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Comments on the FEIR for the Back Bay/South End Gateway Project MEPA: #15502

Comments on the FEIR for the Back Bay/South End Gateway Project MEPA: #15502

August 11, 2017

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

Brian Golden, Director
Boston Planning and Development Agency
ATTN: Michael Rooney
One City Hall Square
Boston, MA 02201-1007

RE: Comments on the FEIR for the Back Bay/South End Gateway Project
MEPA: #15502

Dear Sirs:

WalkBoston has reviewed the FEIR for Back Bay/South End Gateway Project. While we appreciate the proponent’s efforts to address some of the issues we raised in our DEIR/DPIR comments, we continue to have concerns about the project impacts to the extremely busy pedestrian environment around the project area, and to several of the design elements suggested by the proponent.

We have reviewed the letter submitted by South End resident Ken Kruckemeyer and would like to concur with his comments and his very thoughtful suggestions about how to remedy some of the problems that he describes.

Per our own quick review of MBTA data, Back Bay Station Orange Line, Commuter Rail and Amtrak service presently serves approximately 64,000 passenger trips (alighting and boarding) each day. Many more pedestrians are simply walking by the site, arriving on buses, via cabs and in automobiles. The MBTA, MassDOT, and all people concerned with the continued economic vitality of the Boston area and a more sustainable transportation system, hope that this number will rise significantly over the coming decades. The Back Bay/South End Gateway Project must be designed and managed in such a way that the transit and transportation functions of the station are enhanced.

Our key comments and concerns are as follows.

1. Possible garage exit ramp across the Dartmouth Street sidewalk adjacent to the Station
The project proponent and MassDOT support, and are eagerly awaiting, the decision of the FHWA about the closing of an I-90 on-ramp which would allow the project to locate the garage exit elsewhere.

WalkBoston does not think that a project design that includes a garage exit ramp across the Dartmouth Street sidewalk is acceptable. Putting the interests of drivers above those of the tens-of-thousands of pedestrians who use this sidewalk is not an appropriate use of public space. Given the intensity of sidewalk use, and the overlap of peak transit and garage use, we do not believe that the ramp can be designed and/or managed acceptably. Asking pedestrians to wait while single cars exit the garage is not a reasonable solution.

We urge MEPA to recommend that further consideration of the project as presently designed be delayed until this issue is resolved favorably with no garage ramp exiting across the Dartmouth Street sidewalk.

2. Route and layover location for Bus 39
The proponent seems to have reached a reasonable set of recommendations for much of the routing of Bus 39. However, in order to provide accessible and weather protected transfers for people wishing to use the Orange Line, Commuter rail or Amtrak services, the route should include a stop at Back Bay Station on both its inbound and outbound routes. This is particularly important because the Green Line is not fully accessible for people with disabilities and people with strollers.

The FEIR does not provide any details about layover for the Route 39 buses, a critical issue to keep this very busy route operating with reasonable service levels.

Until these questions are resolved, we do not believe that the transportation planning for the project has been adequately addressed and request that the proponent be directed to work
with the MBTA and the City of Boston to find fully workable solutions.

3. Dartmouth Street Sidewalk
The width of this critical sidewalk – critical because of its role as a major element of the Back Bay transportation system that serves well in excess of 70,000 pedestrian trips/day – is
constrained by the introduction of a wide furnishing zone and the filling in of the walking area in the weather-protected arcade beneath the station arcade and the existing garage overhang.
We urge the proponent to continue to modify the sidewalk plan so as to maximize the walking area. A 13-foot sidewalk (at the station) and a 17-foot sidewalk at the new commercial frontage (where the existing garage is located) are each narrower than the existing sidewalk and are not adequate in this location. The arcade could be kept open to walkers, the first floor of new commercial building could be set back, and the large planters shown should be removed (especially important along this street frontage where people will be getting picked up and dropped off).

 4. Pedestrian Bridges across Stuart Street and Trinity Place (outside the project site)
We urge the proponent to delete the pedestrian bridges (other than the one internal to their site) as unnecessary and deleterious to the active street life that makes Boston a walkable and lively City. We disagree with the proponent’s contention that “the pedestrian bridge(s) will …further enhance transit access, pedestrian safety, and neighborhood connectivity.” In fact we believe that such bridges diminish all of these characteristics.

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
Executive Director

Cc Secretary of Transportation Stephanie Pollack
Laura Brelsford, MBTA Assistant General Manager, System-Wide Accessibility
City Council President Michelle Wu
City Councilor Josh Zakim
Ellis South End Neighborhood Association
Bay Village Neighborhood Association
Neighborhood Association of Back Bay
Ken Kruckemeyer

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