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Draft Environmental Impact Report - Belmont Office/R&D Building
Response from Response from Jim Graves, President of the Belmont Citizens Forum
May 7, 2003
Secretary Ellen Roy Herzfelder
EOEA, Attn: MEPA Office
251 Causeway Street, Suite 900
Boston, MA 02114
RE: Belmont Office/R&D Building, EOEA 12376R
Comments on Draft Environmental Report
Dear Secretary Herzfelder,
After carefully reviewing the draft EIR, I am writing to ask you to deny the certificate for this proposed development. There are two critical and well-supported reasons for this request.
First, the property is ecologically sensitive and highly valuable as wild uplands open space. It is ecologically essential to the extensive and diverse wildlife in the surrounding wetlands and the MDC's adjacent Alewife Reservation. The proposed football field sized building and football field sized parking garage and paved areas will obliterate nearly the entire critical uplands forest habitat and a very large portion of the wetlands buffer zone. The uplands habitat will be further diminished when large sections of the uplands area are dug up to provide swales for flood mitigation.
Second, the property is in an area where major intersections are already far overloaded with vehicle traffic. In this already heavily developed region, it is completely unacceptable to completely cover one of the few remaining pieces of forested open space with a large-scale traffic generating development.
These two reasons for denying the certificate are well supported by the documents submitted to EOEA by the experts who are quoted in the balance of this letter.
According to the comments to EOEA on this project in Mass Audubon's July 26, 2002 letter:
"In a compilation of the scientific literature Lynn Boyd at the University of Massachusetts in Amherst found that more than three-quarters of wetland species in Massachusetts require adjacent upland habitat. (Source: Buffer Zones and Beyond: Wildlife use of Wetland Buffer Zones and their Protection under the Massachusetts Wetlands Protection Act. Department of Natural Resources Conservation, U.Mass, Sept. 2001.) Seventy-seven percent of these upland-dependent wetland wildlife species utilize upland up to 100 feet beyond the wetland. More than 58% use areas up to 200 feet from the wetland. More than 50% use areas beyond 200 feet. Many of these wetland species cannot complete their seasonal and life cycle requirements without the availability of adjoining uplands. In these instances, the local populations of those wetland wildlife species are likely to be eliminated by the development of all or most of the uplands around a wetland."
These scientific facts negate the developer's claims that wildlife habitat will be improved by the proposed plans. The rare silver maple forest habitat of the extensive wildlife currently living in the uplands area will be eliminated to construct the office building and parking garage. As a result, most of the wildlife living in the surrounding wetlands, which require the uplands to survive, will be substantially eliminated by the development.
The traffic figures and relatively minor traffic mitigation measures proposed in the draft environmental impact report do nothing to change the major conclusions of the Metropolitan Area Planning Council's July 30, 2002 comments to EOEA on this project:
"The proposed development lies in an area of great regional significance for transportation, where much of the travel demand to/from northwest of Boston funnels through a very constrained area. While the proponent certainly did not cause the existing problems at the Alewife interchange, it is hard to imagine how the expected 2,642 new trips will not exacerbate an already intractable problem. The additional trips will certainly compound the difficulties of finding a workable solution."
Comments by Russell Cohen of The Commonwealth of Massachusetts Riverways Program, in his letter to EOEA dated July 30, 2002, provide a big picture view of why the EOEA should not grant a certificate for the proposed development:
"This past failure to permanently protect the 15.6 acres in a natural, undeveloped condition should be rectified if at all possible. As you know, the Alewife Reservation and adjacent undeveloped lands such as the subject property serve as an open space and wildlife habitat oasis and the last vestiges of what was once an extensive floodplain and tidally-influenced wetland complex containing the Little River and Alewife Brooks. This "island" of open space serves an increasingly important function in an area that is already encroached upon and hemmed in by dense development and is threatened with substantially more development in the future.
My understanding is that the O'Neill Properties Group made a large profit on the purchase of the ADL property and the subsequent sale of a portion of it to the Bullfinch Group. This should put them in the financial position of being able to accept less-than-full market price for the sale of the entire 15.6 acres for open space preservation. The project proponents should be encouraged to carefully consider this "no-build option" for the property."
Officials and citizens in both of the neighboring communities of Arlington and Cambridge oppose the development. Belmont's Alewife Study Committee formally recommended that the property be preserved as open space. A coalition of citizens from all three communities supports swapping development rights to preserve the silver maple forest and the wildlife.
It is not smart growth to permit a large traffic generating development because, to quote the words of the Metropolitan Area Planning Council, the proposed development will "exacerbate an already intractable problem". It is not smart growth to obliterate a wild forest oasis in a desert of dense development. The minutia of the relatively minor mitigation proposed in the developer's draft EIR camouflages but does not solve these major issues. Please look at the big picture and just say no.
President of the Belmont Citizens Forum
593 Pleasant Street
Belmont, MA 02478