Comments on the DEIR/DPIR for the Suffolk Downs Project, MEPA 15783

Comments on the DEIR/DPIR for the Suffolk Downs Project, MEPA 15783

December 14, 2018

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

Brian Golden, Director
Boston Redevelopment Authority
One City Hall Square
Boston, MA 02201-1007

RE:  Comments on the DEIR/DPIR for the Suffolk Downs Project
MEPA: #15783

Dear Secretary Beaton and Director Golden:

Thank you for the opportunity to review and comment on the Suffolk Downs project. We offer the following comments on the project’s pedestrian environment, which overall is well addressed.

The project offers generous walking opportunities

The heart of the proposal is a 15-acre park – the Central Common – with walkways surrounding the site and connecting into and through the open space it provides. The Common has been designed as a one-mile running/walking loop. The park has water features with one pond that can be used for skating and another elongated pond that connects into the nearby saltwater Belle Isle Inlet. The Common connects on either end to meeting and performance spaces on plazas leading to the two Blue Line stations.

Main Street, a second north-south walkway, also connects Beachmont and Suffolk Downs Blue Line stations. This street will have wide, landscaped walkways with setbacks to allow for sidewalk cafes and other such uses along its route.

A third walkway, the Active Linear Corridor, parallels Main Street and runs midblock between Main Street and Tomasello Drive. This pedestrian-only street is intended to provide a series of active play spaces for all ages. The proposal is an extraordinary experiment – a half-mile long area that gives nearby space for casual and active uses. Figure 3.37 lists the potential uses of the corridor as active play, jumping mounds, rolling course, flex turf, climbing health, ping pong and jungle gym. Many of these are likely intended for children.

An additional north-south community trail skirts Tomasello Drive and is shown as a two-way bike facility that follows a swale on the side of the property facing the gas tanks, coupled with a sidewalk on the opposite side of the street.

There are several cross streets that connect the four north-south walkways. They vary in scale and importance. Several contain landscaped walkways and add to the many opportunities for walking throughout the project area.

One concern we ask the developer to address with respect to this generously scaled set of pedestrian ways and open spaces is that the play areas along the Active Linear Corridor (with the exception of the block near Waldemar Avenue) are located within blocks intended to be developed not for housing, but office uses, where presumably there will be few children in nearby buildings. As development occurs within the project, the proponents should ascertain if the proposed Active Linear Corridor is located appropriately to serve the intended users who may be living in residences on-site. Active recreational facilities for small children might be more appropriate lining the loop road at the eastern edge of the proposed Common. This route directly serves the three residential areas near the proposed Beachmont Plaza, the Belle Isle Plaza and the “Panhandle” near Route 1A. This route would strengthen the opportunities for residents to use the Common and its central meeting places as well.

East Boston Greenway extension

WalkBoston encourages the proponents to seriously consider a connection to the East Boston Greenway. The existing East Boston Greenway ends at the Belle Isle Marsh, near the Suffolk Downs MBTA station but on the other side of Bennington Street from the station. There is a roadside path/sidewalk paralleling Bennington Street between the main entrance to the marsh reservation and the crosswalk to the Suffolk Downs transit station. This path is used two-way by both cyclists and pedestrians. Extending the path further north toward Revere Beach is not an easy task. The frontage of Bennington Street is spacious and possibly could be the location of an extended route until reaching Everard Street in Revere, where the Bennington route narrows down on the approach to the Beachmont station at Winthrop Avenue.

A potential alternative location for extending the East Boston Greenway that was suggested in the DEIR exists in the large tract of land between the MBTA rail tracks and the Suffolk Downs property line. This land is nearly 10 acres of unused space and has no buildings on it between the Suffolk Downs transit station and Washburn Avenue in Revere. Depending on ownership the tract might be made available. If owned by the MBTA, the property might become available to the developer, who could include a north-south path that would be available as a substitute for the Bennington Avenue route and link the property into the regional Greenway network as a principal route in the system.

Possible new walking connections into Orient Heights from the project site

A decision has been reached with neighborhood residents that vehicular access between the project site and Orient Heights will not be provided. Several walking issues should be addressed to overcome this lack of street connection.

  1. Walley Street and the Suffolk Downs MBTA station
    Walley Street, just off Waldemar Avenue, is the current road and pedestrian access point to the Suffolk Downs transit station for Orient Heights residents. This approach currently works for all access to the neighborhood, and the proposed development adjacent to it respects existing neighborhood preferences and adds no vehicular access to the existing site. Instead the proposal adds a new access route for vehicles and shuttle buses to drop off transit-riders from the new development as close as possible to the transit station; this connection appears to be a part of the proposed Belle Isle Plaza. It is a bit unclear how this new connection will meet with existing streets and paths, and the developer, the City of Boston and the MBTA will need to coordinate the proposed new access with the existing street and path layout.
  2. South project boundary – Waldemar Avenue
    A community path along the full length of the south project boundary (approximately ½ mile long) connects the bus stop on Route 1A with the Suffolk Downs MBTA station at Walley Street. This is a good walking connection for East Boston/Orient Heights residents, as it provides connections to transit in two directions. From the Suffolk Downs station to a location about halfway between the MBTA station and Route 1A, an on-site road (also called Waldemar Avenue) parallels the path. It will be lined with small residential buildings backing onto the path. The Waldemar Avenue/Tomasello Drive intersection is well located to connect pedestrians into Orient Heights via the sidewalks of the Orient Heights public housing project and especially via Crestway Road, a short street that links to Faywood Avenue and directly to the Manassah Bradley School.
  3. Safe walking access to schools
    The proponents include no discussion or description of schools and safe routes to schools. For any students who are attending nearby schools, walking to school should be safe and convenient. The proponents of the project should work with both the City of Boston and the City of Revere to assure safe passage for all students living in Suffolk Downs and using local schools.

    WalkBoston suggests additional examination of the role of schools on the walking paths proposed for the development. Students attending the Bradley School from both Suffolk Downs and Orient Heights would be well served by a neighborhood connection to the proposed path network. In addition, we suggest looking at whether a playfield that includes active recreation uses could be located where Crestway Road meets Waldemar Avenue (Block 5 on Figure 3.7). A playfield located here could serve both the school and the new neighborhood at a logical intersection of the walkways that are such a positive element of the project.

    For children living in the Boston portion of the Suffolk Downs neighborhood, access to schools in the Orient Heights neighborhood will be somewhat constrained because there is no vehicular access between the two neighborhoods, other than the route provided by going out from Waldemar Avenue onto Route 1A between Tomasello Drive and Boardman Street.

    The closest Revere school is the Seacoast School, located on Bennington Street, which can be reached from Suffolk Downs only by an indirect route through the Beachmont transit station and by sidewalks for a further 1000 feet. The Garfield Elementary and Middle School is about 1500 feet north of Winthrop Avenue. Revere High School is located approximately one mile north of Winthrop Avenue.

Route 1A along the western border of the project area

WalkBoston has significant concerns about the proponent’s plans for the Route 1A corridor. Adding a third vehicular travel lane in each direction and increasing roadway capacity from 2,100 to 3,300 vehicles in each direction – an increase of 57 percent – threatens to undermine the ambitious transit-oriented development goals the proponent expresses elsewhere in the proposal. Increased vehicular traffic will also mean more greenhouse gas emissions and more risks to pedestrian and bicyclist safety. We question the need for more vehicular travel lanes on Route 1A between Furlong Drive and Boardman Street, as most southbound traffic on Route 1A will likely access and exit the project site via Route 145/Winthrop Avenue, rather than the proposed “super street” corridor. Similarly, because of the extensive footprint of the Tomasello Drive intersection with Route 1A, we assume that the proponents are anticipating that most of the northbound Route 1A traffic into the site will enter via Tomasello Drive and exit via the same intersection.

The proposal to add more vehicular travel lanes within the existing roadway footprint will also undermine pedestrian and bicycle accommodations along Route 1A. Adding lanes will likely require narrowing or eliminating the current highway median, which would otherwise provide an important pedestrian refuge at the new proposed crossings at Tomasello Drive and Furlong Drive. Absent such a refuge, pedestrians will be forced to cross six highway travel lanes at once, which increases safety hazards and diminishes connectivity between the project site and development and recreation opportunities along the Chelsea Creek. Adding travel lanes while maintaining a five-foot roadway shoulder also reduces the space available for truly safe and protected bicycle facilities. The current proposal for a narrow five-foot unprotected shoulder alongside fast-moving highway traffic does not provide any meaningful protections for cyclists.

Instead of the “super street” concept, we encourage the proponents to reconsider Route 1A as a truly multimodal transportation corridor, with no new travel lanes except those built as dedicated pull-offs for buses on both the northbound and the southbound sides of Route 1A. This will further advance the proponent’s vision for transit-oriented development, while also maintaining space for protected pedestrian facilities in the median of Route 1A. Dedicated bus pull-out lanes also provide for increased bus service. As part of such a plan, the proponent should commit to improved bus stop facilities along Route 1A, including benches and shelters. Pull-outs for bus lanes and bus stop facilities should be considered for replacement of the existing unsafe bus stops at Furlong Drive, the jug handle at the tank farm, Tomasello Drive and Boardman Street.

Pedestrian access to Route 1A bus connections 

Existing conditions for pedestrians and bus riders on 1A are terrible. We are glad that there are proposals that provide safe access for pedestrians to bus stops on Route 1A, including new pedestrian crossings at Tomasello Drive and Furlong Drive. The principal users of bus services may be most concerned about access at Tomasello Drive. The existing Tomasello Drive intersection is proposed to be divided into two components – one for traffic entering Suffolk Downs from Route 1A and the other for traffic exiting Suffolk Downs onto Route 1A.

Pedestrians from both Waldemar Avenue and Suffolk Downs are affected in a dramatic way by this proposal, which would add a bus stop island for northbound buses on Route 1A, a pedestrian island between the travel lanes for traffic exiting the site onto Route 1A, and a right-turning slip lane for traffic entering the site from Route 1A. We encourage the project proponents to also consider a more conventional T design for this intersection, similar to what exists now.

Under the proposed new configuration, most pedestrians will approach the intersection on the south side of Tomasello Drive, as that is the path that connects to the residential areas in the “Panhandle” of Suffolk Downs, as well as the homes in Orient Heights. The bus stop on the Suffolk Downs side of Route 1A would be located directly adjacent to the Tomasello Drive exit lanes onto Route 1A. Getting to the bus stop would require passengers to cross the right-turning slip lane from Route 1A to reach the bus stop island. The crossing of the slip lane is likely to be more dangerous for pedestrians than other crossings, as traffic entering the site may not be stopped by the Route 1A signals. This should get more attention in final designs; one option would be to install a signal protecting pedestrians and a crosswalk.

Pedestrians crossing Route 1A are primarily bus passengers using southbound Route 1A bus services. They, too, are required to cross the potentially dangerous slip lane from Route 1A into Tomasello Drive, along with the southbound lane that serves traffic exiting from Tomasello Drive. Pedestrians would halt on the island between the travel lanes exiting the site and cross directly to the bus stop on the west side of Route 1A. This movement can be made concurrently with the signal phase allowing exiting traffic to move from Tomasello Drive onto Route 1A. Designers of the traffic flow for this intersection must consider the possibility that walkers cannot cross without a median break that affords refuge and safety for pedestrians who cannot cross in one signal phase.

Offsite mitigation for pedestrians and bicyclists

The project proponents outline an extensive program for offsite traffic mitigation in Section 6.10 of the DEIR, detailing numerous operational improvements for motor vehicles broken down by specific locations and intersections. Pedestrian and bicycle improvements are described only briefly and in largely general terms at the end of this section. We encourage the proponents to provide more detailed plans in the FEIR for pedestrian and bicycle improvements at the same locations and intersections they are prioritizing for offsite traffic mitigation.

Thank you again for this opportunity to comment on the proposals that affect pedestrians in the Suffolk Downs project.


Wendy Landman
Executive Director

Bob O’Brien, City of Revere

Page Czepina, MEPA Office

Tim Czerwienski, Boston Planning and Development Agency

Letter to Review Team on Restoration of the River Edge

Letter to Review Team on Restoration of the River Edge

From: WalkBoston, Charles River Conservancy, Charles River Watershed Association

To: MassDOT – officials, staff, consultants Review Team on the I-90 Allston Interchange Improvement Project

Date: August 15, 2018

Re: Charles River – Restoration of the River Edge

On behalf of three organizations committed to the protection of the Charles River and its parklands, public access and pathways, and environmental health we jointly request that MassDOT fulfill its responsibilities to this invaluable resource by analyzing and developing options for the ecological restoration of the severely degraded and eroded riverbank in the I-90 Interchange Project area – from the BU Bridge to the River Street Bridge. This Project directly impacts the Charles River Basin , its parkland, ecology, water quality, and overall resiliency; dealing with those impacts is integral to the Project.

A study by MassDOT in advance of the FEIR should include re-establishment of a more natural edge, bank restoration, stormwater management, and increased floodplain connectivity and storage for resiliency. It should explore at least one alternative that creates better habitat and provides flood storage through the use of fill material in the river to accomplish these objectives. We ask that between now and when the FEIR is produced, a detailed analysis of alternatives, carried out in a collaborative manner, be developed so that results can be incorporated in the FEIR.

The DEIR did not adequately consider the need to restore the river bank, improve the park, and improve water quality. The DEIR has chiefly dealt with these impacts by trying to avoid them on the theory that permitting for the Project would be more difficult if river edge improvements are included. We are convinced that the contrary is true: a serious examination of these improvements would enlist substantial support from organizations, municipalities, and agencies committed to restoring environmental quality in this area – support that will be important to obtaining required approvals.

Restoration of this area requires attention to a number of issues and several important state and federal requirements, including:

1. Protect the river bank from further degradation and restore aquatic and riparian habitat. Much of the existing bank is degraded and eroding, eliminating fish habitat. The Charles is an important fish run for alewives, blueback herring and American shad, migratory fish that return to the river each year to spawn.

2. Provide parkland and improve safe walking and biking conditions as part of multi-modal improvement called for in MassDOT’s Project “purpose and need” statement and under Article 97.

3. Reduce stormwater runoff discharging to the river via overland flows and outfalls, including the 13 outfalls along Soldiers Field Road in the Throat Area. Both MassDOT and DCR have regulatory obligations to comply with phosphorus limits established in the state’s Lower Charles River Basin Nutrient Total Maximum Daily Load (2007).

4. Provide flood resilience, control and storage capacity for precipitation-based inland flooding within the context of current and expected climate change impacts.

5. Develop landscape strategies and designs that provide Section 4(f) mitigation. Removing invasive species, dead trees and replanting with native vegetation, in addition to incorporating green infrastructure, should be integral to the study.

6. Plan for the riverfront parkland, which is a water-dependent use under Chapter 91.

7. Meet historic requirements for the Charles River Reservation in the Charles River Basin Historic District included in Section 106 of the National Historic Preservation Act and Massachusetts Historical Commission review.

8. Comply with the Article 97 no net loss policy that requires replacement of parkland that is to be taken by the Project.

One example of how an alternatives analysis could address these issues is the environmental assessment and recommendations prepared for the North Shore Riverfront Ecosystem Restoration Project in Pittsburgh, PA. It provides extensive river edge improvements, including a natural bank, new pathways, landscaped parklands, connected floodplain, and wetlands. It was developed jointly by local environmental organizations and local, state and federal agencies, including the US Army Corps of Engineers. (https://www.lrp.usace.army.mil/Portals/72/docs/ProjectReviewPlans/N%20Shore%20Riverfront%20DP R%20MSC%20Approved%20for%20Release.pdf?ver=20160524161651743)

We are committed to working cooperatively with you in this process in order to evaluate the options and to achieve results in an expedited and cost-effective manner to restore and enhance this area of the Charles River and the Basin parklands.

We look forward to your response.

Wendy Landman, Executive Director, WalkBoston
Laura Jasinski, Executive Director, Charles River Conservancy
Margaret VanDusen, Deputy Director and General Counsel, Charles River Watershed Association

Please join WalkBoston, the Charles River Conservancy and the Charles River Watershed Association at a “Throat” Walk, September 12, 5:30 PM. We will meet at “BU Beach” behind the Marsh Chapel.

Images from Environmental Assessment of North Shore Riverfront, Pittsburgh


Comments on Suffolk Downs redevelopment (EEA No. 15783)

Comments on Suffolk Downs redevelopment (EEA No. 15783)

January 25, 2018

Mayor Brian Arrigo
ATTN: Robert O’Brien, Director of Economic Development
City of Revere
281 Broadway
Revere, MA 02151

Secretary Matthew Beaton
ATTN: Page Czepiga, MEPA Analyst
Executive Office of Energy and Environmental Affairs
100 Cambridge Street, Suite 900
Boston, MA 02114

Director Brian Golden
ATTN: Tim Czerwienski, Project Manager
Boston Planning and Development Agency
One City Hall, Ninth Floor
Boston, MA 02201

RE: WalkBoston comments on Suffolk Downs redevelopment (EEA No. 15783)

Dear Mayor Arrigo, Secretary Beaton and Director Golden:

Thank you for the opportunity to comment on HYM Investment Group’s proposed redevelopment of the Suffolk Downs site in East Boston and Revere. WalkBoston looks forward to working with the City of Revere, EEA, BPDA, HYM, and other agencies and project stakeholders to help advance the proponent’s stated goal of “creating a vibrant, mixed-use walkable community.”

Leveraging connections between walkability and transit

The proponent’s Expanded Project Notification Form (EPNF) reflects a strong commitment in principle to walkability and multimodal transportation connectivity. The proposed Phase 1 project emphasizes new pedestrian connections at the Suffolk Downs Blue Line station on the MBTA, and the Master Plan project is similarly premised upon pedestrian access to and from the Blue Line at Suffolk Downs and Beachmont Stations. Overall the Suffolk Downs site is wellpositioned for walkable transit-oriented development, which is reflected in HYM’s high anticipated mode shares for walking and transit for the Master Plan project. (The projected mode shares for walking range from 10.9% for office uses to 19.6% for residential uses; the projected mode shares for transit range from 45.4% for residential uses to 54.7% for hotel uses.)

The Phase 1 project has a much lower projected transit mode share of 37.5%, as well as a 44.4% projected mode share for single occupancy vehicles. We are concerned that this will create significant auto dependency from the onset of this project that will affect the future Master Plan development as well. The proponent states that “while there will be emphasis to support a high proportion of alternative trip making by the Phase 1 Project, this more conservative mode share profile has been utilized given the Phase 1 buildings are being analyzed as a standalone project without the benefit of a mixed-use environment.” We urge the proponent to aim for more ambitious transit, walking and biking mode share goals for the Phase 1 development to maximize the site’s potential for transit-oriented development.

The proponent also anticipates over 54,000 new transit trips per weekday, including over 4,000 trips during the morning peak hour and over 5,000 trips during the evening peak hour. This number is very high relative to current Blue Line ridership levels. As part of their transit analysis for the Draft Environmental Impact Report (DEIR), HYM should detail how they arrived at this number and how Blue Line ridership will change as the Master Plan project is phased in over time. This analysis should be accompanied by the proponent also clarifying their plans to invest in capacity upgrades along the Blue Line as part of a broader package of Transportation Demand Management (TDM) strategies.

Exploring opportunities to reduce single occupancy vehicle trips and parking spaces

While the high projected transit mode share and ridership are positive attributes of this development proposal, the proponent still projects over 33,000 new vehicle trips per weekday, including over 3,000 trips during the morning peak hour and over 3,000 trips during the evening peak hour. This increased vehicular traffic has the potential to significantly affect congestion and pedestrian safety within the project site and along surrounding roadways. Given that vehicular access to the site is limited to just two intersections (Route 1A/Tomasello Way and Winthrop Avenue/Tomasello Way), the proponent should clarify how the project site and surrounding streets will handle this traffic in the DEIR. Significant mitigation measures will be necessary to address 33,000 new vehicles on already congested streets.

While HYM does not specify how many new parking spaces will be needed to accommodate these vehicles, WalkBoston calculates that between 10,800 and 16,200 new spaces will be necessary, depending on the development program and parking ratios used. (The proponent states that the following parking ratio ranges should adequately support the Master Plan project’s parking demand into the future: residential, 0.5 to 1.0 spaces per unit; office, 1.0 spaces per 1,000 SF; lab, 1.0 spaces per 1,000 SF; hotel: 0.5 spaces per room; retail: 0.5 spaces per 1,000 SF). We are encouraged by the relatively low proposed parking ratios for the residential units, as well as HYM’s broader recognition that auto trip rates are likely to decrease over time. The final residential parking ratio should be as close to 0.5 spaces per unit as possible and we look forward to reviewing HYM’s TDM plans as part of the DEIR. Any strategies and mitigation measures proposed must further enhance walkability, bikeability and transit access, while reducing single occupancy vehicle use and the associated need for parking.

Exploring opportunities for bus/shuttle connectivity and related pedestrian access

HYM notes that there are several MBTA bus lines (450, 459 and 119) along Route 1A and Winthrop Avenue within a half-mile walk of the project site, and that “there are opportunities to expand MBTA bus service into the project site and provide for internal site transportation/shuttle to further improve access to public transit” as the Master Plan project is built out. The proponent should further explore and detail these options as part of their TDM plans in the DEIR, as increased utilization of MBTA buses and/or shuttles can reduce single occupancy vehicle use. An analysis of bus/shuttle options should examine the potential for increased service on existing MBTA bus lines and associated changes in ridership, as well as the potential to service the neighborhoods surrounding the project site. The proponent should also clarify their plans for investing in such services, whether through funding the MBTA or their own shuttles.

Ensuring that pedestrians can safely and comfortably walk to and from bus/shuttle stops is critical to ensuring that these services will be utilized. Ideally bus/shuttle stops will be located within a quarter-mile of the project site to maximize their usage. We appreciate HYM’s commitment to improving sidewalks adjacent to the project site to meet ADA standards and to include street trees if feasible, as well as their acknowledgement of the need for mitigation measures and infrastructure improvements at the site’s primary vehicular access points (Route 1A/Tomasello Way and Winthrop Avenue/Tomasello Way). The proponent states that “geometric and traffic signal improvements will be recommended at both of these intersections to optimize traffic operations.”

Improvements at these locations must also address pedestrian safety and traffic calming. HYM plans to widen Tomasello Way and Route 1A as part of the Master Plan improvements, yet there are no crosswalks across Route 1A near the project site and the crosswalk across Tomasello Way at Route 1A is already 140 feet wide with minimal pedestrian refuge. Any signal and roadway upgrades at this location and near other shuttle/bus stops must provide safe pedestrian crossings and well-timed WALK signals that provide countdowns and leading pedestrian intervals. Long crossing distances should be reduced as much as possible using curb extensions, and pedestrian refuges should be created and enhanced to provide protected waiting areas. In extreme circumstances, the proponent might consider working with the MBTA to relocate bus stops to more pedestrian-friendly locations.

Creating a walkable project site that meets Complete Streets standards

In addition to leveraging pedestrian access to and from the Blue Line, the proponent has integrated walkability and pedestrian connectivity into many other aspects of their redevelopment proposal. These include creating a new interior street network on site that meets Boston Transportation Department’s (BTD) Complete Streets guidelines, developing a system of multi-use ADA-compliant paths and trails that connects to adjacent neighborhoods and regional path networks, and activating the public realm with open space amenities and extensive ground-floor retail. Creating streets, sidewalks and paths that accommodate road users of all abilities and travel modes is critical to developing more livable and walkable communities, so WalkBoston is pleased to see a commitment to these issues in the EPNF.

We look forward to seeing more detailed plans for the interior streets, paths, intersections and signals as part of the DEIR. The interior streets should be designed to ensure that vehicles follow a 20 mile per hour speed limit to maximize walking safety as well as walking and transit mode shares. They should also include additional measures for pedestrian safety and traffic calming, including narrow vehicular travel lane widths, frequent and well-marked crosswalks, and well-timed WALK signals that provide countdowns and leading pedestrian intervals. We encourage the proponent to maintain their current plans to not have vehicular access to the project site from Bennington Street or Waldemar Avenue, thus prioritizing multimodal connectivity and reducing the potential for increased local traffic.

Improving pedestrian safety throughout the project study area

The need for traffic mitigation is not limited to the immediate project vicinity and access points. To this end, HYM states that a mitigation program will likely focus on improvements to roadway geometry, traffic signals, and multimodal mobility along the broader Route 1A and Winthrop Avenue corridors, as well as Furlong Drive, the on-site roadway network, and other nearby intersections. The proponent also notes that many of the broader study area intersections are located within Highway Safety Improvement Program (HSIP) clusters and thus are potentially subject to Road Safety Audits (RSAs) per Massachusetts Department of Transportation guidelines. WalkBoston looks forward to reviewing a more detailed discussion of the Master Plan project mitigation phasing and recommendations for the timing of specific roadway improvement projects as part of the DEIR. We are also available to participate in future RSAs as needed. Once again, we encourage utmost consideration for pedestrian safety and traffic calming measures as part of any improvement packages.

Thank you again for considering these issues and feel free to contact us with any questions.


Wendy Landman
Executive Director

Cc: House Speaker Robert DeLeo
Senate President Harriette Chandler
Senator Joseph Boncore, Transportation Co-Chair
Representative William Strauss, Transportation Co-Chair
Representative Adrian Madaro
Boston City Council President Andrea Campbell
Boston City Councilor Michelle Wu, Transportation Chair
Boston City Councilor Lydia Edwards, District 1
Revere City Council President Jessica Giannino
Revere City Councilor Steven Morabito, Economic Development and Planning Chair
Revere City Councilor Joanne McKenna, Ward 1
Becca Wolfson, Boston Cyclists Union
Stacey Thompson, LivableStreets Alliance
Andre Leroux, Massachusetts Smart Growth Alliance
Richard Fries, MassBike Marc Ebuña, TransitMatters
Chris Dempsey, Transportation for Massachusetts

Comment Letter: Tremont Crossing Draft Environmental Impact Report MEPA #14900

Comment Letter: Tremont Crossing Draft Environmental Impact Report MEPA #14900

November 23, 2016

Matthew Beaton, Secretary
Executive Office of Energy and Environmental Affairs
Attn: MEPA Office
Analyst: Erin Flaherty
100 Cambridge Street, Suite 900
Boston, MA 02114

RE: Tremont Crossing Draft Environmental Impact Report  MEPA #14900

Dear Mr. Beaton,

WalkBoston has reviewed the DEIR for the Tremont Crossing proposal in Roxbury. We believe that the very auto-oriented proposed development is inconsistent with the urban character of the neighborhood and needs to be substantially modified to benefit its neighbors.

Parking Spaces Proposed are Excessive
The development calls for a multi-level parking garage of 1,371 spaces that will generate 8,000 vehicle trips per day.  WalkBoston questions the need for such a large garage given that the development will be less than two blocks from Roxbury Crossing and Ruggles Transit Stations, and within a 10-minute walk of Dudley Square that is served by twenty bus lines.

By comparison the two large Target Stores in the Fenway (Boston) and Cambridge have only a couple of hundred parking spaces.  Numerous parking studies of big box stores and shopping malls throughout the country have shown that parking lots/garages are underutilized.

The emphasis on parking and downplaying of the use of transit suggests an imbalance for so large a project in the heart of the city.   As stated in the 2012 comment letter from Boston Transportation Department a consistent supply of available parking will counteract efforts to encourage alternative travel modes.

Tremont Street Should Not Be Widened
To accommodate the large number of vehicles accessing and exiting the proposed development Tremont Street is projected to be widened to eight or nine lanes.  Such a wide roadway at this location is incompatible with the urban character of the street and will create safety hazards to the pedestrians and bicyclists moving to and from the transit services, residences and institutions.

Also, the environmental review should include an assessment of the impact of increased traffic on the busway at Ruggles.  Numerous buses leave Ruggles headed for Dudley and WalkBoston has concern that at peak hours buses will be waiting through numerous traffic signal cycles to exit unto Ruggles Street.  The result could be a backlog of congestion from Ruggles to Malcolm X Boulevard.

Roxbury Crossing Development Should be Integrated into the Neighborhood
As currently designed, the development will be an island, separated from its neighborhood setting.  The proposed development has the opportunity to contribute to the street by creating easy walking access from the transit stations as well as nearby residential developments (Madison Park and Whittier Housing) and institutions (Northeastern University).  The Tremont Street Development is located in an area where Transit Oriented Development is particularly appropriate.

Proposed Project Could Acknowledge Changing Retail
The retail environment has changed since the project was proposed 4 – 5 years ago.  More and more shopping is done on line and traditional walk-in retail is struggling.  Evidence of this is in Dudley Square, the heart of Roxbury.  WalkBoston would like to see the City devote greater efforts to supporting viable retail in Dudley.  Promoting retail within a 10-minute walk of Dudley will only further depress the market for shops in Dudley Square.  However even within the proposed development the liveliness of the retail is questionable given that the proposed network of bridges will connect the garage on the second floor, discouraging patronage of the ground level retail.

Ensure Safety of Major Pedestrian Crossings.
The major pedestrian crossings of Tremont Street will take place at intersections with Ruggles/Whittier Street, South Drive and Prentiss Street. The primary crossing is likely to be at Ruggles/Whittier Street, because of the direct access it provides to the Ruggles MBTA Station. Care should be taken to provide for significant numbers of people wanting to cross Tremont Street at this location. Retention of the median strip in the center of Tremont Street would be useful as a refuge for pedestrians who may not be able to cross the entire width of a widened Tremont Street in one signal cycle. Similarly, leading pedestrian signal intervals should be incorporated to facilitate safe pedestrian crossings at the intersection. Analysis should also be undertaken to determine if a crosswalk is truly needed at South Drive, in view of the nearby Prentiss Street crossing.

Thank you for the opportunity to review this proposal. Please feel free to contact us with questions you may have, and we look forward to hearing how our suggestions are incorporated into subsequent revisions to this plan.


Wendy Landman
Executive Director

Dorothea Hass
Sr. Project Manager

cc: Councilor Tito Jackson
Byron Rushing, State Representative
Deirdre Buckley, MEPA Director
Dana Whiteside, Boston Planning and Development Agency
Kay Matthews, Friends of Melnea Cass Boulevard (FMCB)
Marah Holland, FMCB
Alison Pultinas, FMCB


Comments on the Environmental Notification Form (ENF) for the I-90 Allston Interchange Project

Comments on the Environmental Notification Form (ENF) for the I-90 Allston Interchange Project

December 5, 2014

Secretary Maeve Vallely Bartlett
Executive Office of Energy and Environmental Affairs (EEA)
100 Cambridge St., Suite 900
Boston MA 02114

RE: Comments on the Environmental Notification Form (ENF) for the I-90 Allston Interchange Project

MEPA #15278

Dear Secretary Vallely Bartlett:

We sincerely hope that the Allston I-90 Interchange Improvement Project will bring a wide variety of benefits to the Commonwealth, the City of Boston, and those who live, work, and commute in the area. This project, a major change to our urban environment, affords many opportunities to advance important local and state policies and objectives and protect the adjacent neighborhoods from avoidable adverse impact during and after the reconstruction of the rail and highway infrastructure.

Over the last six months, our organizations have been afforded the opportunity to serve on the Task Force organized by MassDOT to provide advice on the conceptualization of how this infrastructure can be redesigned to lay the groundwork for transportation and environmental goals for a new economically viable regional urban center in the midst of Allston. Through our participation in the Task Force we have been greatly encouraged by the degree to which there is evidence of strong consensus on many issues, and the evolution of MassDOT thinking to apparently embrace many of the multi modal and open space enhancement, and city building aspects of this opportunity.

Now that MassDOT has submitted the project ENF, we are deeply concerned that these and other aspects of the current design and process are not being proposed for adequate analysis, consideration and action.  We urge that the MEPA scope provide that improved transparency and consideration of environmental consequences and we request that MEPA scope require serious attention to the issues which we identify.

Key concerns include:

  • MassDOT should completely integrate planning and construction of the relocated Pike and the new West Station.
  • In the area of West Station, the Turnpike and rail lines should be decked over to enable Smart Growth air rights development and to permit attractive and useful pedestrian, bicycle and bus access to West Station and between North and South Allston. Decking is essential to mitigate the nose and visual impacts from the rail and highway operations so close to residences.
  • A wide riverside park, the “Allston Esplanade,” should extend between the BU Bridge and the River Street Bridge. This is appropriate mitigation for the adverse impact to DCR parkland that appears to be inevitable during construction.
  • Where Soldiers Field Road is parallel to the Turnpike, it should be moved closer to or under the Turnpike viaduct to allow a widening of the park along the Charles River.
  • The Turnpike viaduct should not be widened beyond its current width and should not encroach on the Charles River parkland between the viaduct and Soldiers Field Road.
  • Pedestrian and bicycle paths should extend across the project area, across Soldier’s Field Road (on a new bridge structure) and into the Allston Esplanade, both as key elements of the purpose and need of the project and as essential elements of mitigation for likely adverse impacts during construction.
  • MassDOT should have an ongoing planning process for the Turnpike Relocation and West Station that involves residents and advocacy groups by incorporating the existing task force as a project Area Committee to provide public involvement throughout the finalization of planning and design and oversight during implementation.

With the exception of the first item – the recent integration of the I-90 Interchange project with West Station – none of these concerns are reflected in the ENF. We hope that with MEPA’s review of the ENF, and the scoping of the DEIR, clear guidance and requirements will be set for the elements of study to address the significant concerns and questions that we detail in the comments below.

Thank you for your attention.

Allston Village Main Streets
Alana Olsen, Executive Director

Allston-Brighton Community Development Corp.
Carol Ridge-Martinez, Executive Director

Allston Board of Trade
Marc Kadish

Allston Civic Association
Paul Berkeley, President

Allston/Brighton Bikes
Galen Mook

Boston Cyclists’ Union
Pete Stidman, Executive Director

Charles River Conservancy
Harry Mattison

LivableStreets Alliance
Matthew Danish

Barbara Jacobson

Wendy Landman, Executive Director


Residents of Allston:
Matthew Danish
Rochelle Dunne
Paola M. Ferrer, Esq.
Anabela Gomes
Bruce Houghton
Wayne Mackenzie
Rich Parr
Jessica Robertson

Francis A DePaola, MassDOT Highway Division
James Cerbone, MassDOT Highway Division
Mike O’Dowd,MassDOT Highway Division


The Environmental Notification Form submitted by MassDOT has a limited focus that addresses only the Turnpike reconstruction, ramps to neighborhood streets, and West Station. Though these elements may indeed be focal, they are not the only elements of a project that will have enormous environmental impacts on Allston and adjoining neighborhoods. The ENF has omitted many of the important issues and options that have been the focus of Task Force comments, and that would lead to meeting the strongly expressed community goals of reconnecting neighborhoods with transportation facilities, creating an enhanced mix of walking, biking and transit options, and providing for mixed use development opportunities in the future.

We are particularly disheartened by the lack of transparency evidenced by specific assertions in the ENF that the Task Force has vetted the particular approach expressed in the document during its ten meetings. Exactly the opposite is true. An example is the assertion by MassDOT that the viaduct will be reconstructed to consist of four travel lanes in each direction, incorporating shoulders and a breakdown lane. This proposal by MassDOT would require that a portion of the viaduct be built in or cantilevered over existing parklands. The Task Force expressed concerns about this option, that it would actually make the road less safe by encouraging higher speed travel, and that MassDOT should not permanently take Charles River parkland to widen the highway.  However, MassDOT has not adequately evaluated reconstructing the viaduct in its present dimensions and avoiding taking of any parkland.

The example cited above has guided our investigations of the ENF contents. We are deeply concerned that conclusions drawn by MassDOT are not transparent and that a comprehensive and detailed examination of the future of the area is not included in the presently proposed work activities for the DEIR. The DEIR should address the community’s concerns about access, development and implementation.


The study area boundaries do not adequately include adjacent parts of the community where the project will have impacts. The study area boundaries should be modified to permit a full analysis as listed below. Other environmental concerns such as water quality may require study area changes in addition to those described below.

  • Connections to the Allston Esplanade

The study area should extend to Cambridge Memorial Drive (it now stops at Soldiers Field Road) to incorporate the esplanades on both banks of the Charles River, the reconstruction of the existing structurally deficient two track Grand Junction bridge, and an appropriate pedestrian and bicycle connection between the Cambridge and Boston Esplanades. The proposed stairs and ramps of a new pedestrian crossing adjacent to the river will be partially outside of the presently defined study area, and require a change in the study area boundary to detail the best connections of the new crossing into the narrow strip of land between Soldiers Field Road, the river’s edge, and the existing path through the parkland.

  • Connections to Commonwealth Avenue

The study area on the south side of the highway and rail yard should extend to Commonwealth Avenue, because of the need to examine the potential for cross-town pedestrian, bicycle and bus access connecting North Allston to West Station, Commonwealth Avenue and the MBTA’s Green Line. The study should include potential changes in land use and employment in and near Commonwealth Avenue, where institutional development will have a significant impact on future pedestrian, bicycle, bus, Green Line, and West Station traffic.

  • Noise and vibration impacts

Noise and vibration impacts should be studied in adjacent neighborhoods in the Allston sections of the Turnpike reflecting highway, rail storage yard, West Station and rail operations. Noise impact analysis should extend north of Cambridge Street into North Allston along the Lincoln Street frontage of Allston – an area with recurring noise and vibration impacts from the Turnpike. Noise impact analysis is also required, as requested by residents, in the nearby neighborhoods in Cambridge which are particularly exposed to noise from the elevated Turnpike.

  • Air quality impacts

Air quality analyses should be performed for adjacent neighborhoods in both Boston and Cambridge, on all sides of the projects area, but now outside the study area.

  • Traffic impacts

The study area should include Harvard Avenue and Linden Street, Western Avenue, River, Malvern, Alcorn and Babcock Streets, and Commonwealth Avenue for a fuller understanding of traffic and land use impacts. Auto and truck traffic should be examined separately because trucks are not allowed on Storrow Drive and therefore use neighborhood streets for access into the Longwood Medical Area, Back Bay and elsewhere.


Discussion of the need for the project is minimal and there is room for significant improvement. For example, as cited by the ENF, defining a major need: “The Beacon Park Yards and the I-90 interchange have prevented direct and convenient access from Cambridge Street in North Allston to areas of Allston south of the rail yard.” (ENF, page 4)

  • The DEIR should include detailed analysis of current and potential connections between North Allston, Cambridge Street and Commonwealth Avenue to evaluate the possibilities for pedestrian, bicycle, bus and general traffic, improving neighborhood cohesion, and minimizing cut-through traffic that negatively impacts residents and businesses on streets including Cambridge Street, Linden Street and Harvard Ave.

The shape and type of future land development should help determine the street network, the pattern of development parcels, and access by motor vehicles, pedestrians, bicycles and buses to sites of future development, both north and south of the Turnpike. The 150-acre study area is very significant in terms of land made available for private and institutional development because of the implementation of this project.

  • The DEIR should examine potential land development patterns and how they are affected by different project alternatives including street layout, vertical geometry of streets and ramps, vehicle and pedestrian access into and out of parcels as affected by ramp vs. street configurations, traffic patterns, and parcel size and depth.
  • The DEIR scope should include the identification of specific actions to mitigate the historic damage to neighborhood connectivity and to establish appropriate connections to support a thriving unified urban district. 

The study area being so large provides an excellent location for institution of the MassDOT mode shift goals that call for tripling the mode share of transit, walking and biking, a basic transportation need for the future sustainability of service provided by all modes.

  • The MEPA scope should reference and flesh out the transportation options and opportunities resulting from this project and emphasize options that provide for user-friendly, pleasant access by walking, biking or taking transit between Commonwealth Avenue and Cambridge Street and connections to the rest of the study area.


The components of the project described in the ENF should be more comprehensive and clearly analyzed in the DEIR.

1. I-90 Viaduct

The proposal to completely reconstruct the viaduct to modern interstate highway design standards is stated in the ENF to consist of four travel lanes in each direction, incorporating shoulders and a breakdown lane in each direction. This requires a portion of the viaduct to be built in and/or cantilevered over existing parklands and is the only alternative presented to date.

  • Alternatives for the design of the viaduct should be clearly stated and analyzed in the DEIR including an option that maintains the viaduct at its existing width and location. This option is preferred by many Task Force members but not included or mentioned in the ENF. The consequence of cantilevering a highway over parkland will raise 4(f) questions and result in air quality and noise impacts to the parkland.
  • Additional options for the design of the viaduct are possible, including an on or below grade which could provide further mitigation for adverse construction impacts from the reconstruction process. 

Lowering the design speed of the Turnpike could allow modifications to vertical and horizontal geometry that will minimize impacts and improve opportunities for Smart Growth economic development.

  • The I-90 viaduct alternatives should include an option based on a reduced design speed to benefit the land use and open space impacts of the project and improve safety on the Turnpike. Since MassDOT recently constructed the Big Dig with significant variations from FHWA interstate design standards, we know Massachusetts has the capacity and ingenuity to fit highway projects into constrained urban environments in a manner to allow future multi-modal, mixed use and open space benefits to the surrounding community. Big Dig design exceptions explored and implemented in Chinatown, the Financial District, the Waterfront and the North End should be explored in Allston.
  • “No access” limitations on the proposed ramps and street network options should be revealed in the DEIR, in both maps and text. MassDOT should present alternatives that minimize the extent of these restrictions, as limiting general access to local streets and Turnpike connections negatively impacts land development and will affect roadway speeds throughout the area, which in turn promotes safety for all modes.

2. Soldiers Field Road

Moving Soldiers Field Road away from the riverbank is an essential element of the project.

  • The proposal to move Soldiers Field Road away from the river should extend fully between the BU Bridge and the River Street Bridge to provide new parkland, paths and local street connections.  Planning for Soldiers Field Road should be a principal and formative element of the Turnpike interchange project that feeds the roadway, parkland and path network in the new community being created as part of this project.
  • The Boston Society of Architects has suggested such a park-like entrance to the study area, framed by a crescent relocation of Soldiers Field Road and we request that the MEPA scope include development of such an improvement as mitigation for the construction impact on parkland and as a part of the basic purpose and need of the project. 

Alternatives studied for the Soldiers Field Road portion of the study area should include:

  • Relocation of Soldiers Field Road away from the river, resulting in new parkland – the Allston Esplanade – and pedestrian and bicycle paths along the river between the Turnpike viaduct and the River Street Bridge.
  • New egress and access with Soldiers Field Road’s eastbound traffic to help diminish dangerous conditions at nearby intersections.
  • A new pedestrian and bicycle bridge over Soldiers Field Road (this would currently be difficult to build because of limited land at the riverside end of a bridge).
  • Westbound access from Soldiers Field Road directly into the westbound turnpike frontage road via a vehicle overpass or underpass.

3. West Station

A new major transit station is a welcome component of the project, and a connection between West Station and North Station via the Grand Junction alignment is already included in MassDOT FY2014 – FY2018 Capital Investment Plan. Options for rail connections under the Turnpike viaduct should be included in the DEIR to assure the feasibility of this connection. Options should include examination of the Charles River rail bridge, (now just outside the study area) along with pedestrian and bicycle routes over the bridge.

All options reviewed for the location of West Station should be included in the DEIR, along with a comparative analysis of each location. Analysis of the options should include, for example, these impacts on residences that abut the rail tracks:

  • Noise, vibration and air quality impacts resulting from anticipated daily train traffic passing through the station, as well as periodic traffic arriving for vehicle services in the rail yard.
  • Noise and vibration impacts resulting from operations of the proposed power substations, the proposed wheel truing track and building, the proposed pit track, the proposed covered track, the crew quarters, and the proposed car wash.

Analysis of West Station layout options should include a detailed discussion of potential operations and these effects on design:

  • Location of head house(s) or other access points
  • Ridership using commuter rail services.
  • Walk-in traffic from both north and south of West Station.
  • Bicycle traffic from both north and south of West Station.
  • Cross-town or local bus traffic from both north and south of West Station.
  • Idle and temporary bus storage near West Station.
  • Kiss-and-ride traffic from both north and south of West Station.
  • A bus or vehicle garage near West Station.
  • Service access for West Station and employee parking.
  • Efforts to minimize private vehicle access to the station, and emphasize pedestrian, bicycle and transit access.

4. Transit routes

Examination of local and regional rail and bus services have not yet been provided. All options for potential bus connections across the study area should be explored, and include details of potential connections:

  • West Station with rail connections to Back Bay, Downtown and the Seaport area via the route to South Station and to Kendall Square, East Cambridge and the Bulfinch Triangle via the route to North Station
  • East-west transit, such as express bus services to Back Bay and Downtown via West Station.
  • Local buses
  • Links to Green Line stations along Commonwealth Avenue
  • North-south transit routes, such as a possible Circumferential Bus transit route connecting transit stations such as Harvard Square and Ruggles with alternative, more direct routes to desired employment destinations between Harvard Square in Cambridge, Boston University, Longwood and BU’s Medical Center in South End.

Options for bus routes serving the study area should be examined, including:

  • A bus-only or other connection between Cambridge Street and Commonwealth Avenue across the Turnpike and rail yards via Malvern, Alcorn or Babcock Streets.
  • Local bus routes, such as Route 66, diverted into West Station.

Bus access to West Station is extremely important and should receive special attention in the DEIR. We request that the MEPA scope require a thorough examination of future cross-town, local and express bus services, as well as the use of air rights to provide bus access both to and from the station and the adjacent area south of the station nearer Commonwealth Avenue.

5. Bicycle and pedestrian connections

Proposals for pedestrian/bicycle routes should be made to maximize their potential future use.

  • The DEIR should explore a network of pedestrian/bicycle connections that are not tied to the web of roadways to provide service in the 3,000 foot distance between Babcock Street and the Cambridge Street overpass of the Turnpike.
  • Pedestrian and bicycle connection options should also be examined for Malvern and Alcorn Streets, each very close to the proposed West Station, crossing north-south over the Turnpike and the rail yards.
  • The DEIR should thoroughly explore options for walking and biking connections between Babcock Street and the Paul Dudley White Path at the easternmost edge of the study area. Details of the Babcock Street connection to the river should show how it may serve as access to and from West Station. Analysis should include required elevation changes to make the connection.
  • Additional north-south pedestrian/bicycle connections across the study area should result in options that provide access to West Station, BU and the local residential community.
  • The projected replacement of the existing Lincoln Street pedestrian bridge should be linked to future pedestrian and bicycle routes throughout the study area.

6. Motor vehicle and truck connections

The community has expressed significant concern that roadway connections should be explored that extend from Cambridge Street to Commonwealth Avenue. The DEIR should include an analysis of options that connect Cambridge Street and Commonwealth Avenue that include:

  • An option that provides access for pedestrians and bicycles only
  • An option that provides access for buses, pedestrians and bicycles only
  • An option that provides access for commercial vehicles, buses, pedestrians and bicycles only
  • An option that provides access for non-commercial vehicles, buses, pedestrians and bicycles only
  • An option that provides access for all motor vehicle traffic, buses, pedestrians and bicycles.

Without an investigation of these options, all traffic going between the Turnpike and areas south of the Turnpike (Back Bay, Longwood Medical Area, Brookline) must either use Storrow Drive or go through Allston via Harvard Street. Because of restrictions on Storrow Drive, this pattern requires ALL trucks to travel through the community.

We request that the MEPA scope require an analysis and comparison of connectivity options between Commonwealth Avenue and Cambridge Street, including access for pedestrians, bicycles, buses, autos, taxicabs and trucks, specifically identifying the impacts on existing problem areas such as Linden Street, Harvard Avenue, Cambridge Street, River Street and the BU Bridge. We also request this analysis to form the basis for an open and transparent discussion with the communityof the options that will be carried forward in the preferred alternatives for both highway and transit connections.

7. Decks over the Turnpike and the rail yards

This large area above the Turnpike and rail tracks, with good regional access and in close proximity to downtown, Longwood Medical Area, Harvard and BU, will generate interest in air rights development from developers and institutions.   Air rights are already a major component of the proposal because they must be used to provide access to West Station. We request that the DEIR include specific options for stages of decking, along with an examination of the methods and means to provide for their construction

The location of the West Station head house, and vehicular and pedestrian/bicycle connections will generate options for future decking.  Potential alternative uses for the decks should be explored and footing locations for air rights development should be included in all designs.

The DEIR should also explore options that use decking to aid in noise and vibration reduction and air quality improvement for nearby residential communities and future development. This is especially important in the area near Pratt and Wadsworth Streets.

Options for the design and integration of West Station into the surrounding parcels should be studied, including the impact on residential quality of life, accessibility of the station, and economic development opportunities. At a minimum, this study should compare designs for West Station comparable to Back Bay Station, Assembly Square Station and Yawkey Station and the ways they would be affected if they were served by decks over the transportation facilities.

We urge that the MEPA scope require the analysis of where decking will be most useful, and require that the project include such decking as part of the initial construction, because decking at the time of original construction is most cost effective and least disruptive, and often the only feasible way to protect abutting land uses from adverse noise and visual effects of rail and highway activities. 

8. The route of the People’s Pike through the development area

The ENF describes routes for a bicycle route at the perimeter of the study area, along either Cambridge Street or along the edge of the Turnpike viaduct/frontage road. New options for the People’s Pike should be explored, including likely desire lines across the middle of the study area. The proposed Pike alternatives should be laid out to go through or adjacent to development areas, and to the Charles River in the large triangular study area south of the new, parallel Cambridge Street and north of the Turnpike. This area currently has no proposals for streets and paths east-west through it.

Options to be studied for the street cross-sections and the street grid should include a People’s Pike with the layout and dimensions of Commonwealth Avenue Mall in Boston’s Back Bay.

Options for a network of connections provided by the People’s Pike should be explored. The need to connect North Allston with the Charles River suggests the DEIR should examine a sidewalk and two-way cycle track along the north side of the existing alignment of Cambridge Street. Similarly, to connect North Allston with the new crossing over Soldiers Field Road, a diagonal alignment through the study area should be one of the options.

The People’s Pike is not only east-west. The DEIR should include options for north-south movement, including but not limited to the paths along the Charles River. These alternative routes should connect with other People’s Pike alternatives with West Station and Commonwealth Avenue.

We urge that alternative routes for the People’s Pike be included in the MEPA scope for the project, as the Pike should be a central, formative element and integral portion of the road and street network to be constructed on the site. As it forms a major circulation connection between parkland and residences and new business opportunities that will come to this site. the Pike should not become an adjunct of either Cambridge Street or the Turnpike ramp and main line network, constructed on left-over right-of-way.

9. Profiles and alignment of the rail and I-90 main lines

The vertical profiles of future rail and I-90 main lines will affect noise and vibration impacts on adjacent residential areas, and can significantly impact future use of air rights over the Turnpike and rail yards. To date, only one possible profile for the highway has been explored. Rail line profiles are also at issue – not only the current single track of the existing Boston-Worcester commuter rail service, but also the rail line service proposed to connect to the Grand Junction tracks for the new rail service between West Station and North Station, via Kendall Square, East Cambridge and the Bulfinch Triangle. No alternative profiles for the rail lines have yet been explored, yet both the Worcester and the Grand Junction pass directly beneath the Turnpike viaduct that is to be totally reconstructed. They will thus become a part of the construction staging for the viaduct, and their final profiles should be examined early in the project.

The assessment of profile options for the rail lines and I-90 main lines should include lower profiles so that the cross streets connecting to West Station and between Commonwealth Avenue and Cambridge Street could be less steep. We request that the scope of the DEIR include examination of lower profiles that might be attained by removal of earth contaminated by 100 years of railroad use of the property. We also request that the MEPA scope require a precise discussing of construction sequence of these essential elements.

10. Land use changes resulting from new development

Proposed development plans in the ENF cover only street and highway options. Options for private or institutional development of the blocks formed by transportation routes should be incorporated into the DEIR. Future land use will be an input to all area traffic models, and the DEIR should show, in maps and text, the land use options that underlie the traffic analysis. Densities of development (which could be quite high in this central and very attractive area for development) should be discussed, along with the residential, business, academic development or recreation possibilities in this significant area in the center of the region.

Land use patterns should also be examined for their relevance to the design of all roads and streets in the area, in terms of cross-sections, pedestrian and bicycle services, landscaping, urban design and access to developable parcels, whether they give access to residential, business or academic uses.

While the provisions of Complete Streets guidelines require sidewalks and bicycle accommodation, certain streets can be expected to have driveways and breaks in adjacent curbs. We request that the MEPA scope of study should define the streets or portions of streets that will not provide access to and from development parcels.

11.  Regional impacts of the project

Travelers using vehicles to pass through this interchange include those going to Back Bay, Downtown, Kendall Square, the Innovation District and the Longwood and BU Medical Areas. Private vehicle drivers have many parkway and local street options for distribution, but trucks from around the region are constrained to use Cambridge Street, Harvard Avenue and Brighton Avenue. An investigation of options outside the study area for new Turnpike connections to Park Drive, Beacon Street or other locations should be undertaken by MassDOT as a method of reducing general traffic in the study area and mitigating impacts during the construction of this project. New connections would reduce traffic impacts on neighborhoods which now serve as a pass-through for many trips with destinations outside the area.  We request that the MEPA scope require a full exploration of these truck-related issues, and recommend appropriate mitigation of the already unacceptable burdens the current traffic pattern imposes.

The western corridor of the region, served by commuter rail, rapid transit, express buses and the Turnpike, remains one of the most heavily used in the region. The Turnpike bears a heavy traffic load and is already congested at many locations in the regional growth centers inside Route I-95/128. Unfortunately, the Turnpike is not expandable and parallel routes are also beyond capacity. If the highly desirable economic growth of the region is to continue, the public transportation mode share must expand exponentially to attract vehicles away from the Turnpike so that it can operate at a more reasonable level of service. We request that the MEPA scope include a requirement for development of an overarching regional context with public input for use in evaluating the planning and design options in Allston.

12.  The Beacon Park Yard Layover Facility

The area around the I-90 Interchange project includes the currently vacant rail tracks known as the Beacon Park Yard, proposed in the South Station Expansion Project (EEA number 15028) to become a major rail layover facility and in this ENF to become the principal layover facility for MBTA commuter rail trains to and from the West/Southwest. The analyses of the South Station/Beacon Park Yard Layover Facility should be included in the DEIR to show its relationship to the rail network, West Station and the I-90 Interchange project, and also the additional impacts brought to the site by the layover facility.

The current document for South Station and the Layover Facility points toward potentially severe impacts of noise, vibrations and air quality within short distances from adjacent residential areas along Pratt and Wadsworth Streets. The DEIR should provide a detailed map of the proposed layover facilities for commuter rail services and the need for including facilities that may generate severe impacts on adjacent residences, such as the proposed wheel truing track and building, the proposed pit track, and the proposed covered track. The DEIR should demonstrate how these and other impacts are magnified by the addition of noise, vibrations and air quality issues from the highway relocation and the new West Station, and how these impacts might be abated by alternative locations for each of these facilities at this site or elsewhere.

We are pleased to note that the South Station Expansion Project includes a role for Widett Circle as a layup facility closer to South Station. We request that the MEPA scope include an analysis of the degree to which a more robust facility at Widett Circle might permit some reduction in size of the new facility proposed for Beacon Park Yard, which could allow more flexibility to mitigate noise and other proximity effects, and consider requiring this modification as a mitigation measure in the study area.

13. Construction impacts

Removing a significant highway interchange is complicated and will involve many steps to accomplish safely for all users – highway, pedestrian, bicycle, bus, rapid transit and truck. The staging of construction should be detailed in the DEIR, to report on potential influences of staging on the final design of street networks and ramps, land development, pedestrians, bus and bicycle ways. Staging of construction has not yet been discussed, and both the area and the project are very complicated. Thus, staging should be considered an ever-present and potential reason for modifying the design and should include detailed discussions with the community.


MassDOT should evaluate how its proposed improvements further the following Commonwealth of Massachusetts policy goals and how these goals work together to mutually reinforce one another and strengthen the Commonwealth’s efforts to reduce its dependence on single occupant vehicles. These policy goals are embedded in the MassDOT Transportation Impact Assessment (TIA) Guidelines, instituted in March of 2014.

  1. MassDOT Mode Shift Goals
  2. MassDOT’s Design Guide standards on Complete Streets
  3. The Global Warming Solutions Act
  4. The Massachusetts GreenDOT Policy Initiative
  5. MassDOT’s Mode Shift Initiative
  6. The inter-agency Healthy Transportation Compact
  7. The Healthy Transportation Policy Directive
  8. The Massachusetts Ridesharing Regulation
  9. MassDOT’s Safe Routes to School

Each of the above policy initiatives must be supported through implementation of project elements that provide for a multi-modal transportation development review and mitigation process. These elements emphasize transportation-efficient development and enhancement of transit, bicycle, and pedestrian facilities, as well as foster implementation of on-going, effective Transportation Demand Management programs. We request that the MEPA scope require explicit use of these policies as drivers of planning and design as well as evaluation criteria for decision-making.

E. Further community involvement

This project is one of the most complicated and consequential MassDOT proposals in recent years. Because it involves so many actors and agencies, it is difficult for participants to grasp and understand. In particular, it is difficult for adjacent neighborhoods to monitor because the information provided is complex, but to date has been limited in its explanations, assumptions, and both the agency and the public decision-making process. In light of the investment in getting conversant with complex technical issues which has been made by the existing Task Force members, we propose that MEPA reconstitute the existing Task Force as the Project Area Committee for the remainder of the environmental process, development of design build contracts and eventual oversight of implementation.

To ensure continuous community monitoring, we recommend that the Secretary follow the precedent established by the September 14, 2007 certificate establishing a special review process for the Harvard University – Allston Campus 20 year Master Plan and create a Citizens Advisory Committee that should be empowered to:

  • Meet with MassDOT and its consultants on a monthly basis.
  • Hire its own third-party consultant to review and evaluate MassDOT’s preferred alternative and other related proposals and be supported with a budget of $300,000 provided by MassDOT to fund the consultant who will work for and under the direction of the CAC.

F. Funding considerations

We have been concerned to hear some discussion that only the highway portions of the Allston initiative have secure funding and fear that fundability could be a basis to undermine the environmental integrity of the process. We realize that project funding is not usually a part of MEPA review, but we believe that this project is unique and can readily be built in an integrated manner that will result in savings from designs that are interrelated and construction. This is true of not only the public expenditures, but also those of private developers and the principal landowner of the study area. We request that the MEPA scope include exploration of public-private methods of constructing the transportation facilities, including the required transit, pedestrian, bicycle and open space facilities, as well as early decking to promote air rights development over the transportation facilities.