Tag: FEIR

Westwood Station Comment Letter

October 24, 2007

Secretary Ian Bowles
Executive Office of Energy and Environmental Affairs
MEPA Office
100 Cambridge Street, Suite 900
Boston, MA 02114

RE: Comments on the Final Environmental Impact Statement for Westwood Station,
University Avenue, Westwood, MA
EOEA # 13826

Dear Secretary Bowles:

WalkBoston appreciates the opportunity to comment on the FEIR for Westwood Station. We are commenting because of concern about the pedestrian connections to this site. We are especially interested in commenting on the progress made since the DEIR in incorporating pedestrian facilities and concerns into the proposal.

As the FEIR points out, the existence of superb access to both local and intercity rail service makes the site a great opportunity for a mixed-use transit-dependent community. In this community, pedestrian facilities will be of the utmost importance to create a significant town center for new and existing residents of the region.

The scale of the proposed development is so large that there are challenges to making it safe and convenient for pedestrians. The total development program for Westwood Station is approximately 5 million square feet:
• 1,348,000 square feet of retail and restaurant space located from the MBTA station through the large commercial area south of Rosemont Road. This includes five or six multi-story buildings with ground-floor retail, with smaller scale retail between the larger stores and parking garages on the surrounding streets. The development encompasses more retail square footage than the South Bay Plaza in South Boston, Natick Collection (formerly Natick Mall), North Shore Plaza and Liberty Tree Mall in Danvers, South Shore Plaza in Braintree, or Burlington Mall.
• 1,295,000 square feet of residential uses (1000 housing units)
• 328 hotel rooms
• 1,490,000 square feet of office space
•11,985 parking spaces – 600 for residences, 3676 for offices, 7709 for central commercial

Summary Observations

The site is isolated from its surroundings and principal access will be via car, with a small proportion by train. Access to abutting neighborhoods is not improved by the project.
The real main street of the project is Westwood Station Boulevard because vehicular access to and within the site is principally by car.
The development has three distinct districts each representing different opportunities for pedestrian activity and safety. We have examined several of the indicators of walkability for the project as a whole and for the three areas individually.
– The north end of the project – the area between the MBTA Route 128 Station and Rosemont Road, east of Westwood Station Boulevard – is a mixed use shopping/housing/ hotel/office district that includes virtually all of the proposed housing units, two office structures, two hotels, street-level shops, and most of the usable public open space (the Common, the Promenade and the Meadow.) This is the most pedestrian-friendly district.
– The south end of the project – between Rosemont Road and Harvard Street, east of Westwood Station Boulevard – is a more traditional “big box” mall, with large sites for retail establishments, separated by parking areas and garages. There are a fair number of small street-level retail units along Market Street, the central pedestrian way.
– The west side of the project between Westwood Station Boulevard and the adjacent residential area – is an area of office buildings backed by landscaped buffering space between the development and the adjacent community.
– Both the south and west districts could be improved gradually in keeping with the observed market for mixed-use development and on-site pedestrian needs.
From a large scale transportation perspective, it would be desirable to have the dense office uses near the station, and not west of Westwood Station Boulevard where they are not within easy walking distance of the station. For example, if the garages adjacent to the hotels had office use above them (or parking below grade), the office use would in fact be transit and pedestrian friendly. The currently planned location for significant office use will generate a great deal of traffic for a use that could be served by transit and contribute to the pedestrian life of the Market Street area.
Sidewalks should be provided along all streets. Design standards for all pedestrian facilities should be clearly articulated.
Recreational walking facilities should be expanded and made into a system useable for jogging, strolling and biking.
Walking facilities should be used to increase transit use to reduce vehicular traffic.

Walkability analysis

1. Access to and through the site

Only a small proportion of the daily traffic into the project area is anticipated to be on foot (excluding drivers accessing a building on foot after parking). Most of the walkers will be coming from public transit connections or the MBTA station at the north end of the project. Few walkers are anticipated from abutting neighborhoods.
Westwood Station Boulevard is the real main street of the project. It is the principal connection to local streets and the expressway network, and will carry the lion’s share of vehicular traffic. The large-scale uses in the project – the big box stores and the office buildings – front on the boulevard, while the smaller retail stores front primarily on Market Street. The boulevard design capacity encourages traffic to use it for access throughout the site.
The design emphasis on Westwood Station Boulevard may afford a bypass of the north end of the project with its shops and attractive pedestrian environment. The five street access points from the boulevard into the project encourage drivers to use the boulevard as the major spine of the site, with Market Street being only the first of several access streets.

2. Pedestrian amenities

Throughout the project the proponent has worked toward a pedestrian scale design, with shorter blocks, narrow streets, pedestrian-oriented buildings and street furniture. Because of the design of each district, the results vary in terms of pedestrian safety and the encouragement of walking.
At the north end of the project land uses are integrated in an intentional mix to create a vibrant and interesting area for pedestrians who are residents or visitors. Residents, employees and visitors can walk to transit, local shops, restaurants and nearby offices. Connections are easy to make, because of the relatively short distances (1500 feet or less). More pedestrians might be attracted by a civic use of some kind such as a branch library with meeting rooms.
At the south end of the project, only retail uses are included. There is a significant orientation toward open parking lots facing Westwood Station Boulevard – a traditional big box zone. An attempt has been made to bring pedestrians into the district where it abuts the shopping/housing/hotel/office area by providing a two-sided row of relatively small-scale retail uses along Market Street.
At the southernmost end of the project site, the big box layout is most pronounced, with a grouping of three big box retail outlets arranged around a parking area abutting the intersection of Westwood Station Boulevard and Harvard Street. Market Street connects with this area but turns into a roadway for parking access in front of the big box stores. In general, this will not be a pedestrian-friendly area; people who drive here to shop will likely be strolling through parking areas rather than along the central avenue.
The western portion of the project is a single use office area with large garages and no real provision of pedestrian scale environments.
Traditional pedestrian amenities such as street furniture (e.g., benches, pedestrianoriented street lights, public washrooms, etc.) should be included where possible and not only in areas where pedestrian traffic is expected to congregate. Along all transit routes, the proponent should consider covered waiting areas for passenger pick-up, with shade from hot sun and protection from rain.

3. Pedestrian network connectivity (how well sidewalks and paths are connected, and how directly pedestrians can travel to destinations).

The overall project layout features a grid of streets and sidewalks with frequent cross streets, making access on foot reasonable. The only dead end streets are lead directly to destinations – the train station and the Common. Widths of streets throughout the project are principally 1-lane in each direction, except for Westwood Station Boulevard which has 2-lanes in each direction with additional lanes for turning movements.
The east-west pedestrian connections have been designed to aid in crossing Westwood Station Boulevard. These connections should be well marked and signed and include signals with pedestrian phases.
The Common and the Promenade have been introduced as a connected set of civic spaces. These will serve the best mix of uses in the project: offices, small retail stores, and upper floor residences all within short distances of one another.

4. Design standards for sidewalks, street crossings, paths

The overall project features sidewalks along both sides of the street. However, design standards for both streets and sidewalks reflect a high-volume automobile orientation. On all streets except Westwood Station Boulevard, turning radii are much too expansive given the intent to serve slow-moving traffic. Turning radii that are too large encourage higher speeds, add to pedestrian crossing distances, remove waiting areas of sidewalk and interfere with safe pedestrian crossings.
The project should include universal design features (transportation systems that accommodate special needs, including people using wheelchairs, walkers, strollers and hand carts).
Where possible, sidewalks might be partially covered – perhaps awnings along the fronts of retail spaces – for protection of walkers during inclement weather.
North End – sidewalks appear to be wider here than elsewhere in the project, according to the “Proposed Internal Roadway System” map. This suggests that pedestrian traffic is anticipated to be higher here than elsewhere. Wide sidewalks also allow more space for pedestrian amenities (seats, lighting, etc.) and landscaping.
South End – it would be useful to see the design details for sidewalks in this area. From the “Proposed Internal Roadway System” map, it is unclear if the design includes wide sidewalks and favors pedestrian movement and safety.
West Side – The bicycle-pedestrian path on the west side of Westwood Village Boulevard is set back from the street. On the east side of the boulevard, sidewalks are narrow and directly abut the automobile lanes. A divider between the street edge and the sidewalk would be desirable here, both to encourage walking and to make it safer.

5. Walking Safety

The overall project makes few distinctions between categories of traffic allowed on proposed streets. For example, the proponent should designate truck routes (Westwood Station Boulevard and University Avenue appear to serve the major truck needs). Truck traffic should be discouraged from Market Street and other local thoroughfares – anywhere extensive pedestrian traffic is anticipated.
Proposed intersection traffic controls and their effects on pedestrian movement should be indicated. Signals located on site roadway intersections should include pedestrian phases and countdown signals to indicate how many seconds are left in the walk phase. Traffic controls might be needed for mid-block pedestrian crossings.
Traffic calming would help protect pedestrians. Mention has been made of raised intersections to slow traffic. Speed limit signs should be placed throughout the development, and where possible, should be set for low speeds. Streetscape improvements such as lighting, an extensive tree canopy and on-street parking can also make a street more conducive to walking and lead to slower-moving cars.

6. Recreational walking

While the project includes sidewalks and recreational paths leading into adjacent open space, a network of paths is not created. The proposal for a walking/jogging/biking trail along Westwood Station Boulevard could be part of a larger jogging/strolling trail connected via Harvard Street or Canton Street to University Avenue. This would make a large loop (a mile or more) for residents and on-site employees.
• A trail connection is proposed by the Department of Conservation and Recreation between the Route 128 Railway Station and Royall Street in Canton, which leads to the Blue Hills Reservation. Construction drawings of the trail will be prepared by the 5 proponent, with construction to await final design and construction of the I95/I93/128 interchange. An endowment to operate the trail would be extremely beneficial.
A canoe access site to the Neponset River is near the southern end of Westwood Station. There appears to be limited access to the site on foot. Perhaps there can be an extension of on-site trails into this area.
Paths alone cannot provide the level of exercise provided by outdoor playing facilities. The nearest recreation and sports facilities are nearly a mile away at K-5 Downey School, where there is a baseball diamond, tennis courts and a soccer field. On-site, the principal recreation facilities are paths at the Meadow and a dog-walking reservation. Adding a path network and recreation facilities would be helpful and would encourage walking and physical activity.
Sites west of Westwood Station Boulevard may offer some opportunities for additional recreation – space for a ball diamond, courts for tennis, basketball, public gardens, paths for strolling or nature walks, or a jogging track. This space could serve both the residential community and adjacent office employees.
Additional recreation facilities could be located at the Meadow if they did not interfere with the protective area around the wellhead.
A playground could be added in the Meadow, the Common or the Promenade for shoppers’ children or for families with children living in nearby housing units.

7. Public transit

Pedestrian access between the development and the MBTA station must be encouraged. However, given the size of the project, especially its great north-south length, internal transit will be needed to encourage arriving at the site via longer-distance transit and then walking around portions of the site. For shopping, the large stores at the southern end of the development are almost too distant for significant pedestrian traffic from the residential/retail/office/hotel areas. The farthest stores are more than 3,000 feet from the MBTA station – a 20 minute walk and a distance that may be unattractive for shoppers on foot. The proponent has indicated that it will provide a shuttle bus service, equipment and a maintenance facility. A commitment to operation of shuttle bus services on a permanent basis would be appropriate.
The proponent suggests shuttle bus service with shelters that display real time bus arrival times and support safe and efficient use of non-automobile transportation. This would be a welcome level of transit information.
Bus stops should be provided on all routes, signed to preserve space for the vehicles to pick up passengers at shelters.

8. Sidewalk connections

The proponent has committed to building sidewalks on both sides of all streets to be built or reconstructed. This should include the portions of the existing University Avenue that abut properties to the east that are not included in the proposed development site.
It would be useful to know the proposed dimensions of the sidewalks, and documentation should include proposed cross-sections and landscape and lighting design of all streets, sidewalks and rights-of-way.
Pedestrian facilities are largely self-contained within the project site. There are few nearby residences within walking distance and the design seems to assume that access from nearby neighborhoods will occur only by auto. At a minimum, sidewalks should allow pedestrians to walk into the project along the Blue Hill Drive entrance. Other connections into the abutting neighborhood would be desirable.
Pedestrian access directly to the canopied platform of the MBTA railroad station is essential. Details of the proposed connection and the effects that the reconstruction of Greenlodge Street should be provided.
Preferential parking for carpools, vanpools and Zipcars should be provided in locations convenient for users, who are likely to be carless residents or employees. Signs on sidewalks should indicate where the vehicles are located.

9. Encouraging pedestrians

The proponent should institute an active walking encouragement program. This could include maps of the site that are made available at many locations. It could also include transportation access guides to give concise information for accessing a destination by walking, cycling and public transit, and facilities and services for people with special mobility needs.
One of the real tests of pedestrian-friendly design of a residential proposal could be “Can you live here without a car?” Does the area provide for all resident needs, such as shopping for groceries, access to school, work, and recreation? Does the site provide sufficient access to transportation, whether train, shuttle bus, Zipcar, taxi, sidewalk or path? Are there supportive transportation management aids such as the guaranteed ride home that make movement efficient at all hours?

10. Toward full build out

Phase I of the development is scheduled to include all of the retail uses, half of the residential units, the hotels and one office building.
North end. Build out of this area will be almost complete at the end of Phase I. The exception will be the Meadow residential units that await Phase II. It will be critical that essential retail establishments are present to serve the 500 residential units on-site.
South end. Build out of this area seems more difficult. The big box stores at the southernmost end of the site may be readily built, but the midsection of the area is less well defined. This area, with its small stores fronting Market Street, could be the experimental portion of the development, evolving in accord with feedback from the fully built-out residential/office/hotel community in the north end of the project. If the market holds, it might be possible to incorporate residences above the retail units along Market Street, or office uses that are planned west of Westwood Station Boulevard. This might aid in removing issues caused by siting residential structures that negatively affect the well field at the Meadow.

Thank you for the opportunity to comment on this document. Please feel free to contact us for clarification or additional comments.

Sincerely,

Robert Sloane
Senior Planner

Comments on Cambridge Discovery Park EOEA #13312 Final Environmental Impact Report

November 7, 2005

Secretary Steve Pritchard
Executive Office of Environmental Affairs Attn: MEPA Office
100 Cambridge Street, Suite 900 Boston, MA 02114

RE: Cambridge Discovery Park, EOEA #13312 Final Environmental Impact Report

Dear Secretary Pritchard,

We were pleased to review the Final Environmental Impact Report for the Cambridge Discovery Park. It is gratifying when a project proponent makes considerable effort to comply with EOEA’s certificate.

EOEA’s DEIR certificate called for identification of pedestrian sidewalks, footpaths and bicycle facilities for the proposed development. As shown in the plans provided in the FEIR, the proponent indicates that they will construct all of their off-site pedestrian improvements as part of Phase I of the project, thus making these facilities available to help set non-auto commuting patterns.

The Proponent has agreed to take on significant responsibilities for constructing pedestrian pathways in and near the site. Especially noteworthy is the commitment by the proponent to construct and maintain a path through DCR’s Alewife Reservation on land lying between the proponent’s project and Alewife Station. This path will be wide, well-lighted for pedestrian safety, and maintained in all weather by the proponent.

The proponent has also agreed to take responsibility for improvements to the intersection of the EB Route 2 off-ramp and the entrances to the MBTA’s Alewife Garage. This intersection is of critical importance to pedestrians because several pedestrian pathways – both existing and proposed – will intersect: the Minuteman Bicycle and Pedestrian Path, the new pedestrian path from the proponent’s site through DCR’s Reservation, and the proposed Fitchburg cut-off pathway from Belmont. All three of these routes currently lead pedestrians through an unsignalized intersection that has heavy peak-hour traffic adjacent to the MBTA station. The improvements to be provided by the proponent are a major step in making the intersection safe for pedestrian access to the MBTA Alewife Station.

We remain concerned about maintenance of the sidewalks from the proponent’s site to the Alewife MBTA Station via the Route 2 off-ramp. Although sidewalks exist and may be improved by the proponent, WalkBoston is concerned that this pedestrian route may not be adequately maintained because of the overlapping responsibilities of governmental organizations and the proponent’s position that future developments by abutting landowners should bear incremental or additional costs for maintenance of this walkway. The lack of existing development on abutting land should not relieve the proponent of responsibility for maintaining the sidewalk until such time that another developer is on the scene and an agreement for sharing responsibility is reached.

The DEIR Certificate called for the creation of a pedestrian access master plan that takes a longer-range look at the area and develops a future pedestrian path network. The FEIR does not include this long- range plan. We request that it be added, and that it include three elements that would improve pedestrian access this site:

The proponent has agreed to make a contribution of $400,000 toward the design and construction of a footbridge (which would be constructed by others) over the Little River to the south bank multi- use paths. Since a plan for this footbridge is being actively pursued, it would be useful to know how paths from the proponent’s property would access it, even if the information must be tentative or diagrammatic. Possible locations for the bridge or paths are not shown on the maps.
The existing footbridge over Route 2 is not included or discussed in the planning for the site, even though it is noted on FEIR maps. All of the FEIR pedestrian facility maps (Exhibits 5-8, 5-9, 5-10, and 5-11) show the existing footbridge over Route 2. In addition, one of the maps (Exhibit 5-13) shows a bus stop on the north side of Route 2 that will require connection via the footbridge to the site. We wonder whether there are other pedestrian connections to the footbridge that should also be shown on a long-term plan for the area, such as through Thorndike Field in Arlington; or paths connecting the footbridge over Route 2 with the Minute Man Bike/Pedestrian Path. If such paths exist or are planned, it would be useful to show them on a long-term plan for the area to indicate options for people walking to the site from the Arlington side of Route 2. Again, the connections could be tentative or diagrammatic. The benefit of an Arlington footpath to the bridge would be to provide a shorter route to get to the proponent’s site and avoid a route that requires walking to the Alewife MBTA Station and backtracking to get to the site.
A pedestrian connection to the site from the west through Belmont via Frontage Road and Acorn Park Drive has been briefly mentioned as a longer-term goal. This should also be a part of the master plan for pedestrian facilities in the area. As part of this investigation, consideration might also be given to a sidewalk parallel to the south side of Route 2.

Thank you for the opportunity to comment on this project.

Sincerely,

Wendy Landman
Executive Director

Target Distribution Center Westfield Comment Letter

November 7, 2005

Secretary Steven Pritchard
Executive Office of Environmental Affairs
Attn: MEPA office
100 Cambridge Street, Suite 900
Boston, MA 02114

RE: Target Distribution Center Westfield, MA Final Environmental Impact Report EOEA No. 13361

Dear Secretary Pritchard:

WalkBoston advocates for pedestrian safety, improved facilities, and programs to encourage walking throughout Greater Boston, and takes an active role in promoting pedestrian interests statewide. We offer our comments on the proposed Target Distribution Center in Westfield, MA that is projected to have approximately 860 employees and to generate 6,460 vehicle trips/day. The project site is located on Route 202 and just off Routes 10/202 approximately 4 miles from the city’s center.

Providing access for all modes is now a requirement in state law for new and reconstructed state roads and is being fully incorporated in the new MassHighway Design Manual to be published in January 2006. Access by foot and by bicycle is fundamental to the state’s smart growth policies and programs. We are also concerned Westfield may not address the needs of pedestrians, even when these needs could logically be part of the transportation mitigation of local commercial development.

In examining this FEIR, WalkBoston finds that pedestrian access and its relationship to transit and transportation demand management is given little consideration by the proponent, despite MEPA’s clear guidelines in the February 14, 2005 Certificate on the proponent’s DEIR. The Certificate reads as follows:

Transit: The FEIR should update its inventory of public transit bus services in the project area. The proponent should work with local officials to identify bus connections and potential shuttle bus services from activity nodes and residential areas to the project site.

Pedestrian and Bicycle Facilities: The DEIR described where sidewalks currently exist in the area. The FEIR should identify the proposed pedestrian (sidewalk) and bicycle facility improvements included with this project. Unless the proponent can obtain a letter from the City of Westfield or MHD stating that a sidewalk is unnecessary, I recommend a sidewalk along the site frontage on North Road (Route 202) and Falcon Drive. 2

Transportation Demand Management (TDM) Strategies: The FEIR should examine the full range of potential TDM strategies.

Comments offered by the Executive Office of Transportation (EOT) and the Pioneer Valley Planning Commission (PVPC) also express the need to address bus service and pedestrian facilities:

EOT – The site design should include transit amenities including a bus turnout and bus shelters to further encourage transit usage. The site design should identify sidewalk and/or pedestrian access between the building and the PVTA drop-off area. Bicycle and pedestrian routes in the vicinity of the site should be identified as well. And bicycle lockers and shower facilities should be provided to encourage pedestrians and bicyclists.

PVPC – The DEIR acknowledges the potential for public transit service serving the proposed development using the Pioneer Valley Transit Authority (PVTA) Blue 23 bus route. While the proponent has committed to work with the PVTA to develop transit service for the site, no information was provided in the DEIR on how pedestrians would access the proposed new on site bus shelter. Consequently we’d urge that the FEIR provide additional information addressing the actual location of the proposed bus stop as well as depict and explain and show how pedestrian access will be provided from the Target development to this new bus stop.

The FEIR does not respond adequately to these requests. No details are provided on proposed pedestrian and bicycle facility improvements for the project, either in the plan or in the text. It says only: “The appropriate and safe pedestrian amenities on site, including necessary parking lot crosswalks, lighted pedestrian travel ways, and the like are being considered for the final design of the site.” (from Section 2.8.2, p. 2-48; repeated in Response EOT .08, Appendix B, p. 8-4 and Response PVPC.03, Appendix B, p. 8-9). This is not a sufficient commitment to pedestrian access.

WalkBoston believes that policy direction is needed to determine how pedestrian access should be addressed by this (and other) project(s). The absence of existing pedestrian facilities is not an indication that they are not needed. WalkBoston suggests clear and careful consideration to determine an appropriate approach. Among the possible choices are the following:

a. Over time, perhaps with state EOEA or MHD assistance, the city will provide sidewalks on at least one side of all major roads that provide access to employment.

b. Over time, working with local municipalities and EOEA, MHD will provide sidewalks on at least one side of major state highways near urban and suburban employers.

c. The city or MHD will request all major employers to construct sidewalks from their building’s employee entrances to the sidewalks that parallel major local roads or state highways. The city, MHD or the employer will then construct bus stops and sidewalks to connect to employer-constructed on-site sidewalks.

d. In the vicinity of new development, the city or MHD will require project proponents to construct sidewalks along roadways connecting to transit and schools.

e. The city or MHD will leave most, if not all, of the decisions regarding sidewalks along state highways or local roads near new development to project proponents.

WalkBoston believes that MHD and the City of Westfield should provide clear policy direction to the project proponent about their responsibilities for pedestrian access. At that point, a variety of options exist for pedestrian accommodation. EOEA, in its DEIR Certificate, has taken a position that sidewalks should be provided along North Road (Route 202) and Falcon Drive, unless the City or MHD waives the requirement. The certificate also calls for public transit bus services to the project site, and for the identification of nearby bus stop locations and their relationship to sidewalks providing access to the employee entrance to the site. Since many of the vehicular improvements to be provided as mitigation measures for the project are off-site, it is reasonable to also require off-site pedestrian mitigation measures. Among the options for pedestrian access are the following:

1. A sidewalk along North Road (Route 202) – From the FEIR, it appears that the proponent has designed an auto access road that parallels North Road (Route 202) through most of the site. A sidewalk could be constructed along this road. To avoid security problems, the sidewalk could be located outside the perimeter fencing and adjacent to North Road (Route 202). This sidewalk would provide the first step toward EOEA’s ultimate goal of providing a sidewalk along the full length of North Road (Route 202) in the city.

2. A sidewalk along Falcon Drive – From the FEIR, it appears that the proponent owns very little property along Falcon Drive. However, placing a sidewalk within its property could become part of EOEA’s long-range vision for sidewalks along the full length of Falcon Drive.

3. A sidewalk from the site to North Road (Route 202) – From the FEIR, a pedestrian sidewalk to North Road (Route 202) seems possible along the side of the building adjacent to employee parking, presumably connecting to the employee entrance to the distribution center building. Figure 1-3 FEIR Proposed Conditions Plan (p. 1-6) and Figure 1-5 FEIR Operations Plan (p. 1-10) show auto access directly from North Road (Route 202) This access gate is approximately 2000 feet from the intersection of North and Southampton Roads. It is labeled “emergency vehicle access and gate.” This access gate could also serve pedestrians.

4. A sidewalk from the site to a bus stop – Bus travel to the site should be encouraged through clear routes and signage and direct, well-marked paths for pedestrians between transit stops and the pedestrian entrance to the proponent’s building. The FEIR notes that the Pioneer Valley Transit Authority Blue 23 weekday and Saturday bus routes pass the site on North Road (Route 202) and also on Southampton Road (Routes 10 and 202). Yet the FEIR contains no indication that workers may arrive by transit or estimates of transit’s potential for serving employees coming to or leaving the site. Nor does the FEIR specify where transit stops and sidewalks might be best located to serve employees, or even from which direction or gate the riders would come.

The bus rider’s pedestrian access from Southampton Road is particularly daunting. If bus-riding employees must access the site from a bus stop on Southampton Road and walk via Southampton Road/Falcon Drive to the Target Warehouse employee entrance, they must walk over 4,000 feet. In addition, without sidewalks, walking along these routes is potentially dangerous. This would deter even the most dogged bus-rider/pedestrian.

By contrast, a bus stop near the North Road emergency access/gate that is connected via sidewalk to the employee entrance to the distribution center could be less than 400 away from the entrance. With this option, bus stops for riders coming from either direction could be established on the two sides of North Road, with a walkway from the bus stops through the North Road emergency vehicle access/gate and up to the employee entrance. For security purposes, access for people on foot through the North Road emergency vehicle access/gate could be provided by electronic gate control mechanisms. Analysis of this possibility has not been included in the FEIR and should be provided during the next steps of the environmental permitting process. In addition to a bus stop and appropriate sidewalks, a protected pedestrian crossing of North Road should be reviewed. Such review should include the examination of a pedestrian-activated signal.

5. Improvements along Southampton Road (Routes 10/202) – Local comments mentioned the need for sidewalks for school and day care students attending classes in three buildings located along Southampton Road. It seems appropriate to provide new sidewalks along those portions of Southampton Road that are to be improved as part of the project’s mitigation program.

In the long run, sidewalks will need to be constructed wherever there are students who could walk to their schools from homes or bus stops. Indeed, the state is now involved in an extensive Safe Routes to Schools program that will lead to a greater demand for new or improved pedestrian and bicycle facilities for children to use in going on foot or by bike to their school buildings. They should be included in this project.

Finally, WalkBoston suggests that draft commitments for the Section 61 findings (Section 7.0 of the FEIR) should contain pedestrian and bicycle facilities.

Thank you for the opportunity to comment on the FEIR for the Target Distribution Center in Westfield. We hope that our concerns about pedestrians can be addressed as you examine the proposal and as it moves toward implementation.

Sincerely,

Ann Hershfang Wendy Landman
Advocacy Committee Chair Executive Director

Cc Astrid Glynn, Office of Commonwealth Development Tom Cahir, Executive Office of Transportation Tim Brennan, Pioneer Valley Planning Commission