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Comment Letter on Waltham High School Project #16097

Comment Letter on Waltham High School Project #16097

June 19, 2020

Secretary of Energy and Environmental Affairs Kathleen Theoharides
Executive Office of Energy and Environmental Affairs (EEA)
Attn: MEPA Office, Page Strysky
100 Cambridge Street, Suite 900
Boston MA 02114

Dear Secretary Theoharides, 

Thank you for the opportunity to comment on the Waltham High School Project #16097 for Waltham High School located at 554 Lexington Street in Waltham, MA. WalkBoston and the Massachusetts Bicycle Coalition (MassBike) would like to submit the following comments based on our reading of the DEIR as submitted on May 15, 2020.

Though we appreciate the work involved in relocating and constructing a new high school which will have significant impacts for the City of Waltham for generations to come, our primary concerns arise from the fact that unless the site is designed so that motor vehicle trips are replaced by safe and sustainable modes of walking and biking to and from school, this project will unacceptably increase the amount of expected car and bus traffic coming to and from the site on a daily basis and will have dramatic impacts to worsen the congestion on Lexington Street and increase greenhouse gas emissions.

We implore you to rethink the decisions to a.) remove bike lanes on Lexington Street and b.) raise the speed limit on Lexington Street without other traffic calming measures. As we shared previously in our letter dated November 26, 2019, the TMP noted that the Waltham Police Department identified speeding “as a significant issue” on Lexington Street. However, when a speed study was conducted for the high school project, the 85th percentile speed recorded was 41mph, leading to a new design speed set at 45mph. This does not mitigate the existing problem of speeding drivers on Lexington Street, but instead legitimizes it. The purpose of this project should not be to maximize vehicle speed and throughput. On the contrary, the goal must be to create a safe access to the new high school for all modes and ages, especially the most vulnerable on foot and on bike.

The DEIR states:

 “It is not possible to accommodate an exclusive bike lane through this portion of Lexington Street without taking private land along the right-of-way, which the Project will not pursue.” 

This is a misleading statement, and this project is only not accommodating exclusive bike lanes due to the addition of vehicle turning lanes. We are extremely concerned that adding turn lanes to “mitigate delays” will reduce safety of people who are walking and biking to the site. The DEIR also makes statements of “smooth flow,” “to ease traffic congestion,” “improve travel time reliability within a corridor, and reduce congestion,” but makes no mention of safety of students, staff, and faculty who are walking or biking to school. Instead, the DEIR is proposing “shared lanes” on Lexington Street, essentially a “sharrow” which does nothing to separate bicyclists from fast moving traffic. We believe forcing high school students to ride in “shared lanes” on Lexington Street is a dangerous option.

In contrast to “mitigating delays” of traffic, the roads around a community school should be safe for residents to get around, whether by walking, cycling, using transit, or in a vehicle. That safety and comfort is impacted by the design of our streets and intersections. All existing elementary schools in Waltham currently participate in the Massachusetts Safe Routes to School Program, which encourages students and their parents to walk and bike to school, something they hopefully would continue through high school. Yet we are not confident this roadway design allows for safe bicycling and walking, especially for students, staff, and faculty coming to the school early in the morning. Please take a moment to ask yourself: Would you want a 14-year old student riding a bike at 6:50am in a “shared” lane, or crossing a multi-lane road that has a design speed of 45mph?

Many students walking to and from school will have to cross Lexington Street, with a design speed of 45 mph, which obviously is not consistent with safe crossing by pedestrians. Yet Lexington Street has the opportunity to see more students walking and bicycling to school in the years to come: a proposed new K-8 public school may occupy the site of the existing high school. With additional vulnerable road users in this area, it is important to ensure that anyone driving on Lexington Street is doing it at a safe speed, and that safe and comfortable facilities are provided for vulnerable users. The City should consider expansion of the 20mph School Zone on Lexington Street to include all three schools, or through creating a 20mph “Safety Zone,” which was established in 2016 under Mass General Law Chapter 90, Section 18B. 

The DIER does mention the placement of bike racks for 5% of the building occupants, though without detail if these will be protected or covered or otherwise secure, and building occupancy can be up to 1,830 students, teachers, and staff, plus 600 field spectators. We see no analysis of trips being taken to and from the site by people on foot or on bike, only that dedicated bike lanes outside the entrances and exits will be removed, and crosswalks and ADA accessibility will be studied further. This omission is telling that this project goes completely against the goals of Safe Routes to Schools, and the mode-shift goals that Massachusetts is attempting to pursue. This project, as described in the DEIR, will be a detriment to the sustainable and safety goals that are so essential to mitigate dangers of traffic and the climate crisis, and goes against our goals for Safe Routes to Schools. We feel that the City of Waltham should be constructing a school that facilitates and exemplifies safety and sustainability for their students, staff, and faculty.

Thank you, 

Brendan Kearney, Deputy Director, WalkBoston
Galen Mook, Executive Director, MassBike

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