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Draft Environmental Impact Report - Belmont Office/R&D Building
Response from Michael F. Nakagawa


Michael F. Nakagawa
51 Madison Avenue
Cambridge, MA 02140


May 13, 2003          RE: ENF for #12376R: Frontage Road Office/R&D Center, Belmont MA
                                by mail and FAX: (617) 626-1181

Bob Durand, Secretary
Executive Office of Environmental Affairs
Attn: Jay Wickersham, MEPA Unit
Re: Frontage Road #12376R
251 Causeway Street, Suite 900
Boston, MA 02114

Dear Mr. Durand:

Thank you for the opportunity to comment on the Environmental Notification Form (ENF) for the Frontage Road Office/R&D Center project submitted on behalf of O'Neill Properties Group (O'Neill) for their Belmont project proposal.

I am concerned that the project develops almost all of the currently undeveloped upland habitat in the area near the Alewife Brook Reservation. It appears from their map of the proposal, which was included in the ENF with neither a scale or legend, that about one parking space worth of the non-wetlands bordering uplands will be further than 100 feet from development, unless the yellow region constitutes landscaped area, in which case no such uplands habitat areas will exist adjacent to the Reservation.

The O'Neill project abuts the Reservation and wetlands habitat on the Bulfinch Properties' site formerly owned by Arthur D. Little. The project includes extensive work in the buffer zone of Bordering Vegetated Wetlands (BVW), covered by M.G. L. Chapter 131 Paragraph 40 and 310 CMR 10.02 and 10.55. It appears that the proposed structures will add shading to existing wetlands, since the project essentially occupies all non-wetland areas up to the BVW border.

The additional 4.4 acres of impervious surface will alter hydrologic flow in the area. The surfaces and the structures will act as a localized thermal reservoir which will alter the local heating characteristics. Vegetation provides evaporative cooling, drawing cooler groundwater to the leaves. Replacement of this natural cooling mechanism with an urban heat island in the middle of a wetlands habitat area is irresponsible, unsustainable development. These surfaces will act to dry out the surrounding wetlands.

The proponent do not provide details supporting their claim that they will provide a net benefit to the area. The increased flood storage could be as little as one cubic foot and the area needs much more. I saw nothing to support their claim of "preserving and enhancing significant upland habitat" when they are in fact developing the only existing upland habitat area in or adjacent to the Reservation.

Traffic at the major intersections adjacent to the property are already at Grade 'F' during rush hours. Office and R&D space will put a large traffic burden at rush hour. The area has no ability to absorb an additional 2642 car trips daily.

Please require that a full Environmental Impact Review be performed.

Sincerely,


Michael Nakagawa