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October 5, 2012 Secretary Richard K. Sullivan, Jr. Executive Office of Energy and Environmental Affairs MEPA Office 100 Cambridge Street, Suite 900 Boston, MA 02114 RE:

Millennium Tower Burnham Building Expanded Environmental Notification Form

Dear Mr. Sullivan: WalkBoston has reviewed the EENF for the Millennium Tower Burnham Building proposal in Downtown Boston. Our comments reflect the aspects of the proposal that most affect pedestrians, as these components are likely to play an important role in the way in which the project functions and relates to its surroundings. 1. We are very impressed with the potential improvements that this project will bring to the area and are happy to see the redevelopment of the site move ahead after the dispiriting view of excavation that has blighted the attractiveness of the retail area and pedestrian use of the sidewalks in the vicinity. This new proposal builds on its location at the heart of Downtown Boston, supporting and encouraging walking in a variety of ways. By constructing new sidewalks, adding subway access, revitalizing Shoppers Park, and providing well-located pedestrian access into the new buildings, the project is firmly based on a commitment to serve walkers. 2. The proposed tower involves no cantilevering over the Burnham Building (as in the prior proposal), and a much less visually dominating building for the

Downtown streetscape. There is a new emphasis on the distinct and historic character of the restored Burnham Building that provides for refreshed facades of the old building while carefully restoring its original architecture. With the new tower set back from the street and with new shopping spaces available, the project will enhance the revitalization of Downtown Crossing and aid in promoting its economic development. 3. The proposal is unique in its location in such close proximity to transit – standing astride one of the major crossings of MBTA lines in the region and located close to the other major transfer stations that serve the regional network. Access to public transportation could hardly be better – the site is the ultimate location for transit-oriented development. Access into and out of the subway appears as a major feature of the proposal on both the Summer and Franklin Streets sides of the project. Along Summer Street, escalator and elevator access is proposed to connect from the street to the subway access corridor directly onto the gates providing access to the Orange and Red Lines. The new escalators and elevator are fully enclosed within the building. This will aid transit users, make transit use more attractive, and should help support the proponent’s proposed retail activities. One of the existing stairways between street level and the subway station on the proponent’s site, built in the early years of transit – perhaps 100 years ago – may be retained, presumably for use when the building’s escalators and entrances are not in use, or if they are more conveniently located for some patrons. This stairway is inadequate and antiquated and should possibly be rebuilt to more modern standards. 4. New canopies over the sidewalk are proposed to replace the existing ones. This design feature will benefit pedestrians by providing weather protection while window shopping or walking along the façade of the old building. The canopies will be replaced in a style complementing the restoration of the Burnham Building. One of the drawings in the EENF shows the canopies at intermittently

spaced locations along the façade (Figure 19 in the EENF). If canopies are not continuous they cannot protect pedestrians for their full walk along the façade of the building. We think that the canopies should be continuous along Washington and Summer Streets, even though this may not be totally consistent with the original design for the Burnham Building. If possible, canopies should be added on the Franklin Street façade as well. 5. The proponent’s proposed streetscape improvements are extensive and welcome. The streetscape along Summer Street is appropriate to this busy pedestrianized location, with no curb and with sidewalks that extend between the building frontages on both sides of the street. We urge the proponent to consider ways in which this might be explored for Washington Street as well, recognizing that implementation will require coordination and help from the city and the properties on the other side of the street. We urge the proponent to replace the sidewalks on Washington Street, Franklin Street and in Shoppers Park with flat, smooth sidewalks for the whole width of the sidewalk (possibly with some use of trim materials) as the smooth portion of the sidewalk appears only for the portion of the sidewalk which follows the edge of the curb, extending between street light poles. 6. Shopper’s Park has had a checkered history and is remembered primarily as a site where people got good take-out food and entered the men’s clothing department in Filene’s. The new proposal will dramatically reshape the park and is so attractive that it will draw and serve pedestrians in a very positive way. The primary new element is a proposed amphitheater facing Washington Street and located directly atop the stairs/escalator of the existing MBTA headhouse. The amphitheater seating will provide a location for passers-by to lunch, peoplewatch or be entertained by buskers or other performers. This proposal is exciting for pedestrians and represents a significant effort to bring life and shoppers back into Downtown Boston. We hope there will be lighting to enable the site to be used for three seasons and perhaps at night. An evening light show could be a very positive addition that appeals to people who might not otherwise be drawn

to the area, including those who could be drawn up the street from the theaters located a few blocks away. An element of concern for pedestrians is the proposal to provide a vehicle driveway that crosses the sidewalk for drop-off into the new tower. We understand that a driveway is needed in this location to allow private vehicles to turn around because they are not allowed to use Washington Street. Within the driveway, pedestrians and vehicles will share space as necessary, and a sidewalk is provided along the street edge. Since relatively few vehicles (approx. 438) are projected to require access to the residential tower via this driveway, we think that it will not pose a safety hazard if it is well managed and well signed. Precedents for this type of joint use of space are present at two hotels in locations along the sidewalk parallel to the Rose Kennedy Greenway. 7. Bike parking on sidewalks should be very limited and, given the growing number of bicyclists in the City, ample bike parking should be provided to serve the residences, businesses and retail users of the site underground or otherwise away from the space reserved for Shoppers Park and other pedestrian zones. 8. The transportation demand management program contains good ideas, including efforts to reduce the use of private vehicles at the prime transit location in the city. We applaud the use of orientation packets for new residents, the transportation coordinator, and shared car service. We urge that bicycle storage be provided in such locations and designs that it not interfere with pedestrian circulation. Thank you for the opportunity to provide comments on this important project. Please feel free to contact WalkBoston with questions you may have. Sincerely,

Wendy Landman Executive Director