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