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Draft Environmental Impact Report - Belmont Office/R&D Building
Response from Ernest Kirwan, AIA, Architecture and Planning Consultant
Kirwan Design, Inc. 2 Kenway Street, Cambridge, MA 02138 tel/fax 617.491.0166
May 5, 2003
Ellen Roy Herzfelder
Secretary, Executive Office of Environmental Affairs
251 Causeway Street, 9th Floor
Boston, MA 02114
Subject. Belmont Office/ R & D Building; EOEA #12376R
Dear Secretary Herzfelder,
This letter is written in response to the DEIR submitted by O'Neill Properties of PA, for a 245,00 SF office/R&D building and three-level (above grade) parking structure. In general, the DEIR is well organized and documented by the several firms retained to prepare the architectural, engineering, traffic and environmental plans and studies for the project.
However, upon study of the long-term impacts of the proposed complex, I have a number of observations based on my 40 year professional experience with a large architectural and engineering firm during which I was chief architect for many projects similar to the proposed building and parking structure.
3) Site Plan - Wetlands. Sec. 5.2, Figures 5.21 and 5.22. The buildings are literally shoehorned into the site between designated wetlands and floodplain; during construction there will, inevitably, be damage to the surrounding area which will be very difficult to repair, especially concerning the many plant and animal species found in the area.
Another unknown factor during the building phase will be problems originating from the widespread area of construction debris noted in the Wetlands Report by the BSC Group, submitted to the Belmont Conservation Commission on June 2, 2000. Further investigation of the effects of disturbance of this material should be done before approving construction of the project.
4) Surface Drainage, Sec. 184.108.40.206, Figure 5.3-2 Development companies do not own laboratory-type properties for long periods of time -the buildings are built-to-suit for particular clients and sold to them shortly afterward; in this case the new owner will be solely responsible for maintenance of a very sophisticated drainage system - around and under the proposed buildings and the developer will be long gone. The large building and parking garage are so tightly fit on the site that there is barely room for a service dock and no space for support systems such as electrical switchgear and transformers, tank farms, storage areas, etc. which can be seen by examining the existing Arthur D. Little facilities. These necessary systems will have to be tucked in between the proposed buildings, creating potential drainage, air quality, visual and acoustical problems for people working in the complex.
A site plan showing existing conditions, obtained from Belmont Town Engineer clearly indicates that all drainage from Frontage Road and the adjacent parcels flow directly into Little Pond. With the eventual development of the ADL and Martignetti sites, disturbing this natural site will have a highly negative effect on local drainage conditions including silting in Little Pond and River and on downstream areas in Cambridge.
3) Transportation, Sec. 5.1. The highly-detailed traffic study represents a commendable effort, but will be essentially meaningless since the traffic volumes do not take into account the cumulative impact of the traffic from over 1,300,00 SF of office/lab and housing which will be built on the adjacent parcels. Development of this parcel will only exacerbate the traffic situation - in addition to the other damage it will do to the air quality (removing trees) and other environmental impacts.
4) Long-Term Land Use. The ADL site is similar to many other aging industrial parks in that it is now ready for demolition and rebuilding after about a forty year span - which means that it is likely that the proposed building and garage will become obsolete and need demolition and rebuilding in about the year 2050, once again greatly disturbing the natural environment.
5) Summary. In any objective analysis of the overall land use of the Alewife site, this uplands forest parcel should be retained in its natural state and joined with the other 115 acres of the MDC "urban wild" to form a natural buffer for Little Pond and Little River and to balance out the impacts of the heavily urbanized surrounding areas. We are therefore requesting a moratorium on approval for development of any of the Alewife parcels until a comprehensive review has been made of the overall site - such as proposed by a number of key area legislators in Senate Bill 1872, now under consideration.
5) Developer's Request for Use Change. At a meeting we attended on April 29, 2003 at Belmont Town Hall, the developer - O'Neill Properties, requested a change of use for the site from office/lab to housing, based on market conditions. They stated that the site impacts would be about the same or less than the previous proposal and requested quick approval by the Town for the change. We request that EOEA require a full new EIR for this use and that it be examined in context of an overall area plan as proposed in the S1872 bill, since the housing use will still create heavy impacts on the adjacent sensitive areas with respect to flooding and habitat; the destruction of this important natural resource is an egregious example of bad land use and is not consistent with the planning/development principles now advocated by your office and by Chief Douglas Foy at the Office of Commonwealth Development.
Ernest Kirwan, AIA Architecture and Planning Consultant