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Draft Environmental Impact Report - Belmont Office/R&D Building
Response from Sue Bass, Vice President, Belmont Citizens Forum

Belmont Citizens Forum
P. O. Box 609, Belmont MA 02478     (617) 484-1844

May 8, 2003

Secretary Ellen Roy Herzfelder
Executive Office of Environmental Affairs
Att: Arthur Pugsley, MEPA Unit
251 Causeway Street, Suite 900      Via fax to 617 626 1180 and
Boston, MA 02114      e-mail to

Subject: DEIR for Frontage Road, Belmont, EOEA #12376R

Dear Secretary Herzfelder:

The Belmont Citizens Forum is supported by more than 500 families in Belmont and neighboring communities who are concerned with protecting the environment, preserving historic and archeological resources, and controlling the growth of traffic. We are grateful for the opportunity to submit the following comments on the Draft Environmental Impact Report filed by O'Neill Properties Group, owner of 15 acres of Belmont and Cambridge land at Alewife.

This proposal has three strikes against it. The property on which the proponents want to build abuts an MDC reservation. This small parcel of uplands is the only uplands available for the wildlife that inhabit the wetlands on the reservation. Unless the uplands are preserved, you doom many wetlands species. The property is also the only remaining undeveloped uplands in the surviving remnant of the Great Swamp that could help mitigate the serious flooding problems nearby in Belmont, Cambridge, and East Arlington.

Finally, the property is located on an extremely overcrowded stretch of highway. Traffic in the area is so jammed that the MBTA has refused to expand its Alewife parking garage (now only five stories but designed to be expanded to seven) because additional parking would attract more motorists to the area. There is no easy access from the property to the nearby T station, and the proponent has not offered to provide any. That's why its original estimate was that 95 percent of those going to the property would travel in single-occupancy vehicles.

While the comments below are directed to the DEIR as filed, for an office or R&D building, O'Neill has announced to the Belmont Selectmen and Town Meeting that it has no intention of building such a project. Instead, it plans to request rezoning to permit 200 or apartments or condominium units on the site.

Considering how different such a use would be in its impacts on traffic, drainage, and wildlife, the Citizens Forum believes that it would not be appropriate to apply findings from this environmental review to such a different project. We urge you to reject this DEIR as inadequate and require the proponent to go through a full, multi-stage review for its new proposal.

This filing is inadequate in many other ways, a few of which we detail below. The response to the Secretary's Certificate is minimal. For just one example, the Certificate said, "The EIR should analyze the no-build alternative to establish baseline conditions. The baseline analysis shall identify significant existing on-site resources (with special reference given to the wealth of local wildlife studies attached to or referenced in the comment letters.)"
The response to that requirement, like the response to other conditions, is cursory. I did not spot a mention of those local wildlife studies anywhere in the draft EIR. In the portion officially devoted to wildlife, section 5.2.3, the narrative says that the only area whose wildlife it will consider is the 10,100 cf of Bordering Land Subject to Flooding because that's the only area in which it admits it exceeds the regulatory threshhold. O'Neill also claimed (in, paragraph 3) that a habitat study would be performed through the Notice of Intent process. But I attended O'Neill's presentation to the Belmont Conservation Commission on its Notice of Intent two days ago, on May 6, 2003, and its discussion of wildlife was equally perfunctory and equally limited.

Similarly, a major requirement of the Certificate was to minimize parking and maximize public transit use. The DEIR does, as required, analyze the cut in parking required if it persuaded more of the building's occupants and visitors to use public transportation. However, O'Neill clearly has no intention of trying to cut single occupancy vehicle (SOV) use significantly. According to Table 4-1 , 60 percent SOV use would require only 516 to 688 parking spaces, not the 793 spaces it wants. But what is O'Neill's offer? Merely to postpone the construction of 61 spaces, without giving up the right to build them later. Given the site's proximity to public transportation, it should certainly not be allowed to provide anything like that number of parking spaces. The City of Cambridge recently rezoned the adjoining property formerly occupied by Arthur D. Little to allow only 1 1/6 spaces per 1,000 square feet. O'Neill wants more than three times as much.

Much less parking would be required if O'Neill undertook serious measures to improve access to the Alewife T station and nearby bicycle paths. Now, though they are close, access is not easy. The developer should not be allowed even to consider construction of any project without providing that access. That would mean, at the minimum, a substantial contribution to the MDC to fund its master plan for the Alewife Reservation and aid to the bike paths as well.

A reduction in parking would also enable the developer to eliminate a serious problem with its current design. More than 25 percent of the project is in the wetlands buffer zone. That is most clearly visible in Figure 5.2-5. Building in the buffer zone would have an adverse effect on the wetlands, both to wildlife habitat and other environmental values. In such a flood-prone area, contamination from the parking lots would quickly wash down into the wetlands. And so much construction in the buffer zone allows no room for error. A workman who strays over the official limit of work will often be working in the resource area itself.

Finally, the responses to the many thoughtful comments filed by respondents to the Environmental Notification Form are so cursory as to be dismissive. For example, the major off-site traffic improvements offered consist of timing signals and painting lines in the street. The "Open Space Protection and Habitat Alteration" section, where one might expect finally to read about the important wildlife studies mentioned in the Secretary's certificate, is entirely concerned with the portion of the land to be covered by a conservation restriction B land on which nothing could ever be built anyway because it's almost entirely wetlands.


Sue Bass
Vice President
Board Members: Jim Graves, President    Sue Bass & Mark D'Andrea, Vice Presidents
John Dieckmann, Treasurer
Rosemary Chase    Evanthia Malliris    Grant Monahon    Thomas G. Shapiro