MYSTIC RIVER WATERSHED ASSOCIATION
20 ACADEMY STREET, SUITE 203
ARLINGTON, MA 02476

August 23, 2004

Ellen Roy Herzfelder, Secretary
Executive Office of Environmental Affairs
Attn: MEPA Office
EOEA No. 13312, Nicholas Zavolas
100 Cambridge Street, Suite 900
Boston MA 02114

Dear Secretary Herzfelder:

The Mystic River Watershed Association (MyRWA) is a non-profit organization dedicated to protecting and restoring the watershed's water quality, open space, and habitat. The Mystic River Watershed includes the Little River, which is the site of the proposed Cambridge Discovery Park redevelopment. MyRWA has previously submitted comments to the City of Cambridge Conservation Commission in response to a Notice of Intent (NOI) filed under the Wetlands Protection Act submitted by the Applicant. I am attaching a copy of our letter to the Cambridge Conservation Commission, which addresses specific concerns with stormwater management and flooding issues.

The proposed redevelopment is located adjacent to Little River and immediately upstream of Alewife Brook, which are areas of special concern to us because of their important role in water quality, flooding, and future recreational uses. The poor water quality and flooding problems that plague the Alewife area have been well-documented and are the result of many poor land use planning decisions in the past. These decisions have not taken into account the flat topography of the area and the poor condition of much of the sewer infrastructure. Each decision about development can be portrayed as a minor contributor to the overall problems. The cumulative effects have been dramatic, however. It is clear that the area's wastewater infrastructure and capacity to control flooding are already inadequate, and the affected municipalities are just now beginning to deal with the high costs of past development decisions.

MyRWA believes that the proposed redevelopment of Cambridge Discovery Park can offer important economic benefits to the community, and also provide an opportunity to improve water quality, reduce flooding, and reclaim open space. Many sites developed in the past did not meet adequate standards for stormwater and wastewater management, and provided little open space benefit to the public. Well-designed redevelopment can correct these past errors, and contribute to the recovery of local watershed resources.

The proposed redevelopment has implications for three environmental issues of concern to MyRWA: water quantity (flooding), water quality, and open space. MyRWA offers the following comments based on the Environmental Notification Form (ENF) submitted by the Applicant and the Phase I Waiver Request.

Phase I Waiver Request

In accordance with MEPA regulations, approval of the waiver must meet the specified conditions of the regulations and requires a demonstration that there will be no significant damage to the environment from allowing the early construction of Phase I of the project.

It is MyRWA's opinion that not enough information has been provided in the EENF to support the claim that there will be no significant damage to the environment from the construction of Phase I. In particular, the EENF does not provide adequate information regarding stormwater management and open space reclamation. Nevertheless, MyRWA would not oppose the Applicant's request for the Phase I waiver for the project, provided that the Applicant fully comply with the Stormwater Management Standards, as discussed below, and demonstrate in filings under the Wetlands Protection Act that the Phase I project will result in a net reduction in flooding and stormwater pollution.

Phase I of the project provides a unique opportunity to begin the long-sought restoration of portions of Cambridge Discovery Park and the adjacent former MDC parking lot. As proposed, the former MDC parking lot would be abandoned during Phase I. We believe that the parking lot should not only be abandoned for parking use but should also be restored during Phase I of the project. The restoration of the parking lot represents a major environmental benefit of the project; simply abandoning the parking lot does provide any environmental benefit, because the site remains impervious and the open space and habitat value of the land is not realized. MyRWA is also concerned that, if Phase I proceeds as proposed, the parking lot may never be restored should the final project be postponed or cancelled.

EIR Scope and Schedule

MyRWA requests that a one-year deadline be established for the EIR, given the uncertainty about the timing of later Phases of the project. If later stages are not fully defined within the next year, the EIR should address the Phase I project and the most likely current plans for the later stages.

We also request that the the required scope for the EIR include the following issues:

Alternatives Analysis

The EIR should analyze the no-build alternative to establish baseline conditions. That baseline should be the condition prior to completion of Phase I, not the post-Phase I conditions, so that the fill impact of the redevelopment can be determined.

The EIR should also evaluate variants to the proposed site layout in order to determine which site layout will minimize overall water quality impacts, particularly by configuring buildings and other impervious surfaces as far away from the river and the wetlands as possible.

Flooding and Stormwater Management

The EIR should provide a detailed analysis of the flooding and stormwater impacts of the proposed development, and should include aggressive options for reducing those impacts. The entire site is located in the 100-year floodplain, and should never have been built on in the first place. The hydrology of the subbasin is complex, and includes backflow of water from Alewife Brook waters into the MWRA interceptor sewers in storms of greater intensity than the one-year storm. During the last eight years, there have been four major floods that have closed parts of Route 2 or Alewife Parkway or both. Storms also frequently cause combined sewer overflows (CSOs) into Alewife Brook in Cambridge. The CSO discharges and other sources of wet-weather bacteria contamination, in combination with the flooding, result in exposure of residents to sewage-contaminated waters, as well as preventing the local waters from meeting swimming and boating water quality standards. Because of the severe existing problems with flooding and stormwater contamination, it is very important that each stage of the project include evaluation of a range of alternatives for reducing these problems.

The EIR should provide detailed information pertaining to the adequacy of the drainage infrastructure to handle changes to the site hydrology. MyRWA's letter to the Cambridge Conservation Commission (attached) presents our questions about the drainage structures.

The EIR and the Applicant's filings with the Cambridge Conservation Commission should demonstrate consistency with the DEP Stormwater Management Policy in detail. The Application should be required to meet the Stormwater Management Standards to the maximum extent practicable, as required by the Policy, and not just provide a minor improvement over existing conditions. The project design should aim to achieve the standards for new developments (e.g., 80% TSS removal), and any cases in which those standards are not achieved should be justified. In addition, the stormwater management system should do more than simply prevent an increase in peak flow, but instead should result in a net reduction in flood levels and duration.

MyRWA recognizes that we are recommending a higher-than-usual standard for a redevelopment project, but we believe that higher standards must apply when considering such a large project in an area that is already subject to severe flooding and water quality problems. We encourage the Applicant to consider a full range of options, including storage, minimizing impervious areas, increasing recharge, water capture and reuse, and the various Low Impact Development (LID) practices, to address these problems. Among these options, the Applicant should include restoration of the stream bank to a more natural vegetated state, when the buildings are finally removed from the adjacent areas.

Sewer Generation and Mitigation

The full build-out will increase wastewater flows from the site by 18,500 gpd. The Applicant notes that the existing site sanitary sewer infrastructure is in fair to poor condition, with an additional estimated groundwater infiltration rate of 11,000 gpd. The Applicant intends to upgrade the sanitary sewer system during the full build-out to reduce groundwater infiltration. MyRWA is pleased that the Applicant is committed to upgrading the existing infrastructure at the site. We are encouraged that the Applicant is considering on-site storage tanks for sewage, since such an action would likely reduce pollutant loadings during very large storm events. The EIR should investigate additional methods of limiting the projected increase in wastewater flows due to the larger total building space. Finally, the EIR should consider funding of infiltration/inflow reduction elsewhere in the Alewife subbasin as another method for mitigating for the added wastewater volumes from the proposed development.

Construction Impacts

All construction sites should be protected to trap site runoff and prevent siltation. The goal should be to prevent any further impacts on Alewife Brook and Little River, which are already suffering from very evident siltation problems. The EIR should indicate how the construction site will be protected, including during 10-year flood events.

Open Space

The EENF does not clearly define the scope and phasing of restoration of the former MDC parking lot. As discussed above, MyRWA believes it is imperative to not only abandon the lot during Phase I, but to restore it as well. In addition, the EIR should show how the project will be consistent with the Department of Conservation and Recreation's Master Plan for the Alewife Reservation.

Conclusion

Thank you for considering these comments and questions. Please contact me if you have any questionsabout this letter, or if MyRWA can be of further assistance in your review of this project.

Sincerely,



Nancy Hammett
Executive Director

Attachment

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