December 14, 2018

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

Brian Golden, Director
Boston Redevelopment Authority
One City Hall Square
Boston, MA 02201-1007

RE:  Comments on the DEIR/DPIR for the Suffolk Downs Project
MEPA: #15783

Dear Secretary Beaton and Director Golden:

Thank you for the opportunity to review and comment on the Suffolk Downs project. We offer the following comments on the project’s pedestrian environment, which overall is well addressed.

The project offers generous walking opportunities

The heart of the proposal is a 15-acre park – the Central Common – with walkways surrounding the site and connecting into and through the open space it provides. The Common has been designed as a one-mile running/walking loop. The park has water features with one pond that can be used for skating and another elongated pond that connects into the nearby saltwater Belle Isle Inlet. The Common connects on either end to meeting and performance spaces on plazas leading to the two Blue Line stations.

Main Street, a second north-south walkway, also connects Beachmont and Suffolk Downs Blue Line stations. This street will have wide, landscaped walkways with setbacks to allow for sidewalk cafes and other such uses along its route.

A third walkway, the Active Linear Corridor, parallels Main Street and runs midblock between Main Street and Tomasello Drive. This pedestrian-only street is intended to provide a series of active play spaces for all ages. The proposal is an extraordinary experiment – a half-mile long area that gives nearby space for casual and active uses. Figure 3.37 lists the potential uses of the corridor as active play, jumping mounds, rolling course, flex turf, climbing health, ping pong and jungle gym. Many of these are likely intended for children.

An additional north-south community trail skirts Tomasello Drive and is shown as a two-way bike facility that follows a swale on the side of the property facing the gas tanks, coupled with a sidewalk on the opposite side of the street.

There are several cross streets that connect the four north-south walkways. They vary in scale and importance. Several contain landscaped walkways and add to the many opportunities for walking throughout the project area.

One concern we ask the developer to address with respect to this generously scaled set of pedestrian ways and open spaces is that the play areas along the Active Linear Corridor (with the exception of the block near Waldemar Avenue) are located within blocks intended to be developed not for housing, but office uses, where presumably there will be few children in nearby buildings. As development occurs within the project, the proponents should ascertain if the proposed Active Linear Corridor is located appropriately to serve the intended users who may be living in residences on-site. Active recreational facilities for small children might be more appropriate lining the loop road at the eastern edge of the proposed Common. This route directly serves the three residential areas near the proposed Beachmont Plaza, the Belle Isle Plaza and the “Panhandle” near Route 1A. This route would strengthen the opportunities for residents to use the Common and its central meeting places as well.

East Boston Greenway extension

WalkBoston encourages the proponents to seriously consider a connection to the East Boston Greenway. The existing East Boston Greenway ends at the Belle Isle Marsh, near the Suffolk Downs MBTA station but on the other side of Bennington Street from the station. There is a roadside path/sidewalk paralleling Bennington Street between the main entrance to the marsh reservation and the crosswalk to the Suffolk Downs transit station. This path is used two-way by both cyclists and pedestrians. Extending the path further north toward Revere Beach is not an easy task. The frontage of Bennington Street is spacious and possibly could be the location of an extended route until reaching Everard Street in Revere, where the Bennington route narrows down on the approach to the Beachmont station at Winthrop Avenue.

A potential alternative location for extending the East Boston Greenway that was suggested in the DEIR exists in the large tract of land between the MBTA rail tracks and the Suffolk Downs property line. This land is nearly 10 acres of unused space and has no buildings on it between the Suffolk Downs transit station and Washburn Avenue in Revere. Depending on ownership the tract might be made available. If owned by the MBTA, the property might become available to the developer, who could include a north-south path that would be available as a substitute for the Bennington Avenue route and link the property into the regional Greenway network as a principal route in the system.

Possible new walking connections into Orient Heights from the project site

A decision has been reached with neighborhood residents that vehicular access between the project site and Orient Heights will not be provided. Several walking issues should be addressed to overcome this lack of street connection.

1. Walley Street and the Suffolk Downs MBTA station
   Walley Street, just off Waldemar Avenue, is the current road and pedestrian access point to the Suffolk Downs transit station for Orient Heights residents. This approach currently works for all access to the neighborhood, and the proposed development adjacent to it respects existing neighborhood preferences and adds no vehicular access to the existing site. Instead the proposal adds a new access route for vehicles and shuttle buses to drop off transit-riders from the new development as close as possible to the transit station; this connection appears to be a part of the proposed Belle Isle Plaza. It is a bit unclear how this new connection will meet with existing streets and paths, and the developer, the City of Boston and the MBTA will need to coordinate the proposed new access with the existing street and path layout.
2. South project boundary – Waldemar Avenue
   A community path along the full length of the south project boundary (approximately ½ mile long) connects the bus stop on Route 1A with the Suffolk Downs MBTA station at Walley Street. This is a good walking connection for East Boston/Orient Heights residents, as it provides connections to transit in two directions. From the Suffolk Downs station to a location about halfway between the MBTA station and Route 1A, an on-site road (also called Waldemar Avenue) parallels the path. It will be lined with small residential buildings backing onto the path. The Waldemar Avenue/Tomasello Drive intersection is well located to connect pedestrians into Orient Heights via the sidewalks of the Orient Heights public housing project and especially via Crestway Road, a short street that links to Faywood Avenue and directly to the Manassah Bradley School.
3. Safe walking access to schools
   The proponents include no discussion or description of schools and safe routes to schools. For any students who are attending nearby schools, walking to school should be safe and convenient. The proponents of the project should work with both the City of Boston and the City of Revere to assure safe passage for all students living in Suffolk Downs and using local schools.

   WalkBoston suggests additional examination of the role of schools on the walking paths proposed for the development. Students attending the Bradley School from both Suffolk Downs and Orient Heights would be well served by a neighborhood connection to the proposed path network. In addition, we suggest looking at whether a playfield that includes active recreation uses could be located where Crestway Road meets Waldemar Avenue (Block 5 on Figure 3.7). A playfield located here could serve both the school and the new neighborhood at a logical intersection of the walkways that are such a positive element of the project.

   For children living in the Boston portion of the Suffolk Downs neighborhood, access to schools in the Orient Heights neighborhood will be somewhat constrained because there is no vehicular access between the two neighborhoods, other than the route provided by going out from Waldemar Avenue onto Route 1A between Tomasello Drive and Boardman Street.

   The closest Revere school is the Seacoast School, located on Bennington Street, which can be reached from Suffolk Downs only by an indirect route through the Beachmont transit station and by sidewalks for a further 1000 feet. The Garfield Elementary and Middle School is about 1500 feet north of Winthrop Avenue. Revere High School is located approximately one mile north of Winthrop Avenue.

Route 1A along the western border of the project area

WalkBoston has significant concerns about the proponent’s plans for the Route 1A corridor. Adding a third vehicular travel lane in each direction and increasing roadway capacity from 2,100 to 3,300 vehicles in each direction – an increase of 57 percent – threatens to undermine the ambitious transit-oriented development goals the proponent expresses elsewhere in the proposal. Increased vehicular traffic will also mean more greenhouse gas emissions and more risks to pedestrian and bicyclist safety. We question the need for more vehicular travel lanes on Route 1A between Furlong Drive and Boardman Street, as most southbound traffic on Route 1A will likely access and exit the project site via Route 145/Winthrop Avenue, rather than the proposed “super street” corridor. Similarly, because of the extensive footprint of the Tomasello Drive intersection with Route 1A, we assume that the proponents are anticipating that most of the northbound Route 1A traffic into the site will enter via Tomasello Drive and exit via the same intersection.

The proposal to add more vehicular travel lanes within the existing roadway footprint will also undermine pedestrian and bicycle accommodations along Route 1A. Adding lanes will likely require narrowing or eliminating the current highway median, which would otherwise provide an important pedestrian refuge at the new proposed crossings at Tomasello Drive and Furlong Drive. Absent such a refuge, pedestrians will be forced to cross six highway travel lanes at once, which increases safety hazards and diminishes connectivity between the project site and development and recreation opportunities along the Chelsea Creek. Adding travel lanes while maintaining a five-foot roadway shoulder also reduces the space available for truly safe and protected bicycle facilities. The current proposal for a narrow five-foot unprotected shoulder alongside fast-moving highway traffic does not provide any meaningful protections for cyclists.

Instead of the “super street” concept, we encourage the proponents to reconsider Route 1A as a truly multimodal transportation corridor, with no new travel lanes except those built as dedicated pull-offs for buses on both the northbound and the southbound sides of Route 1A. This will further advance the proponent’s vision for transit-oriented development, while also maintaining space for protected pedestrian facilities in the median of Route 1A. Dedicated bus pull-out lanes also provide for increased bus service. As part of such a plan, the proponent should commit to improved bus stop facilities along Route 1A, including benches and shelters. Pull-outs for bus lanes and bus stop facilities should be considered for replacement of the existing unsafe bus stops at Furlong Drive, the jug handle at the tank farm, Tomasello Drive and Boardman Street.

Pedestrian access to Route 1A bus connections 

Existing conditions for pedestrians and bus riders on 1A are terrible. We are glad that there are proposals that provide safe access for pedestrians to bus stops on Route 1A, including new pedestrian crossings at Tomasello Drive and Furlong Drive. The principal users of bus services may be most concerned about access at Tomasello Drive. The existing Tomasello Drive intersection is proposed to be divided into two components – one for traffic entering Suffolk Downs from Route 1A and the other for traffic exiting Suffolk Downs onto Route 1A.

Pedestrians from both Waldemar Avenue and Suffolk Downs are affected in a dramatic way by this proposal, which would add a bus stop island for northbound buses on Route 1A, a pedestrian island between the travel lanes for traffic exiting the site onto Route 1A, and a right-turning slip lane for traffic entering the site from Route 1A. We encourage the project proponents to also consider a more conventional T design for this intersection, similar to what exists now.

Under the proposed new configuration, most pedestrians will approach the intersection on the south side of Tomasello Drive, as that is the path that connects to the residential areas in the “Panhandle” of Suffolk Downs, as well as the homes in Orient Heights. The bus stop on the Suffolk Downs side of Route 1A would be located directly adjacent to the Tomasello Drive exit lanes onto Route 1A. Getting to the bus stop would require passengers to cross the right-turning slip lane from Route 1A to reach the bus stop island. The crossing of the slip lane is likely to be more dangerous for pedestrians than other crossings, as traffic entering the site may not be stopped by the Route 1A signals. This should get more attention in final designs; one option would be to install a signal protecting pedestrians and a crosswalk.

Pedestrians crossing Route 1A are primarily bus passengers using southbound Route 1A bus services. They, too, are required to cross the potentially dangerous slip lane from Route 1A into Tomasello Drive, along with the southbound lane that serves traffic exiting from Tomasello Drive. Pedestrians would halt on the island between the travel lanes exiting the site and cross directly to the bus stop on the west side of Route 1A. This movement can be made concurrently with the signal phase allowing exiting traffic to move from Tomasello Drive onto Route 1A. Designers of the traffic flow for this intersection must consider the possibility that walkers cannot cross without a median break that affords refuge and safety for pedestrians who cannot cross in one signal phase.

Offsite mitigation for pedestrians and bicyclists

The project proponents outline an extensive program for offsite traffic mitigation in Section 6.10 of the DEIR, detailing numerous operational improvements for motor vehicles broken down by specific locations and intersections. Pedestrian and bicycle improvements are described only briefly and in largely general terms at the end of this section. We encourage the proponents to provide more detailed plans in the FEIR for pedestrian and bicycle improvements at the same locations and intersections they are prioritizing for offsite traffic mitigation.

Thank you again for this opportunity to comment on the proposals that affect pedestrians in the Suffolk Downs project.

Sincerely,

Wendy Landman
Executive Director

Cc:
Bob O’Brien, City of Revere

Page Czepina, MEPA Office

Tim Czerwienski, Boston Planning and Development Agency