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Belmont Citizen Forum responds on Bulfinch
Traffic and flood emphasis
August 23, 2004
Belmont Citizens Forum
August 23, 2004
Subject: Cambridge Discovery Park, EOEA No. 13312
Dear Secretary Herzfelder:
The Belmont Citizens Forum is supported by 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 appreciate the opportunity to submit the following comments on the Environmental Notification Form filed by Acorn Park Holdings Realty Trust for the Bulfinch Companies, developer of 26.5 acres of Cambridge land at Belmont's border, abutting the Department of Conservation and Recreation's Alewife Reservation.
Because the current filing, though labeled an Expanded Environmental Notification Form, actually contains very little information, most of our comments relate to the proponent's request for a waiver to proceed with construction of Phase I before completing the MEPA process. Before considering the waiver, we recommend that MEPA require a supplementary filing with additional information, including a serious alternatives analysis and significant mitigation proposals. We have just learned that considerable additional information was provided to the Cambridge Conservation Commission in a Notice of Intent. The failure to provide that same information as part of the EENF defeats the purpose of the Massachusetts Environmental Policy Act. This area cries out for serious study of the traffic, flooding, wildlife habitat, and other environmental impacts of development. We understand that the new FEMA flood study recommending a flood elevation of 10.6 feet puts virtually the entire property, including the site of the proposed first-phase structure, Building 100, inside the 100-year flood line.
Especially given such scanty information, we are reluctant to support the waiver request, despite our sympathy for Bulfinch's need for a good tenant and the Smithsonian Observatory's need for a new home. This case probably does meet the hardship standard, but it does not meet the second standard. It seems likely that a good MEPA process would serve to avoid or minimize damage to the environment.
The impacts of Phase I are significant, especially during the demolition of buildings with asbestos and the construction of a 100-foot observatory building and a 600-car garage in the flood plain. A good alternatives analysis might well find that a lower building and/or a different garage configuration would be preferable. And it is clear to anyone who drives through Alewife at rush hour that "ample and unconstrained infrastructure facilities" do not exist to support a return to the number of vehicles this property formerly added to the area, much less the addition of a single car.
However, if the Secretary should decide to grant a Phase I waiver, we recommend that she impose a number of conditions to minimize the environmental damage and mitigate the traffic. Those conditions should include
Doubtless the EOEA staff can suggest more conditions. Since this case does not meet the standards for a waiver, only very significant mitigation could possibly justify allowing the developer to go ahead now.
Grant Monahon, President John Dieckmann, Vice President