Epsilon Report - Rebuttal

On November 25, 2003 the Belmont Conservation Commission submitted a report to the Board of Selectmen stating its concerns about the impact of a residential development project proposed by O'Neill Properties Group upon the resource areas at and near the Uplands site. On December 9, 2003, the developer'sconsultant, Epsilon, submitted a report critical of the written evaluation the Conservation Commission submitted to the Town. We would like to clarify our point of view at this time.

We were asked to contribute an assessment of the environmental impacts of this project. The Epsilon report refers to its plan to comply with state regulations. Compliance will be a topic for discussion during site plan approval hearings for whatever project is submitted. We wish that complying with state regulations mitigated all significant impacts from development upon natural resources, but we do not believe that is the case.

In this case, we remain convinced that the Uplands development project will have negative environmental impacts in the following areas -

1. Water Quality. Increases in stormwater runoff pollutant loadings (heavy metals, nutrients, petroleum hydrocarbons)and very likely increases in sanitary sewage discharged to Little Pond subwatersheds.
2. Water Quantity. Increases in the volume of stormwater runoff from the Uplands parcel into an area already experiencing damaging flooding.
3. Wildlife Habitat. Loss of all or very nearly all core forested habitat in the Alewife-Uplands-Little Pond natural area. Reduction of remaining habitat values by increased exposure to noise, artificial light regimes, air and water pollution.

Other direct environmental impacts are best viewed as the opportunity costs of the proposed land use changes; loss of recreation value, loss of educational value, loss of historic and/or archaeological value.

The remainder of this letter includes specific comments on the Epsilon letter of December 9, 2003.

Site

Despite the fact that Epsilon notes in its letter report that the Uplands site is privately owned and should not be identified as a fundamental portion of the Alewife area wildlife habitat reserves, they then go on to acknowledge the wider habitat when they say that of the entire 120-acre Alewife Reservation, their development will impact a mere 5.1% (This is the 5.1% containing the unique forest, home of a number of species which need abutting wetlands to survive.) This reliance on a small percentage area loss as an indicator of minimal impact to wildlife habitat ignores the unique, site-specific values of the Uplands parcel.

Valuable wildlife habitat, as documented in the Alewife-Uplands-Little Pond area, is an interrelated system of structure and function. As a simple analogy, a person might easily survive the loss of 5.1% of his total body mass through diet and exercise, but if the 5.1% loss were, through some other impact, to include the heart or other vital organ then there would be would be irreparable harm. In this case, as in other site-specific assessments, simple percentage arguments are not convincing.

The special value of the Uplands site is that it contains relatively extensive forestland in close conjunction to a pond and a river which is in itself in close conjunction to permanently protected open space. Epsilon?s analysis consistently ignores the site-specific values of the Uplands parcel. This site is the only significant natural area above the 100-year floodplain in the Alewife area.

Our concern is to protect the natural resources of Belmont and the abutting Alewife Reservation in the Mystic River watershed area from the likely negative impacts of this development. We believe the decisions we make for this land have regional/watershed implications as well, and that the project must be evaluated regionally.

Forest

The fact that Epsilon states that beech-birch-maple is a common forest subtype elsewhere does not contradict the Commission's statement that this forest type is unique in the Boston Basin, and is the only mature forest in the Alewife region. Again, Epsilon's rebuttal letter ignores the unique and site-specific context of the Uplands parcel.

Epsilon does not address the impacts of the loss of most of the dense monoculture silver maple stand. They miss the critical point about silver maple buds as an important food source for wildlife: the specific timing of the late-winter early spring bud break provides important food resource at a time when other foods are difficult for birds to find. Epsilon lists other tree sources of food (buds, twigs, bark, berries) found on the project site, but fails to note that many or most of these would also be removed if the project goes forward, reducing overall supply not only on-site but also in the larger Reservation area.

The report asserts that once the project were built, some smaller number of trees left standing outside their impact area would still provide general winter wildlife food value. This may be true, in part, but it does not follow, as Epsilon asserts, that there would be no significant impact if most of the trees in the silver maple forest are eliminated. The squarish forested area designated for the new buildings currently provides food and dense cover which would no longer be available for forest-interior wildlife seeking refuge. Any remaining wildlife habitat at the Uplands parcel would be of reduced value overall and useful only to common edge-dependent wildlife species.

Buffer

A number of our earlier comments focussed on buffer zones, the principal protection which the law affords for our designated resource areas, the ?skin? protecting the ?viscera.? O?Neill?s plans to cut into the buffers by the insertion of fire roads and bits of buildings erodes this essential protection.

Although Epsilon is correct that the Belmont Conservation Commission has, over the years, approved projects within wetland buffer zones, we would not claim that these past approvals have had ?no impacts on downgradient wetlands.? We do our best to condition work proposed within buffer zones so that the work-related impacts to wetland resource areas are minimal, but we are under no illusions that we are entirely successful.

Stormwater

Despite planned detention basins for this project, and notwithstanding O?Neill?s peak rate data, we are not convinced that there will be adequate control of runoff volume into the receiving water system during storm events, and we are concerned that the latter may contribute to flooding downstream. The proposed development will discharge more pollutants in stormwater runoff than currently drain from the undeveloped site. Epsilon has submitted no information on the impacts of additional pollutant loading to the already stressed receiving water environment. Furthermore, hypothetical compliance with DEP's stormwater management standards (since final site use and engineering plans have not yet been submitted) does not eliminate the validity of the Commission's concerns over the quality, quantity and location of groundwater recharge from the undeveloped Uplands site.

Sewage

We stand by our assertion that unless Belmont's sewer system is restored very substantially, development of the Uplands will very likely contribute to the volume of sanitary sewerage discharge to Little Pond and Little River.

In closing, please note that, today, we know more about the impacts of development on natural resources than we did in years past. Our understanding of incremental negative impacts on wildlife and water quality, as parcel after parcel of undeveloped area is developed, has increased. With this new knowledge, our efforts to preserve irreplaceable, site-specific resources such as the Uplands silver maple forest must also increase.

February 2004