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it's private
Health and Environment Committee hearing
on the proposed development on the "Belmont Uplands"
letter to Henrietta Davis, Chairperson

Henrietta Davis, Chairperson
Health and Environment Committee
Cambridge City Council
City Hall, Cambridge, MA 02139

Dear Councilor Davis,

The Cambridge Conservation Commission would like to provide the following information for your consideration at the March 4, 2003, Health and Environment Committee hearing on the proposed development on the "Belmont Uplands." This site is located off Route 2, adjacent to Little Pond and the Arthur D. Little campus on Acorn Park Drive. This letter is also in partial response to City Council Order # 0-24.

We very much appreciate that you are holding this hearing, as we believe that this proposed development needs close review regarding its potential negative and positive impacts on the City of Cambridge, especially its wetland resources and natural areas. In addition, we are concerned about the proposal in a larger, watershed context, specifically whether it is in keeping with "Smart Growth" principles that the City of Cambridge is striving to follow.

Broadly speaking, there are two areas of concern to the Conservation Commission. We are concerned about the potential negative impacts that this development will pose:
1. In the immediate vicinity of the development for resource areas under the jurisdiction of the Cambridge Conservation Commission, such as (but not limited to) the neighboring Little River.
2. For downstream resources under the jurisdiction of the Cambridge Conservation Commission, such as (but not limited to) the Alewife Brook and the Alewife Reservation.

We also believe it is relevant to ask if this development makes sense in the broader context of economic development in an environmentally sustainable context for our region and our Commonwealth.

We will go into a further discussion of these points on the following pages.

To date, the Conservation Commission has not received information from the developer regarding the site plan. Our comments and concerns are based on our own knowledge of the site, review of the Environmental Notification Form (ENF) that the developer submitted to the Massachusetts Office of Environmental Policy, the City of Cambridge response to the ENF, information in newspapers, several briefings at the Conservation Commission by concerned citizens, and an informal briefing by Owen O'Riordan, Cambridge Department of Public Works, on the Cambridge sanitary and stormwater system in the Acorn Park Drive area.

1. Concerns regarding direct impacts to resource areas protected under the Wetlands Protection Act (WPA) Although most of this 16 acre site lies in the Town of Belmont, its southeastern corner lies within the city boundary of Cambridge. In addition, the remaining eastern property line of the parcel abuts the city line. The portion of the site that lies in Cambridge is roughly 1.5 acres. This area abuts the Little River, and we know from our own familiarity with the area that the following resource areas protected under the WPA lie within the site: land under water (Little River), riverfront area, land subject to flooding (100-year floodplain), inland bank, bordering vegetated wetland, and buffer zones to the two latter areas.

Although we understand that no development is proposed on the portion of the site that lies within Cambridge, the Cambridge Conservation Commission must review the proposed development for potential impacts to the wetland resource areas that lie in Cambridge. As a first step, the developer must delineate the resource areas on the site that lie in Cambridge and come before the Conservation Commission for approval of this delineation.

Second, the Conservation Commission must have the opportunity to review the potential impacts of the proposed development on the resource areas of the portion of the site that lies in Cambridge. At a minimum, the developer must submit a Request for Determination of Applicability to the Commission for our determination whether the proposed development is likely to have impacts on protected resource areas. If the Commission's determination is positive, then the developer must submit a Notice of Intent for our review and approval.

Potential direct impacts include impairment of water quality, wildlife habitat, endangered species habitat, and flood control (see below).

2. Concerns regarding indirect and/or downstream impacts to resource areas protected under the WPA In addition to reviewing the direct impacts of the proposed development on the resource areas that lie within the Cambridge portion of the site, the Conservation Commission is also concerned about the potential impacts of the development on protected resource areas downstream of the site. The downstream areas include the Little River and Alewife Brook, the portions of Alewife Reservation and Alewife Brook Parkway that lie in Cambridge, and the wetland complex that abuts the site to the east. This latter wetland complex is commonly referred to as the "ADL [Arthur D. Little] Wetland."

These areas contain the full suite of protected wetland resource areas, namely land under water (Little River, Alewife Brook, and open water wetland in the ADL wetland), riverfront area, inland bank, bordering vegetated wetland, and land subject to flooding (100-year floodplain).

Potential direct and indirect (downstream) impacts to these resource areas include:
  • Impairment of water quality from overland stormwater runoff, discharges of stormwater from point sources, and increased volume and frequency of combined sewer overflows into Little River and Alewife Brook. Stormwater and CSO discharges may introduce sediment, nutrients, pesticides, herbicides, pathogens, road salt, oil and grease, and debris into the water. Any impairment of water quality may negatively impact resident and anadromous fish species that use Little River and Alewife Brook. Two species of anadromous fish, namely alewife and blueback herring, are known to use Alewife Brook and Little River for spawning. In addition, although it is not clear whether any significant populations of freshwater mussels occupy Little River and Alewife Brook, the streams are potential future habitat, once water quality improves. Any potential water quality impairment would harm freshwater mussels that could potentially use the aquatic habitat.
  • Impairment of aquatic and terrestrial wildlife habitat. Aquatic habitat may be impaired by decreased water quality. Terrestrial wildlife habitat "downstream" may also be significantly impaired by loss of habitat on the site. Currently the undeveloped site is home to fifteen species of mammals, including two species for which the site is a refugium, namely eastern coyote and white-tailed deer (see recent Wildlife Inventory by David Brown and Inventory of Resources at Alewife Reservation and Alewife Brook Parkway by the Metropolitan District Commission). In addition, the site provides a continual population of several species of small mammals that can continually recolonize the south bank of the Little River, where a large population of feral cats appears able to decimate the south bank's population of small mammals. Finally, the Alewife Reservation and contiguous natural areas, including the Belmont Uplands and nearby Fresh Pond, is a significant migratory bird stopover location.
  • Impairment of biological diversity: The Belmont Uplands site contains approximately seven acres of forested upland habitat, a habitat type not otherwise present in the Alewife Reservation. Because the site is contiguous with the reservation, it functions ecologically as part of the reservation, and increases the overall habitat and species biodiversity found within this natural area. Loss of the Belmont Uplands will further fragment the remaining relict ecosystem of the once "Great Swamp" that stretched from Fresh Pond to the Mystic River.
  • Loss of flood storage volume will occur in the Alewife area if the upland portion of the site is developed without compensatory flood storage provided. It is widely known that the Alewife area suffers significant flooding.
  • Impairment of endangered species habitat: Although the Massachusetts Natural Heritage and Endangered Species Program does not have official records of rare, endangered, or special concern species using the site, veteran birdwatchers have observed that a number of protected bird species use the Alewife area in general. These include Bald Eagle, Peregrine Falcon, Cooper's Hawk, Sharp-shinned Hawk, Pied-billed Grebe, American Bittern, Least Bittern, Blackpoll Warbler, Northern Parula, Grasshopper Sparrow, and Vesper Sparrow.
  • Construction impacts: In addition to potential permanent impacts to protected resource areas and valued ecological functions, construction may result in temporary impacts. Therefore the Conservation Commission also needs to review the construction plan and ensure that construction-related impacts are avoided, minimized, or mitigated.
3. Concerns regarding impairment of regional importance of Alewife natural area The Alewife Reservation, Alewife Brook Parkway, nearby natural areas, and abutting, undeveloped parcels comprise a large, contiguous open area. Review of the Massachusetts's Executive Office of Environmental Affair's BioMap for the Boston Basin region shows that the Fresh Pond - Alewife - Mystic River complex is the largest, contiguous open area in the basin between Middlesex Fells to the north and Blue Hills to the south. The abutting parcels and nearby natural areas more than double the acreage of the Alewife Reservation and Alewife Brook Parkway.

The larger, contiguous area includes Alewife Reservation (including Blair Pond and Little Pond), Alewife Brook Parkway, Mystic Valley Parkway, the "Belmont Uplands," the "ADL Wetland," the ADL parking lot currently occupying the eastern end of the Alewife Reservation, the undeveloped portions of the Martignetti property on Route 2, the Mugar parcel on the north side of Route 2, Jerry's Pond, the undeveloped portions of the W.R. Grace property, Danehy Park, and land associated with the MBTA Alewife T Station. In very close proximity lies Rafferty Park, Fresh Pond Reservation, Mount Auburn Cemetery, and the Charles River Reservation. In addition, this broad area is interlaced with a network of bicycle and pedestrian paths that connect to a regional (and in the future inter-state) network of trails.

Unfortunately many of the abutting parcels are currently vacant and consist of low quality habitat. However, the potential to link these areas together and to enhance their habitat value to protect the complex as a whole is an outstanding opportunity for the City of Cambridge, in cooperation with Belmont, Arlington, and Somerville. A continuous swath of natural areas could be crafted from the Charles River to the Mystic River if plans are developed with thoughtful foresight and a commitment to protecting natural areas in the midst of our highly urban cities.

The project runs counter to the principles of "smart growth" which call for the redevelopment of existing parcels rather than the development of naturalized environments.

We, your Cambridge Conservation Commission, wish to make you aware of our serious concern over this development, and urge you to promote alternate development schemes and to encourage development in a thoughtful and prudent manner, that will protect our fair city's dwindling natural resources.

Sincerely yours,

The Cambridge Conservation Commission

Albe Simenas, Chariman
Karen McGuire, Vice Chairman
Dorothy Altman
Bette Woody
Maura McCaffery
Cynthia Jensen
Samuel Seidel