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Draft Environmental Impact Report - Belmont Office/R&D Building
Response from Nancy Hammett,
Executive Director, Mystic River Watershed Association

May 8, 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
      Draft Environmental Impact Report

Dear Secretary Herzfelder:

Thank you for the opportunity to comment on the Draft Environmental Impact Report (DEIR) filed by the O'Neill Company for an Office/R&D Building in Belmont (EOEA File #12376R).

The Mystic River Watershed Association (MyRWA) is a community-based nonprofit organization established in 1970 to protect and restore the water and related natural resources of the 21 towns in the Mystic River watershed. Our members live and work throughout the area, including Belmont, where the proposed development is located, as well as neighboring Cambridge and Arlington, which will be adversely impacted by the proposed development. Because of its location adjacent to both the Little River and the Metropolitan District Commission's (MDC) Alewife Brook Reservation, in addition to its proximity to Alewife Brook and wetland resources, the proposed development is sited in an area of special concern to MyRWA. These important water and recreational resources that surround the site play critical roles with respect to water quality, flood mitigation, recreation, open space, and habitat. MyRWA opposes the proposed development in this location because of its importance to the quality of regional open space and the potential environmental impacts of the project.

It is our understanding that the proponent requested that the site be rezoned for residential use after submitting the DEIR for this proposed commercial development. The statements made by the developer indicate that market conditions will preclude profitable construction of an office/R&D building for many years to come, and that they are anxious to move ahead on a residential building project while the market for residential properties is still strong. MyRWA believes that such a change in the proposed project represents a substantial change in the proposed use of the site, and should require the preparation of new DEIR. We will certainly oppose any "hurry-up" EIR review of a new residential project based on the results of the MEPA review of the present DEIR for a project that will now not be built.

We believe that the O'Neill DEIR does not adequately demonstrate that the proposed project "takes all feasible measures to avoid, minimize, and mitigate damage to the environment", as required by MEPA. Moreover, we believe the DEIR for this project should (1) include the results of forthcoming studies of floodplain dimensions, flooding impacts, and wastewater capacity, and (2) reflect the developer's most recent plans for this site. For reasons described below, we urge you to determine that the DEIR is inadequate and require the proponent to file a supplemental DEIR in accordance with 301 CMR 11.07.

The remainder of this letter presents our comments in more detail.

The Project Violates Sound Smart Growth
We have a number of concerns about the design of the proposed project, as described below. More importantly, we believe that any building proposed for this site would violate the Smart Growth goals being emphasized by the state. The Alewife area in which this site is located includes portions of Cambridge, Belmont and Arlington. It surrounds the MDC Alewife Reservation and drains to Little River, Alewife Brook, and the Mystic River. This area has experienced significant development over the last 20 years, encouraged by the extension of the MBTA red line and its proximity to major highways. The area is plagued by flooding and traffic problems, and Alewife Brook is contaminated by stormwater runoff and sewage discharged from illicit connections, old leaking sewer pipes, and combined sewer overflows. Clearly, past development has already strained the area's natural and built capacity to absorb environmental and traffic impacts.

The proposed O'Neill development is sited on a very valuable piece of undeveloped urban wildland, within which is a stand of maples adjoining the wetlands close to the Little River. This land serves as an important habitat for nesting birds and numerous other wildlife on the Belmont/Cambridge border. It sits next to the MDC Alewife Reservation for which a Master Plan has recently been completed Implementing the Master Plan will substantially enhance the value of this area as a nature reserve and recreational resource. Unfortunately, the development will reduce the value of that plan, by consuming a substantial part of the contiguous open space.

Some additional development can probably be accommodated in the area, if it is located on currently built up areas and is carefully designed to minimize stormwater runoff and other undesirable impacts. Of all the potential sites for development, however, the O'Neill property is in many respects the least desirable. It irreversibly destroys a scarce and valuable piece of open space in an area that needs to preserve its limited natural resources. It would be much better to accommodate growth by redeveloping the many vacant previously developed parcels in the area.

As previously stated in our comments on the ENF for this project, we believe that the project should be considered in the context of recent and likely future development and redevelopment projects in the Alewife area. This area has suffered from piecemeal local planning and nonexistent regional planning. Considering the cumulative impacts of development in the area is the only way to truly understand the environmental impact of a proposed project.

The proponent has presented this development as an example of "smart growth," because of its proximity of the site to the MBTA Alewife Station. However, the proponent has not take adequate measures to encourage use of mass transit. The large number of parking spots proposed for the project suggests that mass transit will not be well utilized, contrary to the smart growth claims of the proponent.

The Project is Located in an Environmentally-Sensitive Area
The Belmont Uplands site contains approximately seven acres of forested upland habitat. The proposed project will consume most of the developable area on the site. The wetlands areas, which comprise the majority of the conservation area proposed by the developer, are not developable under current wetland regulations. According to recent wildlife inventories (Metropolitan District Commission, Inventory of Resources at Alewife Reservation and Alewife Brook Parkway; David Brown, Wildlife Inventory), the undeveloped site is home to 15 species of mammals (including eastern coyote and white-tailed deer) and, along with Fresh Pond nearby, is a significant stopover location for migratory birds. Birdwatchers have observed Bald Eagles, Peregrine Falcons, Cooper's Hawks, Sharp-shinned Hawks, Pied-billed Grebes, American and Least Bitterns, Blackpoll Warblers, Northern Parulas, Grasshopper Sparrows, and Vesper Sparrows. As described later, the area is subject to frequent flooding and very poor water quality. It is critical that the high resource value and existing environmental insults to the area be considered when evaluating the impacts of the proposed project. Significant margins of safety should be required when projecting those impacts, given the sensitive nature of the environment.

The DEIR Does Not Reflect Important Forthcoming Studies that Will Help Determine Its Environmental Impacts
A number of studies are underway or just completed that will help shed light on the environmental impacts of this project. We urge that the DEIR not be approved until the results of those studies are available and the project is evaluated in light of their findings. These studies include the following:
  • FEMA's updated and revised federal floodplain studies and mapping for the area, which are likely to show more extensive floodplain areas than are currently delineated in the existing out-dated maps.
  • A recent MDC remapping of floodplains based on improved topographic information.
  • An MWRA study of its collection system in the Alewife Brook area, which discusses the causes of sewer system flooding and overflows, and describes the need for removal of infiltration/inflow and for rehabilitation of the infrastructure.
  • An MDC hydrologic and hydraulic study that shows the impact of extensive development in the Alewife area on local flooding problems.
The DEIR Does Not Fully Respond to Comments Submitted on the ENF
The DEIR does not adequately address a number of the comments submitted by MyRWA on the ENF. For example,
  • The DEIR ignores the rapid development and redevelopment that has occurred in the Alewife area, and does not adequately consider the environmental impacts of the proposed development in the context of its surroundings.
  • The DEIR does not demonstrate that there is sufficient capacity at the proposed wastewater disposal facility to accommodate this project, and that it would not contribute to more frequent Combined Sewer Overflows in Alewife Brook.
  • The proponent did not conduct a full alternatives analysis. The DEIR considers alternatives for parking impacts and wastewater management, but does not consider any ways to move construction away from the existing upland stand of silver maples or to relocate development to an already-developed site, using land swaps, transferable development rights, or other options.
The DEIR Does Not Adequately Evaluate Environmental Impacts

There are well-documented incidences of sewage contamination of Little Pond and Alewife Brook. The attached table, compiled from data collected through MyRWA's DEP-approved water quality monitoring program, indicate very high bacteria levels at sampling locations in this area.

The impacts of this project should be evaluated in light of regional problems with infiltration and inflow and illicit connections. It is MyRWA's hope that MEPA will view this project in a regional context. The review of impacts should recognize that both Belmont and Cambridge must undertake extensive infiltration and inflow removal from their sewage conveyance systems, as well as an aggressive program to identify (though smoke tests, cameras, or dye tests) and remove illicit connections of sewage pipes to stormwater infrastructure, before any new sewer connections are allowed in this area.

The proponent offers three sanitary wastewater routing alternatives in the EIR. MyRWA recommends that no new burdens be put on the wastewater conveyance systems of Belmont or Cambridge until the state of the existing infrastructure has been evaluated and improved. In addition, MyRWA recommends that the chosen wastewater alternative disturb the least amount of wetlands. Any impacts to the wetlands, both during and after construction, should be identified and mitigated. Finally, if sanitary wastewater is to be routed under Little River, we request that new lined or double-walled pipe be used to prevent leaks.

While we are pleased that the proponent has offered $115,000 to the Town of Belmont for infrastructure improvements, we would like to see the EIR describe exactly how the Town plans to improve the sewage conveyance infrastructure (and pumphouses if necessary) and how much additional funding will be required by the Town to remediate the current contamination problems. This information would allow us to assess the impacts of the alternative sanitary wastewater options described in the DEIR.

Open Space
MyRWA is pleased to see that the proponent has proposed an Open Space Management Plan. This plan, as proposed, would require construction and maintenance of a trail system to Little Pond and would require certain habitat "enhancements" on the proponent's property. Many aspects of this plan appear to be ecologically sound. It is not clear, however, how the proponent intends to ensure that the future tenants or owners of the proposed project will adhere to the Management Plan. The transfer of responsibility of the open space plan should be addressed in the DEIR.

A portion of the area depicted as conservation restriction area in Figure 1A (Appendix C, Volume II of the DEIR) has been previously described as compensatory storage to mitigate 100-year floodplain to be paved or built upon. The area of this portion of the conservation restriction parcel should be noted in the DEIR.

Lastly, MyRWA would like the proponent to describe how the proposed project is consistent with the Town of Belmont's and the City of Cambridge's Open Space Plans.

More generally, MyRWA opposes the proposed development in this location because of its importance to the quality of regional open space. The proposed development site lies at the heart of a large contiguous area where there is potential to create valuable urban open space resources, if managed carefully. The Belmont Uplands, along with the surrounding open space, creates valuable habitat for small reptiles, mammals and birds that need both water and protected upland to survive in the area. Building on this site will fracture the existing complex of upland and wetland forest, and damage a rare open space resource in a highly urbanized area. In fact, a substantial portion of the project will be built in the wetlands buffer zone (Figure 5.2-5).

Stormwater Management/Flooding
MyRWA has a number of concerns about the proposed stormwater management plan, and we do not believe that the DEIR adequately analyzes the stormwater impacts of this project. In addition, we are concerned about the impacts of the project on flooding in the Alewife area.

First, we question calculations of peak flow under existing conditions, and believe they may be overstated. Given the history of flooding in the Alewife area, it is critical that the proposed development maintain peak runoff rates from the site at the rate for existing conditions or less. If the existing conditions runoff rates are overestimated, the level of stormwater controls required for the project may be underestimated. The following are areas where the DEIR appears to be inadequate or in error:
  • The time of concentration in basin 3 is about the same for both existing and proposed conditions. This is despite an approximately 0.7 acre reduction in area under proposed conditions. Also, the flow lengths used in the estimates are approximately the same for both existing and proposed conditions, despite the loss in area. The proponent should explain why there is no appreciable change in the time of concentration for this basin.
  • The proponent should show the flow paths used in deriving the time of concentration.
  • The proponent uses the SCS method to estimate runoff at the site. This method uses a "curve number" to express runoff potential. The curve number is a function of both soil hydrologic group and land use. The curve numbers for both existing and proposed conditions are nearly the same. This would be appropriate only if the conversion of the forest to open space would result in no appreciable difference in runoff potential, which is unlikely to be the case. The existing conditions curve numbers are based on woods in fair condition. According to Technical Release 55, "Urban Hydrology for Small Watersheds," woods in fair condition are interpreted as "woods are grazed but not burned, and some forest litter covers the soil." (These curve numbers were originally developed for agricultural watersheds and require extrapolation for use in urbanized conditions.) Woods in good condition are described as "protected from grazing, and litter and brush adequately cover the soil." It is our opinion that the woods are in "good condition" according to this standard. This classification would result in lower estimated runoff under existing conditions. The proponent should justify the site classification of "woods, fair condition" and the use of similar curve numbers for the existing conditions woods and the proposed conditions open space.
Second, the stormwater management plan relies heavily on an infiltration basin, in accordance with Standard 3 of the Stormwater Management Standards. The performance of this basin depends on the seasonal high groundwater level and the soil conditions. We do not believe that the DEIR provides adequate evidence that the infiltration basin will perform as assumed. The DEIR states that groundwater monitoring was performed at the site. No information is given on the timing and frequency of monitoring and the basis of the high groundwater estimate, however. (The proponent states that boring logs for sub-surface explorations performed in the vicinity of the proposed leaching system are attached in Appendix D, however they do not appear to be attached.) The proponent should provide evidence to support the assertion that there will be a greater than 2-foot separation between the seasonal high groundwater level and the invert of the infiltration system. Given the proximity to wetlands and the depth to seasonal high groundwater, the proponent should perform a sub-surface groundwater mounding analysis to demonstrate that the infiltration volumes estimated in Appendix D can indeed be achieved.

The applicant should also conduct an analysis to confirm the assumed constant infiltration rate of 0.52 inches per hour, based on site-specific soil conditions. The proponent should perform percolation tests in the vicinity of the proposed infiltration system, and should evaluate any impacts compaction of soils will have on its efficiency, given the planned construction of the parking garage over the infiltration system.

Third, we question the projected performance of the stormwater management system in removing TSS. The proponent proposes an extended detention basin as part of the overall site stormwater management program. According to the DEP Stormwater Management Handbook (Vol. II), extended detention basins should be designed to provide an average of 24-hours detention for all storms. The minimum detention time for very small storms should be 6 hours. The detention times listed in the HydroCAD output in Appendix D are about 3 hours for the 2-year storm, 3.6 hours for the 10-year storm, 3.7 hours for the 25-year storm, and 3 hours for the 100-year storm. The proponent should explain the design of the extended detention pond in more detail, and should justify the 70 percent TSS removal estimated for the extended detention pond in light of the actual detention times in the pond.

Finally, we believe that additional requirements are needed to minimize the impact of stormwater on water quality, as follows:
  • The proponent proposes a street sweeping program at the site, and counts it towards Stormwater Standard #4, requiring 80% TSS Removal. However, the proponent ensures states that street sweeping will occur only twice a year, once coinciding with the end of the winter sanding season and once during late fall. For this, a 10 percent reduction in TSS is estimated. Given the proximity of the site to the wetlands, a more aggressive street-sweeping program, consisting of more frequent sweepings, should be evaluated. The proponent should also investigate methods of winter street sweeping.
  • Catch basins, area drains, and drop inlets should be inspected monthly and cleaned a minimum of four times per year, in accordance with the Stormwater Management Handbook recommendations.
  • The proponent should address snow and snowmelt management at the site. What are the proposed locations for snow storage? Snow storage locations should not drain towards the adjacent wetlands. What type of deicing chemicals will be utilized at the site, and how will these impact the adjacent wetlands? The proponent should consider alternative methods for deicing.
  • The proponent should also describe how the proposed stormwater storage facility located under the proposed parking lot will be maintained
MyRWA also believes the project will negatively impact the hydrology of the Little River and Alewife Brook watersheds. While the proponent has scaled down the project in some aspects (e.g., building size had been reduced from 290,000 square feet to 245,000 square feet), the footprint of the project has increased from 48,000 square feet to 66,000 square feet. The project as described in the DEIR still proposes almost 800 parking spaces, all of which will be made of impervious surface.

In addition to describing the soils under the proposed stormwater retention basin, the proponent should estimate (1) the future absorptive capacity of the soils over the next 30 years given the proposed use of the new basin, (2) the frequency with which stormwater may overtop the retention basin, and (3) the conditions under which overflow will occur.

The proponent should also describe the water-retention capacity that will be lost due to the removal of several acres of trees. It is not clear how the volume of the proposed stormwater storage retention will compare to the water storage and envirotranspiraton ability of the existing vegetation on the site.

The proponent should fully describe the design of the compensatory storage proposed as mitigation for the project impacting the 100-year floodplain. According to Figure 5.3-4 in the DEIR, roughly half of the proposed compensatory storage area lies within the 100-year floodplain already, so it is not clear how this area can be considered as mitigation for the proposed construction in the adjacent floodplain.

Finally, we are concerned that this DEIR is not based on an accurate delineation of the 100-year floodplain. FEMA is currently conducting a study to update its flood insurance maps, based on the many changes in land use that have occurred in the last 30 years. It is widely believed that the current maps understate the extent of the 100-year floodplain in many locations, and particularly in Alewife Brook. A recent, limited reevaluation of the floodplain dimensions conducted by the MDC does show substantial differences between the existing FEMA map and the actual locations of the 100-year high water level. We urge that approval of the DEIR be delayed until the results of the FEMA study can be considered, to ensure that the proposed project does not impact the 100-year floodplain, in violation of the Wetlands Protection Act.

In light of the already-severe flooding problems in the Alewife Area, the Cambridge Department of Public Works routinely requires that post-construction peak discharge in a 25-year storm event not exceed the pre-construction peak discharge in a 2-year storm event. We believe that this standard, which is stricter than the statewide guidelines in the Massachusetts Stormwater Policy, is appropriate for an area where there is severe flooding already and where there is substantial doubt about the accuracy of the current floodplain maps.

In light of the high open space value and environmental sensitivity of the proposed building site, the uncertainties about stormwater and other impacts of the project, and the fact that the DEIR no longer reflects the applicant's actual plans for the site, MyRWA requests that EOEA not approve the DEIR as final in its current form. We ask that the developers be required to resubmit their application based on their publicly-stated plans for a residential development. Please contact us if you or your staff have any questions concerning our comments.


Nancy Hammett
Executive Director
Mystic River Watershed Association