proponent to give greater consideration to encouraging transit and pedestrian access and discouraging vehicular access.

• A potentially attractive reliance on public transportation may be lost because by the ease of driving and finding a parking space. Perhaps parking should be deemphasized through pricing and location.

• People arriving by vehicle are pampered by weather protection, provided in two ways: either by live access using a porte cochere and valet services, or by direct access into the underground parking garages where access is served by elevators.

• The access area at the porte cochere does not encourage pedestrians who do not arrive by car. For example, walkers using Tomasello Drive to get to the entrance areas of the southwest corner of the site will find a sidewalk that leads into the parking garage where elevators connect to the main floors.

2. Access on foot will be primarily served by public and private transportation to the northeast corner of the site.
At this corner there is access from adjacent MBTA bus stops. The MBTA Beachmont Station on the Blue Line is about 150 feet away. Tour bus bays are immediately adjacent to the concourse of the entry way. The concentration of arrivals into the concourse area appears to be an efficient way to enter the development.

• The grade of the northeast corner concourse may be difficult for certain users to reach. It appears that all people arriving at his corner of the site will have to go up at least one level via elevators and/or stairs to reach the main floor, where further vertical public circulation is available. Access to the concourse level varies. For example, people arriving by public transportation, whether by bus or rapid transit, will need to go up at least eight steps to the concourse level. Arrivals from the tour bus drop-off area may have to do the same. It is unclear how arriving patrons in wheelchairs will access the concourse; there is no evident ADA access ramp from the sidewalk at the intersection of Winthrop and Washburn Avenues up to the concourse level.

• Weather protection for arriving pedestrians should be provided. Covered walkways would be appropriate, particularly on the approach from Washburn Avenue and on the open stairway at the main entrance.

3. Access to and from the Beachmont MBTA station
The proponent should work with the MBTA to enhance access to and from the rapid transit platforms at the Beachmont station. Wayfinding signs inside the station should be used to direct riders to the Mohegan Sun complex. Wayfinding signs at the entrance/exit concourse of the proposed development could reinforce the potential for patrons to take transit, especially because the station is so close.

4. Off-site improvements
The proponent has committed $45 million for off-site roadway, traffic and safety improvements. We hope that the commitment will be honored with full ADA compliance, and with appropriate pedestrian signal equipment at each intersection (including countdown signals, leading pedestrian indicators and automatic recall of WALK signals during the hours when pedestrians will be present). Crosswalks should be provided with zebra striping, and in some locations in-street pedestrian signs such as “yield to pedestrian” may be appropriate. Refuge islands at street centerlines should also be considered on major roadways.

Thank you for the opportunity to comment on this important project.

Sincerely,

Wendy Landman Robert Sloane
Executive Director Senior Planner

Comments on the Single Environmental Impact Report for the Landmark Center Redevelopment MEPA# 15183

August 8, 2014

Secretary Maeve Vallely Bartlett
Executive Office of Energy and Environmental Affairs (EEA)
Attn: Purvi Patel
100 Cambridge St., Suite 900
Boston MA 02114

RE: Comments on the Single Environmental Impact Report for the Landmark Center Redevelopment MEPA# 15183

Dear Secretary Vallely Bartlett:

For large development projects around the state, WalkBoston provides a review of proposed pedestrian facilities and provide comments that suggest ways to help improve pedestrian conditions and/or mitigate negative impacts on pedestrians.

WalkBoston has reviewed the Single Environmental Impact Report for the Landmark Center Redevelopment. The project is designed to intensify the use of the property by relocating existing parking underground, and constructing 600 residential units, 185,000 sq ft of retail space, and 15,000 sq ft of office space. The existing Landmark building is preserved and circulation is upgraded on the retail level. Public open space will be augmented, and additional paths for pedestrians provided.

The project holds many positive improvements for pedestrians. The new connections between the MBTA station and the neighborhood, both inside and outside of the building are well done and very desirable. The new park at the corner of Park Drive and Brookline Avenue will provide a gathering spot and a “green” that will have multiple uses for people-watching or as an entertainment venue.

We have some suggestions that may improve facilities for pedestrians:

• The proponent might consider extending the weather-protected portion of the walking route along the new building frontage between the existing Landmark building and the north side of the property, including both the MBTA station and the multi-purpose path. Weather protection could be provided either inside the new building, as an extension of the interior network of pathways or by a canopy that would provide some protection for walkers across this small portion of the site.

• On page 1-7 the report cites the “….vibrant streetscape along Park Drive, Brookline Avenue, and Fullerton Street.” These three sides of the project warrant such attention. But the north side of the property, where the multi-use path is proposed to be located, has not been provided with attractive treatments. The walls and landscaping along this path be provided with amenities to make it more vibrant and attractive to walkers. For example, murals could be added on the adjacent walls.

• The proposed design for Fullerton Street is confusing. A connection for pedestrians is provided via Fullerton and Miner Street to reach Beacon Street from the development, but the extensive truck use of Fullerton Street may make this connection uncomfortable for pedestrians. The proposal to increase the corner radii at the intersection of Brookline Avenue/Kilmarnock Street/Fullerton Street should be carefully reviewed for its potential safety impacts on walkers.

There is an important pedestrian safety issue that we hope the proponent of the project will undertake – improving pedestrian access across Park Drive at the top of the bridge where bus stops and the stairs to the Green Line are located. Two different improvements should be implemented.

1. By using the underground passageway adjacent to the MBTA D Line station, a pathway along the MBTA right-of-way through the Fenway Station would connect the Riverway portion of the Emerald Necklace to the multi-use path leading to Kenmore Square. This would enhance safety for pedestrians who want to walk between these two off-street paths.

2. An improved pedestrian crossing of Park Drive is needed at the top of the hill where the bus stops and access to the stairs to the Green Line are located. There is currently no crosswalk or signal at this location, and the hill reduces the visibility of pedestrians. As the location of a busy transit connection serving both Green Line and bus riders, this location warrants a careful study to develop safe crosswalks perhaps including a pedestrian activated signal or other high-visibility markings.

Thank you for the opportunity to comment on this important project.

Sincerely,

Robert Sloane
Senior Planner

Cc: Jack Murray, Commissioner, DCR
Jim Gillooly, Interim Commissioner, Boston Transportation Department

Comments on Allston – The I-90 Massachusetts Turnpike Interchange Project, Evaluation Criteria

August 6, 2014

Mike O’Dowd
Project Manager, MassDOT
10 Park Plaza
Boston, MA 02116

Re: Allston – The I-90 Massachusetts Turnpike Interchange Project, Evaluation Criteria

Dear Mike:

Thank you and the project team for providing the opportunity to provide comments on the evaluation criteria for the I-90 Turnpike Interchange Project. Rather than focus on the detailed design and environmental criteria that will be used, WalkBoston feels that it is important to set out big-picture performance standards for the project. Thus far the broader community-building implications of what this project can achieve – beyond its roadway connections to the Turnpike – have not been fully laid out.

The following performance standards should help define the project more completely. We suggest that they be considered as part of the minimum requirements for a successful reconstruction of the interchange.

1. Soldiers Field Road/Storrow Drive – The project should result in the expansion of open space along the Charles River. Based on the alternatives we have been shown to date this is likely to be accomplished through the relocation of some or all of Soldiers Field Road/Storrow Drive under the Turnpike viaduct. Existing rail lines would likely need to be altered or relocated as part of the reconstruction. Thus, all final rail alignments and viaduct supporting members should be designed to make room for this riverside highway relocation.

2. Cambridge Street Bypass – Separate local and regional traffic operations should be evaluated. Multiple lanes of traffic (6 to 8 minimum) will likely be necessary for Cambridge Street to accommodate traffic movements. The number of lanes should be defined as soon as possible so that the neighborhood can comment on whether MassDOT should explore a two-street option that provides for a residential district on both sides of a narrowed Cambridge Street, plus a New Cambridge Street to provide connections to the Turnpike ramps, Stadium Way/East Drive and the River Street Bridge. (See attached diagrams of several conceptual possibilities.)

3. Connecting roads north of Cambridge Street All alternatives should include the construction of both Stadium Way and East Drive as integral links in the access pattern of the study area. Without the construction of these two roadways, Cambridge Street and North Allston will be swamped with traffic.

4. Turnpike ramps Alternatives for the Turnpike’s new alignment should be based on a minimum of retained fill (embankments) between the viaduct and ground level, as suggested in Alternatives 3-D and 3-G. This will allow for over-Turnpike connections to access ramps and to West Station.

5. West Station access All alternatives should include convenient and attractive access to both Cambridge Street and Commonwealth Avenue for pedestrians, bicycles, and buses (perhaps with separate bus access from the north and the south) to the West Station headhouse.

While we think that none of the alternatives presented to date meet these standards, we look forward to MassDOT’s development of alternatives that demonstrate how these standards can be realized.

Sincerely,

Wendy Landman Robert Sloane
Executive Director Senior Planner