Tag: Boston

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

February 10, 2014

Secretary Richard K. Sullivan, Jr.
Executive Office of Energy and Environmental Affairs (EEA)
Attn: Anne Canaday
100 Cambridge Street, Suite 900
Boston MA 02114

RE: Comments on the EIR for Wynn Everett, MEPA #15060

Dear Secretary Sullivan:

WalkBoston offers the following comments on the Wynn Everett Draft Environmental Impact Report. While we are pleased to see that the DEIR includes the proposal for the harbor walk and water transportation docking facilities, we are concerned about the traffic impacts and the lack of sufficient preparation for pedestrian access to the site. Improved pedestrian access is crucial to encouraging transit use as a significant travel choice for both employees and patrons.

Our comments are organized around two key issues: (1) enhancing and encouraging walking and transit, (2) mitigating the impacts of auto trips.

Enhancing and encouraging walking and transit
An Everett casino should be viewed through the lens of an urban re-development project that fits within its neighborhood and enhances the lives of its neighbors as well as its patrons and employees. In order to do that, the development should maximize the number of transit and walking trips, and minimize the number of auto trips.

1. Transit access and emphasis.
As currently planned, primary subway transit access will be provided by the Orange Line Sullivan Square MBTA Station which is about .75 miles from the site. Transit stations at Wellington and Assembly Square are each over 1.5 miles from the site, and currently have indirect, time-consuming pedestrian routes to the proposed casino. Transit should be encouraged through a number of different carrots and sticks.

• Bus service should be enhanced by improving nearby bus stops or providing subsidies to provide additional service for nearby routes. The safe use of bus stops on the far side of Route 99 is especially important to consider; the proponent should assure that there are traffic signals at all bus stops to provide safe passage for pedestrians crossing at these locations.

• Providing an off-site, transit-convenient and/or shuttle-served location for parking used by the majority of employees is one important option. The connection of proponent- or operator-controlled shuttles to these locations will reduce the impact of vehicles at the access points into the site. To attract patrons to use the bus, the proponent may want to experiment with shuttles that are attractive and “fun.”

• The proponent has included shuttle buses to nearby subway stations and to offsite parking lots. Frequency of the proposed service should allow Orange Line and bus riders to be served within very short (maximum 15-minute) wait times. All shuttle services should be made free for employees and patrons.

• The proponent and operator of the casino should price parking spaces to discourage parking during all times of day and evening during which transit service is available.

• Carpooling should be encouraged and subsidized for employees who live outside the MBTA service area or who work late-night shifts.

• The proponent should subsidize ferry services to make use of the proposed water transportation facility.

• The proponent should establish a transportation management organization that can efficiently deal with transit encouragement through subsidized transit passes, and other means that encourage the use of transit.

• Monitoring and reporting on the successes of the proponent and operator of the site in reducing vehicular traffic should be undertaken on an annual basis for the first 10 years of use of the new facilities.

2. Pedestrian access improvements
• Significant improvement of pedestrian access to Sullivan Station should be included in the proponent’s transportation mitigation plan. Access for pedestrians along Lower Broadway remains a concern. When Route 99/Broadway was reconstructed by the state, new bicycle lanes were added in both directions, but the existing sidewalks were narrowed to permit expansion for other transportation modes. The proponent should detail the ways in which sidewalks will be upgraded for pedestrian access into the site. Improved sidewalk access should extend at least as far as the MBTA Sullivan Square Station, which will require the proponent to work closely with the City of Boston.

• The new intersections serving the site should be carefully planned to include safety measures for pedestrian crossings. This should include pedestrian phase timing at these and other signalized intersections constructed or modified as part of the proposal.

• The potential new pedestrian and bicycle connection that the proponent proposes to create an approximately .75 mile direct route between the site and Santilli Circle – is intended to encourage pedestrian traffic. The proponent should be required to continue its work with the DCR and the MBTA to assure that this very short, relatively inexpensive connection actually gets constructed. The proponent should promote use of this route to encourage its use.

• A connection between the site and the City of Somerville could be provided by access over the Amelia Earhart Dam. This connection would lead to both the new Assembly Square MBTA Station and to the Somerville/Charlestown Mystic River path network. A connection across the dam could make the Assembly Square station the closest transit access point for the site. The proponent should work with the cities, as well as the DCR and the MBTA (owners of the land) to see whether this long sought pedestrian amenity that would link the extensive riverfront path networks on the two sides of the river, could be provided by the project.

• A concept plan for the streetscape in Everett has been mentioned. We trust that the plan, if developed, will be generous in its recommendations for pedestrian access.

Mitigating/managing the impacts of auto trips
We are concerned that the location of the site and its considerable distance from centers of population and regional transit stations will result in motor vehicles providing the majority of the access to the site, as the proponent has stated. The emphasis on access for vehicular traffic via Broadway leads to potentially difficult traffic concentrations – not only for Broadway, but also for Sullivan Square and the Sweetser Circle at Route 99/16. Both of these locations are already challenged by daily traffic patterns and the addition of casino traffic would seem to bring new and extensive challenges.

All of the access via Sullivan Square will deeply affect the Charlestown neighborhood and its plans for improvements at Sullivan Square. The proponent should work closely with residents of Charlestown and the City of Boston to reach an improved understanding of potential traffic volumes and impacts and the methods that might be used to partially mitigate the effects on the neighborhood. This should include traffic data collection and analysis, and detailed work with the City of Boston to review and assess all options for mitigating the impacts that casino related traffic will have on city streets, intersections and sidewalks. A community agreement between the City of Boston and the proponent should be reached prior to further planning.

Thank you for considering our comments. Please feel free to contact WalkBoston with questions you may have.

Sincerely,

Robert Sloane
Senior Project Manager

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Government Center Garage Redevelopment Environmental Notification Form EOEA #15134

February 7, 2014

Secretary Richard K. Sullivan, Jr.
Executive Office of Energy and Environmental Affairs (EEA)
100 Cambridge Street, Suite 900
Boston MA 02114

RE: Comments on the Government Center Garage Redevelopment Environmental Notification Form (ENF)

EOEA #15134

Dear Secretary Sullivan,

WalkBoston appreciates the opportunity to provide comments on the Environmental Notification Form (ENF) for the Government Center Garage Redevelopment.

The proposal calls for partial demolition of the underutilized Government Center Garage as an early action, with subsequent demolition and redevelopment to take place over a number of years. Initial demolition will result in opening Congress Street to daylight and allowing redevelopment of the East Parcel, including a new public plaza and pedestrian connection between the Bullfinch Triangle and Greenway. The east parcel is a critical pedestrian link between Downtown Boston and North Station/Bulfinch Triangle, as well as a link to the Rose Kennedy Greenway. The total development will include 812 new housing units, 196 new hotel rooms, over one million gross square feet of office, and 82,500 gross square feet of retail. The garage will continue to provide sufficient parking for the new onsite uses, commercial parking for transient users as well as overnight resident parking.

We offer the following comments:

1. We believe the proposed development will improve the area for pedestrians compared to existing conditions. The existing garage is a large, foreboding structure from the pedestrian viewpoint. While the potential removal of the garage and the reopening of Congress Street to the sky is appealing in its own right, the proposed development offers additional benefits. As the project is refined during subsequent reviews, MEPA and the BRA must ensure that these benefits are not lost during revisions or project changes. We trust that any project approval will condition the following proposed improvements to ensure they are included in the final design:

The removal of overhead parking decks and associated office space, returning sunlight to Congress Street.
The proposed pedestrian-only extension of Canal Street through the newly-configured east parcel that greatly benefits heavy rush-hour foot traffic to/ from North Station.
The narrowing and redesign of Sudbury Street, including elimination and replacement of angled Police Department parking from the right-of-way.
The extension of Bowker Street to make it a through street, eliminating the stairs between Sudbury Street and the existing dead end of Bowker Street.
The project could potentially provide very substantial benefits that would have a lasting effect on the built environment of the immediate neighborhood and the entire downtown core of Boston. Careful attention must be paid to the pedestrian experience in and around the site to take advantage of its tremendous pedestrian and transit access. The project is positioned to capitalize on these features and it is incumbent upon MEPA, the BRA and the City of Boston to ensure that the final design fully accounts for these opportunities.

2. Curb cuts for the garage – All curb cuts provided for the new garage should be kept to a minimum width, should enter the street at a right angle, and should be at sidewalk grade (no curb cut for pedestrians). Appropriate vehicle exiting warning signs must be provided for pedestrian safety. The existing garage access drives are too wide and pedestrians on the sidewalk are often threatened by automobiles traveling at high speeds into and out of the garage’s overly wide parking access ramps.

3. MBTA on-site improvements – The project should not interfere with normal MBTA bus operations, and allowance must be made for continued bus and subway service connections on-site. The proponent and the MBTA should commit to additional design work to improve the walking environment in this area to accommodate the large number of pedestrians using transit, along with the additional pedestrian volumes that will be generated by this very large project.

4. Hawkins and Bowker Streets – Bowker Street should become a through street with a changed gradient that allows an ADA compliant sidewalk. If Hawkins Street cannot also be made a through street, the stairs that connect its dead-end at Sudbury Street should be re-graded into an ADA compliant sidewalk.

5. North End Access – While the project claims to reconnect long divided Boston neighborhoods, it fails to offer the North End the same pedestrian benefits it does for the West End, Government Center and Bullfinch Triangle. In fact the project design seems to turn its back on the North End. A North End pedestrian connection should be explored in greater detail. The connection should work to interconnect the north-south walkway through the east parcel, North End residents, the two Green and Orange Line MBTA subway stations, and the Greenway.

6. Walk Signals – The existing pedestrian walk signals at the intersection of New Chardon Street and Canal Street will need to be adjusted. The pedestrian service from Canal Street through the newly configured east parcel will siphon existing North Station foot traffic away from adjacent streets. As a result, this pedestrian walk signal and the narrow mid-crossing island may be overwhelmed by the additional foot traffic on Canal Street. All walk signals on New Chardon, Friend, Sudbury and Merrimac Streets should be adjusted to handle the additional pedestrian traffic that the project will create.

7. Narrowing Sudbury and New Chardon Streets – A detailed study of the potential for narrowing both Sudbury and New Chardon Streets is essential. Such a study should include provisions for wider sidewalks, coordinate with improvements being planned for neighboring streets as part of the Crossroads Initiative and potential bike lanes. Further pedestrian crossing improvements should be explored including the elimination (or infill) of the truck turning lanes at the corner of Merrimac Street and New Chardon Street, and at the corner of New Chardon Street and Congress Street.

8. Other pedestrian ways – The document does not address whether the proponent will maintain or improve pedestrian connections that skirt the northwestern edge of the site, from New Chardon Street, up the Brattle Way pedestrian mall and ultimately out towards Cambridge Street. This pedestrian mall/walkway and associated small park area is well used during the day and it should be considered with the project’s design. The short length of Brattle Way could be an excellent candidate for expanded pedestrian use.

Thank you for the opportunity to comment on the ENF for the Government Center Garage Redevelopment. We believe this site provides an opportunity to develop a transit-oriented, mixed-use project that could showcase pedestrian friendly sidewalks and streets. We hope our comments on the ENF/PNF are incorporated into your requirements for the next phase of design and permitting documents.

Please contact us for any clarification or additional comments that would be useful.

Sincerely,

Wendy Landman Robert Sloane
Executive Director Senior Planner

Comments on Charles River Basin Connectivity Study

December 16, 2013

Richard K. Sullivan, Jr.
Executive Office of Energy and Environmental Affairs
Attn: Dan Driscoll
100 Cambridge St., Suite 900
Boston MA 02114

RE: Comments on the Charles River Basin Connectivity Study

Dear Secretary Sullivan:

WalkBoston has reviewed the Charles River Basin Pedestrian and Bicycle Study for Pathways and Bridges, the so-called Connectivity Study. Our comments arise from the document and from the recent presentation of the study to the public.

The Connectivity Study is very exciting work, as it assembles the issues of movement along the basin very effectively, and points out the possibilities for positive changes in the paths, walkways and running facilities along the River. DCR should be very proud of this feat, and should proceed into implementation of priority aspects of the planning effort as soon as possible.

We were particularly heartened by the Study’s general recommendations for the Basin: “DCR should strive to develop a 10’-wide paved path with a parallel soft-surface trail or shoulder for runners (emphasis added) where possible….. In “pinch point” conditions, a minimum 8’ paved path, with 3’ shoulder on one side, should be incorporated.”

This acceptance of separate paths for runners and joggers – and also pedestrians – is a very important aspect of the planning and represents continuity with past planning efforts.

In the 2002 Master Plan for the Basin a stated goal was to provide safe and continuous bicycle, skating, and pedestrian access along the entire length of the Basin, with a “separation of footpaths and bike paths where doing so will not create excessive pavement near the shoreline.” The master plan also called for reducing congestion and minimizing conflicts on the paths (presumably conflicts between bicycles and pedestrians).

In 2005, users were surveyed to discern attitudes about the river facilities. The survey asked respondents to list and rank how they used the Basin. The top twelve responses were, in order of frequency:
• Walking for pleasure
• Attending concerts or events
• Relaxing in the park
• Driving on the parkways
• Running or walking for exercise
• Biking
• Using Riverbend Park in summer
• Picnicking
• Enjoying the outdoors with children
• Inline skating
• Walkathons
• Informal sports

More than sixty percent of those surveyed used the Basin more than once a week for strolling, relaxing, attending concerts or attending special events. Eighty-six percent asked for easier and safer pedestrian access to the Basin, and an equal proportion recommended separating pathways by user types. Users also frequently called for more benches and places to sit, more wildlife areas, more park rangers, and more convenient parking.

If the Continuity Study can be regarded as an update to the Master Plan, we think it may be leaving out some of the emphasis that the authors of the two planning documents clearly stated. In particular, the separation of bicycle and pedestrian paths does not seem to be as important an aspect of the plan as the users of the park suggested to be of high importance. WalkBoston believes that path separation should be integral to all elements of the plan, as it will help deal with the many problems inherent in an area that is so heavily used with so many potential conflicts between users.

We urge consideration of the following:
1. The elimination of conflicts between users of the paths should be uppermost as a safety precaution. Conflicts arise where bicycle traffic is moving rapidly through areas where pedestrians are strolling, causing dangerous situations for all. The conflicts are particularly difficult for commuting cyclists, some of whom are loath to slow down.

2. An expansion of the definition of ‘multi-use path’ would open options that are not clearly included at the moment. Multi-use pathways in the Basin should have an element – probably a parallel, separate path – that would cater to slow-moving walkers, runners and joggers. The foot traffic path could be built entirely separated from the paved path or built as a non-cambered shoulder.

3. Multi-use paths are appropriate for areas where there is low density of use by walkers, runners and cyclists, but should not dominate planning for the heart of the very heavily used park system in the center of Boston. Instead, the overriding goal should be provision of facilities in which space is plentiful for all park users and potential conflicts between users are minimized using methods that are appropriate to each location.

4. Existing multi-use paths should be expanded all along the river to meet the definition of separation between paths based on user needs.

5. Recognition of what runners and joggers show about their desires for facilities would help in planning new paths. Narrow dirt paths that exist informally alongside many of the paved paths in the Basin demonstrate a clear desire for a softer surface preferred by runners. The softer surfaces can also be used by pedestrians and will clearly help separate cyclists from people on foot.

6. A demonstration of the path separation is included in the proposal for the Greenough Boulevard narrowing. The effects on users would be an important element to explore.

7. Path separation in the near term may only be possible on one side of the river. The Greenough Boulevard proposal and the Memorial Drive narrowing between the Eliot and Anderson Bridges point in the direction of path separation as a major feature on the north bank. Continuation of path separation both west and east of these two segments would be a next logical step. Except at intersections, parkland seems to be available for new or modified paths.

8. An unfortunate aspect of all path planning along the river is the intersections with streets at the bridges. The narrow paths that exist at many of the bridges will be a major feature of riverfront paths for a long time, but should not preclude path separation away from the bridge intersections.

9. As long-term improvements, underpasses at bridge intersections are appropriate and important options that will enhance the recreational and transportation options for many Basin users.

We 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 Nicole Freedman, Boston Bikes
Cara Seiderman, City of Cambridge
Steve McLaughlin, MassDOT
Margo Levine Newman, The Esplanade Association
Renata von Tscharner, Charles River Conservancy
Herb Nolan, Solomon Fund
Jackie Douglas, LivableStreets Alliance
Pete Stidman, Boston Cyclists Union
David Watson, MassBike
Tom Grilk, Boston Athletic Association

Comments on the DEIR for The Boston Garden, MEPA #15052

November 8, 2013

Secretary Richard K. Sullivan, Jr.
Executive Office of Energy and Environmental Affairs (EEA)
Attn: Alex Strysky
100 Cambridge Street, Suite 900
Boston MA 02114

Commissioner Thomas Tinlin
Boston Transportation Department
One City Hall Plaza
Boston, MA 02201

RE: Comments on the DEIR for The Boston Garden, MEPA #15052

Dear Secretary Sullivan and Commissioner Tinlin:

WalkBoston has reviewed the DEIR for the Boston Garden project. The proposal will improve the second largest pedestrian, transit and commuter rail interchange locations in the city. From WalkBoston’s perspective, one of project’s key challenges is handling the many daily pedestrian trips generated by subway and commuter rail riders, on-site workers and residents, and the large crowds generated by the TD Garden Arena.

The design of the 2.8 acre site includes a large office building, a hotel and a substantial residential building, comprising 1,870,000 square feet of new structure. The basement and first two levels of the building are predominantly retail. A lower level garage expands the existing below-grade parking facility by 800 spaces, for a total of 2075 in the complex.

The magnitude and importance of pedestrian access has prompted a number of comments and questions about the ways in which the proposed plan meets the needs of walkers both to and within the site. It is very important to distinguish between the site design, which is under the control of the developer, and the design of Causeway Street, which is under the control of the City. We believe that these two components must be designed to work well together, and our comments address both areas because it is not possible to separate them from a pedestrian perspective. For that reason we have addressed our comment letter to both MEPA and the City of Boston Transportation Department.

CONFUSION ABOUT PEDESTRIAN CROSSINGS OF CAUSEWAY STREET

The DEIR includes a design for Causeway Street that has been superseded because of the City’s receipt of a federal TIGER grant that will pay for the reconstruction of the street. As described to WalkBoston by several City staff members, the designs shown in the document are currently being modified by the City to incorporate cycle tracks instead of bicycle lanes and to possibly alter original alignments of lanes on the street. New designs will change the approved 25% design drawings for all pedestrian crossings on Causeway Street, and for vehicular accommodations on the street as well. The details of the proposed changes have not yet been shared, and WalkBoston will actively participate in review of the new design once it is presented. Rather than provide comments on the current design we have focused this letter on suggestions about elements we would like to see in the new design.

MAJOR PEDESTRIAN ISSUES

1. Projected pedestrian volumes into and out of the site exceed vehicular volumes.
The number of people who currently enter the rail and arena adjacent to the site is impressive. Per the MBTA Blue Book, there are 26,763 weekday commuter rail boardings at North Station, and 16,702 weekday entries into the Green and Orange Lines. In addition many more people use the transit lines, streets and sidewalks when an event is scheduled in the 19,000 seat TD Garden. North Station is the 2nd busiest transit station in the MBTA system (exceeded only by South Station). Causeway Street carried 14,800 vehicles per day in 2009, according to MassDOT.

2. Pedestrian crossings of Causeway Street are one of the most important issues to be explored.

a. Canal Street is the major pedestrian approach to the site.
Reflecting the significant anticipated growth in transit and pedestrian trips, a new pedestrian entrance to both the rail station concourse and the TD Garden is planned for the location where pedestrians will cross Causeway Street from Canal Street. Historically Canal Street served as the pedestrian route to North Station from the Downtown financial and retail districts, and in the planned design it will regain that prominence (Fig. 1-14.)
Walking along Canal Street is fostered by wide sidewalks and by the street’s slow speed, narrow travel lanes, corner bulb-outs and traffic signal designs. Pedestrians are encouraged to follow a walking route along Congress Street from the financial district and up Canal Street to North Station.
Retail property uses along the frontage of Canal Street have also changed over time and it now includes many uses catering to people attending sports events including bars and restaurants with large outdoor seating areas.
The private and public expenditures on Canal Street have emphasized it as the primary walking route, thus leaving Friend, Portland and Haverhill Streets much less used by walkers.

b. The design of the Canal Street entrance emphasizes its importance
“Champions Way,” is the grand entrance into the project from Causeway Street – directly aligned with Canal Street. It is approximately 50’ x 200’ (10,000 square feet), sized to handle large numbers of people accessing the site and lined with retail facilities to attract walkers. (Nothing of this nature is proposed for either the Friend Street or Haverhill Street approaches.)
About half of Champions Way will be open to the sky, and at the far end, near the rail concourse, is a ‘mixing bowl,’ where the entrance is divided into three parts leading to the Commuter Rail Station, the second-floor TD Garden and the below grade North Station subway station.
Interestingly, the proposed Champions Way has roughly the same dimensions as the Channel Gardens/Promenade leading into New York’s Rockefeller Center. The New York example spreads out into wide sidewalks at either end of the Promenade; here, that would be somewhat comparable to the wide sidewalk along Causeway Street and the expanse of the rail station concourse at the opposite end of the entrance court.
Other local comparisons are also apt. The Canal Street entrance is about one-half the length and roughly the same width as Yawkey Way, used as a pedestrian street for access to the 40,000-seat Fenway Park. South Station’s main entrance has roughly 6,500 square feet divided into two walkways and a row of escalators and small shops. The South Station vestibule also connects with relatively large open areas on both ends, a triangle of sidewalk in front of the station is about 9,300 square feet and a plaza for pedestrians on the opposite side of the street is an additional 17,500 square feet.

c. The new entrance to the site is more than a replacement of existing site entrances.
Walkers currently enter the TD Garden and rail station concourse via east doors facing the sidewalk along Legends Way and west doors facing the O’Neill Building path. This layout is reflected in current pedestrian access patterns with existing peak hour pedestrian traffic heaviest where Friend Street crosses Causeway Street, as commuters walk toward the western doors. The same pattern does not exist at the intersection of Haverhill and Causeway Streets, perhaps because walkers heading to the east entrance use the MBTA’s underground passage beneath Haverhill Street. Once the proposed new development is in place, the importance of the east and west entrances will diminish significantly and the new entrance at Canal Street will be the focus.

3. Projections of pedestrian activity on parallel streets do not seem to reflect the current design. Causeway Street intersects with four streets in front of the project site – Portland, Friend, Canal and Haverhill, and the distance between the streets is quite narrow. The intersections of Portland, Friend and Canal are three-way, and Haverhill St. is a four-way intersection. All have at least one crosswalk, and there are signals at Haverhill and Portland Streets. A brief analysis of each street is useful to explore their role in the pedestrian network leading to North Station. As noted above, Canal Street is the primary pedestrian route and the other streets have narrower sidewalks, fewer retail outlets catering to Garden event patrons, and more parking lots that reduce the quality of the pedestrian experience.

Portland Street, slightly west of the project site, serves relatively few pedestrians. Most walkers on this street may be heading toward the O’Neill Federal Building at the corner of Causeway and Merrimac Streets, and some may be heading toward the west entrance to the TD Garden and the rail station concourse, although the walking route is not direct.
Friend Street provided a more direct route to the west entrance of the TD Garden/Rail Station, but it crosses Causeway Street at a location that does not align with the O’Neill Building pathway, and the existing diagonal path across the project site will disappear with the new development.
Haverhill Street provides access to the Orange Line/Green Line station, and both sides of this 2-block street have been recently developed with large apartment buildings. However, many loading zones for the new buildings and vehicular entrances make the street less pedestrian-friendly than Canal Street.

4. Pedestrian volume projections may need re-examination.
Existing and projected pedestrian volumes for the four street crossings are provided in the document. Existing pedestrian volumes are highest in the weekday AM peak hour at Portland Street which would seem to stem from Commuter Rail passengers walking from North Station, exiting via the west door and walking toward downtown.
In future projections for the 2017 Phase I development, all pedestrian movements grow, but the largest growth is projected for Friend and Haverhill Sts. which lead only to the east and west entrances to the building. Canal Street traffic grows somewhat, but Haverhill Street projections for the AM peak hour grow to be 10 times larger than the existing pedestrian movement at that intersection. It is unclear if these volumes reflect a route using Haverhill Street’s underpass beneath Causeway St. and the sidewalk along Legends’ Way leading to the east doors of the rail station and the TD Garden. It seems unlikely that such high volumes could cross Causeway St. safely at grade.
For the 2028 full-build, pedestrian volumes grow again, but the pattern is difficult to understand: pedestrian numbers increase substantially at both Friend and Haverhill Sts., but change very little for Canal Street, despite the design’s clear emphasis on the new entrance focused on the traditional walking path from Downtown to North Station.
By contrast, vehicular traffic through the four intersections changes very little from existing levels, declines slightly for the 2017 Phase I, and rises again for the 2028 full-build.
We are puzzled by the projections and request that the proponent describe the volumes and their projected locations in detail.

5. The traffic signal program for Causeway Street needs re-examination.
If this development is to focus its principal entrance on Canal Street, and pedestrian traffic at that location is to increase, the intersection of Causeway and Canal Streets must be signalized for pedestrian safety. The DEIR deliberately fosters jaywalking at both Canal and Friend Streets: a logic of unsignalized intersections is stated in the report: “The unsignalized crossings of Causeway Street at both Friend Street and Canal Street operate at a pedestrian LOS F during the peak hours independent of the full build-out of the Project. Again, under actual operating conditions, pedestrians cross these locations in a platoon when a gap in traffic is afforded in at least one direction on Causeway Street thereby resulting in less pedestrian delay than predicted by the analysis model.”(DEIR page ES-7; pages 3-2 & 3-4; table ES-4)

PROPOSED SOLUTIONS
WalkBoston is excited about the pedestrian service this project will provide. To make the project more appealing and safe for walkers, we suggest the following steps that would more clearly recognize the important role of pedestrians in accessing this site:

THE CAUSEWAY STREET FRONTAGE OF THE SITE

1. Propose a hierarchy of pedestrian crossings on Causeway Street. Canal Street will be the most important pedestrian crossing of Causeway Street (on ground level) based on this design. Haverhill Street is the most important pedestrian crossing of Causeway Street (that passes underground) based on this design. Friend and Portland Sts. will be relatively lowvolume pedestrian crossings.
2. Think of Canal and Haverhill Sts. (and possibly Friend St. as one intersection to aid in finding pedestrian solutions. The block front distance between Haverhill Street and Canal Street is manageably short (about 120 feet). Friend St. is a bit further away from Canal St.
3. Signalize Canal/Haverhill Street at Causeway Street as a single coordinated traffic intersection. Portland St. could also readily be signalized. Friend St. does not necessarily need a traffic signal, if alternative pedestrian crossing locations can be encouraged and if sidewalk and street crossing designs discourage pedestrians from crossing at this location.
4. Build a level pedestrian crossing table for this intersection to slow traffic from both directions. The table should extend a total of at least 200’ from the MBTA headhouse area at Haverhill and Causeway Sts. to the west side of the intersection of Canal and Causeway Sts.
5. Try to attach Friend Street to this raised crossing, recognizing there will be some difficulties. Canal, Friend and Haverhill Sts. constitute the majority of pedestrian crossings 5 on Causeway St. and thus may be considered as a single unified crossing location. Friend Street might be included in the raised table, but issues arise. First, extending the platform to Friend Street doubles its length, potentially leading to the use of the street for storage of vehicles at signals that may interfere with large-volume pedestrian crossings. Second, an additional signal at Friend St. so close to the Canal/Haverhill signals complicates the vehicular signal patterns for the whole street. Third, much of the proposed truck service traffic into the site is located at a door between Friend and Canal Streets, perhaps causing conflicts with surface gradients of the proposed raised platform and adding turning movements into a pedestrian facility. Entrances and exits into this truck service area should take place only from westbound Causeway Street – thus, no left turns for eastbound access.
6. Permit no left turns to or from Causeway Street. Both Causeway Street westbound and Haverhill Street northbound can become vehicular entrances into the site’s parking garage, but exiting traffic from this ramp should only be permitted to turn left to find its way to the Central Artery or Keaney Square. Traffic exiting here and wanting to turn right should be encouraged to use the existing exit ramps at the rear of the building, where Nashua Street provides direct access to Storrow Drive, Route 28, and the entrances to the Central Artery bridge and tunnels.
7. Design the cycle track proposed for Causeway St. to minimize impacts on pedestrians. The alignment of cycle tracks should not interfere with pedestrian movement. Cycle tracks could be located in space where landscaping is proposed. Cycle tracks should be located together so that pedestrians know where to expect bicycles. Pedestrians should be informed of the existence of the cycle tracks through a combination of eye-level signs and painted warnings on the pavement. Bicycle signals and signs in both directions should be installed to warn of pedestrian crossings. Bicycles waiting for signals and thus stored on the raised pedestrian platform should be minimized. Curbing along the cycle track should disappear at the raised pedestrian platform at Canal/Haverhill Sts. to avoid mishaps and to comply with ADA regulations.
8. Design lanes for movement on Causeway St. carefully. Preliminary designs indicate four 10.5’ vehicular lanes, a 5’ cycle track in each direction (possibly combined), a median strip of 6’ located between the two cycle tracks, and restrictions on existing turning movements at both Canal and Friend Streets.

WITHIN THE SITE

1. Reflect by design the number of pedestrian movements anticipated in Champions Way.
Where Champions Way meets the entrances to the TD Garden and the rail station concourse, pedestrians will be passing through between:
• The Green and Orange Line subway stations and the Commuter Rail Station
• The Commuter Rail Station and TD Boston Garden
• The Green and Orange Line subway stations and TD Boston Garden
• Canal St. and the Commuter Rail Station
• Canal St. and TD Boston Garden
We are concerned about the dimensions of this complex entrance and especially the ‘mixing bowl’ near the entrance to the TD Garden and suggest a detailed analysis to explain its ability to fully, conveniently and safely handle the many pedestrian demands to be placed on it.
2. Reconsider the dimensions of the MBTA underground passageway between the ‘mixing bowl’ and the subway station to maximize pedestrian convenience, safety and service. It has a 90-degree turn at one location, along with an inconsistent width progressing through the site. Additional width may be essential at the 90-degree turn. The queue of pedestrians at the bottom of the escalators should have adequate space for waiting.
3. Add a stairway inside the ‘mixing bowl’ to avoid overcrowding of the escalator and elevators. A stairway would also offer an opportunity for people to exercise during their on-site walk from the subway to the Garden or the commuter rail concourse.
4. Provide generous space for pedestrian circulation in and around the first floor at Champions Way.
The DEIR design has two escalators, two stairways (leading upward only) and two elevators (leading downward only.) Space is provided on both sides for people walking through between Canal Street and the rail station concourse. It is important that these facilities and spaces are matched closely to anticipated pedestrian traffic. It may also be important to look forward to future pedestrian traffic to be certain that the spaces and facilities are able to handle projected demand. For example, escalator redundancy may be a consideration to assure that pedestrian traffic moves without impediments.

BEHIND THE SITE

1. Commit to financial aid for the construction of the Charles River Southbank
pedestrian/bicycle bridge over the MBTA tracks. This proposal has been on the agenda for a considerable time. It has been proposed to complete the various pedestrian/bicycle projects along the Charles River in the vicinity of North Station. It will benefit all of the users on the South Bank of the river, and will aid non-motorized traffic to reach the site of this project.

WAYFINDING
1. Signs and other indications of routings for pedestrians should be provided to aid walkers and to direct pedestrian traffic to certain entry points.

We 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,

Robert Sloane Wendy Landman
Senior Project Manager Executive Director

Comments on the DEIR for Caesars Resort At Suffolk Downs, MEPA #15006

October 11, 2013

Secretary Richard K. Sullivan, Jr.
Executive Office of Energy and Environmental Affairs (EEA)
Attn: Deirdre Buckley
100 Cambridge Street, Suite 900
Boston MA 02114

RE: Comments on the DEIR for Caesars Resort At Suffolk Downs, MEPA #15006

Dear Secretary Sullivan:

WalkBoston has reviewed the DEIR for a Caesars Resort at Suffolk Downs. The DEIR documents walking improvements that the proponent will undertake as part of the plan and we are generally pleased with the proposals. We offer comments below to supplement the current proposal with further improvements.

The scale of the site proposed for this project is noteworthy. The existing roadway extends nearly a mile through the L-shaped site between Route 1A and Winthrop Avenue, and the site is roughly 3,000’ north-south and east-west. Opportunities for integration with the existing community are substantial, as the site is bounded by industrial uses on the west side, by residential neighborhoods on both the north and south sides, and by the combination of the MBTA Blue Line, Bennington Street and the Belle Isle marsh on the east side. The urban setting of the project sets the stage for planning elements to allow the development to relate physically and operationally to the surrounding community.

Recognizing the scale of the site, its urban location, and the number of people anticipated to be present each day, the proponent has made efforts to shift trips away from private vehicles and toward public transportation. This is in keeping with the recently announced MassDOT statewide goal of tripling the share of walking, bicycling, and transit travel in Massachusetts. Reducing auto dependence would also reduce the environmental impacts of the development and help preserve capacity on the adjacent highway network. In addition, encouraging greater use of active travel options – walking and biking – will help the development achieve some positive public health effects. We believe that there are additional measures that could be taken to further reduce auto trips and have described several opportunities in our comments.

The details of the development plan offer evidence of some innovative thinking that has created opportunities for walkers on the site. For example, the introduction of water-catching swales on parking lots creates an opportunity to construct parallel walkways that are more pleasant ways of walking through open parking areas. Our comments are organized into those affecting access to and through the site and the pathways that help people get where they want to go within the site.

A. Access to the site via MBTA rapid transit service.

The Blue Line forms one boundary of the site, and has two stations near the proposed project – Beachmont Station and Suffolk Downs Station. Most of the Blue Line users are expected to use the Suffolk Downs Station.

This is reflected in the proposed walkways, bikeways and shuttle bus services to be constructed at that location. No improvements are proposed at Beachmont Station. The proponent has estimated that 15% of daily trips to and from the site will be made via the Blue Line. A total of 4,00o on-site employees are projected, and 40% of these employees, or 1,600 people, are expected to use public transit daily. In addition, 11% of the 23,674 to 32,992 daily casino visitors (2,614 – 4,086 people) are expected to use the Blue Line for access. Since there is no current MBTA bus service to the site, all of the public transit users – some 4,000 to 6,000 people per day – are expected to access the site via the Suffolk Downs Station, which in recent years has handled daily traffic of roughly 1,000 riders.

In recognition of this major impact on the use of rapid transit by employees and visitors to this site, the Suffolk Downs Blue Line Station will be upgraded by the proponent to handle anticipated transit and foot traffic. Elevators will be added on both sides of the tracks to make the station fully accessible and convenient for people wanting to cross the tracks between Bennington Street and the site. We offer several suggestions regarding the MBTA station and the access it provides to the site:
1. A new plaza in front of the station should encourage access for all users, using a design that provides adequate space for walkers, bicyclists and shuttle bus users.
2. The connection into Orient Heights should be enhanced and the proponent should work with neighborhood residents to design a connection that encourages safe and pleasant walking to the station.
3. The shuttle bus shelter proposed near the plaza should have signage that includes both bus and walking information, including the estimated walking time from the station to the casino and other facilities in the proposed development.
4. Walkways between the station and on-site buildings should be attractive, safe and conducive to walking. Separate paths for pedestrians and bicycles are an important and positive design feature. This separation should be made very clear to users, through a significant landscaped buffer strip and wayfinding signs that clearly indicate the separation. Different textures or colors of surface pavement, slightly different elevations, or decorative pathway curbs could all help signify which path belongs to pedestrians. Walkway lighting could also be designed to distinguish pedestrian lighting from the roadway/bikeway lighting.
5. East Boston Greenway connections should be thoroughly explored. The Belle Isle Marsh lies across Bennington Street from the main entrance to Suffolk Downs MBTA Station. Plans show a path along the marsh edge connecting to the existing East Boston Greenway, and the proponent has agreed as part of a consent decree with the US EPA to fund a new boardwalk at Belle Isle Marsh to improve public access and protect natural resources within the marsh. In the short term, the path and the boardwalk should be considered concurrently and include a link to the Suffolk Downs Station. Pedestrian access improvements on Bennington Street could include moving the existing crosswalk now located at Leverett Street 200 feet north to align with the main station entrance and the route of the Greenway at the edge of the marsh. This would allow an extension of the Greenway into the proponent’s site, where significant new open space with paths and nature trails could expand and extend the Greenway network to Route 1A and to Winthrop Avenue.
6. Future Greenway connections should be considered. The East Boston Greenway, if extended through the proponent’s site to Route 1A, could eventually be extended to link with walkways on the opposite side of Route 1A along Chelsea Creek in Revere, where open spaces are cited in the DEIR as possible future projects.

B. Access to the site via MBTA bus service

The DEIR includes a proposal for MBTA bus service within the site, including a stop on Tomesello Drive near the entrance to Casino Area II, but bus service on Route 1A is not addressed in the DEIR. MBTA bus service should be more completely examined, as it could significantly affect access to the site from throughout the region. In addition, it could affect internal site pathways – their alignments, construction standards and levels of potential use.

1. MBTA bus service within the site has not been detailed to explain off-site routings and their consolidated or separate connections into the site. Such bus service might supplement private carriers such as the anticipated dedicated charter buses and shuttles from Logan airport, nearby business districts and other major tourist, cultural and travel venues in Boston, Revere, and the surrounding region. MBTA bus service should be more clearly explained as a possible option, including potential routes that might be devoted to accessing the casino/racetrack on this site from a variety of locations.

2. MBTA bus service along Route 1A should be more thoroughly explored. Currently, MBTA service on Route 1A consists primarily of express buses which run between Salem, Lynn and Boston or the airport. Route 1A may also be an appropriate route for bus service that serves this site and could affect the attractiveness of public transit options.

3. Future Route 1A bus service might stop near the site’s principal entrance at Tomesello Drive. Bus stop locations would need to be closely coordinated with proposed traffic signals at Route 1A and Tomesello Drive because pedestrians would cross Route 1A using this signal. It is likely that a separate pedestrian phase at the signal would be needed.

4. Route 1A bus stops at Tomesello Drive should be connected to all pedestrian paths leading to the casino and racetrack. A primary, well-marked pedestrian path is essential and should be located on the same side of Tomesello Drive as a bus stop. It should be well designed, attractive to walkers, safe, well lit, and signed to reassure visitors that they are on the right track. Ideally, the pedestrian path should be separated from the bicycle path. Distances in time might be added to encourage walking along this route. It is about a 10-minute walk from Route 1A to the entrance to Casino II.

5. Late night MBTA transit service should be considered to serve both patrons and staff. This may require subsidies by the proponent to support increased transit service that would not otherwise be provided by the MBTA, such as late night Blue Line service or bus shuttles from Downtown Boston. Late night service would help shift workers and patrons away from private vehicles.

C. High Quality Design, Amenities and Year Round Maintenance

WalkBoston assumes that the proponent will commit to providing the levels of landscaping, lighting, security, snow shoveling and maintenance needed to make transit riders, pedestrians and bicyclists feel invited, safe and comfortable year-round. Because the site is so large, and the length and number of pathways and sidewalks are so substantial, this will require a serious commitment of resources. WalkBoston believes that this investment is needed to ensure that the proponent’s projection that 15% of trips to the site will occur via the Blue Line. As noted above, we urge the proponent to also investigate the potential to shift additional trips to public buses.

D. Pedestrian paths through the property

WalkBoston is pleased to see the attention paid to walking paths through the property. Each of the paths are discussed below.

1. The path between Suffolk Downs MBTA Station and the South Plaza is the site’s prime example of walking/biking path separation. Separate paths are preferred by both walkers and bikers and should be considered for the other paths on the site. The path follows a new street called Blue Line Road that will provide access for the shuttle bus between transit and the casino and other facilities. The physical layout includes a 23’ roadway, with an 8’ two-way bikeway immediately adjacent to it. An 8’ two-way walkway is separated from the bikeway by a 6’ wide greenway and from the horse track by an 18’ landscaped buffer and fenced grassy area.

2. The path along the edge of the racetrack connects directly with the station path described above and provides one part of a connection that traverses the entire site from south to north, on a route that follows the edge of the racetrack, past the apron, the paddock for parading horses and the grandstand. It connects to the Sales Creek Path and the path leading along the edge of the North Parking Lot and to Winthrop Drive at north edge of the project site. This long attractive walking route could potentially be of significant use as a recreation trail. However, the DEIR calls for ‘controlled’ use of the path, and the degree to which public access will be allowed should be explained in detail.

3. Possible pedestrian connections to Orient Heights. The edge of the proponent’s site is separated from Orient Heights by a steep grade along most of its southern boundary. However, at one location, near the point where Tomesello Drive currently makes a 90- degree turn, the grades of Tomesello Drive and Waldemar Avenue coincide. If the residents of Orient Heights are interested, the project proponent should explore new pedestrian access at this location to provide a connection into the South Parking Lot which would allow pedestrians to walk via on-site pedestrian paths and sidewalks between Orient Heights and the Suffolk Downs facilities and the shopping area along the west side of Tomasello Drive.

4. Path connections meet at the South Plaza, where there is a major entrance into the casinos. This is where the path from the Suffolk Downs MBTA station and from the South Parking Lot connect with the Winter Garden entrance and the link between the casino areas and the North Plaza. The plaza is proposed to be a shaded space with adjacent activities such as a sidewalk café. It has a good model – the Lincoln Center grove of trees – and affords a place to walk, with ample sitting areas where people can wait to meet others arriving at the south entrance, or take an outdoor break from other activities. The South Plaza is also called out as a location for active events. A description of the possible events should be provided, as they may affect the layout and pedestrian use of the plaza.

5. The path between the Route 1A site entrance and Casino Area II is a handsome entrance amenity for the site. It will become especially important if bus service and bus stops are added at Route 1A. The total distance from Route 1A to the entrance to Casino Area II is approximately 2,400’ – about a 10-minute walk. At the moment there are two paths proposed, passing through areas to be extensively landscaped around restored water areas. The paths could readily become parts of the East Boston Greenway.
However, the alignment of the walks may need attention for walker safety. The current location of the walks, though parallel to Tomesello Drive, is some 50’ away from it. This distance may be too far for walkers to feel safe. Many designers suggest that pedestrians should be visible from the roadway and that they should be able to reach the roadway in case of an emergency. A more suitable distance, predicated on safety, should be explored.
It may also be useful to explore if both of these walkways through this pleasant green area are essential. One walkway, located along the desire line of people expected to use it between the bus stops on Route 1A and the casinos, may be all that is needed. The proposed bollard lighting system sounds promising and should be help provide maximum safety for walkers.

6. Paths from Route 1A lead to the plaza/main entrance to Casino Area II where significant vehicular access is proposed. Four lanes serve the entry point and there are direct connections into the underground parking beneath Casino II for this valet parking area. At this entry point, a large roof above the vehicle lanes (called a porte cochere) provides weather protection. Because many vehicles, including taxis, will arrive on each of the four lanes, it will be important to know how pedestrians will be able to safely walk between their cars and the entrance to the casino. (This area is similar to the drop off and pick up area at airport terminals, where many pedestrians are required to walk across a number of lanes of arriving and departing vehicles.)
An additional question concerns direct access for people arriving from Route 1A or from the MBTA Station on foot. The current plan includes an indirect route for the approaching walkway rather than a more direct route. People who have walked from Route 1A should not be asked to walk several hundred feet out of their way when they can see the entrance clearly ahead of them.

7. Paths along Tomesello Drive north of the casino area are proposed for the west side of Tomesello Drive as far as the traffic circle entrance to the parking garage and North Plaza. On the east side of Tomesello Drive, paths are shown from Route 1A all the way to Winthrop Ave. The path on the east side is separated from the road by an 8’ buffer; on the west side it is not clear whether a buffer is provided. The paths are 14’ wide and are twoway shared bike-ped facilities. A planted 6’ wide slope separates the path from the parking bays north of the parking garage. Overhead lighting is designed to provide illumination that differs between the roadway and the path.
The proponent should consider whether the proposed path on the west side of Tomesello Drive is essential for access to any part of the site, and whether it will see much use.

8. Path connections at the North Plaza will serve significant numbers of visitors who will enter both casinos via this large square. The plaza provides access for all bus and limo shuttle services at a scale that indicates that many buses are anticipated. At the north end of the plaza there is a weather-protected drop-off location where individual drivers can access Casino Area I and the racetrack. Access to Casino Area II is provided at the south end of the plaza through the Winter Garden.
The North Plaza is approximately 500 feet long and 200’ wide, encompassing 2.2 acres. It is laid out with two lanes of traffic surrounding it (suggesting a one-way pattern of traffic movement) with adjacent sidewalks for loading and unloading visitors to the sidewalks adjacent to the casino entrances. Vehicular access into and out of the plaza is provided by four lanes of traffic that connect the plaza and the large parking garage to Tomesello Drive. No pedestrian paths are provided along these routes.
The plaza is designated as an event space and viewing area, which is still undefined. The side of the plaza abutting the Grandstand and Casino Area I appears to have the widest sidewalk leading directly into the casinos. This is where many of the bus and shuttle services are likely to discharge and pick up passengers. On the opposite side of the plaza is the large parking garage. Rather undefined sketches show the first floor of this garage as a future retail area.
It will be important to design the North Plaza so that pedestrians have a pleasant and safe walking experience. Especially important will be the provision of visual interest for the very tall and lengthy facades and the provision of landscaping to provide walkerfriendly scale and materials. To clearly separate pedestrians from vehicles, safety improvements such as bollards, seating areas between the line of trees, and different treatments of sidewalk surfaces should be considered. To make the area more interesting for walkers entering the casinos, the west wall of the Grandstand facing this long sidewalk might considered for the installation of art or information diagrams or posters.
It is also important to ensure that air circulation systems diminish the accumulation of exhaust fumes from the many vehicles in the plaza.

9. Paths to and through the parking structure should be detailed. A second-level walkway connects the garage directly into Casino Area II, but access from the garage to Casino Area I and the racetrack involves crossing the busy North Plaza at crosswalks. These crosswalks should be designed for the safety of walkers passing through the traffic bringing visitors to the site.

10. The path between the North Plaza and the North Parking Lot is a long, straight walkway serving users of the 1,468 parking spaces. A tree-lined path connects all of the site’s activities to the shopping area west of Tomasello Drive. As a unique on-site feature, transverse swales across the parking lot are planned to direct storm water runoff into the underground drainage system. It is unclear if these swales will be landscaped. As currently planned, there are four transverse swale areas laid out to separate every three or four rows of parking and to collect runoff through their permeable surfaces. For each of these transverse swale areas, the opportunity exists to create shaded walking paths along each swale. A similar opportunity may exist at the South Parking lot.

11. The Sales Creek Path is approximately 800 feet long, and extends from the racetrack diagonally to Tomesello Drive on a route that parallels an original waterway. This route affords the proponent an opportunity to use the creek as a focus of landscaping to provide screening at the edge of the North Parking Lot, and create a shaded place to walk. It might be possible to extend the landscaping along the creek up to Tomesello Drive on both sides of the street, and use the creek as a major feature that designates the entrance into the site.

E. Boardman Street Overpass

A path along the proposed Boardman Street overpass should be constructed to replace the existing sidewalk that parallels Route 1A between Boardman Street and the site entrance. A buffer strip between the sidewalk and the overpass would be desirable, as the overpass is likely to be very busy. Connections into existing adjacent open space and the new sidewalk might be considered in consultation with residents of Orient Heights.

We 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 Robert Sloane
Executive Director Senior Project Manager