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Draft Environmental Impact Report - Belmont Office/R&D Building
Response from Ellen Mass, President, Friends of Alewife Reservation - May 2003

Friends of Alewife Reservation

BOX 161
1770 Mass Ave.
Cambridge, MA. 02140-2818

To Ellen Roy Hertzfelder
MEPA Offices
250 Causeway St.
Suite 900
Boston, MA. 02116

RE: Frontage Road @12376

Dear Mr. Pugley,

Friends of Alewife Reservation has performed hundreds of community service projects in and around the Alewife Reservation and its buffer areas for the last 5 years. We have brought many tour groups to the area and have been the major voice in the region to speak out on the need to retain the critical core of the Alewife Reservation, a rare silver maple (acer saccharinum) forest as open space northern floodplain forest. Our knowledge has come from the extensive inventories provided by a Riverways grant to FAR, which identified sightings and habitat evidence throughout 3 seasons. The Brookline Bird Club regularly visits the area for its members. This year FAR had a second annual docent training where we identified significant mammal presence collaborated by David Brown who contributed the supplementary inventories to the ENF process in Volume I of Belmont Office/R&D. Docent trainers take their groups, families and neighbors to the forested area and wetlands for urban wild recreation, for learning about nature in the largest untouched urban wild in the Boston area, an area that is highly accessible to many populations in the metropolitan region, especially accessible to schools which need field trip areas without monies for bus transportation.

To date, the Developer has not shown that the large 100 year old trees will be kept, nor has it recognized these trees.
FAR has been able to register one of the largest silver maples with the large tree certification group which will entitle it as one of the largest in the United States with a Circumference of 19.9 feet.

Developer has noted that it will create the roadways. This will require state infrastructure and maintenance which has not been verified by the Mass Highway Dept. Thus traffic is still an issue. The number of cars have not decreased from the ENF, but the four and a half acre office park footprint has increased to seven and a half as of recent testimony at the Belmont Conservation Commission meeting on May 6. Another words half of the 15 forested acreage is designated for impervious cover and this is a different presentation

Because the MDC plan is not finalized and there is no connection between the property and T stop, it cannot be assumed that such a pedestrian public transportation connection can be made. Trails discussion in the master plan are in great controversy among public groups who will decide the final placement of trails, based on wildlife protection and conservation standards. It cannot be assumed that permits will be obtained here.

Forest Awareness:
There is still no measurement of environmental impact of tree removal, and dismantling a huge cooling system and water absorption-evaporation system of trees. According to FAR's Intern researcher, "Urban wetlands are sensitive to changes in the volume or quality of the water discharged into them. Even slight changes in the water can have significant repercussions. As for climate mitigation, forests act as a "carbon sink" by storing carbon dioxide in soil and plant biomass, which helps control the effects of the greenhouse gas, keeping air cleaner and cooler. Deforestation and increased use of fossil fuels have introduced more carbon into the atmosphere than ever before, probably contributing to a trend of global warming. Recent non-profit Environmental Defense News stated that this past decade was the hottest of the century, and possibly of the last 1,000 years."

"The fast growing silver maple tree drops its seeds from April to June unlike other trees which drop in the fall. This would be the time after the floods would have washed away any ground plants and left bare soil. This makes it very easy for the seeds to grow without any competition. The seeds also are a source of food for animals. Along with the early seeds, silver maples are one of the first trees to create pollen. This is very important to bees and other insects that use pollen. Silver maples are considered to be a hard wood, however the woods is very brittle, and can be easily damaged in high winds. Preserving this area and any areas of the floodplain would be beneficial , because animals thrive here, and help keep the ecosystem in balance."
From "Conceptual Site Model" -Wentworth Institute of Technology students- Geology 400, Apr. 17, 2003.

In the O'Neill Properties EIR, I have yet to locate any significant information on wildlife habitat preservation, its value and location. The detention basins are hardly designed for that purpose. The flora/fauna listings are a fifth of FAR's inventories which are included as *supplement to this letter. Underbrush is greatly exaggerated. Buckthorn is a minor tree species in the silver maple forest area. Its extensive ecosystem variations are poorly noted as well. Company photos in the ENF and Maintenance Open Space Report of Epsilon show heavy underbrush, but much of the forest is clear area and not underbrush.

Water Quantity:
Storm run-off cannot be ameliorated with the upland slopes as they exist and with the drainage storage detention as it is planned. As the impervious parking lot intrudes into the wetland buffer area in several locations, it becomes clear that storm water run off will be a significant problem. No special drainage systems have been devised for the parking lots. For years, hundreds of floodplain silver maples have been an important means of ameliorating flooding in the area, and it is unlikely that the O'Neill compensatory storage plan will not meet the silver maple standards. According to the topographical map of engineering students "Draft Little Pond Site Characterization Report", and studying the silver maple forest from Wentworth Institute, the topographic map is located in the floodplain.

Since the ENF filings, the City of Cambridge has clearly noted its awareness to the possible serious impacts downstream in the vast Little River marshes and ponds, related to flooding and to the watershed wide improvement projects planned for the area by the city of Cambridge, MWRA and the MDC..
* Letter attached.

The Wentworth maps, soon to be forthcoming, also designate where the lower wetlands and upper dry lands reside.

Water Quality:
The very poor Water quality which is highly contaminated already from the town * Report attached, is somewhat ameliorated by the cleansing and filtering on the shoreline of the silver maple forest wetlands.

What is most glaring is that the area has not been objectively assessed by the town either as a forest, a contiguous open space to the Alewife Reservation and its long greenways which connect to the Mystic River and Atlantic ocean. This long wildlife green corridor, in the age of environmental disintegration, should be more carefully scrutinized through the many available GIS maps. Objective consultants and assessments by the town of Belmont are absent on all fronts. From an ecological perspective, it becomes highly obvious that the contiguous urban wild requires the Silver maple forest for its sustenance, health, inhabitants from predators to small rodent mammals. The property owners have the right to develop on the silver maple forest because they own it. However, they endanger the health of the Alewife Reservation, which is legally protected.

EIR Responses of O'Neill Properties:

I have noticed that the EIR has not referred specifically to citizen comments, either to the Mass Historical Society, Mystic River Watershed Association, City of Cambridge and many other comments. Guidelines require specific responses to my understanding. Its main response is to the Mass Highway Dept. and the use of an antiquated floodplain map.

Intruding on this rare forest by removing most of it would be an environmental crime and would create a travesty of the word "smart growth" in the region, because the term was coined to encourage developers to use developed, impervious surfaced areas to do their building; not to take down a rare open space forest. The greater Boston area has 2 percent of its open space protected according to the EOEA's Biomapping charts developed over the last 5 years. Alewife Reservation and its critical core habitat buffer, the silver maple forest, are one of the few "protected" areas for wildlife habitat left. They give health to the region, to the greenways down which migrant, shore and songbirds fly, and protect the waterways which allow the Alewife herring to spawn in Little Pond, an important ecological function for Atlantic ocean's eco-balance.

Ellen Mass
Friends of Alewife Reservation

*Silver Maple Forest Hearings- City of Cambridge: Health and Environment Committee
*Flora (US Fish and Wildlife category) inventories at and around Silver Maple forest in Belmont and Cambridge
*Cambridge Conservation Commission letter to City Hearing
*City Council Resolutions on Wetland Protection
*Northern Floodplain Forest chapter by US Forest Field Guide, Janine Benyus
*Floodplain- FEMA alternative Map of area
*City of Cambridge wetland designation abutting development proposal
*Satellite View of area and approximated simulated building model on site
*Letter to Arlington Conservation Commission