The Commonwealth of Massachusetts Executive Office of Energy and Environmental Affairs 100 Cambridge Street, Suite 900 Boston, MA 02114 Charles D. Baker GOVERNOR Tel: (617) 626-1000 Karyn E. Polito Fax: (617) 626-1181 LIEUTENANT GOVERNOR http://www.mass.gov/envir Matthew A. Beaton SECRETARY
October 26, 2018
CERTIFICATE OF THE SECRETARY OF ENERGY AND ENVIRONMENTAL AFFAIRS ON THE ENVIRONMENTAL NOTIFICATION FORM
PROJECT NAME : Mystic Village PROJECT MUNICIPALITY : Medford PROJECT WATERSHED : Mystic River EEA NUMBER : 15910 PROJECT PROPONENT : Mystic Property Associates Limited Partnership DATE NOTICED IN MONITOR : September 5, 2018
Pursuant to the Massachusetts Environmental Policy Act (M.G. L. c. 30, ss. 61-62I) and Section 11.06 of the MEPA regulations (301 CMR 11.00), I hereby determine that this project does not require an Environmental Impact Report (EIR).
Project Description
As described in the Environmental Notification Form (ENF), the project consists of the redevelopment of an existing mixed-use site with the construction of three buildings (7-story, 85-foot (ft) high) with a combined gross floor area (GFA) of 884,038 square feet (sf). The buildings will include 544 apartments, 3,864 sf of leasing office space, 36,478 sf of retail and restaurant uses and 788 garage parking spaces. An additional 156 parking spaces will be provided in surface lots. The project includes driveways, sidewalks, landscaping, a multi-use path and a stormwater management system. The buildings will be served by the City of Medford’s (City) water and sewer system. The project is anticipated to proceed in two phases: the first phase will include construction of the building at the northwest corner of the site and the other two buildings will be constructed in Phase 2.
EEA# 15910 ENF Certificate October 26, 2018
Project Site
The 8.15-acre project site is bordered to the west by commercial uses on Mystic Avenue, to the east by Interstate-93 (I-93), to the north by Mystic Valley parkway and to the south by commercial properties. It consists of four contiguous parcels:
• 278 Mystic Avenue: contains a two-story, 21,776-sf building partially occupied by commercial uses; • 282 Mystic Avenue: formerly occupied by buildings containing retail and restaurant uses and is now used primarily as a vehicle storage lot; • 300 Mystic Avenue: owned by the Massachusetts Department of Transportation (MassDOT) and occupied by a 27,500-sf building used as a sign shop, vehicle storage space and offices; and, • 312-326 Mystic Avenue: occupied by a 41,733-sf building with commercial and light industrial uses.
Winter Brook passes across the site between 282 Mystic Avenue and 300 Mystic Avenue and carries runoff from the City’s drainage system to the Mystic River. According to the Federal Emergency Management Agency’s (FEMA) Flood Insurance Rate Map (FIRM) number 25017C0438E (effective June 4, 2010), the site is located in Zone X. This designation indicates that the site is within a 0.2 percent Annual Chance Flood Hazard area, a 100-year floodplain with average depth of flooding of one foot or less, or in a drainage area of less than one square mile. The site includes filled tidelands associated with the Mystic River that are considered landlocked and not subject to licensing under M.G.L. Chapter 91 (c. 91).
The ENF listed seven Release Tracking Numbers (RTN) assigned to releases of hazardous materials at the site that are regulated under M.G.L. c. 21E, the Massachusetts Contingency Plan (MCP). According to the Proponent, the RTNs have been closed and no further action is required. The 278-282 Mystic Avenue site is subject to an Activity and Use Limitation (AUL) that prohibits residential use on the site; the AUL must be modified to allow residential use.
Environmental Impacts and Mitigation
Environmental impacts associated with the project include the addition of 0.21 acres of impervious area, generation of 1,208 new unadjusted average daily trips (adt)1, construction of 544 new parking spaces, consumption of 95,905 gallons per day (gpd) of water and generation of 88,697 gpd of wastewater. The ENF identified impacts to 460 linear feet (lf) of Bank; during the review period, the Proponent clarified that this work will be limited to removal of debris and will not alter the Bank.
Measures to avoid, minimize and mitigate project impacts include improvements to local roadways and intersections, bicycle and pedestrian facilities, Transportation Demand Management
1 MassDOT concurs with the calculation of new adt provided in the ENF. During the review period, the Proponent provided a calculation of existing site trips that did not include trips associated with 16,336 sf of retail space vacated by Staples over three years before the ENF was filed. This alternative estimate of existing trips is 3,934 adt. Based on the calculated trip generation of 5,992 for the proposed project, the new adt would be 2,058, which is also below the Mandatory EIR threshold of 3,000 new adt.
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(TDM) measures to minimize single-occupancy vehicle trips and construction of a stormwater management system with subsurface infiltration and water quality units that will improve water quality and reduce pre-development peak discharge rates and volumes.
Jurisdiction and Permitting
The project is undergoing MEPA review and requires preparation of an ENF because it requires State Agency Actions and meets or exceeds the following MEPA thresholds: 301 CMR 11.03(6)(b)(14), generation of 1,000 or more adt on roadways providing access to a single location and construction of 150 or more new parking spaces at a single location; and 301 CMR 11.03(6)(b)(15), construction of 300 or more new parking spaces at a single location. The project requires a Vehicular Access Permit from MassDOT and may require an 8(m) Permit from the Massachusetts Water Resources Authority (MWRA).
The project requires an Order of Conditions (OOC) from the Medford Conservation Commission (and, if the OOC is appealed, a Superseding Order of Conditions (SOC) from the Massachusetts Department of Environmental Protection (MassDEP)) and a National Pollutant Discharge Elimination System (NPDES) Stormwater Permit for Construction Activities from the U.S. Environmental Protection Agency (EPA).
Because the Proponent is not seeking Financial Assistance from the Commonwealth for the project, MEPA jurisdiction extends to those aspects of the project that are within the subject matter of required or potentially required State Agency Actions and that may cause Damage to the Environment as defined in the MEPA regulations. Within the area subject to the Land Transfer, MEPA jurisdiction is broad. For the remainder of the project, MEPA jurisdiction extends to land alteration, traffic and transportation, wetlands and water quality.
Review of the ENF
The ENF described existing site conditions and the proposed project and its programmatic and physical elements. It included existing and proposed conditions plans, identified environmental resources and potential impacts and provided a transportation study. During the review period, the Proponent provided supplemental information, including updated plans, supplemental information on project alternatives and additional analysis and data regarding trip generation and traffic impacts.
I received comments from the City, the Mystic River Watershed Association and residents expressing significant concern regarding potential environmental impacts, particularly impacts on traffic, water quality and open space, and the lack of climate change resiliency and greenhouse gas (GHG) mitigation measures in the project design. I note that MassDOT’s comment letter indicates its concurrence with the trip generation methodology and indicates that outstanding transportation issues, including access and pedestrian and bicycle mitigation, will be addressed through consultation with MassDOT during the permitting process. The project requires multiple zoning variances and I expect that the City’s review process will require the Proponent to provide additional details and may result in design refinements and additional mitigation measures. I encourage Proponent to coordinate transportation-related improvements with MassDOT and the City as the project undergoes review and permitting.
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Alternatives Analysis
The ENF reviewed four alternatives to the Preferred Alternative. The Reuse (or No Build) alternative would maintain the existing buildings with similar uses. It would not add impervious area, vehicular trips or parking spaces and would not increase water and wastewater usage. This alternative would not be financially feasible because of the costs of purchasing the land and would not meet the project goal of adding residential uses. The Strip Mall alternative would demolish the existing structures and construct approximately 100,000 sf of retail and restaurant uses. This alternative would not increase impervious area and would have similar trip generation and water and sewer use as the Reuse alternative. According to the ENF, this alternative would also be financially infeasible.
The Two Apartment Buildings alternative would involve the construction of two 21-story buildings with a total of 1,530 apartments. This alternative would be expected to use more than twice the water of the Preferred Alternative, generate over 10,000 adt and add 0.5 acres of impervious area. This alternative would meet the Proponent’s development goals, but would have significantly greater traffic impacts. The Reduced Scale alternative would include 250 apartment units and 10,000 sf of retail space. This alternative would slightly reduce impervious area compared to existing conditions, would generate approximately 2,500 adt and generate approximately 44,000 gpd of wastewater. This alternative is not financially feasible because it will not generate enough revenue to cover construction and land acquisition costs.
According to the ENF, the Preferred Alternative will provide residential units to help meet the demand for multifamily housing in the metropolitan Boston area identified by the Metropolitan Area Planning Council (MAPC).2 It involves the redevelopment of a site in commercial use and will add 1,208 adt to the roadway system. The project’s transportation impacts will be mitigated by adjustments to signal timing, site access improvements, pedestrian and bicycle facilities and TDM measures. The project will construct a stormwater management system that meets MassDEP’s Stormwater Management Standards (SMS).
Traffic and Transportation
The ENF included a Transportation Impact Assessment (TIA) prepared in conformance with the MassDOT/EEA Transportation Impact Assessment Guidelines. It described existing and proposed traffic volumes and operations; roadway, pedestrian, and bicycle conditions; public transit service; site access conditions; and roadway safety issues. The TIA provided intersection capacity analyses documenting traffic conditions under Existing 2017, No Build 2025 and Build 2025 scenarios. It identified mitigation, including pedestrian and bicycle accommodations, roadway improvements and TDM measures that will be implemented to minimize impacts to the local transportation network. The TIA analyzed the transportation impacts of the project in a study area including the following nine intersections listed below. Intersections 1, 2 and 3 are signalized and the rest are or will be unsignalized.
1. Mystic Valley Parkway at the I-93 Southbound/Route16 Off-Ramp; 2. Mystic Avenue at Mystic Valley Parkway and Harvard Street;
2 Population and Housing Demand Projections for Metro Boston prepared in January 2014. Accessed on October 19, 2018 at https://www.mapc.org/wp-content/uploads/2017/08/MetroBoston-Projections-Final-Report_1_16_2014_0.pdf
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3. Mystic Avenue at the I-93 Ramps; 4. Mystic Avenue at Alexander Avenue and Existing/Proposed Site Drive A; 5. Mystic Avenue at Bonner Avenue; 6. Mystic Avenue at Existing/Proposed Site Drives B and C; 7. Mystic Avenue at Hicks Avenue; 8. Mystic Avenue at Proposed Site Drive E; and, 9. Mystic Avenue at Fulbright Street.
Access to the site is provided by nine curb-cuts on Mystic Avenue. The project will reduce the number of curb-cuts. Plans submitted with the ENF identified five proposed curb-cuts: Site Drives A, B, C, D and E. During the review period, the Proponent submitted revised plans showing that proposed Site Drive D has been eliminated from the project. Site Drive A is located at the northern end of the site across from Alexander Avenue and approximately 200 ft south of the Mystic Avenue at Mystic Valley Parkway and Harvard Street intersection; it will provide one access lane and one right-turn only egress lane. Site Drives B and C, at the center of the site, and Site Drive E, at the southern end of the site, will each provide one access lane and dedicated left- and right-turn egress lanes.
Traffic Operations
The project’s trip generation was based on trip rates published in the Institute of Transportation Engineers’ (ITE) Trip Generation Handbook, 10th Edition. Based upon ITE land use codes (LUC) 221 (Multi-Family Mid-Rise) and 820 (Shopping Center), the project will generate 5,992 unadjusted adt. The traffic analysis indicates that the number of trips associated with the retail uses was reduced by 34 percent to take into account pass-by trips, or trips associated with vehicles already on the roadway network. The project’s residential trip generation was further reduced by ten percent to account for trips taken by other modes of travel; according to U.S. Census journey-to-work data, approximately 11 percent of residents who live in the census track use a bus to travel to and from work. As adjusted for these factors, the project will generate 4,660 adt, including 199 vehicle trips in the morning peak hour and 386 vehicle trips in the afternoon peak hour. The project will generate 3,510 vehicle trips on Saturday, including 396 trips during the Saturday mid-day peak hour.
The TIA reviewed traffic operations under 2017 Existing, 2025 No Build, and 2025 Build scenarios at the study area intersections. It provided 50th and 95th percentile queue lengths, capacity analyses and level-of-service (LOS) designations for each intersection at peak periods. For unsignalized intersections, LOS reflects conditions experienced by traffic on side streets attempting to enter the intersection. All unsignalized intersections operate at LOS D or better under 2017 Existing conditions. The LOS for signalized intersections reflects overall operating conditions, with LOS A denoting limited delays and LOS F denoting long delays and congested conditions; LOS D is considered to be an acceptable LOS for urban intersections. Under 2017 Existing conditions, the signalized intersections at Mystic Avenue at Mystic Valley Parkway and Harvard Street and Mystic Valley Parkway at I-93 Ramps operate at LOS E or F during at least one peak period and the Mystic Avenue at I-93 Ramps intersection operates at LOS D or better. During the review period, MassDOT requested that Proponent confirm the 95th percentile queue length at the Mystic Avenue at Mystic Valley Parkway and Harvard Street, which the TIA indicated was 271 ft in the evening peak hour. Based on observations of the intersection, the Proponent reported that the 95th percentile queue exceeded 600 ft due to the traffic signal at Mystic Valley Parkway at the I-93 Southbound/Route16 Off-Ramp.
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Traffic operations for the 2025 No Build scenario were modeled assuming a 1.0 percent annual growth rate in vehicular trips over the seven-year period studied in the TIA. The TIA identified three large development projects in Medford that may generate significant vehicle trips by 2025. Traffic operations under the 2025 No Build condition will degrade at the Mystic Avenue at I-93 Ramps intersection (LOS E in the evening peak period) and Mystic Avenue at Mystic Valley Parkway and Harvard Street (LOS E in the morning and evening peak periods). Operations of study area intersections under the 2025 Build condition will not change significantly.
MassDOT and the City have expressed concerns with the project’s traffic impacts, including added traffic to the roadway network and the safety and operational impacts associated with site access and egress. Mystic Avenue includes a center turning lane that could potentially facilitate left turns into the site; however, the turning lane is not present adjacent to the northernmost driveway and peak hour queues are likely to block left-turns in and out of the site. MassDOT will require the Proponent to demonstrate that the project has been designed to provide safe access to and from the site, which may include further consolidation of site drives and a right-in/right-out configuration for some of the access points. MassDOT will require the Proponent to demonstrate that signal timing optimization at the Mystic Avenue at Mystic Valley Parkway and Harvard Street and Mystic Valley Parkway at I-93 Ramps intersections will restore operations to No Build conditions prior to occupancy of the site.
Pedestrian and Bicycle Facilities
Sidewalks are located on both sides of most streets in the study area, including Mystic Avenue. Crosswalks are located at all intersections except for Mystic Avenue at I-93 Ramps. Mid-block pedestrian crossings of Mystic Avenue are located near Bonner Avenue and Fulbright Street. The Mystic River Path is a multi-use path located in the Department of Conservation and Recreation’s (DCR) Mystic Reservation east of the site. According to the City, the path is heavily used by residents and serves as a commuting route to Assembly Row in Somerville with connections to the Charlestown and Wellington Station Orange Line station and Charlestown.
The project includes measures to facilitate walking and bicycling. The sidewalk along Mystic Avenue will be reconstructed, on-site sidewalks and crosswalks will connect to adjacent pedestrian facilities and an 8-ft wide multi-use path will be provided along the south and east sides of the site. The Proponent will restripe the mid-block crossings and install a HAWK pedestrian-activated signal to facilitate bicycle and pedestrian access across Mystic Avenue. The Proponent will consult with MassDOT and the MBTA to possibly relocate a mid-block crossing coincident with a bus stop. According to the ENF, the on-site multi-use path will connect to the Mystic River Path; however, project plans show that the multi-use path will connect to an approximately 5-ft wide sidewalk north of the site that extends east under I-93 to the Mystic Reservation. The Proponent should continue to coordinate with MassDOT, DCR and the City to establish a safe connection to the Mystic River Path from the site and Mystic Avenue.
Public Transportation
The Massachusetts Bay Transportation Authority’s (MBTA) Route 95 bus service runs along Mystic Avenue between West Medford and Sullivan Square and provides direct access to the Orange
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Line. Bus stops in both directions are located adjacent to the site on Mystic Avenue. As noted above, the Proponent has proposed to relocate the mid-block crossing to provide better access to the bus stops.
Transportation Demand Management
The TIA identified TDM measures that will be implemented to encourage and facilitate the use of non-vehicular modes of transportation by residents of the site. During the review period, the Proponent committed to additional TDM measures not listed in the ENF. The Proponent will implement the following TDM measures:
• Designation of an on-site TDM Coordinator; • Posting of MBTA maps and schedules, bicycle and pedestrian routes, and car- and ride- sharing information within the buildings and online; • Provision of an Emergency Ride Home program; • Provision of dedicated parking spaces for carpools; • Sponsorship of annual employee transportation information events; • Provision of a “welcome packet” to new residents detailing public transportation services, bicycle and pedestrian facilities and commuter options available through MassRIDES and their NuRide program; • Provision of exterior and secure, weather-protected bicycle parking spaces; • A minimum of two electric vehicle (ev) charging stations in the garages; and, • Review of Mystic Avenue bus shelter installations with the MBTA.
The Proponent should consider additional TDM measures, including developing and implementing annual commuter education programs for residents, subsidizing monthly MBTA bus passes for employees and residents and hosting a bicycle sharing station. I encourage the Proponent to further reduce the project’s parking supply. The Proponent should consider land banking space on site and construct remaining parking spaces only when warranted by demand.
Transportation Monitoring Program
The Proponent will monitor traffic conditions in the study area for a period of five years following occupancy of the site. The monitoring program will include vehicle counts to identify peak hour and daily traffic volumes and trip distribution patterns for vehicles entering and leaving the site. The Proponent will collect 24-hour weekday and Saturday automatic traffic recorder (ATR) counts of vehicles at each site driveway and turning movement counts (TMC) and capacity analyses for each peak period for mitigated intersections. The monitoring program will document the transportation modes used to access and leave the site. The goal of the monitoring program should be to evaluate the assumptions made in the TIA, the adequacy of mitigation measures and the effectiveness of the TDM program.
Stormwater
According to the ENF, the site is largely covered by buildings, asphalt and compacted gravel. Site runoff flows to catch basins that discharge untreated stormwater into the City’s system in Mystic Avenue or directly to Winter Brook. The ENF provided a conceptual design of the stormwater management system and reviewed its compliance with the SMS requirements for redevelopment
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projects. The system will include Best Management Practices, such as deep-sump catch basins, water quality units and subsurface infiltration chambers that will remove Total Suspended Solids (TSS) from stormwater prior to discharge into the City’s drainage system or directly to Winter Brook.
I encourage the Proponent to continue to evaluate options for minimizing impervious area as the project undergoes design development and permitting, including through reducing or land banking the area designated as surface parking. The Proponent should consider incorporating Low Impact Development (LID) measures into the project design, including the use of pervious pavement, raingardens/bioretention areas, bioswales, tree box filters, and green roofs, and analyze the potential onsite reuse of roof runoff for irrigation purposes.
Wastewater
The project will generate 88,697 gpd of wastewater. The City is a member of the MWRA Regional Sewer System and is required to assist in the ongoing efforts of MassDEP and MWRA to reduce infiltration and inflow (I/I) into the sewer system. High volumes of I/I can contribute to surcharging of the sanitary sewer system and combined sewer overflows (CSO) in large storms. The Proponent must offset its wastewater flows by providing a monetary contribution or infrastructure improvements in accordance with Medford’s I/I removal policy that will remove I/I at a ratio of 4:1 for every gallon of wastewater generated by the project. The project must also include gas/oil separators in the garage drain systems. As noted by the MWRA in its comment letter, the project is located in proximity to MWRA infrastructure. The Proponent should consult with the MWRA regarding the need for an 8(m) permit.
Climate Change Resiliency
Executive Order 569: Establishing an Integrated Climate Change Strategy for the Commonwealth (EO 569) was issued on September 16, 2016. EO 569 recognizes the serious threat presented by climate change and directs agencies within the administration to develop and implement an integrated strategy that leverages state resources to combat climate change and prepare for its impacts. The Order seeks to ensure that Massachusetts will meet GHG emissions reduction limits established under the Global Warming Solution Act of 2008 (GWSA) and will work to prepare state government and cities and towns for the impacts of climate change. MEPA projects that are required to prepare and submit an EIR must include an analysis of potential climate change impacts on the project and review resiliency design alternatives.
The Northeast Climate Science Center at the University of Massachusetts at Amherst has developed projections of changes in temperature and precipitation for each river basin in Massachusetts. This data is available through the Climate Change Clearinghouse for the Commonwealth at www.resilientMA.org. By the end of the century, average annual temperature in the Boston Harbor Basin is expected to rise by 3.5 to 10.8 degrees Fahrenheit (F), including an increase in the number of days with temperatures over 90 degrees F from 12 to 67 days. During the same time span, the average annual precipitation in the Boston Harbor Basin is expected to increase by 1.1 to 9.0 inches, most of which is expected to occur in the winter with increasing dry days in the summer. The Massachusetts Climate Change Adaptation Report (2011) reviewed studies that have established a range of sea level rise in Massachusetts of 7 to 31 inches by 2100.
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According to the City, it is undertaking a climate change vulnerability assessment that supports these findings and identifies the project site as being in an area at risk of urban heat island effects and increased flooding due to storm surge and inland precipitation. I encourage the Proponent to incorporate climate change resiliency into the building and site design. Appropriate measures may include:
• Elevating or floodproofing floors susceptible to flooding; • Locating critical building systems above the ground level; • Elevating driveways, paths and entrances to buildings above future flood levels; • Decreasing impervious area; and, • Incorporating green infrastructure, such as bioswales, stormwater planters, drought- tolerant plantings, green roofs and permeable pavement, to absorb increased precipitation and reduce the heat island effect.
Greenhouse Gas Emissions (GHG)
I encourage the Proponent to voluntarily incorporate energy conservation measures into the project design to minimize the GHG emissions. Multi-family residential buildings are particularly well- suited to Passive House design methods, which include high-efficiency building envelopes and require significantly smaller heating, ventilation and air conditioning (HVAC) systems. Buildings designed to Passive House standards are potentially eligible for financial incentives from a number sources; heat pumps may be eligible for Alternative Energy Credits (https://www.mass.gov/service-details/statutes- regulations-and-guidelines) and Massachusetts Clean Energy Center incentives (http://www.masscec.com/residential/clean-heating-and-cooling). I encourage the Proponent to consult with the appropriate utility company regarding any available programs.
I note that the City has adopted the Stretch Energy Code, which requires projects to minimize energy use in comparison to baseline Building Code. Buildings constructed to a Passive House design standard are likely to exceed Stretch Code requirements. In the event the Proponent does not proceed with Passive House design, the Proponent should consider incorporating the following GHG mitigation measures into the design of the buildings:
• Roof and wall insulation with high R-values, increased continuous insulation, and energy efficient windows; • Increased furnace efficiency or, use of high-efficiency condensing boilers; • Efficient water heater (heat pump, combination with condensing boiler, and on-demand); • Duct sealing; • Use of energy efficient appliances (i.e., Energy Star); • Installation of low-flow plumbing fixtures; • Use of LED lighting; • Combined heat and power; • Solar thermal; • Air-source or ground-source heat pumps for heating and cooling; and • Rooftop solar photovoltaic (PV) systems.
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I encourage the Proponent to consider taking advantage of a new feature of the Commonwealth’s solar PV SMART plan that allows building owners to receive financial incentives by providing solar production directly to the utility, without requiring the participation of residents as offtakers. For more information, please consult the Massachusetts Department of Energy Resources’ (DOER) web site at https://www.mass.gov/service-details/development-of-the-solar-massachusetts-renewable-target-smart- program. I also encourage the Proponent to pursue the following:
• Massachusetts Clean Energy Center rebates for air source heat pumps, ground source heat pumps, variable refrigerant flow systems, and solar thermal. See http://www.masscec.com/get- clean-energy/business. • MassSave utilities for rebates and incentives on energy efficiency equipment and for performance-based incentives. See https://www.masssave.com/. • Credits associated with the Alternative Energy Portfolio Standards for ground source heat pumps, air source heat pump, solar thermal systems, and combined heat and power. See https://www.mass.gov/alternative-energy-portfolio-standard.
Construction
All construction should be managed in accordance with applicable MassDEP Solid Waste and Air Pollution Control regulations pursuant to M.G.L. c.40, §54. The Proponent will prepare a Stormwater Pollution Prevention Plan (SWPPP) to meet EPA NPDES Construction General Permit requirements. I encourage the Proponent and its contractors to comply with MassDEP’s Diesel Retrofit Program (DRP) and restrict on and off-road idling to the maximum extent practicable. All construction activities should be undertaken in compliance with the conditions of all State and local permits
Conclusion
The ENF has sufficiently defined the nature and general elements of the project for the purposes of MEPA review and demonstrated that the project’s environmental impacts will be avoided, minimized and/or mitigated to the extent practicable. Based on review of the ENF and comments received, and in consultation with State Agencies, I have determined that no further MEPA review is required. Based on comments provided by MassDOT and the City, I anticipate that the project will be revised as it proceeds through permitting. If material changes are proposed that would increase environmental impacts compared to those identified in this Certificate, the Proponent should consult the MEPA office regarding the need for further MEPA review.
October 26, 2018 ______Date Matthew A. Beaton
Comments Received:
09/12/2018 Kim DeAndrade
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09/17/2018 Leslie and Jeff Keats 09/19/2018 Denis Kalthofer 09/20/2018 Alex Lussenhop 09/25/2018 Massachusetts Department of Environmental Protection (MassDEP)/Northeast Regional Office (NERO) 09/25/2018 Mayor Stephanie Burke, City of Medford 10/03/2018 Mystic River Watershed Association 10/09/2018 Nancy Quinn 10/09/2018 Denis Kalthofer 10/11/2018 Medford Energy and Environment Committee 10/16/2018 Massachusetts Department of Transportation (MassDOT) 10/16/2018 Massachusetts Water Resources Authority (MWRA) 10/16/2018 Kenneth Krause 10/16/2018 Abigail Salerno and 30 co-signers 10/20/2018 Suzannah Lela
MAB/AJS/ajs
11 Strysky, Alexander (EEA)
From: Kim DeAndrade
Dear Mr. Strysky,
I am writing with comments about the Mystic Village Development project in Medford.
I am advocating for a commitment to more trees in the development and also some sort of public open space/green space. I would like to see a higher per cent of permeable paving be used. This is not a very green project, but could be with the addition of r ooftop solar arrays, significant bicycle parking, and liberal use of sustainable building materials. thank you,
Kim DeAndrade 54 Canal Street Medford
1 Strysky, Alexander (EEA)
From: Leslie & Jeff Keats
Alexander,
We are very concerned about the impact that Mystic Village will have on an already congested Mystic Ave. The traffic is horrible in this area and a project of this magnitude will cause worse backups on Route 16, Mystic Avenue, and 93. This will impact the dense residential South Medford neighborhood that borders Mystic Avenue. We already have significant issues with traffic, pedestrian, and bicyclist safety in our neighborhood.
We need green space and to create safe ways for pedestrians and bicyclist to move around Mystic Avenue. The upper part of Mystic Avenue residential properties is two family homes, not apartment buildings. We are a thriving community that needs to provide affordable housing for families and individuals who work in Medford.
I strongly encourage that there be a community meeting, so we are informed about the Developers plans for Mystic Village and to be able to provide feedback.
Thank you,
Leslie and Jeff Keats
1 Strysky, Alexander (EEA)
From: Denis Kalthofer
To Whom It May Concern:
This is my comment about the proposed development:
I am against any development this size in Medford, unless ALL of the living units would be affordable housing. We already have terrible traffic, and there is way too much unaffordable housing in Medford and the entire Boston area.
Thank you.
Sincerely, Denis Dettling Kalthofer
1 Strysky, Alexander (EEA)
From: Alex Lussenhop
Hello,
I am writing to comment on the Mystic Village project in Medford (EEA No. 15910). I am resident of South Medford and live just a few blocks from the proposed site. From reviewing the proposal, it appears that the developer will take the opportunity to improve public access to Winter Brook and connect some of the existing bike paths as well as improve the groundwater and runoff at the site. I love this! I think this area is a fantastic spot for new housing that is sorely needed in this area, and this is a good opportunity to make environmental improvements at the site.
I have one question about the environmental impact of the development. I understand from the Medford Transcript's reporting ( http://medford.wickedlocal.com/news/20180830/mixed-used-mystic-village- development-proposed-for-mystic-ave ) that the area was used as a dump for many years. Does this have implications for the future residents? Is it a safe living site for them? Was the dump cleaned up prior to the development of the bank and MassDOT offices? If so, is there documentation of that cleanup effort? I would appreciate seeing this addressed in future communications or public meetings, especially seeing documentation of any prior or ongoing cleanup efforts. If there are still lingering environmental concerns from the site's use as a dump, perhaps the developer could put additional effort into addressing those before building, simply out of concern for the future residents.
Overall, I think this sounds like a great project and would welcome future residents to my neighborhood!
Best, Alex Lussenhop 28 Wright Ave
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Charles D. Baker Matthew A. Beaton Governor Secretary
Karyn E. Polito Martin Suuberg Lieutenant Governor Commissioner
September 25, 2018
Matthew A. Beaton, Secretary Executive Office of RE: Mystic Village Energy & Environmental Affairs Medford 100 Cambridge Street EEA # 15910 Boston MA, 02114
Attn: MEPA Unit
Dear Secretary Beaton:
The Massachusetts Department of Environmental Protection's (MassDEP) Northeast Regional Office (NERO) has reviewed the ENF submitted by Combined Properties, Inc. on behalf of Mystic Property Associates Limited Partnership for Mystic Village in Medford, MA. The Department provides the following comments.
Wastewater
The ENF indicates that the proposed project will generate increased wastewater flows of 88,697 gpd gallons per day (gpd). MassDEP regulations at 314 CMR 12.04(2)(d) require sewer authorities with permitted combined sewer overflows, or tributary to such systems, including the City of Medford, to require removal of four gallons of infiltration and inflow (I/I) for each gallon of new wastewater flow generated for any new connection to their system where greater than 15,000 gallons per day of new wastewater flows will be generated. Accordingly the proponent should meet with staff from the City of Medford to ensure that this mitigation requirement is met. In addition, the EIR should also identify any deficiencies in the wastewater system serving the project site and confirm that the system has sufficient capacity to accept the flow.
This information is available in alternate format. Call Michelle Waters-Ekanem, Diversity Director, at 617-292-5751. TTY# MassRelay Service 1-800-439-2370 MassDEP Website: www.mass.gov/dep Printed on Recycled Paper
The MassDEP appreciates the opportunity to comment on this proposed project. Please contact [email protected] at (978) 694-3236 for further information on wastewater issues. If you have any general questions regarding these comments, please contact me at [email protected] or at (978) 694-3304.
Sincerely,
John D. Viola Deputy Regional Director
cc: Brona Simon, Massachusetts Historical Commission Kevin Brander, Eric Worrall, MassDEP-NERO
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October 3, 2018
BY EMAIL: [email protected]
Alex Strysky, Environmental Analyst Massachusetts Environmental Policy Act (MEPA) Office Executive Office of Energy and Environmental Affairs Commonwealth of Massachusetts 100 Cambridge Street, Suite 900 Boston, MA 02114
RE: Comments on Environmental Notification Form (ENF) for development of Mystic Village, 278-326 Mystic Ave., Medford, MA (EEA No. 15910)
Dear Mr. Strysky:
The Mystic River Watershed Association (MyRWA) is pleased to submit comments on the Environmental Notification Form for the Mystic Village project, 278-326 Mystic Ave., Medford. We believe that this project could benefit the community by redeveloping underutilized properties. However, we feel that in order to fully realize the benefits to residents and the surrounding environment, the project needs to be a model of transit-oriented development with functional and beautiful green infrastructure that improves stormwater management and prevents harm to its residents and property from climate change-enhanced heat and flooding.
MyRWA was founded in 1972 “to protect and restore the Mystic River, its tributaries and watershed lands for the benefit of present and future generations and to celebrate the value, importance and great beauty of these natural resources. We recently launched the Mystic Greenways Initiative, a multi-year, multi-stakeholder effort to renew and stimulate more active use in waterfront lands. There are several opportunities for Mystic Village to advance and benefit from this initiative, as outlined in the comments below.
Connectivity The site is well located for providing access to the waterfront path network that extends along the Mystic River. MyRWA is working to create a shared vision for a seamless waterfront park system along both sides of the Mystic River, connecting communities in Medford and Somerville to this important natural resource. Currently, there is significant connectivity both upstream and downstream of the proposed site. MyRWA is also working on connecting neighborhoods to the Mystic Greenway. We commend the developer for including a bike path connection to the Greenway. It will be a valuable amenity for Mystic Village residents and will benefit the surrounding neighborhoods. We ask that the developer of Mystic Village financially contribute to the completion of the Mystic Greenway adjacent to and upstream of the project site and to assist with its long-term stewardship as a non-motorized pathway and riverfront habitat.
MysticRiver.org | 20 Academy Street, Suite 306 | Arlington, MA 02476-6401 | (781) 316-3438
We urge the developer to not only improve access to the river, but to increase active transportation as well as contribute to a neighborhood-feel rather than one dominated by cars. The project is located in an area that can attract a commuter population with its close proximity to public transportation facilities, including the future Green Line Extension. Four existing bus stops are located adjacent to the site along Mystic Avenue; however, the bus stops are merely signs along the sidewalk. We ask that the developer contribute to a covered bus stop to encourage use of public transit toward mitigating traffic congestion.
Green Infrastructure and Stormwater Management We are encouraged by redevelopment in the area but are concerned about the increase in impervious area of the site by 0.8 acres, increasing the impervious area to 89% of the total area. Considering that Winter Brook itself represents a portion of the total area, there will be essentially no pervious surface in the project other than the brook and its banks. We ask that the developer instead increase the amount of pervious area to at least 25% of the property, and maximize the amount of trees along the stream bank and buildings in order to lower summer temperatures and increase both stormwater infiltration and aesthetics.
The stormwater management plan is to collect stormwater from paved surfaces and roof areas throughout the project site and have it treated prior to discharge. Instead, the Assembly Square Partners HealthCare site provides an excellent example of beautiful, on-site, stormwater infiltration involving below-grade rain gardens, stormwater swales, trees, porous pavement and other strategies that also cool the site and provide other amenities. We also encourage the developer to use other green building strategies such as green (living) or white (reflective) roofs and/or solar panels.
MysticRiver.org | 20 Academy Street, Suite 306 Arlington, MA 02476-6401 | (781) 316-3438
Although the project is not currently in FEMA’s 1% flood zone, it is in FEMA’s 0.2% (500- year) flood zone. With climate change increasing the intensity and duration of precipitation events, flood resilience must increasingly extend beyond the historical 1% flood zone. The figure above, for example, includes state, federal and academic flood projections for the project site. Clockwise from upper left, the maps represent:
• FEMA’s 500-year (0.2% annual) flood zone, • NOAA’s current hurricane flood projections from Mass EOEEA’s resilientma.org website, • Periodic salt water flooding with four feet of sea level rise (projected for 2070+), and • Chronic salt water flooding with five feet of sea level rise (i.e., the Amelia Earhart Dam is regularly or permanently overtopped)
We ask the developer to build to Cambridge’s climate resilience guidelines for sites with similar flood risks.
In closing, we are encouraged to see a development that will redevelop the existing site and bring more people to neighborhoods surrounding the Mystic River. We hope to partner with the city and developer to make connectivity to waterfront parklands a local and regional amenity. If you have any questions or require additional information please contact MyRWA at (781) 316-3438 or by emailing [email protected] or [email protected].
Sincerely,
Patrick Herron Executive Director
MysticRiver.org | 20 Academy Street, Suite 306 Arlington, MA 02476-6401 | (781) 316-3438 Strysky, Alexander (EEA)
From: Nancy Quinn
Dear Mr. Strysky & Mr. Cafferty,
I am a South Medford resident and am concerned about the impact of this project on the area. I have lived in the area for nearly 14 years and have seen traffic increase dramatically. Commuters seem to forget people live in the surrounding neighborhoods and they use our streets as cut throughs and increasingly ignore standard traffic rules and norms.
If you are going to add to the daily traffic (944 cars+), traffic calming measures need to be added -- and on a large scale. My children live close enough to their schools to walk or bike but we rarely let them do so on their own because of the constant traffic and unsafe walking conditions we have in the area. If we are bringing more people to live, work and shop -- then there need to be changes.
I propose that this project makes sure our community sees an increase in safe sidewalks, bikeways, clear and frequent crosswalks, speed limit and traffic rule enforcement on a large scale. There should be safe, clear and well lit walkways and bike paths along Harvard & Mystic. A great area of concern is at that intersection and through the underpass to the middle schools and Meadow Glen shopping plaza. This should be a vibrant connection to both parts of Medford -- but just not for cars. Incentivize people to walk or bike. Work with the MBTA to create more safe and comfortable bus stops and increase bus routes in the area -- especially during weekday rush hour. This project should benefit the community and not take advantage of it -- which seems to be the standard in many of these large scale developments. It is not that people don't want change -- they want smart, useful change that makes the community a better place.
Thank you for your time and attention, Nancy Quinn
34 Hancock Street Medford, MA
------Forwarded message ------
Info from MEPA as follows:
Mystic Property Associates Limited partnership to construct 3 buildings, with a combined gross floor area of 884,038 sf, in two phases. The buildings will contain 554 apartments, 3,864 sf of office space, 36,478 sf of retail/restaurant space and 944 parking spaces. The project will add 1,204 average daily trips (adt) for a total of 5,992 adt, construct 558 new parking spaces for a total of 944 spaces, use 95,905 gallons per day of water and increase impervious area by 0.81 acres (7.23 acres total impervious area on the 8.15-acre site)
Send comments to: 1 Alex Strysky
MEPA Office
100 Cambridge Street, 9th Floor
Boston, MA 02114
[email protected] ph: (617) 626-1025 fx: (617) 626-1181
More project info below.
NOTICE OF MEPA SITE VISIT
EEA No. 15910 Mystic Village, Medford
Project Description : An Environmental Notification Form (ENF) has been filed with the Executive Office of Energy and Environmental Affairs by Mystic Property Associates Limited partnership to construct 3 buildings, with a combined gross floor area of 884,038 sf, in two phases. The buildings will contain 554 apartments, 3,864 sf of office space, 36,478 sf of retail/restaurant space and 944 parking spaces. The project will add 1,204 average daily trips (adt) for a total of 5,992 adt, construct 558 new parking spaces for a total of 944 spaces, use 95,905 gallons per day of water and increase impervious area by 0.81 acres (7.23 acres total impervious area on the 8.15-acre site).
The project meets thresholds for filing an ENF pursuant to 301 CMR 11.03(6)(b)(14), Generation of 1,000 or more New adt on roadways providing access to a single location and construction of 150 or more New parking spaces at a single location and 301 CMR 11.03(6)(b)(15), Construction of 300 or more new parking spaces at a single location. The project requires a Highway Access Permit and the transfer of a 1.67-acre parcel of land from MassDOT.
MEPA SITE VISIT IS SCHEDULED FOR: Friday September 14, 2018 at 10:00 AM. We will meet at 278 Mystic Avenue at the rear of the building.
2 MEPA Comments Due On or Before : September 25, 2018 - now October 16
Certificate Due : October 5, 2018 now Oct 26
Contact for Project Information : Brian G. Cafferty, (781) 321-7800 x321, [email protected]
MEPA Contact : Alex Strysky, (617) 626-1025, [email protected]
*****Updated Info****
MEPA Comment Period Extension- EEA # 15910- Mystic Village, Medford
The Proponent has requested an extension of the comment period. On behalf of the Secretary, the request is granted. The comment period will end on October 16, 2018 and the Certificate will be issued on October 26, 2018. The Proponent will be providing a link for more information about the project.
Alex Strysky
MEPA Office
100 Cambridge Street, 9th Floor
Boston, MA 02114
ph: (617) 626-1025
fx: (617) 626-1181
3 Strysky, Alexander (EEA)
From: Denis Kalthofer
To Whom It May Concern:
Please ensure that the new development includes: 1. Lots of affordable housing 2. Solar panels on all roof surfaces 3. Sharing of solar electricity with the surrounding community
Thanks, Denis Dettling Kalthofer 120 North St Medford MA 02155
1
City of Medford Medford Energy Committee City Hall Room 205 Medford, MA 02155 781-393-2137 [email protected] www.medfordenergy.org
TO: Secretary of Energy and Environmental Affairs Executive Office of Energy and Environmental Affairs (EEA) Attn: MEPA Office Alex Strysky EEA No. 15910 100 Cambridge Street, Suite 900 Boston MA 02114
FROM: City of Medford Energy & Environment Committee
RE: Public Comment on ENF for proposed Mystic Village, 278-326 Mystic Ave, Medford, MA
Dear Mr. Strysky,
The City of Medford’s Energy & Environment Committee would like to submit this letter as public comment in accordance with our mission: to promote policies and actions that improve energy efficiency, encourage conservation, and increase the use of renewable energy to meet our present needs while considering future generations of the Medford community. The Medford Energy & Environment Committee works in conjunction with the Medford Office of Energy and the Environment to support the City’s goals of energy independence and environmental stewardship. The Committee is comprised of Medford residents who bring a variety of expertise to the city, particularly in the areas of energy efficiency, clean energy, community outreach and education.
We recognize that this project will be the first of its kind on Mystic Avenue in Medford, so it will set an important precedent for future development in this growing area. With this in mind, it is our hope that this project will embody principles of environmental health and conservation, active transportation, and clean energy. We suggest the following:
Mitigate increased air pollution, reduce the heat island effect and absorb stormwater runoff Mystic Ave. is a high-traffic area that produces much air pollution from vehicle emissions, which will only increase upon the completion of Encore Casino in the nearby City of Everett. Such traffic is in addition to the constant stream of vehicles on Interstate 93, located just behind the project property. This project is expected to add at least another 300 vehicles, the size of the proposed parking lot, plus vehicles coming and going to visit any retail establishments. To address this increased pollution to an already polluted area, we propose that mature trees are planted around the property to serve as air filters.
Furthermore, this project includes a significant amount of impervious surface. Such paved areas will increase the heat island effect, which is harmful for both people and trees on the property (particularly new trees, which are very sensitive). We would like to see a significant reduction in
City of Medford Medford Energy Committee City Hall Room 205 Medford, MA 02155 781-393-2137 [email protected] www.medfordenergy.org
the amount of impervious surface where possible. Where impervious surface is unavoidable, we suggest that light-colored pavers or concrete are used instead of black tar to prevent intense heat absorption and rising, and mature trees will also provide shade and generally help to cool the area.
It is particularly important to consider the two bus stops that border the property. To promote residential use of public transportation—which would further reduce vehicle pollution—it would be helpful to install bus stop shelters that are further shaded with trees. This would be a valuable addition to both the project and the wider community.
Such tree plantings would also address other problems that often come with development and increased impervious surfaces. If enough vegetation were planted around these trees and graded in such a way that allows stormwater to flow towards the trees, the trees would absorb this excess run-off. This would also contribute to the proper watering of newly-planted trees.
Connect to the “Path Along Mystic Basin” to expand and improve the Mystic River Greenways system The planned bike path behind the buildings could serve as a “closed system” by residents for skateboarding and children’s use of bicycles. However, it would also be advantageous if improvements were made to the nearby “Path along Mystic Basin” just on the other side of Interstate 93 behind the property. This path is shown on the MedfordBikes website here: https://www.google.com/maps/d/u/0/viewer?mid=1xRO7to5gy- Vz35zPRzx4pymmD14&ll=42.40208369567049%2C-71.094949457099&z=16.
The following description from a local biker concisely summarizes the current problems with the path that could be addressed in the proposed project:
“This path is an excellent alternative to riding my bicycle on I-93, or on Mystic Ave. However it has hazards: 1. Extremely poor clearing of snow in the winter. 2. Over growth of weeds and trees along path in spring/summer narrows the path. 3. Root ruts in the pavement. Presently these serve as informal speed bumps, reminding me to pedal at safe speeds around people walking and jogging on the path. But if not addressed/maintained, they'll shorten the useful life of the pavement and make the place a mess for all users.”
If the project work were to mitigate the hazards of this bicycle path, it would be beneficial to adult bicyclists living in the Mystic Village as well as other Medford residents. A more thorough description of the benefits and current needs of the Mystic River Greenways system can be found in this report:
City of Medford Medford Energy Committee City Hall Room 205 Medford, MA 02155 781-393-2137 [email protected] www.medfordenergy.org
https://as.tufts.edu/uep/sites/all/themes/asbase/assets/documents/fieldProjectReports/2018/growi ngMysticRiver.pdf
Expand use of solar in Medford with a rooftop solar farm Considering the expansive nature of the proposed buildings, there is ample room for a 3-4 acre rooftop “solar farm.” This installation would allow Combined Properties to take advantage of renewable energy tax incentives, while reducing the development’s overall energy consumption. Excess energy could be donated back to a microgrid composed of low/moderate income households in the community, which would also assist the region in meeting its clean energy goals to be carbon neutral by 2050 and allow those community members who cannot afford clean energy to still benefit from it. The Committee would be willing to consult Combined Properties on such a project.
Provide additional resources that encourage environmental sustainability in the wider community It would also be beneficial if a portion of the roof was created as a “green roof” (depending on the status of the “solar farm” as proposed above). The presence of plants and vegetation increases the pervious surface of the property and provides natural cooling for the buildings. It would be beneficial for Mystic Village residents and businesses if some of this green-roof space were reserved for a food-producing community garden.
Additionally, we recommend installing charging stations for electric vehicles to accommodate and support electric vehicle use in the region, which will also reduce aforementioned automobile pollution.
We hope that you will consider and accommodate our recommendations where possible to make Mystic Village a prominent example of green development in Medford that will greatly benefit the wider community. If you want to discuss any of our recommendations further, please contact Alicia Hunt, Medford’s Director of Energy & Environment and staff member affiliated with the Committee, at [email protected] or 781-393-2137.
Thank you.
Sincerely, Medford Energy & Environment Committee Erica Colwell Lauretta James Bob Paine Bindi Doshi Kathleen McKenna John P. Rogers Matt Drapeau Luke McKneally Curtis Tuden Barry Ingber Nicole Morell Sergi Valme
Kenneth J. Krause 50 Mystic Street Medford, MA 02155 781-874-0920 [email protected]
October 16, 2018
Secretary of Energy and Environmental Affairs Executive Office of Energy and Environmental Affairs (EEA) Attn: MEPA Office Alex Strysky EEA No. 15910 100 Cambridge Street, Suite 900 Boston MA 02114
Dear Mr. Strysky,
Thank you for the opportunity to comment on the Environmental Notification Form (ENF) for the proposed Mystic Village development at 278-326 Mystic Avenue in Medford. Thanks also to the MEPA Office for extending the comment period to allow time for the proponent to share the latest plan documents and some revisions based on feedback from the Sept. 14 site visit.
In looking at the project from an environmental impact perspective, I offer my comments in three categories: Positive, Negative, and Inadequate/Questionable:
POSITIVE IMPACTS • Stormwater Management: Currently, all stormwater from the site flows untreated into storm drains that discharge into the Mystic River. The proposal to collect stormwater from rooftops and paved surfaces and treat it to remove total suspended solids before its discharge to storm drains or Winter Brook/Mystic River will improve the quality of the water entering the Mystic and perhaps better distribute its flow. One unresolved question may be whether the Winter Brook can accommodate the new discharge pattern (and potentially increased direct volume), as the proponent said there are no plans to dredge or otherwise modify the brook to increase its capacity. • Pedestrian-Bicycle Path: The inclusion of a path to connect to the existing paths on the other side of I-93 is a welcome addition, although the design is flawed as it does not connect to Mystic Avenue, which the ENF states it would (see more comment below). • Bicycle and EV Accommodations: The provision for secure bicycle parking for residents and exterior bicycle racks for visitors (largely absent on Mystic Avenue today), as well as the inclusion of two electric charging stations, both are welcome additions to the project (these were not apparent in the initial ENF documents but were noted in an Oct. 10 memo from project consultant Vanasse & Associates to MassDOT). • TDM Coordinator: The provision for a full-time, on-site Transportation Demand Management Coordinator affirms the proponent’s statement that the promotion of alternative modes of transportation to and from the site will be a priority. However, more concrete actions than promotion will be needed to achieve a significant mode share among transit, vanpools, walking, bicycling and other alternatives to single-occupancy vehicles.
Kenneth J. Krause – EEA No. 15910
NEGATIVE IMPACTS • Increase in Impervious Area: With nearly 80% percent of the project site currently covered with impervious surfaces (6.42 of 8.15 acres), an opportunity exists to reduce the amount of pavement and structure coverage and blend in some additional open and public space, which is almost nonexistent today along Mystic Avenue between Medford Square and the Somerville line. Instead, the project as proposed would increase the impervious area by 3.3%, to 6.63 acres. While this represents an improvement from the original plan filed with the ENF — removing a driveway and adding green space reduced what was a nearly 13% increase in impervious area, to 7.23 acres — more work should be done to reduce the net change in impervious surface area to zero, or, better, to decrease the amount of impervious surface area. • Increase in Building Footprint: Perhaps of greater concern is the proposed 112% increase in building footprints on the site, from 1.86 acres to 3.96 acres, or nearly 50% of the total acreage. Once buildings are constructed, the loss of any land for potential additional open or green space is essentially irreversible, due to the buildings’ permanency. More work should be done to decrease the size of the building footprints to allow more open/green space within the development. • Additional Vehicle Trips: The proponent estimates that activities at the project site will add 1,208 vehicle trips per day, and that the estimated daily traffic on roadways serving the site will increase by 4,660 (2,290 on Mystic Avenue north of the site, and 2,370 on Mystic Avenue south of the site), a 13.7% rise. This is a substantial increase that will contribute to already congested main and side streets in the neighborhood, as well as increase air pollution from idling cars. With even more proposed development forthcoming on Mystic Avenue and in the surrounding communities, more attention must be given to reducing the anticipated increase in daily vehicle traffic at this location. • Curb Cut Reduction: While reducing the number of curb cuts in the project area from 9 to 4 might result in a more orderly flow of traffic in and out of the site, the ability of that few curb cuts to efficiently accommodate the large increase in vehicle traffic is very questionable and concerning. This is especially true given that the smallish retail parking area is located in front of the buildings along Mystic Avenue, which will see a large percentage of the daily traffic activity as cars attempt to enter, exit, and park in a very confined area. It is not far-fetched to expect that vehicles will be queued up on Mystic Avenue during busy periods trying to enter the parking area while vehicles in the lot await other drivers to back out of parking spaces (this occurs regularly at the much smaller retail strip along Riverside Avenue in front of Fellsway Plaza in Medford). This manufactured additional traffic congestion will also add to increased air pollution and perhaps compromise public safety. A closer evaluation should be done not only of the number of curb cuts, but more important, the movement of vehicles on the site and their ability to queue up when leaving the retail parking area, whose exits are extremely close to the curb cuts and portend a real potential for gridlock. The retail parking area would function better on the I- 93 side of the building, which would allow longer queues of cars exiting the development and fewer conflicts between arriving and departing cars.
INADEQUATE/QUESTIONABLE • Highway Proximity/Health Effects: The proponent makes no mention of any concern with or potential mitigation for residents of the proposed complex living just a few hundred feet from heavily traveled and heavily congested I-93. The Community Assessment of Freeway Exposure and Health (CAFEH) research project, much of which has taken place nearby in Somerville, has
Kenneth J. Krause – EEA No. 15910 been examining for the last 10 years the connection between exposure to air pollution from traffic and cardiovascular health in communities near highways. Researchers are especially concerned about the health effects from exposure to ultrafine particles (UFPs), very tiny particles measuring 0.1 microns or smaller. UFPs come from motor vehicles, so highways are a great source of UFPs because of the traffic volume on them. The closer people’s homes are to highways the more likely it is that they will be exposed to higher level of UFPs. Researchers believe that being exposed to high levels of UFPs might be related to greater risk for cardiovascular disease. In studying the areas near I-93 in Somerville and Boston, CAFEH researchers found that levels of pollution were higher near highways and that pollution decreased just a quarter-mile away from the highway. They also found higher amounts of pollution when traffic was heavier, during colder seasons, and on days with less wind. In addition, they found that these UFPs are present in the air in people’s homes whether or not the windows are open. Recommended protective measures for residences close to highway traffic include the use of HEPA filters to capture UFPs, which can be standalone machines or part of an air conditioning system. Sound barriers also are known to lessen the negative health impacts associated with living near a highway, such as asthma and other lung- or heart-related issues. Earlier this year, the Metropolitan Area Planning Council said it would be performing a Health Impact Assessment in regard to the potential sound barriers along I-93 in Somerville. I urge the developer to review the CAFEH findings and recommendations (http://sites.tufts.edu/cafeh/) and also the research by MAPC and other agencies about the potential health benefits of sound barriers and look to incorporate best practices for dealing with near-highway pollution for the benefit of future Mystic Village residents’ health. • Incomplete Pedestrian-Bicycle Path: As noted above, the path circling the rear and southeast side of the property is a positive aspect of the development, but as currently designed, it is ineffective and downright dangerous. The path abruptly ends a few hundred feet from reaching Mystic Avenue, directly in an area that was labeled as a loading area in one of the plans. Those words have been removed from the latest plan drawing, but where the path ends, users still will be directly facing incoming traffic entering the site, and have to cross over to the exit lane while contending with incoming cars turning left into the building 3 parking area. More work needs to be done to complete the ped-bike path all the way to Mystic Avenue, which will improve safety for everyone traversing the area (auto drivers included), as well as make it more likely for pedestrians and bicyclists to enter onto the path where it connects with Mystic Avenue, rather than likely bypassing it if it ends out of view a few hundred feet away within the development. Moreover, the proponent should work with the City of Medford and MassDOT, which has jurisdiction over Mystic Avenue (State Route 38), to examine the opportunity to install a protective bike lane in each direction from at least Harvard Street to the Somerville line (and hopefully beyond). • Invalid Traffic Study Comparison: The proponent downgrades the projected traffic impact of the Mystic Village project by stating that the actual traffic generated by the nearby Lumiere apartment complex in Medford was significantly less than was projected in the traffic study for that project. The Lumiere data is not 100% valid for comparison or extrapolation because that project was much different than Mystic Village in that it did not contain any retail or office uses; it is strictly a residential building. As noted above, the presence of 36,500 square feet of retail businesses and restaurants is going be a major traffic generator and during many more hours than the morning and evening commuting hours, which will see the bulk of the traffic generated by residents. The application of “empirical evidence” from the Lumiere project to reduce the traffic generation projections for Mystic Village should be rejected. Further, since the Lumiere traffic
Kenneth J. Krause – EEA No. 15910 study (and one for the Wynn Casino noted below) was conducted, there has been a wholesale makeover of the former Meadow Glen Mall site across the street, including the addition of a highly popular Wegmans grocery store that is generating significantly more traffic than the mall stores it replaced. Also, another residential development (five stories, 350 units) is being planned on the former Shaw’s supermarket site across from Meadow Glen, which will also add to traffic volumes. These all make previous traffic studies largely irrelevant to the Mystic Village project analysis. • Insufficient Traffic Mitigation Plans: The Vanasse & Associates letter to MassDOT states that observations of the Mystic Valley Parkway/Harvard Street intersection revealed traffic volumes significantly greater than had been projected by the Wynn Casino traffic analysis, with queues of over 600 feet during weekday evening peak hours compared to the 387 feet that was projected in the casino traffic study. Rather than acknowledge the inaccuracy of the casino traffic study, the VA letter blames poor signal timing at the intersection as the cause for the long queues, and that optimizing the signal timing will cure the problem. This strikes me as a oversimplified and unrealistic solution to this problem, as increasing the green signal time for one direction of travel only increases the red signal wait time for those traveling in the other direction and will not address the problem created by thousands of additional vehicle trips at this intersection. • Lack of Sustainability Initiatives: The project description contains virtually no information about any plans for sustainable construction methods, such as use of environmentally friendly materials, or solar or wind power generation, nor a reference to what level of LEED certification will be sought for the building. Environmental sustainability is an important aspect of any project being proposed in Medford, a community that has made reducing its carbon footprint a high priority. This oversight should be corrected as the plans continue to be developed. • Ineffective Pedestrian Safety Improvements: In addition to the incomplete pedestrian- bicycle path design noted above, other proposed measures to improve pedestrian safety are lacking. Relocating a crosswalk from Bonner (not “Banner”) Avenue to a more centralized location and adding a flashing pedestrian signal are not enough; the crossing distance (nearly 70 feet) needs to be shortened with the addition of bulb-outs, curb extensions, and perhaps an area of refuge in the middle of Mystic Avenue. The addition of the retail destinations will mean a marked increase in pedestrians traveling to the development from the densely populated residential neighborhoods on the other side of Mystic Avenue. In addition, since most public transit commuting by residents of the development will be inbound to Somerville, Cambridge, and Boston, there will be a large increase in pedestrians crossing Mystic Avenue to get to the bus stops on the side of the street opposite the development. More attention needs to be given to better pedestrian accommodations for crossing Mystic Avenue, and at more than one crosswalk location. Also, in addition to installing bus shelters at the stops, the MBTA should be required that these be illuminated and contain countdown clocks for all buses serving Mystic Avenue.
CONCLUSION The Mystic Village development represents a welcome improvement to the underutilized or in some places empty parcels along Mystic Avenue. A mixture of housing and retail represents a higher and better use of the properties and will address shortages in both of these areas for this section of Medford.
However, as noted above, the project as proposed has many flaws, most of which I hope can be corrected. A major shortcoming is the misconception, often stated in the ENF, that this is a
Kenneth J. Krause – EEA No. 15910
“master-planned” development. There is little evidence of any serious master planning of the site, which is essentially consists of three discrete buildings with little thought given to how residents or visitors would interact with them, or with each other, except for coming and going. There is no creativity with regard to the design or layout of the buildings; no opportunities for interaction between them except for the late addition of some green space between buildings 2 and 3; no evidence of shared use areas indoors or outdoors; no sense of creating any kind of community that the name “village” might imply. This is an aspect of the development badly in need of attention and improvement.
I also am concerned about the height and massing of the three buildings. The proponent states that the current buildings on the site “no longer fit with the character of the immediate neighborhood.” I maintain that neither would these three proposed building. At seven stories, they are more than twice as high as any nearby buildings, and four stories higher than the largest residential buildings in the South Medford neighborhood just beyond Mystic Avenue on the other side of the street, many of which face this development. While these residents might appreciate the Mystic Village buildings serving as a partial visual and noise buffer to I-93, the structures also will present a massive wall of wood, brick, and glass, where previously the sky (and a couple of electronic billboards) dominated.
My preference would be for these buildings to be no more than five stories high, which would be more palatable to the nearby residential neighborhoods and also decrease the project’s trip generation due to fewer units and residents.
Mystic Village is an extremely significant project for the future of Medford and the additional redevelopment of Mystic Avenue that will rapidly follow. It will break new ground, literally and figuratively, creating an appealing mixed-use development that will undoubtedly see high demand, especially if the housing units are reasonably priced (that is, not luxury housing). It is vitally important to right-size this development, including portions of open/green space, and to use environmental best practices in construction and utilities, as well as comprehensive efforts to incentivize travel by all means other than single occupancy vehicles. This development needs to set a high standard in all of these areas that will be the benchmark for all other developments to follow.
I hope these comments will be received with that goal in mind.
Thank you for your consideration.
Ken Krause 50 Mystic Street Medford, MA 02155 781-874-0920
Kenneth J. Krause – EEA No. 15910
Introduction
I’m writing on behalf of concerned residents of Medford, South Medford and families from the Columbus School. The Columbus School is one of 4 Medford K-5 public schools and currently has an enrollment of approximately 400 students. The Columbus School is in the immediate neighborhood of the proposed Mystic Village development - less than half a mile away at 37 Hicks Ave - and the school district reaches to the Mystic River to the north and east, and to the Somerville border, to the west and south. As Columbus parents and Medford residents, We are concerned about the environmental impact of the Mystic Village development on the neighborhood and the health of our families.
Concerns
We are primarily concerned about the addition of 1,200 vehicle trips per day to our neighborhood.
● This vehicle traffic will congest the neighborhood that surrounds the school - Harvard St, Bonner St, Alexander St, Willis St and Main St, Mystic Ave and Route 16, as well as add to congestion on nearby Interstate 93. This congestion will create persistent air pollution in a neighborhood where children walk to school, and play outdoors at recess and after school.
● Medford’s Energy Department has already identified Mystic Ave as the city’s largest urban heat island (UHI). Increased traffic, combined with the new higher-rise construction of the Mystic Village development, will worsen this problem.
● Vehicle traffic from the Mystic Village development will also contribute to congestion during the morning rush hour, at the start of the school day. With more traffic congestion our children and families would be spending more - unhealthy - time on their daily commutes.
Suggestions
Connecting to local commuter networks that encourage Mystic Village residents to walk, bike and use public transport will mitigate persistent air pollution, rush-hour congestion and increased heat in the Mystic Ave UHI. The multi-use path planned to run “through” the complex is appreciated, but alone it is not enough. This path must be connected to other commuter routes and networks nearby, including, but not limited to the following:
● The Wellington T Station
● MBTA Bus Route 95, on Mystic Ave.
● MBTA Bus Route 101, on Main St.
● The Clippership Connector, a multi-use path that will connect Medford Square with the already existing multi-use paths in Riverbend Park, which run along the east side of the Mystic between Route 16 and Riverside Ave.
● The Blessing of the Bay path, a multi-use path that runs from the south side of 16 between the east side of 93 and the west side of the Mystic.
● Ball Square Green Line Station. Access to this station would be facilitated by improved sidewalks and pedestrian-bicycle routes through the Tufts Park neighborhood.
Medford, and the region, have already made significant investments in our non-car-based commuter infrastructure and the Mystic Village development will benefit from this. All of these paths and routes need improvement and regular maintenance. Contributions to the neighborhood’s non-car-based infrastructure would mitigate the effect of an estimated 1,200 vehicle trips per day.
Improving and increasing green spaces and environmental assets would mitigate increased air pollution, and the increased traffic-related and high-rise related heat in the Mystic Ave UHI. Green spaces should include:
● public green space along or above Winter Brook
● a public playground near your commercial and residential development, as at Assembly Square
● a planted median on Mystic Ave, which would increase green space without “giving up” residential, commercial or parking space needed for financial viability of the complex
● a collaboration with DCR to develop the green space on the northeast corner of Route 16 and Mystic Ave
Medford and its residents have invested money and time in the neighborhood’s green spaces and environmental assets which - within a square mile of the proposed development - include, but are not limited to Hormel track, Macdonald Park, Riverbend Park and its dog park, Tufts park and its public pool, and the community gardens at Riverbend Park, Tufts Parks and Willis Ave. The Mystic Village development will benefit from all of these and contributions to create, improve and maintain the environmental assets of the neighborhood would mitigate the effects of increased traffic-related and high-rise related heat in the Mystic Ave UHI.
We also encourage Combined Properties to find commercial tenants that will contribute to a healthy neighborhood, and a strong local economy. This would mitigate the health impacts of increased commute-times to school and through the neighborhood. To this end:
● We support Combined Properties’ efforts to relocate current businesses on the properties within Medford. We are concerned about a potential loss of tax revenue to the city and its schools if the businesses currently on the property relocate outside Medford.
● We support businesses and services that have already proven viable in Medford - gyms (WOW, BSC), fitness (martial arts, dance), preschool and afterschool childcare, coffee shops with workspaces (Starbucks, Mystic Coffee, Panera), neighborhood groceries (Alexander’s, Roberto’s).
● We support businesses and services that Medford residents have expressed a need for - convenient hardware and housewares, fresh produce (Neighborhood Produce), a kids’ gym or indoor playspace (Imagine, The Little Gym, My Gym, Together in Motion) and shared workspaces (Workbar). We also support Combined Properties’ intention to invite Bank of America and Core Power Yoga to remain as tenants.
● Finally, we are concerned that using a large piece of Medford’s commercial-industrially zoned land for residential development is harmful to the city’s economy and tax base. We encourage CP to include large scale commercial development beyond retail establishments; regionally there is a shortage of lab and office space and Medford is an attractive option for companies that would bring high paying jobs. This employment would, in turn, support retail and restaurants in the community.
Thank you for the opportunity to comment on this project, Abigail Salerno
Eric Falke Sharon Guzik Monica Revert Trish Flanagan Julie Parker Andrea Graham Nancy Bojan Quinn Bill Conroy Sarah Florenz Sarah Kramer Gareth McFeely Nick Tomaszazuk Cristina Reale McGorty Gretchen Ferreira Jason McGorty Rosie Maminstine Michelle Ciccolo Cheryl Rodriguez Michael Bernstein Melanie Tringali Jillian Sam Kris Kay Kathy Turner Mandi Maloney Rebecca Schrot Kelly Garvin Kristina Gasson Anna Ferrentina Barrosa Gabriella Stornaiuolo Ritchie Debra Welch
Strysky, Alexander (EEA)
From: Suzannah Lela
Dear Alexander,
I realize these comments and questions regarding the Mystic Village, Medford mixed-use project are late, but I hope you can still consider them.
1. The project appears incredibly auto-centric with so much parking in front of the buildings and with so many driveways. Such an approach is a dated development model and undermines the idea of the project being transit- oriented and pedestrian-focused. It also undermines current approaches the city is considering though the Mystic Avenue Rezoning Study which seeks to improve walking and biking safety and conditions on Mystic Ave. 2. The site design should seek to reinforce the street wall on Mystic Avenue and improve the pedestrian and bicycle environment. The buildings should be brought forward, closer to the property line, and surface parking placed at the rear. A double row of trees along a widened Mystic Ave sidewalk should be provided to create a more enjoyable pedestrian environment. The entire edge along Mystic Ave should be generously landscaped to improve the pedestrian realm. This could join the landscaping adjacent to Winter Brook, and should include seating, pedestrian lighting and other pedestrian amenities. 3. The documents seem to s uggest that since the site is on, or near, a transit route/stop it’s appropriate for such housing density. But, with over 900 parking spaces provided, the new residents, staff and visitors will most likely be driving and that is confirmed with the estimated 4,660 vehicle trips on a daily basis. The high parking rate of 1.5 spaces per residential unit also indicates that this is the case. 4. Transportation demand management mitigation measures should include consideration of the following: • Subsidized T-passes for residents and staff. • Parking for electric vehicles and car sharing. • Short-term bicycle parking for visitors to both residential and retail uses, located close to building entries. • Shared bicycle facilities such as Blue Bikes, Lime Bike, etc. • Separated/protected bicycle lanes on Mystic Ave. The proposed bike path at the rear of the property, adjacent to a service drive and back-of-house functions appears very isolated. 5. Pedestrian and bicycle improvements should also be more wide-reaching. Consideration should be given to: • Curb extensions on Mystic Ave to calm traffic at pedestrian crossings, and other Complete Streets initiatives, which are recommended in the 2016 Bicycle Infrastructure Master Plan • Raised driveways at sidewalks so the pedestrian realm is prioritized and continuous, and vehicles are forced to slow down. • Options to improve the pedestrian/bicyclist environment along Route 16, under the elevated freeway structure. This space, while providing a connection to the Mid-Mystic Loop pathway network, is very unsafe and unattractive, and therefore rarely utilized by pedestrians or bicyclists. 6. Increasing impervious area in a flood zone seems to be a poor approach to the site’s environmental constraints. Climate change vulnerability assessment mapping undertaken by other cities also shows that this area will be impacted by sea level rise and storm surge in 2030 and 2070. What other resiliency initiatives are planned? 7. The documentation does not identify any other sustainability features such as white roofs, green roofs, LEED building design, permeable paving, etc. Given that the project is asking for a significant increase in density, additional environmental benefits should be considered. 8. How does the project address noise and air pollution associated with residents being in such proximity to the freeway? Tufts University has been undertaking a study on the impacts of air pollution on public health.
Best regards, 1
Suzannah Lela 244 Main St, Apt 5 Medford MA 02155
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