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Environmental Notification Form comments
for the Frontage Road Office/ R&D Center - July 2002

Comments are from:
Mary White-Friends of Alewife Reservation
Tim Toomey-City Council
Grace Perez-Mystic River Watershed Association
Ralph Yoder-Friends of Alewife Reservation
Ellen Mass -Friends of Alewife Reservation
Professor Stephen M. Meyer - Director, Project on Environmental Politics & Policy, MIT

Volunteers are needed for FAR work, contacts, work site projects, cleanups, trail maintenance, MDC envisioning plans, new articles, public relations, monitoring-both water quality and regular visits.

Contact: Ellen Mass, 617 547-1944, or respond to

Points Made to Secretary Durand's Offices Mepa Unit Executive Office of Environmental Affairs

Dear Secretary Durand:

I have read the Environmental Notification Form for the Frontage Road Office/ R&D Center and my comments are made below.

On page one only a permit from the Belmont Conservation Commission is listed, but one is needed from the Cambridge Commission as well as they are within the 200-foot Riverfront Area and the 100-year floodplain.

On page four the proponent states that the project will provide a net benefit to the area, will preserve and enhance significant upland habitat and enhance public recreation. The proponent should discuss how this project specifically would accomplish and, monitor these goals over time.

Land Section
Section K. The proponent states that "Significant portions of the site's buffer areas along wetlands and waterbodies will be left undisturbed and preserved. What percentage of land will fall into this category?

The proponent needs to supplement Section III. Consistency on page six. Attached to this letter please find a copy I wrote to the Belmont Board of Selectmen, dated October 5, 2001. It mentions the Cambridge City Council Resolution to respond to a comprehensive watershed plan for the Alewife area and include a plan and timeline for regional cooperation and planning and cooperation with existing planning efforts. The proponent should respond to this resolution. They should also respond to the MDC's master plan for the Alewife Reservation.

Under III A. Who is on the Alewife Study Committee and how were they appointed? It appears that no open public process was conducted on this project to non-Belmont residents. Some of the roadway is located in Cambridge and Cambridge residents will be the ones to feel the impacts.
III. B Consistency with the Regional Policy Plan was not answered.
III C local zoning by law approval or ordinance was not described.
III D. The proponent did not mention any local site plan or project
review being undertaken by Cambridge. What are the issues each entity is reviewing, concerns, dates of permits these groups are reviewing?

Wetlands, Waterways, and Tidelands Section
II. Wetlands Impacts and Permits
F. The on -site wetland Enhancement Program was not described in the ENF. Shading to wildlife, removal of canopy, and the introduction and control of invasive species are issues to be addressed. A comprehensive wildlife habitat assessment must be completed. Mitigation must be described in an EIR.

Water Supply Section
III. Consistency with water conservation plans, enhancement of water services, and water quality enhancements are not discussed.

Wastewater Section
II. Impacts and Permits
D. This Section although checked was not defined.
III. Once again, Consistency with plans and policies related to wastewater management was not discussed.

Roadways and Other Transportation Facilities Section
II. B. Was not answered, and also III. Consistency Energy Section
Part III. Consistency section was not addressed.

Air Quality Section
Part III Consistency was not addressed.

Solid and Hazardous Waste Section
This section was not filled. If it is medical research and development as suggested, this section will need to be addressed in its entirety.

Historical and Archaeological Resources Section

III. Consistency section should be addressed for both Cambridge and Belmont. Key areas should be protected and described.

The "Belmont Office/Lab Building, Proposed Conditions Plan" by Rizzo Associates, inadequately presented the entire area in question. The Friends of Alewife Reservation have inventoried the resources of the MDC Reservation by David Brown, a noted naturalist. Also Stewart Sanders has written a book, identifying key environmental characteristics of this site. The MDC has just completed a comprehensive study of this area as well. The surrounding roadways, buildings and utilities were not shown.

To conclude, if no outreach to these diverse constituents has taken place by the proponents or the MDC, how can they say that what they are proposing are improvements? This urban wild is adjacent to a large and racially and economically diverse North Cambridge/ Arlington neighborhood the proponent states they will improve recreational and opportunities for the public. I would like the proponent to demonstrate they have taken economical diversity and racial/ ethnic diversity into consideration in their planning.

Those unable to drive to state owned lands miles outside city limits are welcome to this rich, peaceful and beautiful land accessible by MBTA, bicycle, and foot. The cumulative destruction of open land in urban areas will affect everyone as compensation must be paid for increased flooding, decrease in air quality, habitats are lost for migrating birds and insects, decrease in water quality in our rivers, streams, and oceans.

Mary L. White

RE: Cambridge City Council Order #24 7/29

Councilor Toomey:

Whereas: It has come to the attention of the City Council that developers in Belmont may be planning to remove 8 acres of dense silver maple forest abutting Cambridge: and

Whereas: The forest is made up of some 100 year old trees, which are habitat for close to 90 bird species; the forest also provides a home for many species of mammals; and

Whereas: This forest, with tits dense vegetation and huge vernal pool areas, provides significant protection from the upland flooding that Cambridge would experience if the forest were to be destroyed; not therefore be it

Ordered: That the City Manager be and hereby is requested to confer with the Conservation Commission and the appropriate Belmont offices to request that all efforts be made to preserve this forest and protect Cambridge from the floodwaters that removal of the forest would bring to North Cambridge; and be it further

Ordered: That the City Manager be and hereby is requested to report back to the City Council on this matter.

Dear Secretary Durand

The Mystic River Watershed Association, a grassroots organization dedicated to the protection and restoration of the Mystic River, its tributaries and related natural resources throughout the watershed's 21 communities, submits the following comments on the Environment Notification Form (ENF) O'Neill Frontage Road Office/R & D Center in the Alewife area of Belmont.

At the July 24th MEPA scoping session, we were heartened to hear the project proponents state that they anticipate filing Draft and Final Environmental Impact Reports (EIRs) on this project. Given the location and nature of the project, we concur with the need for this more extensive project review.

Our most fundamental concern about this project is that it be considered in the context of recent and likely future development and redevelopment projects in the Alewife area. Located at the edge of three municipalities (Arlington, Belmont and Cambridge), the area has suffered from piecemeal local planning and nonexistent regional planning. The result is an area known for serious traffic problems, flooding, and deteriorated surface water quality. We ask that you carefully consider the cumulative environmental impacts of any development in this area, including the proposed project.

Specific comments on the ENF:
  • On page 4, the ENF states that the project will provide "a net benefit to the area . enhancing public recreation and wildlife habitat values of the parcel and adjacent lands." No details are provided to substantiate this claim, other than the stated plan to put 7.8 acres under a conservation restriction and easement. Open space on a privately owned parcel can indeed be used to "enhance public recreation," but doing so takes considerable effort, including signage, parking facilities, pathways, etc. We hope this aspect of the project will be covered in depth in the Draft EIR.
  • Page 10 of the ENF states that there is enough capacity at the proposed wastewater disposal facility for this project. We question whether this is in fact the case. Several Combined Sewer Overflows exist on Alewife Brook close to the site. Our Mystic Monitoring Network water sampling program as well as sampling by Belmont officials have shown that there are illicit connections in Belmont resulting in sewage entering area waterways. Arlington, Belmont and Cambridge are under order from EPA to find and eliminate these sources of dry weather flows. Elimination of these connections in the coming years will further strain the capacity of the local wastewater infrastructure. We expect the project proponent to confer with the Mass. Water Resources Authority as well as Arlington, Belmont and Cambridge public works engineers to determine how the additional flows from this project will be mitigated.
  • The ENF mentions the acreage that is to be put under a conservation restriction and easement, but the accompanying map does not show the location of the land in question. This information, as well as details regarding the restriction, should be included in the EIR.
We hope that the Secretary will require the proponents to include and/or examine the following issues in the EIR:
  • A full alternatives analysis that includes possible "land swaps" that could satisfy the proponents' need for developable land while protecting or mitigating impacts in the Alewife area ways to significantly reduce the projected total vehicle trips generated by the project
    the possible relocation of construction away from the existing upland stand of silver maple trees and/or the preservation of at least a portion of this unique habitat for use by wildlife and passive recreation ways to maintain wildlife corridors through the site and to the Alewife Reservation, including Little Pond
  • detailed maps showing the area to be put under conservation restriction or easement and the wetlands delineations on this area
  • any plans that the proponents may have for developing their own remaining Alewife property
  • a summary of other likely Alewife area redevelopment or development projects known to the planning boards in the three communities
  • the impacts and expected interactions of the proposed project with any proposed or ongoing projects, such as conversion of nearby MDC land into a soccer field
  • a detailed stormwater management plan that conforms to the state's Stormwater Policy, maximizes on-site groundwater recharge, and features the use of Best Management Practices to reduce input of contaminants into Little River and Alewife Brook. We encourage the proponent to consider the use of Stormceptor, Vortechnics or other commercially available systems, including the diversion of first- flush flows, to mitigate stormwater quality and reduce peak flows from the site.
  • details and results of all relevant hydrology, drainage and groundwater studies
  • mitigation for increased MWRA sewage loadings (and resulting potential overflows to surface waters from this already overloaded system) in the form of Infiltration/Inflow reduction in the Alewife portions of Arlington, Belmont and Cambridge
  • a full traffic study including morning and evening rush hour analysis at the Route 2/Route 16 intersection, the Fresh Pond rotary, Lake Street, Pleasant Street, and any likely "cut-through" routes likely to be taken to avoid increased traffic in the area (especially those through residential areas.) The study should verify that its results are consistent with recent traffic studies done for other Alewife area projects including the Mugar parcel in Arlington - and should explain any significant discrepancies found.
  • A map and description of the path pedestrians would take from Alewife Station to the project site, including those segments that are not directly under the control of the proponent, and any rights- of-way or other agreements in place with the Metropolitan District Commission or other affected landowners
  • a natural resource inventory of the site, including inventory of fauna in any vernal pools on the site
  • discussion of light pollution impacts on the area and ways to mitigate these impacts
Finally, the MDC is currently developing a Master Plan for the Alewife Reservation and riverfront park along Route 16. This provides the only existing opportunity to look at the Alewife area from a regional (i.e., multi-town) rather than local perspective. We believe both MEPA and the proponent should consider the Master Plan in its deliberations and planning for this project.

We appreciate the opportunity to comment on the Frontage Road Office/R & D Center ENF.

Grace I. Perez
Executive Director

REASONS TO REJECT DEVELOPMENT IN THE BELMONT UPLANDS AT ALEWIFE (and everywhere else in the Alewife floodplain ecosystem)

1) According to Mass. Executive Office of Environmental Affairs naturalist Peter Alden, the uplands represent a fairly complete example of silver maple ecosystem. Uplands is at the extremity of range for this habitat. Wide range of age in trees.

2) Essential water recharge area for adjacent Rte. 2 marsh which has perfect habitat for state endangered bitterns, vernal pool species, herons etc. Underground utilities and driveways alters groundwater flow.

3) Wintering ground for robins. Last count 2,500 at least. They use upland trees before settling in the marsh.

4) Vernal pool species such as some salamanders and wood frogs use woods after reproduction cycle. They need buffers of 300 feet minimum and will travel relatively long distances.

5) Major area for important birds of prey including state protected species. Bald eagles, osprey, sharp-shinned hawks, cooper's hawk. Also witnessed nearby as well as at the site: three owl species, merlins, goshawks, kestrals and others including federally endangered peregrine falcons.

6) The Mystic River system has had record numbers of spawning alewife and blue-backed herring, with several hundred thousand reported at the Mystic Lakes. Many use Alewife Brook and Little River to get to spawning areas.

7) Alewife has a major heron roost with as many as 9 regular great blue herons, at least a half dozen black-crowned night herons, and several green herons. By mid summer the area is also frequented by state endangered bitterns and great egrets. During spawning times 25 herons have been seen in the upland trees. Development would disturb them a great deal.

8) According to Peter Alden this is probably the first time in 350 years that we have beavers. As beavers naturally flood an area, we could, and, according to Peter, would have herons nest here. In fact as coastal populations increase, they are likely to choose Alewife anyway. It is a historic area for a heron rookery. As waterways become more eco-friendly more and more herring will entice herons to stay around. If we had this in the remote wilderness, we would fight tooth and nail to save it.

9) Alewife area, according to reports from naturalist Stewart Sanders, is a significant piece of the oldest studied natural history area in the northeast. Thus it is easy to speculate, the oldest in the western hemisphere.

10) I have suggested that it recieve the greatest respect possible, as well as a greater desination and protection. Could Alewife be designated the country's first internationl heritage preserve?

11) Ammenities suggested by developers include the furthur intrusion of public access in areas with extreme sensitivity. I have personally led many tours in the area. Until this year I have kept the uplands off my schedule partly because it would scare fox and other wildlife.

12) The upland habitat adds to the great diversity of the area and is reflected by upland plants and animals in this otherwise wetland ecology.

13) Death by a thousand cuts, is the worry described by Mystic River Wateshed Authority rep Grace Perez. Too many development projects in the floodplain ecological area.

14) It is most important to keep the area for the animals. Primacy of wildlife here should be key. Others have said that we should be content knowing they have a place of refuge, solitude and peace.

SINCERELY, Ralph Yoder, Alewife area naturalist

Dear Secretary Durand,





The developer has not proven that evidence is lacking for endangered species.On the contrary, Piliated woodpecker holes are evidenced in tall trees, as are weasel, mink and beaver."Rare species" said to be "not existent" in the Developer's ENF are not accurate as a result. Also "Exemplary Natural Communities" do not exist according to the Developer ENF. Proof is needed. The developer has not proven that evidence is lacking for endangered species.On the contrary, Piliated woodpecker holes are evidenced in tall trees, as are weasel, mink and beaver which are not rare, but cumulatively, they are a unique habitat in this area. "Rare species" said to be "not existent" in the Developer's ENF are questioned for their accuracy as a result.

Under Wetland delineation, Cambridge Conservation Commission has to view the area, as its property will be impacted. It appears that the Building area does come into the Cambridge wetland designation.

Stream Beds on either side of the property (north and south of the property) have not been assessed or noted.

City and Town By-Law or Ordinances pertaining to wetlands have been ignored or omitted.

Storm water processing is absent from the reports. Sewage transportation and removal have yet to be addressed.

There is no connection or reference to Regional environmental policy

The unique forest type, and forest assessment is absent. Such statements by professional environmental leaders showing its unique qualities must be noted and assessed.

The report enclosed proves beyond any doubt a large range of wildlife And rich forest habitat for the wildlife. Vernal pools are clearly present in the area, is it is an area subject to flooding, and have yet to be noted.

Accompanying evidence by Mail: 1)Professional Mammal Survey of the Alewife Reservation and Frontage Rd. area
2)Professional Bird Survey of the Alewife Reservation and Frontage Rd. area.

Ellen Mass
Friends of Alewife Reservation


Department Of Political Science Project on Environmental Politics & Policy
E53-402 Stephen M. Meyer, Director
Cambridge, Massachusetts 02139

Tel: (617) 253-8078
Fax: (617) 389-7736

July 29, 2002

Ellen Mass
Friends of Alewife Reservation

Dear Ellen,

Thank you for providing me with copies of the David Brown's Mammal Tracking Survey Alewife Reservation - 2002 and Migrant and Breeding Bird Survey Alewife Reservation - 2002. I have also visited your very well designed website. The purpose of my letter is not to offer a document for submission to the review process, but rather to provide you with my sense of the situation.

So, I begin by saying that I am highly sympathetic to your effort to preserve the Alewife Reservation intact. I find your arguments for the social importance of this urban wild to the greater Boston urban communities compelling.

However, I sense that FAR has tried to make most of its case on the basis of biological importance. This I do not find as convincing. The wildlife surveys have found abundant cosmopolitan wildlife - that is animals that cooexist with humans well and are flourishing in the state. Beaver and white-tailed deer populations, for example, are reaching pest proportions in the Northeast.

"Rare-species" have a specific legal status in Massachusetts, as defined by the Massachusetts Endangered Species Act (MESA) and my reading of the surveys leaves me with the impression that there is not much to say in this regard. I note that there are no apparent data on herptiles (reptiles and amphibians) nor invertebrates (especially dragonflies and butterflies and moths) within the reservation. If this is true, it is an unfortunate oversight because the biological importance of this parcel would more likely be indicated by animals in these taxa.

I have seen no discussion of the proximity of the proposed work to jurisidictional wetlands under the Massachusetts Wetlands Protection Act (MWPA) - especially riverfront areas - so I assume that none is contemplated. If work is contemplated within these areas, then local conservation commissions (in the appropriate towns) should request a formal wildlife habitat evaluation.

But let me return to my comment on social significance. The strongest argument for preserving the Alewife Reservation appears to be its value as an urban wild easily accessible by public transportation. Residents of Boston, Cambridge, and all the surrounding towns can take the "T" directly to a 115 urban wild that allows for unbounded educational and recreational opportunities. Those unable to drive to state owned lands, town owned conservation lands, and NGO protected properties dozens of miles outside the city can visit the special place. Your documentation of the abundant wildlife makes the case that this could be a valuable destination for urban environmental recreation and education - similar to the Franklin Park Zoo, the New England Aquarium, and Science Museum.

Unfortunately, this vital function has no regulatory protection. There is no regulatory hook that I can see in MEPA, MWPA, or MESA. At best these regulatory schemes might impose constraints on the proposed development - limiting size, location, or configuration -- but they are unlikely to halt it completely.

This suggests that the most viable strategy for protection would be an eminent domain taking with market value compensation. For this to happen municipal authorities in one or more towns will have to be convinced of the community importance of this land and be willing to mobilize financial resources to acquire the property. Alternatively, one or more interested municipalities might own land of lesser socio-ecological value that could be swapped with the developer.

This is not to say that the regulatory schemes I mentioned are irrelevant. Determining the true market value of the land will require a complete environmental, wetlands, and wildlife evaluation to answer the question: What would really be permitted on this site?

The great shame in all this is that urban wilds are greatly discounted by most parties - builders, government officials, and environmentalists -- because they are not "pristine" habitats with rare species. What is lost is that their true environmental value is derived from their nearness to urban populations, their accessibility, and their evidence of the adaptability of wildlife to the changing landscape. We miss great opportunities to improve the quality of life of Massachusetts urban residents by not investing in the protection of these remnant wild spaces, foolishly believing that most people would or could drive 100 miles to enjoy "the woods."

In the end, the best hope of preserving the Alewife Reservation may be in convincing state and local officials of the broad social value of protecting this urban wild, which is far less expensive than a new sports stadium or convention center.


Stephen M. Meyer