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Draft Environmental Impact Report - Belmont Office/R&D Building
Response from Heidi Roddis, Senior Environmental Policy Specialist;
Ricci Roger Wrubel, Sanctuary Director, Habitat;
Mass Audubon

May 8, 2003

Ellen Roy Herzfelder
Secretary, Executive Office of Environmental Affairs
Attention: Arthur Pugsley
MEPA Office
251 Causeway Street, 9th Floor
Boston, MA 02114

Re: EOEA #12376R, Belmont Office/R&D Building

Dear Secretary Roy Herzfelder:

On behalf of Mass Audubon, we submit the following comments on the Draft Environmental Impact Report (DEIR) for the above-referenced project.

This site is part of an "urban wilds" area of open space straddling three communities: Arlington, Belmont, and Cambridge. Although the site is privately owned and zoned for the type of development proposed, it is nevertheless important to recognize and minimize as much as possible the project's impacts on the overall integrity of wildlife habitat in and around the adjoining Metropolitan District Commission (MDC) Alewife Reservation. In particular, more detailed analysis of the impacts of proposed buffer zone alterations on the wildlife habitat functionality of the adjacent wetlands. Further information is also needed regarding impacts and mitigation in regard to stormwater, floodplains, wastewater, and transportation. Mass Audubon requests that detailed analysis and plans on these topics be required to be submitted in the Final EIR (FEIR). Because of existing problems with flooding, combined sewer overflows (CSOs), and traffic, this and other projects in the area should be held to high standards whereby each project results in net improvements in these areas.

The MDC Alewife Reservation is an urban wildlife refuge, harboring an unusual diversity of species and habitats within a heavily urbanized landscape. The proposed project will consume most of the last remaining block of undeveloped, mostly forested upland habitat adjacent to the Reservation. This is likely to impact the overall viability of the Reservation's habitat functionality for at least some of the wildlife species presently utilizing the site. Ideally, this loss of upland habitat should be avoided entirely through permanent protection of the parcel. If this is an unattainable goal and development of the site is inevitable, then impacts to wetland buffer zones should be avoided. Scaling back the project and/or reducing the amount of onsite parking could achieve this, as discussed below.

It is our understanding that the project proponent is considering changing the project from Office/R&D to residential. Mass Audubon hopes that this will provide an opportunity to develop an alternative plan that avoids destruction of vegetation and other wildlife habitat features within the buffer zone. If the Office/R&D approach continues forward, revisions should be made to reduce buffer zone impacts.

Wetlands Habitat and Buffer Zone

Mass Audubon's comments on the Environmental Notification Form (ENF) expressed concerns that the proposed alterations of buffer zone on the site would adversely impact the wildlife habitat within the adjoining wetlands. The DEIR did not adequately address those comments, so we reiterate and further elaborate our points and request that they be addressed fully and directly in the FEIR.

The DEIR indicates that a majority of the buffer zone on the site - 1.54 acres --will be altered. This figure does not include additional buffer zone impacts associated with the proposed construction of a small parking area for trail access. In the context of these particular wetlands, which already have urban development encroaching from every direction, all remaining buffer zones should be preserved. This is especially true in light of the proposed destruction of the entire upland forest habitat on the site outside of the buffer zone. While there is no legal mechanism to protect the upland habitat, buffer zone features can and should be protected to the extent that their destruction would degrade the wildlife habitat in the adjoining wetlands.

One of the eight public interests protected under the Massachusetts Wetlands Protection Act is wildlife habitat. The local conservation commission has the authority to review and if necessary deny alteration of buffer zones in instances where the work in the buffer zone will impact the ability of the wetland to maintain its existing protected functions including wildlife habitat. Scientific studies have repeatedly shown that the majority of wetland-dependent wildlife species require significant amounts of adjoining upland to complete their life cycle requirements.

A compilation of the scientific literature was published by Lynn Boyd at the University of Massachusetts in Amherst 1. More than three-quarters of wetland species in Massachusetts require adjacent wetland habitat. 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 upland habitat. In such 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.

Since this site is the last remaining block of upland habitat adjacent to the wetlands in question, it is likely that alteration of much of the buffer zone (in addition to loss of all nonjurisdictional upland forest) will have an adverse impact on the wildlife habitat function of the wetlands. The wildlife habitat information in the DEIR does not adequately document existing wildlife habitat and species on the site, nor does it evaluate the effects of the proposed buffer zone alterations on the wildlife habitat functioning of the adjoining wetlands. The project proponent should be required to conduct a more detailed biological impact assessment based on the species of wildlife that live in the wetlands and the existing habitat characteristics of the project site.

Loss of vegetated cover within the buffer zone also will impact the physical and chemical characteristics of the wetlands, through reduction in shading, changes in runoff, etc. These impacts need to be evaluated in more detail, and should be avoided and minimized as much as possible.

The DEIR indicates that invasive species on the site will be selectively removed and native and non-invasive species with wildlife habitat value will be planted. The FEIR should include a detailed landscaping plan for the site. Areas of the buffer zone that are unavoidably but temporarily disturbed during construction should be densely re-planted with native trees and shrubs, to maximize the amount of food, shelter, and nesting habitat provided in this area. These areas should then be allowed to naturalize. The FEIR should clearly designate buffer zone areas where landscape maintenance activities like mowing, trimming, raking, pruning, removal of dead trees and fallen logs, etc. will not be conducted.

Additional details on locations, methods, and sequencing of invasive species control efforts should also be included in the FEIR. The open space management plan in the DEIR acknowledges that invasive species management will be an ongoing issue, as plants recolonize from adjoining areas and complete eradication is not a viable or appropriate goal. The FEIR should clearly state the duration and scope of the proponent's ongoing commitment to maintenance activities such as invasive species management and trail maintenance (on the CR property).

The DEIR mentions that cut trees and/or earth stockpiles may be placed in the buffer zone during construction. Use of the buffer zone in this manner should be avoided if possible, and in any event should be restricted to areas within the limit of work that will unavoidably be disturbed by construction anyway.

The draft plan for trails that would link the CR parcel with the MDC Reservation calls for a small gravel parking area off Acorn Park Drive. This parking area would be located within the buffer zone. An alternative location for this parking, such as designation of a few parking spots within the development project area, should be required in the FEIR.

Flooding and Stormwater

The entire Alewife area suffers from flooding problems due to historic filling of floodplain and progressive urbanization of the landscape. Given the severity of the existing situation, each new project in the area should be required to show a net improvement in flood control, and a reduction in peak stormwater runoff from the development site.

The FEMA floodplain delineation on the site is out of date. Increased urbanization since the last FEMA study was completed has led to further increases in the frequency and degree of flooding in the area. The floodplain delineation around the site should be reevaluated to take into account actual current conditions.

The DEIR proposes a flood storage area to compensate for floodplain impacts from the project, and a detention/infiltration facility to recharge stormwater to the groundwater. The FEIR should demonstrate that the proposed flood storage area will in fact function as a replacement to the lost flood storage, i.e. that runoff that presently flows to the area proposed to be filled will in fact flow to the proposed compensatory area on the other side of the site.

The DEIR construction sequencing plan for erosion and sedimentation control calls for the use of temporary sedimentation basins during construction. The DEIR also states that the area proposed for detention/infiltration system will not be used for temporary construction sedimentation to avoid compaction that would interfere with the functionality of the infiltration system. No information is presented regarding where temporary sedimentation basins will be located. Due to the space constraints on the site, it is imperative that detailed plans be presented for erosion and sedimentation management during each phase of construction. Temporary sedimentation basins should be located within the construction limit of work and must not result in additional buffer zone impacts.

Wastewater and CSOs

All three alternative routes under consideration for the project's sewer connection ultimately flow to the MWRA's Belmont Branch sewer. This line frequently experiences surcharging and CSOs during storm events. These CSOs pollute wetlands and waterways, and new developments must not be allowed to exacerbate this serious water quality noncompliance problem. The proponent is proposing mitigation in the form of payment(s) to the Town of Belmont and potentially to the City of Cambridge. This payment is intended to help finance system improvements such as reduction in infiltration and inflow. However, it is unclear what the time delay will be between the mitigation payment and the actual work reducing infiltration and inflow. This project should not be allowed to connect to the sewer system until an equal or greater amount of flow has actually been removed from the Belmont Branch system.

Transportation and Parking

The Certificate on the ENF acknowledged the serious traffic problems in the Alewife area and required the EIR to evaluate this subject in detail and present a Transportation Demand Management (TDM) program. Given this site's proximity to the Alewife MBTA station and the Minuteman Bikeway, it should be possible to reduce single occupancy vehicle access well below what is achieved at most office parks. Every parking space that is eliminated on the site plan has a dual benefit: 1) parking constraints act as an incentive to use other means of accessing the site, and 2) reducing parking spaces reduces the project footprint therefore allowing more buffer zone to be preserved and reducing impervious surfaces. We urge that the FEIR be required to present more rigorous TMD commitments, and a revised plan that reduces parking spaces and buffer zone impacts.

Conservation Restriction, Management and Coordination with MDC

The proponent intends to place a Conservation Restriction (CR) on half of the property, or 7.8 acres for permanent protection of open space for wildlife habitat and passive recreation purposes. This contribution is appreciated as a substantive mitigation effort by the proponent.

The draft CR designates the Belmont Board of Selectmen as the Grantee. We recommend that the final CR designate the Belmont Conservation Commission as the entity with care and custody of the CR property. We also recommend that the CR be reviewed and approved by the MDC (or successor agency if the state government reorganizes the state parks agencies) before it is finalized. The CR and management plans for the CR parcel also should further clarify the process for coordinating planning and management of trails connecting to the MDC Reservation.

The CR management plan should include plans for monitoring and enforcement against inappropriate uses and security issues such as motorbikes, drinking parties, dumping, etc., since it is already known that these are management issues in this urban open space location.

The trails are proposed to be simple foot trails, with only hand trimming of vegetation and perhaps minor grading with hand tools. This is appropriate for the sensitive setting, where more intensive trail construction methods involving equipment and major alterations would involve excessive impacts. The FEIR should, if possible, include more detailed plans for the trail system. Approval by the Belmont Conservation Commission and the MDC (or successor agency) is needed.

The proposed trail along the Little River is in an especially sensitive area prone to flooding. It is preferable to close the trail during high water periods rather than undertake more extensive trail/boardwalk construction in this area.


The FEIR for this project should include revisions that reduce buffer zone impacts. Further details of flood control, stormwater management, construction sequencing, traffic demand management, vegetation management and wildlife habitat enhancement, trails, and management of the CR parcel should be presented in the FEIR.

Thank you for considering these comments.


Heidi Roddis Ricci Roger Wrubel
Senior Environmental Policy Specialist Sanctuary Director, Habitat

Laura Rome, Epsilon Associates
Dan Driscoll, MDC
Conservation Commissions: Arlington, Belmont, Cambridge
Friends of Alewife Reservation
Mystic Valley Watershed Association

1 Buffer Zones and Beyond: Wildlife use of Wetland Buffer Zones and their Protection under the Massachusetts Wetlands Protection Act. Department of Natural Resources Conservation, UMass, Sept., 2001.