Category: Comment Letter

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

Joint Comment Letter on the Allston Multimodal Project

Joint Comment Letter on the Allston Multimodal Project

June 19, 2020

Stephanie Pollack
Secretary and CEO, Massachusetts Department of Transportation
10 Park Plaza, Room 4160
Boston, MA 02116

Jeff McEwen
Division Administrator, FHWA
55 Broadway, 10th Floor
Cambridge, MA 02142

MassDOT Board of Directors

MBTA Fiscal and Management Control Board

Dear Secretary Pollack, Administrator McEwen, MassDOT Board of Directors and MBTA Fiscal and Management Control Board:

We appreciate that you will take our comments into account in the decision making process that leads to a final Allston Multimodal Project design. We want to be your partners and allies in building support for a truly bold, visionary and future-focused reconstruction of this area. We believe that the opportunity exists to set the stage for meeting the needs of the next ten years while also working toward the transformation of our transportation system and riverfront to meet the needs of equity, climate change, and environmental resiliency.

This is more than a viaduct replacement project.  We hope that this project will be transformative and help knit the community of Allston back together and connect it to the Charles River. Therefore, we feel strongly that replacing the MassPike viaduct is not a viable or appropriate option – even if it is technically feasible. 

While much collaborative work is needed with MassDOT, FHWA, advocates, residents, and other agencies to develop the final project design we agree on: 1) the alternatives that should be analyzed; 2) a set of common criteria to form the basis for evaluation; and 3) the project components that should be included in every alternative.

We fully recognize that this is a complex project and that there are no straightforward solutions. Therefore, in order to ensure the best possible outcome for those who live in the community and who utilize I-90, we recommend that you study both the surface option and hybrid option as briefly described below.

We agree that the following roadway options should be studied in the throat area.

  1. All at-grade roadways with a total of 12, 11, 10, 9 and 8 total vehicle lanes, using the narrowest feasible lane and shoulder widths. A 12-lane cross section would include 8 lanes on the MassPike and 4 on SFR. Because reducing I-90 to 6 lanes for several years of construction is feasible, study is needed to consider why I-90 capacity should be increased by one-third when construction is completed. 

The reduction in the number of lanes could be accomplished through elimination of lanes on either roadway. An 8-lane option would include 6 lanes on the MassPike and 2 on SFR.

As we understand from the many sketch alternatives produced over the last 5+ years, a 12-lane cross section would require approximately 30-feet of encroachment on the Charles River (for a length of approximately 700 feet) to provide space for riverbank restoration and the provision of separate walking and biking paths. The elimination of a vehicular lane would yield approximately 10 feet of roadway width – thus an 11-lane cross section would reduce encroachment into the river of approximately 10 feet. A 9 or 8-lane cross section would likely allow the riverbank restoration and PDW paths without any encroachment into the river.

  1. A modification of the “Modified Hybrid” scheme identified by the Independent Review Team that includes a slightly below-grade MassPike and with SFR on a viaduct above the eastbound MassPike, including the lane counts mentioned above. This alternative can be modified to significantly reduce its impact on the Charles River and its parklands, simplify its construction process, and make it a useful alternative for evaluation.

The common criteria for analysis of each alternative should include the following elements.

  1. Improvements to public health, active recreation, and transit-oriented urban design
  2. Mode-shift from single occupancy vehicles to transit, biking, and walking
  3. Environmental and travel impacts of construction
  4. Environmental and transportation impacts and benefits of the completed project
  5. Construction and post-construction mitigation of project impacts
  6. Climate impacts including flooding impacts to the project site and surrounding areas from sea level rise and precipitation in 2030 and beyond
  7. Location of construction
  8. Duration of construction
  9. Total lifecycle cost of construction
  10. Annualized maintenance costs

We agree that the following project elements should be included in all project alternatives.

  1. Enhanced public transit
  • 4 tracks at West Station
  • 2 tracks on the Worcester Line remaining open throughout construction
  • 2 tracks dedicated to a Grand Junction connection
  • Reconstruction of the Grand Junction Bridge over Soldiers Field Road
  • Design of a Grand Junction Bridge over the Charles River, with 2 rail tracks and walk/bike space
  • Anticipation of electric trains and high frequency service.
  • A reassessment of the need for a layover yard given Regional Rail service on the Worcester Line as called for by the FMCB
  • Worcester Line modernization to encourage mode-shift during and after construction (high level platforms, two-track stations, expanded parking or other forms of improved access at suburban stations)
  1.   Bike and pedestrian connections so that neighbors and neighborhoods would be reconnected to the river and transit. 
  • By adding pedestrian/bike connections in Allston: one in the vicinity of Agganis Way; one at the BU Bridge/Comm Ave nexus; and one serving the new neighborhood east of Cambridge Street.
  • The People’s Pike walk/bike path from the Franklin Street Footbridge to West Station and the Agganis Footbridge.
  • Paul Dudley White (PDW) path in service throughout construction.
  • A final design that includes a Paul Dudley White path with separated walking and biking trails.
  • PDW path in the river during construction and permanently should be studied but could be justified only if it can be accomplished in conjunction with river and riverbank restoration in a way that improves the overall ecological integrity of the river.
  • The number of lanes in the street grid and on/off ramp in Allston should be reduced to reflect the existence and use of the West Station transit facilities which will reduce vehicle trips and increase walking and biking trips.
  1.   Any encroachment into the river should be for the primary purpose of ecological restoration; no vehicular encroachment into the Charles River during construction and in the final design.  
  • River restoration measures should consider co-location of other public benefits such as stormwater mitigation and public access. Due to the project’s close proximity and significant impact on the Charles River and surrounding parklands, river restoration should be a key element of the project.
  • The riverbank should be naturalized along the southern bank between River Street and the BU Bridge by creating a natural floodplain or living shoreline.

Why the time is right to evaluate a variety of roadway capacities in this corridor:

First, we believe an evaluation of post-COVID roadway demand is critical for all the options due to the massive change in commuting patterns and assumptions in the post-COVID era.

  • Anecdotally, some businesses that never considered work from home policies are not only experiencing them but say they will never go back to requiring all employees to work on site.
  • A recent MassINC poll found that 41% of workers who are able to do so said they would prefer to continue to work from home, and 29% said they would do so if asked. A previous Pioneer Institute poll found that 63% of respondents would prefer to work from home at least one day per week after COVID-19 vaccine is available, with most saying they would prefer to work from home 2 or 3 days per week.

Second, in light of Boston and Commonwealth stated transportation and greenhouse gas (GHG) reduction goals we believe that it is imperative to evaluate a variety of roadway capacities to deter-mine how they will contribute to meeting these critical climate, health and transportation goals.

  1. Prioritize investment in public transit.
  2. Transform roadways and travel corridors – MassDOT, municipalities, and other roadway owners should redesign them to prioritize person-throughput rather than vehicle-throughput, so that limited corridor capacity is allocated to moving as many people as possible, while accommodating mobility alternatives.
  3. Better manage traffic congestion The Commonwealth must consider a full set of options to address roadway congestion, including improvements to public transit, better systems operations, and the consideration of congestion pricing. The Commonwealth should prioritize and target investments in public transit and other high-capacity transportation modes to make these more efficient, attractive, and reliable to reduce single occupancy vehicle (SOV) use, particularly on our most congested roads in the urban core.

The Future of Storrow Drive/Soldiers Field Road

During the course of the planning and design efforts undertaken for the I-90 Allston project, there has been discussion about the ways in which the Charles River Reservation from Leverett Circle to Watertown is compromised by the presence of a high-speed, multi-lane roadway with numerous underpasses and overpasses all of which cut the City off from the river.  There should be a separate, serious, and concurrent study of the future of Storrow/SFR from Charles Circle to Watertown. The purposes and objectives of the study should be to explore ways to improve the parkway and surrounding parkland and the river that borders it to facilitate human enjoyment, natural restoration, and safe and effective travel for all modes of transportation.

The scope should include: methods to calm the traffic so it returns to a parkway (including potential for the use of signalized at-grade intersections); enhancement of pedestrian and bike travel throughout, specifically to achieve dual ped and bike lanes for as much of the length as possible; restoration of the river edge to enhance the ecological health of the entire river; enhancement of parkland along entire length; the number of lanes and width of roadway for entire length; financing mechanisms that could involve substantial public/private partnerships to supplement state funds for this underfunded parkway area; significantly improved access for peds and bikes at all intersections including underpasses for bikes and peds at bridges where none currently exist (River, Western) and where design is 25% complete and approved by the Massachusetts Historical Commission (Anderson).

The results of this study should be integrated into the I-90 Multimodal Project in the area from the BU Bridge to Western Avenue in a timely manner with the ongoing federal and local process for the Allston Multimodal Project. The work should be managed jointly by MassDOT and DCR, with committed funds from MassDOT. The scope should be developed collaboratively with active participation by municipalities, other state agencies (such as DEP), major private institutions along the river and parkway, abutting neighborhoods, groups concerned about the river, parks, and parkway, and others. The study should meet strict deadlines so results from this study and I-90 can move forward in a compatible manner. The study should be funded with sufficient resources to enable the hiring of a multimodal consultant staff to reflect the broad purposes of the study, to create a continuing, active, and meaningful advisory process and to conclude with an action plan to implement specific improvements.


The reconfiguration of the Allston interchange is the chance of the century to transform the options for multi-modal transportation, help the Commonwealth meet its absolutely necessary climate goals, and rectify long-standing deprivation of public amenities and degradation of the environment by transforming the Allston section of the Charles River Basin into a stunning urban park with a restored river’s edge that is connected to adjacent communities and that enhances, rather than pollutes, the river itself.

Thank you for your consideration and we look forward to turning this vision into reality.

Allston Brighton CDC, Jason Desrosier, Task Force Member
Allston Civic Association, Anthony D’Isidoro, President, Task Force Member
Charles River Conservancy, Laura Jasinski, Executive Director, Task Force Member
Charles River Watershed Association, Emily Norton, Executive Director, Task Force Member
Conservation Law Foundation, Staci Rubin, Senior Attorney
LivableStreets Alliance, Ari Ofsevit, Task Force Member
Massachusetts Bicycle Coalition, Galen Mook, Exec. Director, Allston Resident and Task Force Member
WalkBoston, Wendy Landman, Senior Policy Advisor, Task Force Member
Harry Mattison, Allston resident, Task Force Member
Jessica Robertson, Allston resident, Task Force Member
Steven Miller, Cambridge resident, LivableStreets Alliance
Fred Salvucci, Allston/Brighton resident
Bob Sloane, Brookline Resident, WalkBoston
Jack Wofford, Cambridge resident
Douglas Arcand, Allston resident

Comment to the Fiscal Management Control Board Regarding Commuter Rail Contract Renewal

Comment to the Fiscal Management Control Board Regarding Commuter Rail Contract Renewal

Dear MBTA Fiscal Management Control Board,

The commuter rail contract being considered must allow flexibility in providing improved service on the commuter rail lines, especially those that will be bearing the brunt of construction activities on highways. Certain commuter rail services may be called upon to help commuters when highway construction brings reductions in lanes available and congestion for vast numbers of commuters. Case in point – the Worcester branch, where planning for mitigation of highway construction on the Turnpike in the Allston interchange area should be underway and planned for implementation prior to the construction on the highway. In this way an option will be provided for commuters to avoid the highway by using a rail alternative during the construction period and hopefully afterward as well.  Along with this heightened attention to commuters should be a commitment to construction of new services, including an early opening of a new station at West Station, a critical component of the Allston planning. Pedestrian access to this and other stations must be considered as well to assure access to the newly improved services and to workplaces in the city. This pedestrian access includes the proposed pedestrian way along the south border of the project adjacent to Wadsworth  sand Platt Streets, and along the proposed Cambridge Street Bypass, which provides additional access to West Station on air rights above the rail lines (and which has not been included in MassDOT projections of traffic, despite a long-term need for the new street leading to West Station.)


Bob Sloane
Senior Project Manager

Comment Letter on Recommendations around the Role of Police Enforcement in Vision Zero and Removal of Captain Danilecki from the Vision Zero Task Force

Comment Letter on Recommendations around the Role of Police Enforcement in Vision Zero and Removal of Captain Danilecki from the Vision Zero Task Force

June 9, 2020

Mayor Martin J. Walsh

1 City Hall Square, Suite 500

Boston, MA

Dear Mayor Walsh,

As members of the Boston Vision Zero Task Force, we urge you to reform the way the Boston Police Department engages with the City’s Vision Zero program and to remove Captain Danilecki from the Vision Zero Task Force. 

In your comments to the press on Thursday, June 4, you committed to making Boston a leader when it comes to battling racism, saying: “We are listening — I am listening — to the voices and the messages of our black neighbors who are harmed by systemic racism every single day. As elected officials, it’s time to listen and learn and keep those voices at the center of the conversation.” As many have noted already, listening isn’t enough. Our Black and brown communities need concrete actions from our elected officials. Central to these conversations is the role of our transportation system in perpetuating racism. 

Boston has a legacy of destroying vibrant Black communities to make space for highways, creating barriers between certain neighborhoods and critical resources. Many streets in Black and brown communities act as conduits for cars to pass through quickly, without regard for the effect this has on people who live there. BIPOC communities often don’t have sufficient walking or biking infrastructure and lack access to high quality public transit, which in turn leads to well-documented public health disparities. Layered on top of these injustices is the violent reality of policing on our streets. 

We have long been concerned by the attitude and role that the various Boston Police Department representatives demonstrate at monthly Vision Zero Task Force meetings. When reporting on the details of fatal car crashes, officers have consistently engaged in victim-blaming, either suggesting or outright attributing a person’s death to their own fault. This attitude runs counter to the very concept of street safety and Vision Zero that the Boston Police Department is supposed to uphold. On top of this, it is clear that not all officers at Task Force meetings are trained or even aware of the Vision Zero program. 

Any conversation about moving away from enforcement as a community must include moving away from enforcement in transportation as well — and we should start with fundamentally rethinking the role of police and enforcement in Vision Zero. 

  • Remove police enforcement as a tenet of Vision Zero effective immediately. Law enforcement nationwide often make race-based stops and searches which further inflict harm, violence, and trauma in communities of color.

  • Instead of relying on police, use automated enforcement to address speeding, which is the cause of most fatal crashes. We are calling on you to champion state legislation that would allow automated enforcement explicitly built on equity principles (see attached FAQ for more details). 

  • Work with the City Council to pass an ordinance banning facial recognition technology in Boston communities. This would also establish necessary civil liberty protections for the use of automated enforcement in the future.

  • Ensure adequate long term funds for crash data collection and analysis. It is shameful that it took two years of advocacy from our organizations and several City Councilors to secure funding for a single civilian research and crash data analyst position within BPD after grant funding for the position ran out. 

  • Reduce the BPD budget and reallocate resources for social programs designed to strengthen communities. Follow the calls from organizations such as the Muslim Justice League, Families for Justice as Healing, Youth Justice and Power Union, and others.

  • Create a diversion program for any nonviolent traffic- and transportation-related infractions. For example, the City can provide front and rear lights to cyclists who may be traveling without them after dark or offer educational opportunities in lieu of fines for other similar minor and non-violent offenses. 

And lastly, in addition to changing the relationship between streets, enforcement, and Vision Zero, we are calling on you to condemn the actions of Captain Danilecki, who currently serves as the BPD designee on the City’s Vision Zero Task Force. 

Captain Danilecki’s violent actions against protestors exercising their right to gather peacefully at a white supremacist rally in Boston on August 31, 2019 are well-documented. More recently, Captain Danilecki was filmed acting in an aggressive, escalatory, and unacceptable manner towards peaceful protestors on May 31, 2020. 

We understand there has been at least one formal complaint filed with the BPD internal affairs division based on a video of Captain Danilecki’s behavior from that recent demonstration, and we hope that he is held accountable through that process. In the meantime, we are calling for the immediate removal of Captain Danilecki from the Vision Zero Task Force. It is unacceptable for an officer who engages in brutal tactics against civilians to be the liaison between BPD and those of us who are fighting to make our streets safer. 

We believe Boston is capable of achieving zero traffic fatalities and serious injuries on our streets. However, we will not have achieved our goal of safe streets if officer-initiated enforcement remains a tenet of Boston’s Vision Zero Action Plan, and furthermore, if Boston police officers are not held accountable for engaging in racist and aggressive tactics. We hope you agree and will take immediate action. 


Becca Wolfson, Boston Cyclists Union

Stacy Thompson, LivableStreets Alliance 

Stacey Beuttell, WalkBoston

Chief of Streets Chris Osgood,
Transportation Commissioner Greg Rooney,
Chief of Police William Gross,
Boston City Council

Comment letter on the Northern Avenue Bridge Replacement Project

Comment letter on the Northern Avenue Bridge Replacement Project

June 9, 2020

Kathleen A. Theoharides, Secretary of Environmental Affairs
100 Cambridge Street, Suite 900
Boston, MA 02114
Attn:  Alex Strysky, MEPA Unit

Chris Osgood, Chief of Streets
Public Works Department
Boston City Hall
Boston, MA 02201
Attn: Para Jayasinghe, City Engineer

Re:       MEPA Project 16194 – Northern Avenue Bridge Replacement Project

Dear Secretary Theoharides and Chief Osgood:

We are writing to provide comments on the ENF for the Northern Avenue Bridge (NAB) Replacement Project. This is a project with a 30-year history which has included many internal City deliberations as well as many public processes, both within and outside those managed by the City. While we are pleased that the City is now seeking to bring the project planning to closure, we strongly disagree with the City’s choice of a bridge design that includes regular vehicle use that impinges on the use and safety of the bridge by people walking and biking, and does not provide the traffic benefit that the City says is the reason for including buses on the bridge.

While the design includes substantial space for use by pedestrians, much of that space would not be built until the unfunded and unscheduled Phases 2 and 3 of the project are built. Bicycles are relegated to shared lanes with buses. The lack of clarity about how pedestrians, bikes and buses will circulate raise many safety and operational concerns.

The scale and cost of the bridge has grown enormously simply to accommodate 110 shuttle buses/day. In addition to the lack of transportation efficacy and the design problems discussed below, we believe that the project is simply too big and too expensive. A smaller bridge that serves people walking and biking, and provides access for emergency vehicles, could provide the benefits and urban enhancements that both the public and the City desire.

While the loss of the Old Northern Avenue Bridge and the design of a new Northern Avenue Bridge raise many historic and contextual design issues, we are confident that the comments of our fellow advocates with specific historical and urban design expertise will speak to those issues, and we leave that task to those able commenters.

Our comments are organized as follows:

  1. Decision regarding the modes to be served by the bridge
  2. Funding and budget for the project
  3. Walking and biking designs as described in the ENF
  4. Public process

Decision regarding the modes to be served by the bridge

The City has determined that the bridge will carry pedestrians, bicycles, emergency vehicles and “transit”, which has never been clearly defined by the city, but thus far seems to include private buses and shuttles utilized by businesses located in the Seaport District. . We believe that the decision to serve these private vehicles  is the wrong choice, and that this wrong choice has in turn led to a wide variety of problems with the selected alternative.

  • Will the inclusion of a bus lane on the bridge provide transportation benefits to the public?

There has been widespread and consistent public support for pedestrian, bicycle and emergency vehicle access. It is worth noting that of the online public comments regarding the project, 68% of the respondents preferred a bike/ped/emergency bridge option and only 1 person called for allowing general traffic on the bridge. The remaining 31% of comments didn’t reference a mobility preference.

  • Will the inclusion of a bus lane reduce congestion?

As the City has stated in the ENF (page 6) ”… the intent of the project is (to) re-open the bridge for public enjoyment, provide additional means of pedestrian access across Fort Point Channel, provide a dedicated bus lane to reduce traffic congestion in Downtown Boston, and provide an alternate route for emergency vehicles if the need arises.”  This statement of purpose seems to be the City’s justification for selecting a large and very expensive bridge rather than a smaller and less expensive alternative, that serves only  pedestrians, bicycles and emergency vehicles. However, the transportation analysis provided by the City’s consultants – AECOM Memo: Northern Avenue Bridge Reconstruction – Mobility Analysis (November 13, 2018) makes the following conclusion: (P 16)   “The overall level of service for all study area intersections remains consistent between the No Build and all concepts analyzed in 2035 PM peak hour as previously shown on Table 5. The intersections of Seaport Boulevard and Atlantic Avenue and Seaport Boulevard and Purchase Street continue to operate at LOS “F”, and would remain congested under all concepts analyzed.”

Thus, the City’s own transportation analysis concluded that putting buses on the bridge does not reduce congestion. 

Having been closed to vehicular traffic since 1997, the downtown Boston side of the NAB ends at a one-way roadway lacking direct access to the entrance of I-93, completed as part of the central artery in Big Dig which opened up many years later. Thus, the utility for vehicular traffic traveling from the Seaport into downtown will be extremely limited and cause further disruption in travel demand due to congestion and redundancy (forced increase in VMT from driving around the block to get to the entrance). Therefore, having motorized vehicle traffic travel from and utilize the NAB will not fit into the existing fabric of the street network.

When asked about this mismatch between the stated purpose for the project and the lack of efficacy shown by the data during the MEPA “Site Visit” call, City Engineer Para Jaysinghe suggested that the City was planning for “unknown volumes” for the next 75 years. The standard practice for transportation studies is to use the time frames actually evaluated (2035).

  • Is the inclusion of a bus lane on the bridge a reasonable financial decision?

The ENF states that the bridge would carry 110 buses/day (at a generous occupancy factor of 25 people/bus this equals 2,750 people/day). The very wide bridge now proposed at a cost of $100 million (for Phase 1, Phases 2 and 3 have not yet been costed out) is at least twice as costly as a bridge that could very comfortably accommodate walkers, cyclists and emergency vehicles. As stated in City presentation from the Mobility and Traffic Evaluation Workshop: “Most people on NAB will be walking; 70 to 90% of trips are by foot across all concepts.

  • Will any public transit make use of the bus lane?

There has been no indication that any MBTA public buses will use the bridge, and the MBTA’s study of improvements to its bus networks and routes does not include any use of a Northern Avenue bus lane. Thus, as we understand it today, a bus lane on the NAB would only serve private shuttle buses serving employees in the Seaport District. Over the years many advocates for better bus service have urged the MBTA and the City to look at the feasibility of an exclusive Congress Street bus lane from South Boston to North Station – a route that could provide significantly more direct and efficient service for both MBTA and private shuttles. We do not believe that this bridge should be built to accommodate buses unless the MBTA and the City can demonstrate that there is a clear benefit to public transit, and the MBTA identifies which specific routes will run over the bridge when it has been completed.

We urge the City to select a design to accommodate walking, biking and emergency vehicles and to delete accommodation of other vehicles.

Funding and budget for the project

  • How much will the bridge cost?

The cost information provided at the June 3, 2019 community meeting showed a range in cost from a “basic” 12-foot wide bridge for $40 million to a “contextual” 56-foot wide bridge for $110 million. The contextual bridge now being proposed is more than 100-feet wide (at the center of the span) and thus could be guesstimated to cost well in excess of $150 million for Phase 1. The public needs to be informed about the actual estimated cost of Phases 1, 2 and 3 of the entire bridge.

  • How will the bridge be funded?

Appendix C of the Massachusetts Historical Commission PNF (included as Attachment 5 to the ENF) provides a funding summary that shows $46m in City funding; $10m in Federal funding; and $2m in private funding – for a total of $58m in allocated funding. This would seem to indicate a gap in sufficient funding for the bridge in the range of 50-$100m for Phase 1 of the project. The City needs to disclose its funding plan for all phases of the project to prove the feasibility of the design that has been shared with the public.

  • Is this the moment in time to spend a lot of money on this project?

The combined Federal and private funds for the bridge comprise less than 10% of the overall cost of the bridge as it is currently designed. This means that the City will need to contribute significant funds to complete even the first phase of the bridge at a point of great economic uncertainty locally and globally. There is significant risk that the City will be unable to finance the completion of the bridge through Phase 3. Additionally, the City already has enough dedicated funds, $46m, to build a basic 12 ft bridge as described at the June 2019 NAB Task Force meeting (see above).

Walking and biking designs as described in the ENF

As laid out above, we strongly disagree with the City’s choice of a design alternative that includes vehicle use (other than emergency vehicles) on the bridge. However, we feel compelled to also comment on the specific design of the bridge as shown in the ENF because it has so many problematic design features for people walking and biking. While we understand that the designs are not expected to be complete at this point in the project, the lack of attention to simple operational and safety questions raises doubts about the project design. If the City continues to pursue this preferred alternative we request that each of the design issues raised below be answered in the response to comments on this ENF. In addition, we recommend designing any bikeway and pedestrian facility using the NACTO, Boston Complete Streets, MassDOT, and FHWA design standards to have a low level of traffic stress (LTS by Furth) and high level of local access (by MAPC) rating.

  1. The pedestrian//bike/bus interaction at the Seaport side of the bridge seems to show the bus lane taking up the entire entrance area onto the bridge with a pedestrian ramp entering directly into the bus lane. All of the pedestrian access onto and off the bridge is in the area shown as a bus lane. How will this area be designed to ensure the safety of people walking and biking? The plan shows shuttle buses directly adjacent to people walking/biking; paint is not an appropriate or safe separation or protection for pedestrians and cyclists on a new bridge.
  2. On the downtown side of the bridge the buses would cross the heavily traveled Atlantic Avenue sidewalk into the congested Atlantic Avenue vehicular traffic without a traffic signal to provide them with a break in traffic. How will bus movement be managed to ensure that the buses do not inch up to the travel lane and block the sidewalk while waiting to turn right onto Atlantic Avenue?
  3. How will pedestrian connections between the new bridge and the Harborwalk be designed on both sides of the Channel and how will the connection on the Seaport side of the bridge impact the operations and attractiveness of the Barking Crab restaurant and the Envoy Hotel? The new bridge is itself planned to be a new part of the Harborwalk, but these connections which have complicated vertical and alignment design challenges have not been described in the ENF. Specifically, how does the bridge gain enough height to pass over the water 8′ higher than it is now? Is there a long ramp from Northern Avenue near the courthouse? Is that ramp steep enough to affect walkers trying to use it?  Does the existing Harborwalk at the Courthouse connect under the new bridge to the part of the Harborwalk that parallels the Fort Point Channel? Will the new bridge allow this connection?
  4. On the downtown side of the bridge, it appears that service access to the Coast Guard Building and the Hook Lobster site are to be provided through the pedestrian, bike and bus zones of the bridge. How would this work? Would service vehicles (or any other vehicles) be allowed to turn right from Atlantic Ave into the bus lane and pedestrian zone?
  5. Bus/Bike Lane – The functionality of bus/bike lanes prioritizes bus travel, but do provide some safety benefits for bikes in places where buses were already operating in the roadway space and the only other option bikes have is to ride in dangerous, high speed vehicular traffic. For example, after the bus/bike project was implemented on Washington St, bikes now have the option of riding in a less congested space, which they share with buses, hence reducing the potential for conflicts and ultimately crashes. While the bus/bike lane provides some protection, we feel that it is not enough for the following reasons: 

    – Since the Northern Ave Bridge has not allowed vehicles for many years and it is being designed from scratch, adding an additional layer of bus traffic (transit) without proper space for segregation for bikes and pedestrians only increases the exposure to conflict and risk.

    – In a 12’ bus/bike lane, buses will travel at a much greater speed than cyclists and will want to overtake cyclists, which becomes stressful and can cause potential conflicts. The cyclist is forced to rely on the decision-making of bus drivers behind them. The cyclist is also usually traveling slower, causing the bus driver to reduce their speed and accept the delay from being “stuck” behind the cyclist. This conflict may cause aggressive behavior, which can promote overtaking movements due to impatience from the delay.

    – The ENF states there the number of vehicle trips per day will be 110 bus trips (potential for occasional emergency vehicles). Within a 12-hour period, for example from 8 AM – 8 PM, frequency will be approximately 10 buses per hour, or 1 bus every 6 minutes. This pushes the limit of the NACTO recommendations for a safe shared bus/bike facility. If there is more frequent vehicle transportation in the future, the bus lane should definitely not be designed to be shared with cyclists. Overtaking a cyclist leaves too much room for human error, especially in the confined space of 12’ wide lane.

    – Finally, other bus/bike lanes in Boston are shared with MBTA buses whose drivers get specific and detailed training on sharing a lane with bikes. We understand that the Northern Avenue bridge bus lane would be for private shuttles and have no reason to believe that these drivers know how to safely share and pass cyclists.

  6. Air quality – As we now understand in a more visceral way than before COVID19, air quality matters to health. We share concerns that were expressed at the last public meeting about air pollution from diesel fumes, given the proximity of pedestrians and cyclists to the bus travel lane.Future Design Considerations – In the current 25% design, there are two spans (ribbons) each 24’ wide. One side is a pedestrian only zone and the other includes a bus/bike lane (12’), an unprotected bike lane (6’), and a pedestrian walkway (6’). The plan is designed to keep bikes separate from the pedestrian side, by signing that they ride in or adjacent to bus/shuttle traffic. However, we do not believe this design is realistic given that we can expect tourists and people who are new to the bridge to ride in whatever space is furthest from vehicles, and who also will want to visit the ocean side of the bridge. We suggest separating all bike facilities completely from vehicular facilities, and providing a bike lane with clear ocean views. If the purpose of this bike lane is to be a recreational bike path, which we support, then we suggest designing bike lanes for people to ride 2 abreast which demands that the lanes be 7.5-8 feet wide.
  7. Future Design Considerations – In the current 25% design, there are two spans (ribbons) each 24’ wide. One side is a pedestrian only zone and the other includes a bus/bike lane (12’), an unprotected bike lane (6’), and a pedestrian walkway (6’). The plan is designed to keep bikes separate from the pedestrian side, by signing that they ride in or adjacent to bus/shuttle traffic. However, we do not believe this design is realistic given that we can expect tourists and people who are new to the bridge to ride in whatever space is furthest from vehicles, and who also will want to visit the ocean side of the bridge. We suggest separating all bike facilities completely from vehicular facilities, and providing a bike lane with clear ocean views. If the purpose of this bike lane is to be a recreational bike path, which we support, then we suggest designing bike lanes for people to ride 2 abreast which demands that the lanes be 7.5-8 feet wide.

Public process

Over the past two years, we have raised concerns about the public process on numerous occasions — and LivableStreets raised these issues formally and repeatedly as an official NAB task force member.

The City of Boston established a NAB task force as a means of utilizing the abundant knowledge the City of Boston has to offer, to direct the process for turning the Northern Avenue Bridge into an iconic destination that improves mobility, strengthens resiliency, and honors history. Unfortunately, this process was mismanaged and flawed from the onset.

Though the Task Force process had been framed as transparent and open to the public, there was limited discussion of public comment and often blatant disregard for public consensus.  At each task force meeting, while there was a short amount of time allotted to public comment, there appeared to be no method for incorporating those comments into the process for decision making. Additionally, while there was a tool for providing online comment, there was no discussion about how to incorporate those comments into the process.

Similarly, public meetings for the project were problematic. Ahead of the June 2019 public meeting, Stacy Thompson of LivableStreets, along with several other task force members expressed strong concerns and reservations about the approach the City was taking, which appeared to be purposefully obstructive of public feedback. Stacy also followed up with Chief Osgood, the consulting team and the chairs of the committee outlining her direct concerns in writing. None of the feedback was acknowledged or incorporated into the meeting.

In advance of the May 6, 2020 meeting for this project, we again directly expressed our concerns to the project team and Chief Osgood, that it was inappropriate to even hold public meetings of this nature while the State’s stay-at-home advisory related to COVID 19 was in place. BTD’s decision to hold the meeting was in direct contradiction to the policies of other city of Boston departments such as the BPDA which  stated that, “to ensure that the public process is equitable to all”, it would not be holding virtual public meetings for Article 80 projects or planning studies at this time. This inconsistency between agencies is concerning and needs to be addressed.

We would be pleased to speak with the MEPA Office or the City of Boston about our comments.

Best regards,

Stacey Beuttell, WalkBoston

Stacy Thompson, LivableStreets Alliance

Becca Wolfson, Boston Cyclists Union

Cc:        Mayor Marty Walsh
Congressman Stephen Lynch
State Senator Nick Collins
State Representative David Biele
City Councilors – Kim Janey, Annissa Essaibi-George, Michael Flaherty, Julia Mejia, Michelle Wu, Lydia Edwards,
Ed Flynn, Frank Baker, Andrea Campbell, Ricardo Arroyo, Matt O’Malley, Kenzie Bok, Liz Breadon
Tammy Turley, Chief Regulatory Division, U.S. Army Corps of Engineers
Harborfront Neighborhood Alliance
Northern Avenue Bridge Task Force members – Rick Dimino, Sara McCammond, Kathy Abbott,
Dennis Callahan, Carol Chirico, Senator Nick Collins, Handy Dorceus,
Councilor Michael Flaherty, Councilor Ed Flynn, Gregory Galer, Susan Goldberg, Susanne Lavoie, Representative Stephen Lynch, Richard Martini, Bud Ris, Patrick Sullivan,
Stacy Thompson