Comments regarding the transportation model underlying project design and operational decisions

Comments regarding the transportation model underlying project design and operational decisions

Re: Comments regarding the transportation model underlying project design and operational decisions

Dear FHWA Administrator McEwan and MassDOT Acting Director O’Dowd,

The I90 Allston Task Force met last night (December 11, 2019), the evening before today’s deadline for comments on the Allston I-90 NEPA Scoping Report.

The entire meeting (2+ hours) was consumed by a conversation about the model being used by CTPS (also to be used by MAPC on an additional study) to evaluate the requirements and impacts of the project. As became clear during the course of the presentation and Q&A, the assumptions about transit service that are built into the model will lead to results that point to very low use of West Station (45-60 minute headways during peak hours) and no use of the Grand Junction line (no service at all). The Task Force asked the project team for information about these assumptions a year ago because we were concerned about this issue and its potential impacts on the project review.

We ask that FHWA and MassDOT incorporate the meeting minutes of the Dec. 11 Task Force as WalkBoston’s comments about the Scoping Report because they reflect the serious questions needed to be answered about the basis on which project plans and designs will be made.

Most notably, if the model assumptions lead to results that show little to no use of West Station we fear that a number of decisions will be based on incorrect data:

  1. West Station will be put at risk because it will show such low ridership use
  2. Grand Junction components of the project will be at risk because there will seem to be no travel demand
  3. Bus, walking and biking elements of the West Station area will seem to be of little use because West Station will be shown as having very low use
  4. Sizing of roadway elements of the project (both highway and street elements of the project) will expand because almost all of the trips to be served will be modeled as vehicle trips – because such inadequate transit service has been baked into the model assumptions
  5. West Station and the rail service included in the project assessment will be at odds with the MBTA’s own plans for regional rail as recently voted on by the FMCB – thus putting the MEPA and NEPA analysis at risk for not conforming with state and local plans
  6. The I90 “Allston Multimodal Project” will be at odds with Massachusetts policies and goals regarding the reduction of GHG emissions because it will be premised on a vehicle-based transportation system – thus putting the MEPA and NEPA analysis at risk for not conforming with state and local plans

Thank you for the opportunity to provide comments, and for including the comments of the I90 Task Force in the project record.

Wendy Landman

WalkBoston Senior Policy Advisor and Task Force Member

WalkBoston and MassBike comments on Waltham High School MEPA #16097

WalkBoston and MassBike comments on Waltham High School MEPA #16097

November 26, 2019

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, 

WalkBoston and MassBike have reviewed the MEPA filing #16097 for Waltham High School located at 554 Lexington Street in Waltham, MA. 

We are concerned with changes to Lexington Street that are included in the environmental filing: in particular, a new design speed of 45 mph, the removal of bicycle lanes in order to add additional general travel lanes, and poor connectivity. The changes are at odds with the Waltham Complete Streets policy as well as the recommendations put forth in the Waltham Transportation Master Plan (TMP) from January 2017. As proposed, this project will make Lexington Street more dangerous for all Waltham residents, even motorists. The segment of Lexington Street where the changes are proposed is, in addition to an important north-south arterial for motorists, bicyclists and pedestrians, a residential street lined with single-family homes and their driveways where residents turn left across oncoming traffic, and pull in and out.

Three of our major concerns from the filing:

  1. This project has set a new design speed limit of 45mph on Lexington Street near the new high school; the street previously varied between 40 mph, a 30 mph advisory speed, and 20 mph school zone. The AAA Foundation for Traffic Safety has found that the average risk of severe injury for a pedestrian struck by a vehicle reaches 10% at an impact speed of 16 mph, 25% at 23 mph, 50% at 31 mph, 75% at 39 mph, and 90% at 46 mph. 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.

    A community 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. Parents also need to feel comfortable allowing their children to walk or bike to school. Many students walking to and from school will have to cross Lexington Street. A speed limit of 45 mph 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 20 mph “Safety Zone,” which was established in 2016 under Mass General Law Chapter 90, Section 18B.

  2. Existing bicycle facilities will be converted to shared-use lanes in order to accommodate turn lanes at the proposed intersections. This is not in accordance with the TMP recommended cross section for the Lexington Street Corridor, which included sidewalks and a consistent 6’ bike lane throughout the corridor on each side of Lexington Street, and has been implemented. Additionally, the TMP recommends any redesigns consult up-to-date design guidance. It is unlikely any guidance would pair an increased speed limit with the removal of bike lanes.

  3. Lack of non-Lexington Street connections to the site. If the high school is to be constructed at the Stigmatine site, paths should be constructed connecting it with residential neighborhoods to its north, south and west. These neighborhoods are within easy walking and bicycling distance of the Stigmatine property, as long as connections are established, with an opportunity significantly to reduce traffic to the site from Lexington Street and demand for parking. The initial plans show only access via Lexington Street, but supplemental filings include letters from the Police and Fire Department that reference potential emergency access routes to Lincoln Street and Jericho Hill Road that could be used by people walking or bicycling. These should be investigated further, as they could be an important option for encouraging walking and bicycling to the site, while excluding cut-through motor traffic. 

Potential solutions at the Stigmatine site are restricted by the additional problems that will be created on Lexington Street. We are hopeful that the city can consider more ways to use this project to back up the vision put forth in the TMP: “In addition to implementing physical improvements, easing today’s congestion and minimizing the congestion encountered in the future will require mode shift, smart land use planning, and mitigation on the state, City and private partnership level.” 

We encourage the MEPA office to take a deeper look at this project: the impacts are serious enough that it may require an environmental impact report.

Thank you, 

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

Comment Letter RE: MEPA 16015 Mystic River Pedestrian and Bicycle Crossing

Comment Letter RE: MEPA 16015 Mystic River Pedestrian and Bicycle Crossing

May 13, 2019

Kathleen Theoharides
Secretary of Energy and Environmental Affairs 100 Cambridge St., Suite 900
Boston, MA 02114

RE: MEPA 16015 Mystic River Pedestrian and Bicycle Crossing

Dear Ms. Theoharides:

WalkBoston has worked closely with other community and advocacy groups in support of this proposed bridge over the Mystic River. Because of its critical location at the junction of several lengthy riverside paths, it is of regional significance as a key element in the area’s network of pedestrian and bicycle thoroughfares – a system of facilities that WalkBoston has long supported. The critical nature of the connection is magnified by its potential service as a major walkway between a high traffic generating facility (the casino in Everett) and public transportation (the Assembly Station in Somerville). This new walkway will provide a three- minute walk to public transit (as opposed to a twelve-minute existing walk) and encourage a reduced amount of vehicular traffic in the area.

The Casino operators have supported the proposed bridge with investments of $2,000,000 to date, and have committed to help with further capital funding. We are grateful for this assistance and hope that this provision of private funding will encourage the state to fund a portion of the capital costs, giving the project a higher priority than it now has.

We were surprised that the proposed bridge width has been reduced from 15 feet to 12 feet. Given the impending opening of the casino, the bridge will see a great deal of use by cyclists and walkers who need to share the limited space. Nearly all other pedestrian bridges recently built or under construction by MassDOT exceed this reduced width, adopting a standard that is 14′ or wider. We urge you to adopt the more generous standard that reflects the design standards for 21st century bike and pedestrian bridges. When it is constructed, the bridge will be the only safe, off-road non-vehicular connection between North Shore communities and Boston.


Stacey Beuttell
Deputy Executive Director

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

Comments on the Supplemental Information Document for the Back Bay/South End Gateway Project

Comments on the Supplemental Information Document for the Back Bay/South End Gateway Project

October 5, 2017

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

RE: Comments on the Supplemental Information Document for the Back Bay/South End Gateway Project dated August 18, 2017

Dear Mr. Golden:

WalkBoston has reviewed the documents for Back Bay/South End Gateway Project many times. Although the proponent has made efforts to address some of the issues we raised in our prior comments, we continue to have concerns about the project impacts to the extremely busy pedestrian environment around the project area, and to several of the design elements suggested by the proponent.

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

Possible garage exit ramp across the Dartmouth Street sidewalk adjacent to the Station
We remain vitally concerned about the possibility of an exit ramp from the project garage onto Dartmouth Street into the heaviest pedestrian traffic in the area. Back Bay Station Orange Line, Commuter Rail and Amtrak service presently serves approximately 64,000 passenger trips (alighting and boarding) each day. Many more pedestrians are simply walking by the site, arriving on buses, via cabs and in automobiles. The MBTA, MassDOT, and all people concerned with the continued economic vitality of the Boston area and a more sustainable transportation system, hope that this number will rise significantly over the coming decades. The Back Bay/South End Gateway Project must be designed and managed in such a way that the transit and transportation functions of the station are enhanced.

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

We are very concerned about the changes proposed for the station, the bus layover and the sidewalks and interior passageways, but we believe the exit ramp onto Dartmouth Street is a potentially disastrous step to take in such a congested area. We urge the BPDA to recommend that further consideration of the project as presently designed be delayed until this issue is resolved favorably with no garage ramp exiting across the Dartmouth Street sidewalk.

We would appreciate your consideration of our comments and look forward to your responses to them. Please feel free to contact WalkBoston with questions you may have.


Wendy Landman
Executive Director

Cc Secretary of Transportation Stephanie Pollack City Council President Michelle Wu City Councilor Josh Zakim Ellis South End Neighborhood Association Bay Village Neighborhood Association Neighborhood Association of Back Bay Ken Kruckemeyer