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Sewer Connection by O'Neill Project in Belmont
letter to Cambridge City Council

Michael F. Nakagawa
Cambridge, MA 02140

March 5, 2003     Re: Sewer Connection by O'Neill Project in Belmont

Cambridge City Council
c/o Health and Environment Committee
Cambridge City Hall, 2nd Floor
Cambridge, MA 02139

Honorable Mayor and City Councilors:

Thank you for the opportunity to comment on the connection of the sewer outflows into the Cambridge sewer system of the Office/R&D Center project submitted on behalf of O'Neill Properties Group (O'Neill) for their Belmont project proposal.

The O'Neill project represents just one of the projects slated for development in the Alewife region, an area that is already plagued by sewer problems. The Alewife Brook periodically floods residences near its banks with water contaminated by an overflowing combined sewer system creating public health risks.

The City is currently facing a much larger task in addressing the issue than was originally anticipated just a few years ago during the preliminary study of the combined sewer systems that overflow into the Alewife Brook. Combined sewer outflow (CSO) discharges, estimated to occur 16 times per year in the 1997 plan were found to occur 63 times per year, with an annual volume of 49.7 million gallons of untreated combined sewage dumped into the Brook. The original estimated $12 million plan is now estimated to be $74 million, yet the final discharges, compared to the original plan, increase from 4 to 7 times per year, barely meeting the absolute minimum requirement by the federal Environmental Protection Agency, with an increase in annual volume of 255%. Because of the increased cost of the project, a significant portion of the area will remain unseparated and overflowing.

In actuality, the proposal has not even been approved, and the public comment period for further changes to the proposal has just ended. Despite the deplorable state of our sewer system, caused by years of intense development without corresponding infrastructure support, the costs of which might have hurt our Triple-A bond rating, we are considering further sewer connections from large-scale development projects.

The O'Neill project alone, 245,000 square feet of research and development space, will bring an estimated 4.6 million gallons of wastewater into our overburdened sewer system each year, given a 250-day work-year. Consider that the Acorn Park Drive area alone is slated for an additional 900,000 square feet of new office space by the Bulfinch Company, with the plans to be released shortly, plus an additional estimated 125,000 square feet of new office space and 400,000 square feet of residential space by the Martignetti Brothers. Other development in the Alewife Floodplain includes the recent 366,000 square foot apartment complex on Cambridge Park Drive, and the 400,000 square foot office and hotel proposed by W. R. Grace and Company. Furthermore, the Concord-Alewife Study Committee has just been formed to consider the development opportunities north of Fresh Pond to the Alewife Reservation.

It is unlikely that all these projects have been considered in the current proposal for the sewer improvements. And by just meeting the minimum federal standards for CSO control, it becomes questionable whether the additional projects will return the City to noncompliance. Furthermore, the proposal included design elements that appear to put it in violation of the state regulations covering the Wetlands Protection Act, specifically the performance standards of 310 CMR 10.57, Bordering Land Subject to Flooding.

Considering the current state of uncertainty, both in projected regional development and with regard to understanding the hydrology of the sewer proposal (specifically during large storm events) and its final performance, I urge you to submit a municipal order preventing further connections to our sewer systems until both the proposal for the sewer changes has been officially approved and the design of system has been shown to accommodate the upcoming development slated for the region.

Furthermore, the proposed O'Neill development shows a blatant disregard for the environment, one that does not warrant any special concessions. With the constraints on the Alewife Brook Reservation because of its nature as an urban wildlife refuge in one of the most densely populated cities in the country, the developers are destroying almost all of the habitat of the only area outside the floodplain in the vicinity of the Reservation. The area they plan to develop represents an important support function to the wetlands habitat, one that, by law, cannot be replicated elsewhere in the Alewife Floodplain.

It appears from their map of the proposal, which was included in their Environmental Notification Form, that about one parking space worth of the non-wetlands bordering uplands will be further than 100 feet from the development, unless the yellow region constitutes landscaped area, in which case no such uplands habitat areas will exist adjacent to the Reservation.

The O'Neill project abuts the Reservation and wetlands habitat on the Bulfinch Properties site formerly owned by Arthur D. Little. The project includes extensive work in the buffer zone of Bordering Vegetated Wetlands (BVW), covered by M.G. L. Chapter 131 Paragraph 40 and 310 CMR 10.02 and 10.55. It appears that the proposed structures will add shading to existing wetlands, since the project essentially occupies all non-wetland areas up to the BVW border.

The additional 4.4 acres of impervious surface will alter hydrologic flow in the area. The surfaces and the structures will act as a localized thermal reservoir that will alter the local heating characteristics. Vegetation provides evaporative cooling, drawing cooler groundwater to the leaves. Replacement of this natural cooling mechanism with an urban heat island in the middle of a wetlands habitat area is irresponsible, unsustainable development. These surfaces will act to dry out the surrounding wetlands.

Finally, the project will degrade the environment and create public health risks from the pollution generated by the addition traffic congestion that will be caused by the project. Traffic at the major intersections adjacent to the property is already at Grade 'F' during rush hours; office and R&D space will put a large traffic burden at rush hour. The area has no ability to absorb an additional 2642 car trips daily.

The main intersection in this area overlooks the Russell Field children's outdoor recreational area. I hope the members of the Health and Environment Committee recognize the greatly increased urban asthma problem among children, and that studies have suggested it may be caused by outdoor pollutants, particularly small particulate matter caused by combustion sources.

Again, I urge you to order that an approved CSO control plan must be shown to provide sufficient margin for additional area development, beyond just this one project, before additional sewer connections by large projects can be allowed.


Michael Nakagawa