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Final Environmental Impact Review - Belmont Uplands, EOEA #12376R
Response from Belmont Citizens Forum
Belmont Citizens Forum
September 24, 2003
Secretary Ellen Roy Herzfelder
EOEA, Attn: MEPA Office
251 Causeway Street, Suite 900
Boston, MA 02114 Via fax to 617 626 1180
Subject: Belmont Uplands, EOEA #12376R
Dear Secretary Herzfelder:
The Belmont Citizens Forum is supported by nearly 600 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 Final Environmental Impact Report filed by O'Neill Properties Group, owner of 15.6 acres of Belmont and Cambridge land at Alewife.
As we said in our comments on the Draft EIR, this property is sensitive because it abuts an MDC reservation. This small parcel of uplands is virtually the only uplands available for the wildlife that inhabit the wetlands on the reservation. (A wildlife study commissioned by the Friends of Alewife Reservation was provided to you by FAR in response to the ENF or the DEIR.) Unless the uplands are preserved, many wetlands species are doomed. This land 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.
The FEIR reports (in 3.5.1) that O'Neill Properties has explored suggestions for a land swap with private developers just over the town line in Cambridge but had difficulty understanding how such a thing could work.
Because of the ecological importance of this land, we recommend that the proponent explore a land swap with the state Department of Conservation and Recreation as successor to the Metropolitan District Commission. The former MDC owns both the Alewife Reservation abutting the O'Neill property and a ______-acre property a short distance away on Route 2 that once contained a skating rink. Both properties are in Belmont, simplifying negotiations, and the skating rink site appears to contain more buildable land. The MDC would very much like to own the O'Neill property and has informally expressed interest in a land swap.
This new site would not be problem free. It has been eyed for decades for regional flood prevention; and we would urge O'Neill to consider building such flood controls into its new structure. The site is also a few feet farther from the Alewife T station than the Uplands and would require a different and cleverer traffic demand management program. However, these are problems that engineers are good at solving. The problems caused for the wildlife by destroying critical habitat cannot be solved by human ingenuity.
Contrary to the proponent's statements, protection of wildlife habitat is an issue in this development. The FEIR notes that the project has been redesigned so that "only" 4,912 square feet of Bordering Land Subject to Flooding will be affected, 88 square feet less than would trigger the Act. (18.104.22.168 and Table 3.3) But that depends on MEPA's acceptance of a segmented project. As was noted in the hearings before the Belmont Conservation Commission and is evident from the FEIR and earlier documents, this project has been segmented so that the impacts of the proposed highway work are not included. Given the amount of wetlands surrounding the site, it is reasonable to think that the omitted segment would likely affect an additional 88 square feet of vulnerable land, if not much more. The proponent's wildlife studies included in the FEIR and in the DEIR appendix, while interesting and impressive, do not explain how the wildlife will cope with the loss of the uplands.
We urge, therefore, that O'Neill Properties be directed to file a Supplementary Environmental Impact report responding to the MDC land-swap suggestion. If that is infeasible, the proponent must find ways to solve the wildlife habitat problems created by the development, including the areas to be affected by road work. If they are beyond the reach of human ingenuity, as we suspect, the project should not be allowed to go forward. The developer should not be permitted to evade this requirement, or others, by segmenting its project.
We would like to inform the MEPA unit that, in response to O'Neill's appeal of the Belmont Conservation Commission's denial of an order of conditions for this project, the Department of Environmental Protection's Northeast Regional Office has ordered a new delineation of the wetlands, probably in the month of October 2003. That delineation should also be covered in a SEIR, if the changes do not require a Notice of Project Change instead.
In its responses to comments, the proponent remarks that air quality issues were not addressed in the comment letters. However, air quality is a major element of traffic, and 20 of the comment letters deal with traffic. Air quality impacts should be addressed in a supplementary filing.
We are generally pleased by the Traffic Demand Management (TDM ) program and appreciate the improvements in bicycle and pedestrian access proposed by the developer in section 22.214.171.124 and figure 3-2; but we note that the proponent does not commit even to studying those improvements until the project receives a certificate of occupancy and does not commit to funding the improvements. That is absurd. The work should be complete before the building is occupied, and its funding should be guaranteed by the developer. Unless that is done, the proposed TDM program will not work. How can anyone be encouraged to walk or bicycle to the site unless the developer provides a safe route to the nearby bike paths and T station?
Further, previous requests for a substantial permanent reduction in the number of parking places provided have been spurned, with only a temporary reduction of a few spaces planned. Without a substantial permanent cut in the number of parking spaces, the TDM program is unlikely to work. Both the traffic jams and the attendant air pollution from so many unnecessary vehicles will damage the environment of this fragile treasure.
The MEPA process is an opportunity to save the last unprotected undeveloped remnant of the Great Swamp. The Belmont Citizens Forum hopes that you will require O'Neill Properties to explore the land swap fully and to improve its development, if develop it must.Cordially,
Jim Graves, President Sue Bass & Mark D'Andrea, Vice Presidents John Dieckmann, Treasurer