Belmont Citizens Forum
P. O. Box 609, Belmont MA 02478 (617) 484-1844 www.belmontcitizensforum.org

August 23, 2004

Secretary Ellen Roy Herzfelder
Executive Office of Environmental Affairs
Attn: MEPA Office, Nicholas Zavolas
100 Cambridge Street, Suite 900      via fax to 617 626 1181 & e-mail
Boston MA 02114      to nicholas.zavolas@state.ma.us

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

1. that, to mitigate the increase in traffic from Phase I, the developer be required to build the pedestrian bridge envisioned in the Alewife Reservation June 2003 master plan at the east end of the Little River and to build the master plan's proposed connections from that bridge to the bicycle path on the south side of the Little River;
2. that, to mitigate the impact of the construction of such a tall building and such a large garage, the developer be required to reconstruct the MDC parking lot now in accordance with the Alewife Reservation master plan, rather than waiting for a later phase of construction, and to make a significant financial contribution toward the implementation of the rest of the master plan;
3. that, as one small step toward flood mitigation in storms smaller than the 100-year storms, the owner place a conservation restriction now on all its land west of Building 100 and make a binding commitment to put a conservation restriction later on all its land south of Acorn Park Drive (between Acorn Park Drive and the Little River);
4. and that construction equipment be banned from entering or exiting the site during morning or evening rush hours (for three hours each in the morning and in the evening, not just a single peak hour or two.)

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.

Cordially,



John Dieckmann
Vice President

Grant Monahon, President John Dieckmann, Vice President
Evanthia Malliris, Secretary     Mark D'Andrea, Treasurer
Sue Bass     Jim Graves     Thomas G. Shapiro