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The Commonwealth of Executive Office of Energy and Environmental Affairs 100 Cambridge Street, Suite 900 , MA 02114 Charles D. Baker GOVERNOR Tel: (617) 626-1000 Karyn E. Polito Fax: (617) 626-1081 LIEUTENANT GOVERNOR http://www.mass.gov/eea Kathleen A.Theoharides SECRETARY

October 23, 2020

CERTIFICATE OF THE SECRETARY OF ENERGY AND ENVIRONMENTAL AFFAIRS ON THE ENVIRONMENTAL NOTIFICATION FORM

PROJECT NAME : 1690 Parkway PROJECT MUNICIPALITY : Everett & Chelsea PROJECT WATERSHED : EEA NUMBER : 16270 PROJECT PROPONENT : Everett Land Holdings LLC, c/o The Grossman Companies, Inc. DATE NOTICED IN MONITOR : September 23, 2020

Pursuant to the Massachusetts Environmental Policy Act (MEPA; 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 involves the construction of 800 rental apartment units (150 Studio units, 494 One-Bedroom units, and 156 Two- Bedroom units), 5% of which will be affordable housing, in addition to residential amenities, ground- level retail and restaurant space, and approximately 906 parking spaces split between garage podiums and surface parking both within the site and in new on-street spaces. The project proposes to demolish all existing infrastructure on the project site, and to construct three mixed-use residential buildings in the City of Everett and one retail building in the City of Chelsea. The three residential buildings will consist of an eight-story building (Building 1), a seven-story building (Building 2), and an eleven-story building (Building 3). Buildings 1 and 2 will be connected through ground-level podium parking. The retail building located in Chelsea will be one-story (Building 4). The project also includes the construction of a stormwater management system, sidewalks, driveways, parking, landscaping, and a bike lane through the center of the site.

EEA# 16270 ENF Certificate October 23, 2020

Access to the project will be achieved via one proposed curb cut on , three proposed curb cuts on Boston Street, and two proposed curb cuts on Locust Street. The existing curb cut on Revere Beach Parkway and on Boston Street, as well as the two existing curb cuts on Vale Street are proposed to be closed as part of the project. The project proposes a minimum 2% of parking spaces (approximately 15-20 spaces) to be constructed with electrical-vehicle (EV) charging stations and 5% of parking spaces (approximately 40-45 spaces) to be constructed as EV-ready. Additionally, the project proposes a 10-foot shared-use path on Revere Beach Parkway in place of the existing 5-foot sidewalk for pedestrian and bicycle accommodations.

Project Site

As described in the ENF, the approximately 6.90-acre project site is located at 1690 Revere Beach Parkway with approximately 5.64 acres in the City of Everett and approximately 1.26 acres in the City of Chelsea. The project site is currently developed and is occupied by a grocery store and associated paved parking areas (EEA# 12098), all of which are proposed to be demolished. The project site is bounded by Locust Street to the south, Vale Street to the west, Revere Beach Parkway and Boston Street to the north, and an existing gas station and garage to the east. Surrounding land use is characterized as a mix of industrial uses and multifamily residential buildings that were recently constructed or are currently under development. The project site is subject to an Activity and Use Limitation (AUL) that, according to the ENF, does not currently list residential use as an expressly permitted use of the property. The AUL is proposed to be revised to include the proposed project use.

The Mystic River is located within a half-mile of the project site and is classified as an impaired water body. The portion of the project site located in Chelsea is mapped as Land Subject to Coastal Storm Flowage (LSCSF), although the entirety of the project site was considered LSCSF for purposes of MEPA review, as discussed further below. The Chelsea portion of the project site is mapped as a 100- year floodplain (Federal Emergency Management Agency (FEMA) Flood Zone AE (an area inundated during a 100-year storm)), with a Base Flood Elevation (BFE) of elevation (el.) 10 ft NAVD88. As described in the ENF and discussed during the remote consultation session for the project, the portion of the project site located in Everett is not currently located within LSCSF nor mapped within this 100-year floodplain, although the FEMA Flood Map for this area is in the process of being updated. The ENF states that, irrespective of these mapping discrepancies, the base flood elevation for the entirety of the project site has been assumed to be el. 10 ft NAVD88, meaning the entire project site has been assumed to be within the 100-year floodplain for purposes of calculating impacts during this MEPA review.

Environmental Impacts and Mitigation

Potential environmental impacts associated the project include the creation of an additional 0.25 acre of impervious surface within the project site (6.15 acres total) and the alteration of 300,636 square feet (sf) (6.90 acres) of LSCSF.1 The project will increase water demand by 114,496 gallons per day (gpd) (122,062 gpd total) and will generate an additional 104,087 gpd of wastewater (110,965 gpd

1 An updated calculation of impacts to LSCSF was provided during MEPA review. The original ENF submittal identified 54,825 sf of impacts to LSCSF. This number was refined in response to discussion during the remote consultation session held on October 1, 2020.

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total).2 The project will result in a total of 3,464 average daily trips (adt) for the project site, an overall decrease of 610 adt when taking into account the trips generated by existing on-site uses, which will be replaced by this project. The project will increase the number of parking spaces by 498 spaces (906 parking spaces total).

Measures to avoid, minimize, and mitigate environmental impacts identified in the ENF include the construction of EV charging stations and EV-ready parking spaces, the construction of bicycle and pedestrian accommodations, development of a Stormwater Pollution Prevention Plan (SWPPP), and the implementation of sedimentation and erosion controls during construction, including: a proposed construction entrance, protection for stormwater inlets, temporary sediment basins, and protection around temporary material stockpiles.

Jurisdiction and Permitting

This project is subject to MEPA review and preparation of an ENF pursuant to 301 CMR 11.03(3)(b)(1)(f), 11.03(5)(b)(4)(a), and 11.03(6)(b)(15) because it requires State Agency Actions and involves the alteration of one half or more acres of any other wetlands (LSCSF); the expansion in discharge to a sewer system of 100,000 or more gpd of sewage, industrial waste water, or untreated stormwater; and the construction of 300 or more new parking spaces at a single location, respectively. The project requires a Massachusetts Department of Transportation (MassDOT) Vehicular Access Permit, as well as a Constructing Dewater Permit and 8(m) Permit from the Massachusetts Water Resources Authority (MWRA).

The project will require an Order of Conditions (OOC) from the Chelsea Conservation Commission (or in the case of an appeal, a Superseding Order of Conditions from MassDEP) and Site Plan Review Approval from the Chelsea Planning Board. From the City of Everett, the project will require Dimensional variances, as well as a Land Disturbance Permit; Stormwater Management Permit; Inclusionary Housing Special Permit; Special Permit(s); and Site Plan Review Approval from the Everett Planning Board. The project may also require an Order of Conditions from the Everett Conservation Commission. The project requires Sewer Connection Permits, Water Connection Permits, Demolition Permits, Building Permits, and Certificates of Occupancy from both the City of Everett and the City of Chelsea.

The project requires a National Pollutant Discharge Elimination System (NPDES) Construction General Permit from the EPA and may require a Notice of Proposed Construction or Alteration from the Federal Aviation Administration.

The project is not receiving Financial Assistance from the Commonwealth. Therefore, MEPA jurisdiction for any future review would be limited to those aspects of the project that are within the subject matter of any required or potentially required Agency Actions and that may cause Damage to the Environment, as defined in the MEPA regulations.

2 Impacts associated with existing uses, which will be demolished and replaced with this project, were not included in the net “new” calculations, since these uses already have impacts on the surrounding water/wastewater system and traffic network.

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Review of the ENF

The ENF provided a description of existing and proposed conditions, preliminary project plans, project phasing plans, a transportation impact assessment, and identified measures to avoid, minimize and mitigate environmental impacts. The Proponent also provided updated impact calculations to LSCSF that assumed the portion of the project site located in Everett as being located in the 100-year floodplain, resulting in the entirety of the project site being considered LSCSF. An updated narrative reflected resiliency measures that were discussed during the remote consultation session as well as a more specific estimate of parking spaces with EV charging infrastructure.3 For purposes of this Certificate, this supplemental information and original filing are referred to as the ENF.

Comments from State Agencies do not request additional analysis in the form of an EIR but identify additional information that should be provided during the permitting process. This information is detailed below.

Alternatives Analysis

The ENF evaluated several project alternatives based on their ability to meet project goals while minimizing environmental impacts. Project goals were identified as the creation of housing (including income-restricted housing), urban development, and community contributions to the Cities of Everett and Chelsea. The project evaluated the following Alternatives: No-Build Alternative, Alternative A, Alternative B, and the Preferred Alternative.

The No-Build Alternative would leave the site in its current condition and would not result in further environmental impacts to the project site. According to the ENF, this Alternative was dismissed as it would not result in the redevelopment of the project site consistent with rezoning efforts and would not meet project goals. Alternative A would include the construction of a single-story 15,000 gross square-foot (gsf) office building and 5,000 gsf retail building. This Alternative would result in the generation of an estimated 1,375 gpd of sewer discharge and the use of approximately 1,513 gpd of water, significantly less than comparable impacts of the Preferred Alternative (110,965 gpd of wastewater generation and 122,062 gpd of water demand). According to the ENF, the underlying zoning for the project in Everett is the City’s newly established Commercial Triangle Economic Development District (CTEDD). The ENF states the purposes of the CTEDD is to encourage “high-quality and high- density mixed-use development” and “a greater range of residential development and housing options for the City of Everett with particular focus on the enhanced access to mass transit routes offered by this neighborhood,” among other goals. The ENF states Alternative A was dismissed as the smaller project would make it cost-prohibitive to construct all buildings within the project site to accommodate the 10 ft NAVD88 BFE, and would not align with the goals of the City of Everett included in the CTEDD.

Alternative B proposes the redevelopment of the existing site as a mixed-use development at a smaller scale than the Preferred Alternative. The project would include four new building varying from one to seven stories, containing approximately 700 rental apartment units, residential amenities, ground- level retail and restaurant space, and approximately 980 parking spaces split between garage podiums and surface parking both within the site and in new on-street spaces. According to the ENF, Alternative

3 Supplemental information was provided in an email sent from Zachary Richards (Bohler) to Eva Murray (MEPA Office) on October 9, 2020. 4

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B would result in a similar volume of water demand and generate similar amounts of wastewater due to a unit mix that would contain more two-bedroom apartments. This alternative was dismissed in favor of the Preferred Alternative, as Alternative B would result in similar impacts with fewer community benefits. The Preferred Alternative (described herein) proposes a slight increase in density as compared to Alternative B, but with less parking and greater investment in alternative transportation modes and municipal infrastructure. According to the ENF, the Preferred Alternative was selected as it meets project goals and contributes most significantly to the goals of the CTEDD.

Wetland Resources

As previously discussed, the portion of the site located in Chelsea (54,825 sf) is mapped as FEMA Flood Zone AE (100-year floodplain); however, the portion of the site in Everett (245,811 sf) is not currently located in the 100-year floodplain as designated in FEMA mapping, although this is in the process of being updated. The ENF states draft FEMA Flood Zone maps for the City of Everett indicate that the 100-year floodplain will extend across the entirety of the site, and that due to the proximity of the site to Boston Harbor, the floodplain within the project site is tidally influenced. The ENF further states that, “pending the adoption of the draft floodplain maps, and upon review and coordination with the City of Everett, MassDEP staff, and MEPA staff,” the entire project site will be considered to be LSCSF, and the project is therefore assumed to result in permanent impacts to 300,636 sf (6.90 acres) of LSCSF. The Chelsea Conservation Commission will review the project to determine its consistency with the Wetlands Protection Act (WPA), the Wetlands Regulations (310 CMR 10.00), and associated performance standards. Comments from MassDEP and from the Massachusetts Department of Conservation and Recreation (DCR) also note the work proposed in the Everett will be located within FEMA Flood Zone AE based on updated mapping that will become effective in the near future.

The ENF states that according to draft flood plain mapping for the City of Everett and current mapping for the City of Chelsea, the base flood elevation (BFE) within the project site is 10 ft NAVD88. As described in the ENF, the project will be designed to accommodate this BFE, with the proposed first floor elevation set at 11 ft NAVD88 to provide one foot of freeboard above the BFE for all residential, critical functions, and utility infrastructure in both the Chelsea and Everett portions of the project site. The ENF additionally states the Proponent will work with the Everett Conservation Commission (in addition to the Chelsea Conservation Commission) and Everett Public Works Department to file necessary information for the City of Everett to assess impacts from the project, assuming a flood plain elevation of 10 ft NAVD88. As discussed below, these design choices do not appear to reflect increases in precipitation and flood levels that may result from the impacts of climate change.

DCR’s Flood Hazard Management Program (FHMP) serves as the coordinating agency for the National Flood Insurance Program (NFIP). Comments from DCR state that the buildings constructed in the 100-year floodplain as mapped in the City of Chelsea will be required to meet the standards of the State Building Code for Flood Resistant Construction (780 CMR Section R322.1). DCR strongly encourages the Proponent to design the structures located in Everett to meet these standards as well. The Proponent has committed to elevating structures for residential uses and critical infrastructure in both Chelsea and Everett, and will take additional resiliency measures for retail components located in lower elevations as described below. In addition, comments from MassDEP identify concerns regarding the impact of the placement of fill in the floodplain, specifically, the potential for flooding risk to surrounding properties and infrastructure during coastal storm flood events. MassDEP indicates that

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information regarding such potential impacts to wetland areas should be provided during the subsequent permitting process. I strongly encourage the Proponent to engage in careful planning during final design and permitting, so that the impacts of precipitation and flooding on the project site (as exacerbated by the impacts of climate change) are weighed against the secondary effects of the placement of fill in the floodplain including the potential for flooding risk on adjacent properties and infrastructure.

Stormwater

The project will create 0.25 acres of impervious surface, for a total of 6.15 acres of impervious surface on the 6.9-acre project site. According to the ENF, stormwater runoff from the site currently flows to one of several existing catch basins located on the property, which appear to discharge via a pump station to the existing drainage infrastructure located within Revere Beach Parkway with minimal pretreatment. Improvements to the existing stormwater system will be made as part of the proposed project. The ENF states that the proposed stormwater management controls will be designed in accordance with both the City of Everett requirements and those described in the MassDEP Stormwater Handbook. As described in the ENF, stormwater runoff generated as a result of the project will be collected and treated through a combination of Best Management Practices (BMPs) prior to discharge to the existing City of Everett drainage infrastructure, and that an Operation and Maintenance (O&M) Plan will be prepared for the project site’s proposed stormwater management system. The O&M Plan will outline procedures and time tables for the long-term operation and maintenance of the proposed site stormwater management system, including initial inspections upon completion of construction, and periodic monitoring of the system components, in accordance with established practices and the manufacturer’s recommendations. Comments from the Massachusetts Water Resources Authority (MWRA) request that the Proponent confirm the locations of stormwater discharge and the fact that no stormwater generated on the Project Site will enter a sewer system.

Water and Wastewater

According to the ENF, the project will increase wastewater flow by approximately 104,087 gpd, from an existing wastewater flow of 6,878 gpd to 110,965 gpd and will increase water demand by approximately 114,496 gpd, from an existing water demand of 7,566 gpd to 122,062 gpd. The project does not propose the construction of new water mains or sewer mains. The ENF states that based on initial discussions with the City of Everett there is sufficient sewer and water infrastructure in the project vicinity to serve the proposed project. Comments from MWRA state the project site is served by a sanitary sewer system owned and operated by the City of Everett that conveys the wastewater flows to MWRA’s North Metropolitan Sewer, which, in turn, conveys flows to MWRA’s Headworks and ultimately to the Deer Island Treatment Plant. MWRA comments state that due to high infiltration and inflow volumes entering tributary community systems, wet weather flows can exceed the capacities of the MWRA system and contribute to system surcharging and overflows, including combined sewer overflows (“CSO”) to the Mystic River and Mystic/Chelsea Confluence in large storms. The ENF states the project will be contributing to I/I (infiltration and/or inflow) removal at a 4:1 ratio as required by the City pursuant to 314 CMR 12.04, thereby increasing the overall capacity of the local sanitary sewer system. The ENF further states various water conservation measures such as low-flow toilets and urinals, restricted flow faucets, and sensor operated sinks, toilets, and urinals may be incorporated, which will likely bring the project’s sewer generation below the 100,000 gpd usage projections established by the MassDEP Title V flow analysis.

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Construction Dewatering and Section 8(m) Permitting

According to the ENF, the project will require a Constructing Dewatering Permit and 8(m) Permit from MWRA. The discharge of groundwater and stormwater into the sanitary sewer system is prohibited pursuant to 360 C.M.R. 10.023(1), except in a combined sewer area when permitted by the MWRA and the local community. Comments from MWRA state that the project site is not located in a combined sewer area and therefore, pursuant to 360 C.M.R. 10.023(1), the proposed discharge of groundwater or stormwater to the sanitary sewer system associated with project construction is prohibited, and a construction dewatering permit from MWRA cannot be issued. Section 8(m) of MWRA’s enabling legislation (Chapter 371 of the Acts of 1984) allows MWRA to issue permits to build, construct, excavate, or cross within or near an easement or other property interest held by the MWRA. Comments from MWRA confirm that the project will require a Section 8(m) Permit due to proximity of the project to MWRA infrastructure. The Proponent should consult with the MWRA to determine the requirements for issuance of this permit.

Climate Change Adaptation and Resiliency

Governor Baker’s Executive Order 569: Establishing an Integrated Climate Change Strategy for the Commonwealth (EO 569; the Order) was issued on September 16, 2016. The Order recognizes the serious threat presented by climate change and direct Executive Branch agencies 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. I note that the MEPA statute directs all State Agencies to consider reasonably foreseeable climate change impacts, including additional greenhouse gas emissions, and effects, such as predicted sea level rise, when issuing permits, licenses and other administrative approvals and decisions. M.G.L. c. 30, § 61.

The Northeast Climate Science Center at the University of Massachusetts at Amherst has developed projections of changes in temperature, precipitation, and sea level rise for Massachusetts. This data is available through the Climate Change Clearinghouse for the Commonwealth at www.resilientma.org. By the end of the century, the average annual temperature in the Boston Harbor Drainage Basin is projected to rise by 4.85 to 9.33 degrees Fahrenheit (°F), including an increase in the number of days with temperatures over 90 °F from a minimum of 20.61 days and a maximum up to 53.83 days compared to the 1971-2000 baseline period. During the same time span, the average annual precipitation is projected to increase by a minimum of 4.42 to a maximum of 4.95 inches, which may be associated with more frequent and intense storm events. The Massachusetts State Hazard Mitigation & Climate Adaptation Plan (2018) may provide additional data and resources applicable to the project site.

The Cities of Everett and Chelsea are both participants in the Commonwealth’s Municipal Vulnerability Preparedness (MVP) program. The MVP program is a community-driven process to define natural and climate-related hazards, identify existing and future vulnerabilities and strengths of infrastructure, environmental resources, and vulnerable populations, and develop, prioritize and implement specific actions the Town can take to reduce risk and build resilience. Through the MVP

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program, the Cities received funding to conduct a planning process for climate change resiliency and implementing priority projects. The results of the initial community-driven process for the City of Everett were presented in the “City of Everett Community Resilience Building Workshop Summary of Findings” (Everett Report) dated June 20194, and added to by the Urban Heat Island Effect Supplemental Report, also dated June 20195. The results of the planning process for the City of Chelsea were presented in the “City of Chelsea Community Resilience Building Summary of Findings”, dated May 19, 20186 (Chelsea Report). The Everett Report identified coastal storm damage and flooding, inland flooding, and the urban heat island effect as top areas of concern. The Chelsea Report identified sea level rise, extreme heat, air pollution, severe storms, and inland flooding/stormwater management as top areas of concern.

The project site is mapped as a Hurricane Surge Inundation Zone. As stated previously, a portion of the project site is currently mapped as within FEMA Flood Zone AE (100-year floodplain) and based on draft updated floodplain maps for the City of Everett, the entirety of the project site may be located within the 100-year floodplain. The ENF states the proposed project will be designed to accommodate the BFE of el. 10 ft NAVD88, with the proposed first floor elevation will be set at 11 ft NAVD88. In areas of the project site with a significantly lower elevation (3.0 ft NAVD88), the ENF states retail stores may incorporate vestibules with a blend of interior and exterior stairs, ramps and half-stop elevators to provide an active street wall while still protecting the bulk of the retail square footage during a flood event. The ENF states that if necessary, the vestibules or garage entrances located at street level could utilize temporary flood measures and barriers. I refer the Proponent to comments from MassDEP that identify concerns regarding impacts from and to the project related to coastal flooding, and from DCR that recommend additional strategies to construct the project such that it is resistant to damage during flooding events. I strongly suggest that the Proponent consider climate change data and projections in finalizing project design. Building elevations should be evaluated to ensure they provide sufficient protection from flooding when considering the effects of increased precipitation from climate change. These effects should be appropriately balanced against the secondary effects of the placement of fill in the floodplain including the potential for increased flooding on adjacent properties and infrastructure.

Greenhouse Gas (GHG) Emissions and Sustainable Design

The ENF states the Proponent has engaged a consultant to perform energy modeling and review renewable energy feasibility for the Project. As described in the ENF, studies will include preparation of prototype energy models for the proposed buildings that will include the following design options: “a code compliant baseline, a basis of design, a basis of design with all electric systems, and a passive house equivalent.” The ENF states the consultant will perform feasibility studies for renewable energy potential including solar photovoltaic, solar thermal, and combined heat and power. While the project does not exceed the thresholds for application of MEPA’s GHG Policy and Protocol, it does involve the development of new residential homes that will add to GHG emissions from the building sector. I encourage the Proponent to voluntarily undertake measures to minimize GHG emissions from the

4 Everett Report can be accessed from: https://www.mass.gov/doc/everett-report/download 5 Everett Supplemental Report can be accessed from: https://www.mass.gov/doc/everett-mvp-urban-heat-island- supplemental-report/download 6 Chelsea Report can be accessed from: https://www.mass.gov/doc/2017-2018-mvp-planning-grant-report- chelsea/download 8

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project by incorporating energy conservation measures into the housing design. Measures that may be suitable include:

• Passivehouse building standards; • Efficient Electrification of space and water heating; • Maintaining envelope integrity with framed, insulated walls with continuous insulation; • Avoiding glass curtain wall assemblies and excessive windows; • Mitigation of solar heat gains; • Energy recovery; and • Rooftop solar PV.

Significant incentives may be available including MassSave® incentives, Alternative Energy Credits (AECs), and Solar Massachusetts Renewable Target (SMART) incentives. I note that the City of Everett has adopted the Stretch Energy Code (SC), which the three multifamily buildings would be subject to as each are over 100,000 gsf. I refer the Proponent to comments from the Massachusetts Department of Energy Resources (DOER), encouraging the Proponent to investigate Passivehouse as an alternative to constructing to minimum code standards as Passivehouse could be more cost effective than building to Massachusetts’ minimum code standards once $2.4M in MassSave® incentives are considered. Further, Passivehouse results in significant reduction in utility costs, increasing affordability for residents, and improves the resiliency of the buildings, as Passivehouse buildings can stay warm (or cool, in the summer) for extended periods of time even with loss of power. I refer the Proponent to the Massachusetts Department of Energy Resources (DOER) comment letter which provides additional guidance on key mitigation strategies, energy efficiency pathways, and available incentives.

I encourage the Proponent to consider taking advantage of a new feature of the Commonwealth’s solar PV SMART program that allows building owners to receive financial incentives by providing solar production directly to the utility, without requiring the participation of residents as off-takers. The Proponent should commit to setting aside roof space for PV as required by the SC to maximize opportunities for future PV. Electrification of heating and Passivehouse design both contribute to allowing more PV as these approaches can greatly reduce rooftop equipment associated with conventional code HVAC. The Proponent should consult with the MassSave Program to determine an incentive path. I encourage the Proponent to consult with local utilities about rebates or consider other incentives for implementing energy efficiency measures.

Traffic

The project will increase the number of parking spaces by 498, from the existing 408 parking spaces to 906 total. The project will generate 3,464 total average daily trips (adt), a decrease of 610 adt compared to the existing trips generated by on-site uses. The project requires a Massachusetts Department of Transportation (MassDOT) Vehicular Access Permit as it abuts and would be accessed from Route 16, which is a State Highway. As described in the ENF, the project is a transit-oriented redevelopment that creates housing within close proximity to public transportation. The project proposes bike sharing facilities and the construction of dedicated bicycle accommodations around and through the project site, as well as a 10-foot shared-use path on Revere Beach Parkway. The project proposes a parking ratio of approximately 1.1 parking spaces per residential unit, less than is required per zoning. The ENF states the Proponent has agreed to participate in the establishment of the area Transportation

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Management Association (TMA) associated with the CTEDD, which will further increase area accessibility to non-single-passenger vehicle (SPV) options.

Access to the project will be achieved via one proposed curb cut on Revere Beach Parkway, three proposed curb cuts on Boston Street, and two proposed curb cuts on Locust Street. The ENF included a Transportation Impact Assessment (TIA) prepared in conformance with the current MassDOT/EEA Transportation Impact Assessment Guidelines. Project-related impacts were analyzed at eight intersection surrounding the project, plus the three unsignalized project driveways, including four locations on Route 16. According to MassDOT, the Proponent has committed to working with MassDOT to conduct a Road Safety Audit (RSA) at the intersection of Revere Beach Parkway and Everett Avenue (which was included in the MassDOT Highway Safety Improvement Program (HSIP) for crashes occurring between 2015 and 2017) to identify measures to reduce crash potential. Comments from MassDOT state the Proponent should coordinate with MassDOT to determine if an RSA is warranted at the other intersections where the crash rates exceed the State and/or District averages.

As described in the TIA, one movement at three of the eight intersections studied exhibit a decrease in one Level of Service (LOS) under the 2027 Build scenario as compared to 2027 No-Build conditions. Specifically, the project would result in a decreased LOS from: • LOS B to C for AM travel westbound on Boston Street at the Intersection of Boston Street and Vale Street; • LOS A to B for AM travel southbound on Vale Street at the intersection of Carter Street and Vale Street; and • LOS D to E for PM travel eastbound at the intersection of Carter Street at Everett Avenue and Fifth street. The TIA also indicated that, as compared to 2027 No-Build conditions, under the 2027 Build scenario north and southbound movement on Vale Street (at the intersection of Vale Street and Boston Street) would exhibit an increased LOS during weekday evenings (PM travel) - from LOS F to E for travel northbound, and from LOS D to C for travel southbound. Comments from MassDOT state that overall, the project causes little to no impact on traffic operations, though safety issues should be further examined, as discussed above.

Construction Period

According to the ENF the project is anticipated to be constructed in four phases. Phase 1 consists of demolishing the existing grocery building and the construction of Building 1 and associated podium garage. Additionally, the center arrival court will be constructed, as well as associated sidewalks along Vale Street and Locust Street. Phase 2 consists of the construction of Building 2 and the podium garage that connects Building 1 and 2, as well as the continuation of the center arrival court. Phase 3 consists of the construction of Building 3 and associated podium garage followed by Phase 4 and the construction of Building 4. The ENF states that Phase 1 is expected to begin in the Spring or Summer of 2021 and take approximately 24 months, followed by the remaining three phases. According to the ENF, the Project is designed to provide construction period erosion and sedimentation controls as required by the NPDES General Construction Permit. The ENF states this will include a proposed construction entrance, protection for stormwater inlets, temporary sediment basins, protection around temporary material stockpiles, and various other techniques. Additionally, the ENF states a Stormwater Pollution Prevention Plan (SWPPP) will be prepared prior to the start of construction and implemented by the site contractor.

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All construction and demolition activities should be managed in accordance with applicable MassDEP’s regulations regarding Air Pollution Control (310 CMR 7.01, 7.09-7.10), and Solid Waste Facilities (310 CMR 16.00 and 310 CMR 19.00, including the waste ban provision at 310 CMR 19.017). The project should include measures to reduce construction period impacts (e.g., noise, dust, odor, solid waste management) and emissions of air pollutants from equipment, including anti-idling measures in accordance with the Air Quality regulations (310 CMR 7.11). I encourage the Proponent to require that its contractors use construction equipment with engines manufactured to Tier 4 federal emission standards, or select project contractors that have installed retrofit emissions control devices or vehicles that use alternative fuels to reduce emissions of volatile organic compounds (VOCs), carbon monoxide (CO) and particulate matter (PM) from diesel-powered equipment. Off-road vehicles are required to use ultra-low sulfur diesel fuel (ULSD). If oil and/or hazardous materials are found during construction, the Proponent should notify MassDEP in accordance with the Massachusetts Contingency Plan (310 CMR 40.00). The Proponent must perform asbestos surveys of these buildings prior to disturbance of the buildings. If asbestos is found, MassDEP must be notified prior to its handling or removal in accordance with the Asbestos regulations (310 CMR 7.15). All construction activities should be undertaken in compliance with the conditions of all State and local permits. I encourage the Proponent to reuse or recycle construction and demolition (C&D) debris to the maximum extent.

Conclusion

The ENF has adequately described and analyzed the project and its alternatives, and assessed its potential environmental impacts and mitigation measures. Based on review of the ENF and comments received on it, and in consultation with State Agencies, I have determined that an EIR is not required.

October 23, 2020 ______Date Kathleen A. Theoharides

Comments received:

10/13/2020 Massachusetts Department of Environmental Protection (MassDEP), Northeast Regional Office (NERO) 10/13/2020 Massachusetts Water Resources Authority 10/15/2020 Massachusetts Department of Transportation (MassDOT) 10/15/2020 Massachusetts Department of Conservation and Recreation (DCR) 10/21/2020 Massachusetts Department of Energy Resources (DOER)

KAT/ELM/elm

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Charles D. Baker Kathleen A. Theoharides Governor Secretary

Karyn E. Polito Martin Suuberg Lieutenant Governor Commissioner

October 13, 2020

Kathleen A. Theoharides, Secretary RE: Chelsea, Everett Executive Office of 1690 Revere Beach Parkway Energy & Environmental Affairs EEA# 16270 100 Cambridge Street Boston MA, 02114

Attn: MEPA Unit

Dear Secretary Theoharides:

The Massachusetts Department of Environmental Protection Northeast Regional Office (MassDEP-NERO) has reviewed the Environmental Notification Form (ENF) for the proposed 1690 Revere Beach Parkway in Chelsea and Everett. MassDEP provides the following comments.

Wetlands

As described in the ENF, the approximately 6.90-acre project site is located at 1690 Revere Beach Parkway with approximately 5.64 acres in the City of Everett and approximately 1.28 acres in the City of Chelsea. The project site is bounded by Locust Street to the south, Vale Street to the west, Revere Beach Parkway and Boston Street to the north and an existing gas station and garage to the east. The project site is currently developed and is occupied by a Stop and Shop supermarket and associated paved parking areas.

The proposed project entails demolishing all existing infrastructure and constructing 800 units of multi-family residential development with amenities such as a pool area, fitness center and management office, plus 15,000 sf of retail/commercial space. The proposal consists of three buildings ranging in height from 8 to 11 stories in Everett, and a one-story building in Chelsea. Two of the buildings in Everett will have connected ground-level podium parking. Combined with additional surface parking, the proposed project will provide a total of 906 parking spaces.

This information is available in alternate format. Contact Michelle Waters-Ekanem, Director of Diversity/Civil Rights at 617-292-5751. TTY# MassRelay Service 1-800-439-2370 MassDEP Website: www.mass.gov/dep Printed on Recycled Paper

The stormwater controls for the project are proposed to be designed in accordance with both the City of Everett requirements and with MassDEP’s Stormwater Standards. In general, stormwater generated from the project site is proposed to be collected and treated through a combination of Best Management Practices prior to discharge to the existing City of Everett drainage infrastructure.

The ENF states that the wetland resource area on the project site is Land Subject to Coastal Storm Flowage (LSCSF), currently mapped by FEMA over the entire City of Chelsea portion of the site (1.26 acres or 54,825 sf) as an AE Zone (elevation 10 NAVD88) that floods from the tidally influenced portion of the Mystic River. The ENF also states that, although the FEMA map has not been updated for the portion of the site located in Everett to include it within the mapped 100 year flood plain, the project is being designed using best available information and using elevation 10 as the 100 year flood plain elevation for Everett (5.64 acres or 245,811 sf).

In the ENF, the project proponent commits to filing a Notice of Intent (NOI) only for the work in Chelsea. It is MassDEP’s opinion that an NOI should also be filed for the work located in Everett since that part of the site lies within the 100-year floodplain.

The ENF describes the work as consisting of solid fill or buildings constructed at or below the 100-year floodplain (El. 10). The ENF states that the project, including infrastructure, will be designed to accommodate the 100-year flood and sea level rise as much as possible. However, the ENF does not contain any specific information or site plans demonstrating these goals for the project. No plans have been provided showing any specific proposed topography, area(s) for filling, buildings, surface area treatments, parking structure(s), stormwater or flood management, or other infrastructure. There have been no hydrological calculations provided for existing or proposed stormwater management.

It is MassDEP’s opinion that the ENF does not provide an adequate evaluation of the impacts of the proposed project during coastal storm events when the Mystic River floods. Further information will be needed to demonstrate how impacts to other properties, roadways or infrastructure through the redirection, reflection or changes in flood patterns will be avoided during coastal storm events. Additional details about how the stormwater BMPS will function during flooding events will also be required. MassDEP is concerned that, as currently proposed, the project may have adverse impacts on surrounding properties and infrastructure during coastal flood events. The applicant should be prepared to address the issues raised in this comment letter during the permitting process.

Construction, Demolition, Asbestos and Recycling

Solid Waste

MassDEP’s current Massachusetts 2010-2020 Solid Waste Master Plan1 –Pathway to Zero Waste, issued in April 2013 identifies a key goal to reduce solid waste disposal by 30% by 2020,

1 Note the Draft 2020-2030 Solid Waste Master Plan is in review and may be finalized in late 2020.

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from 6,550,000 tons of disposal in 2008 to 4,550,000 tons of disposal by 2020. MassDEP encourages the Proponent to review the plan to identify project management and operations practices that will assist the Commonwealth in meeting its material management goals. More information on the Solid Waste Master Plan and yearly update reports can be found at: https://www.mass.gov/guides/solid-waste-master-plan.

Waste Ban

Section 310 CMR 19.017 Waste Bans of the Massachusetts Solid Waste regulations prohibit the disposal of certain construction-related wastes in Massachusetts, including, but not limited to, metal, wood, asphalt pavement, brick, concrete, clean gypsum wallboard. Further guidance can be found at: https://www.mass.gov/guides/massdep-waste-disposal-bans.

MassDEP regulations also ban disposal of food and other organic wastes from businesses and institutions that dispose of more than one ton of these materials per week. The ban is one of MassDEP’s initiatives for diverting at least 35% of all food waste from disposal statewide by 2020. Diverted food waste may be composted, converted to energy (through anaerobic digestion), recycled, or reused. Additional information on the Commercial Food Material Disposal Ban can be found at: https://www.mass.gov/guides/commercial-food-material-disposal-ban.

C&D Recycling

Many construction and demolition materials are currently banned from disposal or transfer for disposal in Massachusetts (https://www.mass.gov/guides/massdep-waste-disposal-bans). Therefore, MassDEP encourages the Proponent to make a significant commitment to construction and demolition (C&D) waste recycling activities as a sustainable measure for the project and to assist in complying with waste ban requirements. MassDEP considers an asphalt, brick, and concrete (ABC) rubble processing or recycling facility (pursuant to the provisions of Section (2)(b) under 310 CMR 16.03), the Site Assignment regulations for solid waste management facilities), to be exempt from the site assignment requirements, if the ABC rubble at such facilities is separated from other solid waste materials at the point of generation. In accordance with 310 CMR 16.03(2)(b), ABC can be crushed on-site with a 30-day notification to MassDEP. However, the asphalt is limited to weathered bituminous concrete (no roofing asphalt), and the brick and concrete must be uncoated or not impregnated with materials such as roofing epoxy. If the brick and concrete are not clean, the material is defined as C&D waste and requires either a Beneficial Use Determination (BUD) or a Site Assignment and permit before it can be crushed.

Pursuant to the requirements of 310 CMR 7.02 of the Air Pollution Control regulations, if the ABC crushing activities are projected to result in the emission of one ton or more of particulate matter or other pollutant to the ambient air per year, and/or if the crushing equipment employs a diesel oil fired engine with an energy input capacity of three million or more British thermal units per hour for either mechanical or electrical power which will remain on-site for twelve or more months, then a plan application must be submitted to MassDEP for written approval prior to installation and operation of the crushing equipment.

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Asbestos

Pursuant to 310 CMR 7.15 the removal of asbestos from the buildings must adhere to the special safeguards defined in the Air Pollution Control regulations. An asbestos survey to identify all asbestos containing materials (ACM) shall be conducted by a Massachusetts Department of Labor Standards certified Asbestos Inspector. All identified ACM shall be abated prior to demolition activities. The Proponent is required to submit to MassDEP an Asbestos Removal Notification (Form AQ04 (ANF-001)) at least 10 working days prior to initiating work for any project involving asbestos abatement, removal, or disposal. If any ACM will need to be abated through non-traditional abatement methods, the Proponent must apply for and obtain approval from MassDEP, through Application BWP AQ36 - Application for Non-Traditional Asbestos Abatement Work Practice Approval.

Pursuant to 310 CMR 7.09, for any Construction and Demolition, except in a residential building with fewer than 20 units, the Proponent is required to submit to MassDEP a Construction/Demolition Notification (Form BWP AQ06) at least 10 working days prior to initiating work. MassDEP Asbestos, Construction and Demolition Notifications can be found at: https://www.mass.gov/guides/massdep-asbestos-construction-demolition-notifications.

Pursuant to 310 CMR 19.061, disposal of ACWM within the Commonwealth must be at a facility specifically approved by MassDEP. The Proponent is advised that asbestos containing waste materials (ACWM) are a special waste as defined in the Solid Waste Management regulations. There are specific ACWM disposal exceptions for intact vinyl asbestos tile (VAT) and asphaltic-asbestos felt and shingles. The disposal of the ACWM outside the jurisdictional boundaries of the Commonwealth must comply with all the applicable laws and regulations of the state receiving the material. Pursuant to 310 CMR 16.05, ACM including VAT, and/or asphaltic- asbestos felts or shingles may not be disposed of at a facility operating as a recycling facility.

Recycling Infrastructure

MassDEP supports voluntary initiatives to institutionalize source reduction and recycling into operations. Adapting the design, infrastructure, and contractual requirements necessary to incorporate reduction, recycling and recycled products into existing large-scale developments has presented significant challenges to recycling proponents. Integrating those components into developments during the planning and design stage enables the project’s management and occupants to establish and maintain effective waste diversion programs.

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The MassDEP appreciates the opportunity to comment on this proposed project. Please contact [email protected] at (978) 694-3258 for further information on wetland issues. Please contact [email protected] at (978) 694-3262 for further information on Construction, Demolition, Asbestos and Recycling. 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 Eric Worrall, Rachel Freed, John MacAuley, MassDEP-NERO

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COMMONWEALTH OF MASSACHUSETTS EXECUTIVE OFFICE OF ENERGY AND ENVIRONMENTAL AFFAIRS DEPARTMENT OF ENERGY RESOURCES 100 CAMBRIDGE ST., SUITE 1020 BOSTON, MA 02114 Telephone: 617-626-7300 Facsimile: 617-727-0030

Charles D. Baker Kathleen A. Theoharides Governor Secretary

Karyn E. Polito Patrick Woodcock Lt. Governor Commissioner

21 October 2020

Kathleen Theoharides, Secretary Executive Office of Energy & Environmental Affairs 100 Cambridge Street Boston, Massachusetts 02114 Attn: MEPA Unit

RE: 1690 Revere Beach Parkway, Everett and Chelsea, Massachusetts, EEA #16270

Cc: Maggie McCarey, Director of Energy Efficiency, Department of Energy Resource Patrick Woodcock, Commissioner, Department of Energy Resources

Dear Secretary Theoharides:

We’ve reviewed the Environmental Notification Form (ENF) for the proposed project. The project includes construction of over 800 residential units (three mid-rise multifamily buildings having 7, 8, and 11 stories) and one 1-story retail building. The objective of this letter is to share strategies for the project to reduce greenhouse gas emissions (GHG), improve resiliency, and affordability.

Key Strategies

Deployed together, the following have been found to be effective strategies in advancing emission reduction, resilience, and affordability:

• Passivehouse building standards;

• Efficient Electrification of space and water heating;

• Maintaining envelope integrity with framed, insulated walls with continuous insulation;

• Avoiding glass curtain wall assemblies and excessive windows;

1690 Revere Beach Parkway,, EEA #16270 Everett and Chelsea, Massachusetts

• Mitigation of solar heat gains

• Energy recovery;

• Rooftop solar PV;

Experience has shown that the above deliver 50 to 80% less emissions than projects built to Code while improving affordability and resilience. In addition, significant incentives may be available, as well, including MassSave® incentives, Alternative Energy Credits (AECs), and Solar Massachusetts Renewable Target (SMART) credits.

Key Mitigation Strategies Explained

Passivehouse

Passivehouse is an energy efficiency building standard that results in an ultra-low energy building requiring little energy use for space heating and cooling. This is achieved by focusing on envelope performance, airtightness, and energy recovery. Passivehouse projects also typically have much smaller HVAC systems. Published studies show that in low-rise and mid-rise construction, Passivehouse doesn’t necessarily cost more to build because improvements to envelope are offset by reductions in HVAC1 and in high-rise construction, Passivehouse costs nominally more2.

Passivehouse is an energy code standard which is unlike other energy efficient building approaches in that its truly performance based by requiring mandatory, rigorous in-field tests to confirm that strict standards are being met. Passivehouse methods are recognized by both Massachusetts building Code, MassSave®3, and incentives under Massachusetts’ Alternative Portfolio Standard (APS). For qualifying multifamily buildings, MassSave® incentive for Passivehouse is approximately $3,000 per dwelling unit, or $2.4M when applied across the project.

Passivehouse also delivers:

• Significant reduction in utility costs: thus is much more affordable to residents;

• Improved resiliency: Passivehouse buildings can stay warm (or cool, in the summer) for extended periods of time even with loss of power.

At this time there are over 5,000 passivehouse units being designed or under construction in eastern Massachusetts.

Passivehouse projects typically use efficient electric space heating (air source heat pumps/VRF). Efficient electrification is more readily achieved with Passivehouse because HVAC loads are much smaller in Passivehouse applications. (More discussion of efficient electrification is provided below.)

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1690 Revere Beach Parkway,, EEA #16270 Everett and Chelsea, Massachusetts

Passivehouse Examples

Bunker Hill Housing Development Newton Riverside Charlestown, MA Newton, MA

Efficient Electrification

Efficient electrification and renewable thermal space and water heating entails the swapping of fossil fuels (natural gas, oil, and propane) or electric resistance systems with one or more of the following:

• Cold-climate air source heat pumps and variable refrigerant flow (VRF) for space heating; • Air source heat pumps for water heating; • Ground source heat pumps; • Solar thermal.

Electrification of space and water heating is a key mitigation strategy with significant short- and long-term implications on GHG emissions. Massachusetts grid emissions rates continue to decline with the implementation of clean energy policies that increase renewable electricity sources. The implication is that efficient electric space and water heating with cold climate air source heat pump and VRF equipment have lower emissions than other fossil-fuel based heating options, including best-in-class (95% efficient) condensing natural gas equipment. Currently, efficient electric heating has approximately 50% lower emissions in Massachusetts than condensing natural gas

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1690 Revere Beach Parkway,, EEA #16270 Everett and Chelsea, Massachusetts

heating. By 2050, efficient electric heating is expected to have approximately 85% lower emissions in Massachusetts than condensing natural gas heating. See illustration below.

Efficient Electric Space Heating in Mid-rise and High-rise Tower Setting

The project consists of three mid-rise buildings (ranging from 7 to 11 stories). In the past, use of air source electric heat pump/VRF for space heating was typically associated with low-rise construction. These days, mid-rise and even high-rise, projects have successfully used air-source heat pump/VRF. Electric heating equipment manufacturers design manuals now typically describe what to do for towers, showing that electrification of space in towers is not unusual.

Industry experts were able to provide the DOER examples of constructed towers up to 44 floors in height which are fully heated and cooled with air source systems, including examples of projects built over 15 years ago.

Industry experts also provided the DOER design manuals that show a design solution for application of variable- refrigerant-flow (VRF) heat pumps in tall buildings (see insert). The solution is to split the tower into two vertical sections, with the upper portion of the tower served by condensing units on the roof and the lower portion of the Application of air source efficient tower served by condensing units near ground level. (This electric heating to tower splitting may not be necessary for the 7 to 11 story mid-rise building proposed.)

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1690 Revere Beach Parkway,, EEA #16270 Everett and Chelsea, Massachusetts

Another innovative solution for towers is to locate the outdoor equipment on each floor. This works well in Passivehouse setting because the high-performance envelope and small peak loads means that each floor-plate can be served by relatively small outdoor equipment.

This approach is demonstrated by the Cornell Tech Tower project. This tower is entirely heated and cooled with electric VRF systems. Each floor has only two, relatively small (10-ton +/-) exterior condensers. The condensers are The 26-story Cornell Tech Tower is entirely heated and cooled with VRF systems. entirely inconspicuous, hidden Condensers (2 per floor) are entirely hidden behind the louvers shown in the behind louvers shown in arrow above. illustration on the right.

Heat Pump Water Heating

Water heating can be accomplished in many ways, common technologies include fossil fuel boilers and electric resistance systems. There are approaches that utilize air-source heat pumps, as well. These applications include centrally located systems that distribute hot water to the units, or unit- based heat pump water heaters.

DOER recognizes that heat pumps in this application are challenging but encourages the proponent to analyze and review all opportunities for electrification, including heat pump water heaters for the building.

Integrity of Building Envelope

High-performing envelope is essential to successful GHG mitigation, affordability, and resilience. Key strategies for maintaining integrity of envelope are:

• Continuous insulation; • Reducing air infiltration; • Eliminating thermal bridges; • Limiting or eliminating use of glass “curtain wall” and spandrel assemblies; • Maximizing framed, insulated walls sections; • Avoiding excessive window areas.

The thermal performance of windows, curtain walls, and spandrels is typically about 70 to 80% less than the thermal performance of the framed, insulated wall assemblies. Accordingly, buildings which use extensive curtain wall, spandrel, and windows have compromised envelope performance which impacts energy consumption, emissions, resiliency, and affordability.

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1690 Revere Beach Parkway,, EEA #16270 Everett and Chelsea, Massachusetts

Mitigation of Solar Heat Gains

To limit solar heat gains, we encourage examination of building self-shading, external shading, and varying glass solar heat gain coefficient (SHGC) as a function of exposure. (For example, targeting lower SHGC-rated glass for building sides and areas more exposed to sun and/or less shaded.)

Rooftop Solar PV

Rooftop PV can provide significant GHG benefits as well as significant financial benefits. Code requires that at least 50% of the buildings’ roofs be PV ready. Experience has shown that, with planning, up to 80% of roof space can be set aside for PV on roofs of both low-rise and high-rise buildings.

Even if PV is not installed during building construction, it’s important to plan the project to ensure that roof space is set aside for PV and that roof space doesn’t become unnecessarily encroached with HVAC appurtenances, diminishing the opportunities for future PV. Electrification of heating and Passivehouse both contribute to enabling more PV as these approaches can greatly reduce rooftop equipment associated with conventional code HVAC.

Incentives

Buildings which incorporate the above strategies can qualify for significant incentives:

• MassSave® performance-based incentives4 offer incentives for every kWh or therm saved compared to a program-provided energy model. The above energy efficiency strategies offer opportunities for large kWh and therm savings.

• MassSave® Passivehouse incentives are available to multifamily buildings which meet either PHI or PHIUS Passivehouse certification. In addition to a $3,000/unit incentive, MassSave® also incentives feasibility and modeling. The incentive structure is as follows:

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1690 Revere Beach Parkway,, EEA #16270 Everett and Chelsea, Massachusetts

• Alternative Energy Credits (AECs)5 offer incentives to electrify building space heating using heat pumps and/or VRF. This program also includes multipliers which increase value if the building meets Passivehouse standards or buildings built to HERs 50 or less. These credits may be distributed on a quarterly basis over time; or, may be distributed in a lump sum to the developer if certain conditions are met.

• Massachusetts SMART program7 provides significant incentives for solar development on top of federal and state tax incentives. SMART includes pathways which allow solar production to be sold without off-takers. This may be of potential interest to building developers as this allows them to develop rooftop solar without necessarily engaging with building tenants. For this reason, setting aside rooftop solar PV areas helps ensure that building owners’ ability to monetize the roof is not impacted.

Codes and Baseline

Massachusetts’ energy efficiency codes are adopted from Energy Rating Index (ERI), IECC, and ASHRAE codes and contain many amendments, unique to Massachusetts, to further strengthen minimum requirements.

In addition, Massachusetts allows local cities and municipalities to adopt a “stretch code1” which further strengthens code requirements.

The three multifamily buildings would be subject to stretch code provisions because they are all over 100,000-sf each and are in a community (Everett) which has adopted the stretch code. Although the fourth building is located in a community (Chelsea) which has adopted the stretch code, the building is smaller than 100,000-sf and thus is not subject to stretch code provisions.

Below contains a detailed summary of minimum code requirements (and the various “pathways” available). The developer is encouraged to investigate Passivehouse as an alternative to constructing to minimum code standards because Passivehouse could be more cost effective than building to Massachusetts’ minimum code standards once $2.4M in MassSave® incentives are considered.

Beginning in November 2020, minimum Code requirements are as follows:

Buildings 1, 2, and 3 (subject to Stretch Code)

These building shall:

• Achieve 10% reduction on an EUI basis using ASHRAE 2013 Appendix G Performance: o Baseline building shall comply with C401.2.4 (24% fenestration limit for Multifamily) o Baseline building shall include the 3 out of 10 efficiency measures per C406

1 https://www.mass.gov/files/documents/2018/06/08/Appendix%20AA%20Stretch%20Energy%20Code.pdf Page 7 of 10

1690 Revere Beach Parkway,, EEA #16270 Everett and Chelsea, Massachusetts

o Proposed building shall comply with C402.1.5 (envelope), C402.3 (Solar Readiness), C405.3 (interior lighting), C405.4 (exterior lighting), C405.10 (EV ready wiring) o Proposed building shall use the same C406 measured used in the baseline building.

Note, based on our experience, buildings that meet Passivehouse requirements readily meet the above.

Building 4 (not subject to stretch code)

This building shall comply with one of the following:

• ASHRAE 2016 Prescriptive Pathway with Massachusetts Amendments C402.3 (Solar Readiness), C405.3 (interior lighting), C405.4 (exterior lighting), C405.10 (EV ready wiring), C406 (choose 3 out of list of 10 efficiency measures)

Or

• ASHRAE 2016 Appendix G Performance Path with following modifications o Baseline building shall comply with C401.2.4 (fenestration limit) o Proposed building is improved using a Building Performance Factor per ASHRAE 90.1 Section 4.2.1.1 o Proposed building shall comply with C402.1.5 (envelope), C402.3 (Solar Readiness), C405.3 (interior lighting), C405.4 (exterior lighting), C405.10 (EV ready wiring), C406 (choose 3 out of list of 10 efficiency measures)

Or

• IECC 2018 Prescriptive Pathway with Massachusetts Amendments C402.2.4 (slab on grade exception), C402.3 (Solar Readiness), C402.5 (air leakage), C402.6 (CommCheck) C405.2.3 (daylight controls), C405.3.2 (interior lighting), C405.10 (EV ready wiring), C406 (choose 3 out of list of 10 efficiency measures).

Recommendations

The strategies described above provide pathways to GHG mitigation, increased affordability, and improve resiliency. The following are questions that should be considered throughout the planning process:

• Was Passivehouse considered? Early analysis improves the feasibility of Passivehouse. Were the following answered:

o Does the analysis include all benefits (GHG mitigation, affordability, and resiliency)?

o Were the MassSave® performance and Passivehouse incentives incorporated? Page 8 of 10

1690 Revere Beach Parkway,, EEA #16270 Everett and Chelsea, Massachusetts

o Did the buildings that qualify for the MassSave® Passivehouse incentive use the pre-construction feasibility and energy modeling incentives?

o What is the cost difference between the minimum code compliant buildings versus Passivehouse once $2.4M MassSave® incentive is considered?

• Was efficient electrification considered? Air source systems are feasible for most building types and should be considered for all buildings. Were the following answered:

o Does the analysis include all benefits (GHG emissions, affordability, reduced dedicated mechanical space, reduced floor to floor height or more flexible HVAC arrangements)?

o Did the analysis of water heating consider all available technologies, including heat pumps (centrally located, split, and combined systems), solar thermal, and ground source?

o Were all MassSave® and AEC incentives accounted for in the analysis?

• Is the project managing solar gains with exterior shading and improved solar heat gain coefficient?

• Is the project using continuous insulation, reduced air infiltration (with in-field confirmation), and limiting or eliminating use of glass “curtain wall” and spandrel assemblies?

• Did the project set-aside as much space as possible for rooftop PV? It is important to set- aside roof space for PV early to ensure that mechanical equipment spacing is designed to maximize rooftop space. A target of 80% roof set-aside is generally achievable.

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1690 Revere Beach Parkway,, EEA #16270 Everett and Chelsea, Massachusetts

• Furthermore, integration of these recommended measures has compounding and interrelated benefits. For example: the adoption of an above code building envelope and air-sealing measures greatly improve the feasibility and economics of an all-electric space heating system; electrification reduces rooftop equipment; inclusion of solar PV in a project improves the economics of efficient electrification of space and water heating. Accordingly, these solutions should be considered as a package rather than in isolation.

Sincerely,

Paul F. Ormond, P.E. Energy Efficiency Engineer Massachusetts Department of Energy Resources

Brendan Place Clean Energy Engineer Massachusetts Department of Energy Resources

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October 14, 2020

Kathleen Theoharides, Secretary Executive Office of Energy and Environmental Affairs 100 Cambridge Street, Suite 900 Boston, MA 02114-2150

RE: Everett and Chelsea: 1690 Revere Beach Parkway – ENF (EEA #16270)

ATTN: MEPA Unit Eva Murray

Dear Secretary Theoharides:

On behalf of the Massachusetts Department of Transportation, I am submitting comments regarding the Environmental Notification Form for the 1690 Revere Beach Parkway mixed-use project in Everett and Chelsea, as prepared by the Office of Transportation Planning. If you have any questions regarding these comments, please contact J. Lionel Lucien, P.E., Manager of the Public/Private Development Unit, at (857) 368-8862.

Sincerely,

David J. Mohler Executive Director Office of Transportation Planning

DJM/jll

Ten Park Plaza, Suite 4150, Boston, MA 02116 Tel: 857-368-4636, TTY: 857-368-0655 www.mass.gov/massdot

1690 Revere Beach Parkway Page 2 10/14/2020 cc: Jonathan Gulliver, Administrator, Highway Division Patricia Leavenworth, P.E., Chief Engineer, Highway Division Paul Stedman, District 4 Highway Director John McInerney, District 6 Highway Director Neil Boudreau, Assistant Administrator of Traffic and Highway Safety Metropolitan Area Planning Council Massachusetts Bay Transportation Authority Everett Department of Planning & Development Chelsea Housing and Community Development

MEMORANDUM

TO: David Mohler, Executive Director Office of Transportation Planning

FROM: J. Lionel Lucien, P.E, Manager Public/Private Development Unit

DATE: October 14, 2020

RE: 1690 Revere Beach Parkway – ENF (EEA # 16270)

The Public/Private Development Unit (PPDU) has reviewed the Environmental Notification Form (ENF) for the proposed 1690 Revere Beach Parkway project in Everett and Chelsea. The project site consists of approximately 6.9 acres of land bounded by Route 16 (Revere Beach Parkway) and Boston Street to the north, a gas station and a garage followed by Everett Avenue to the east, Locust Street to the south which is currently being upgraded from a private way to a public roadway as part of the adjacent development project, and Vale Street to the west. The site currently contains a 70,912 square foot supermarket and 408 surface parking spaces.

The project consists of the construction of approximately 800 residential units, of which 40 will be affordable, and 15,000 square feet (sf) of ground floor commercial space. All the residential units and most of the commercial space will be located in Everett, spread across three buildings. The part of the project in Chelsea will consist of 5,000 sf of commercial space located in one building. The project will include provisions for 906 parking spaces, located mostly beneath the buildings, with 100 spaces located on surface parking lots. The existing site is accessed via one curb cut on Route 16, one curb cut on Boston Street, and two curb cuts on Vale Street. Access to the proposed project will be provided via one curb cut on Route 16, three curb cuts on Boston Street, and two curb cuts on Locust Street. The Route 16 and Locust Street driveways will connect via an internal roadway that provides access to parking and an on-site drop-off area. The project is expected to generate 4,254 unadjusted daily trips but would cause a decrease in daily trips compared to the current land use. MassDOT notes that the unadjusted trip generation was not included in the ENF, but it was provided separately upon request. The project increase in parking exceeds the Massachusetts Environmental Policy Act (MEPA) ENF transportation threshold and the project requires a Vehicular Access Permit from MassDOT because it abuts and would be accessed from Route 16, which is a State Highway.

Ten Park Plaza, Suite 4150, Boston, MA 02116 Tel: 857-368-4636, TTY: 857-368-0655 www.mass.gov/massdot

1690 Revere Beach Parkway Page 2 10/14/2020

The ENF includes a Transportation Impact Assessment (TIA) prepared in conformance with the current MassDOT/EOEEA Transportation Impact Assessment Guidelines.

Trip Generation

As presented in the TIA included with the ENF, the project is estimated to generate 3,464 vehicle trips on an average weekday, including 234 vehicle trips during the weekday morning peak hour and 267 vehicle trips during the weekday evening peak hour. The trip generation calculation was based on the Institute of Transportation Engineers (ITE) Trip Generation Manual (10th edition) land use codes 221 – Multi-Family Housing (Mid-Rise), 820 – Shopping Center, 932 – High-Turnover Sit-Down Restaurant, and 850 – Supermarket. The above-mentioned trip generation accounts for internalization between the land uses and a 20% non-auto mode share for the residential land use.

As mentioned above, the site currently contains a supermarket. To estimate the net new project trips, driveway counts were collected at the supermarket in 2020 during the peak periods. The daily to peak ratio, based on ITE, was used to estimate the daily supermarket trips, using the counts for the peak periods. MassDOT finds this approach acceptable. Compared to the current use of the site, the proposed project is expected to generate 610 less vehicle trips on an average weekday, including 87 net new vehicle trips during the weekday morning peak hour and 84 less vehicle trips during the weekday evening peak hour.

Trip Distribution

The project trip distribution is based on US Census Journey to Work Data for Chelsea and Everett. The trip distribution for the project trips estimates that two percent of the project traffic will travel to/from the north, seven percent to/from the east, 45 percent to/from the southeast, 20 percent to/from the southwest, and 26 percent to/from the west.

Traffic Operations

Project-related impacts were analyzed at eight intersection surrounding the project, plus the three unsignalized project driveways, including four locations on Route 16. The existing volumes are based on counts conducted in April 2019 as well as data collected for the Fairfield at Chelsea project adjacent to the project site. This data was available at all study locations, except the project driveways. The project driveways were counted in 2020 and although the driveway ins and outs were not adjusted, the through volumes were adjusted up to match the 2019 volumes observed on the Revere Beach Parkway, Boston Street, and Vale Street corridors. Although this methodology is not described in the TIA, MassDOT communicated with the project team to understand this approach.

The future roadway volumes are based on a one percent per year compounded annual growth rate. As presented in the TIA, in the 2027 Build scenario three intersections exhibit a

1690 Revere Beach Parkway Page 2 10/14/2020 decrease in LOS at only one movement at each intersection, compared to the No-Build (2027) conditions. Overall, the project causes little to no impact on traffic operations.

Safety Analysis

The TIA includes a summary of crash rates derived from MassDOT for the continuous five-year period of 2014 through 2018. Three of the eight study area intersections experience crash rates below the District 4 or 6 averages for signalized or unsignalized intersections. These intersections include Route 16 at Everett Avenue, Everett Avenue at Carter Street and 5th Street, and Carter Street at Vale Street. The Route 16 at Everett Avenue intersection was included in the MassDOT Highway Safety Improvement Program (HSIP) for crashes occurring between 2015 and 2017. The Proponent has committed to working with MassDOT to conduct a Road Safety Audit (RSA) at the intersection of Revere Beach Parkway and Everett Avenue to identify measures to reduce crash potential. The Proponent should also coordinate with MassDOT to determine if an RSA is warranted at the other intersections where the crash rates exceed the State and/or District averages.

Site Design Mitigations

The site design will include bicycle and pedestrian facilities and amenities. Along Route 16, the Proponent has committed to working with MassDOT to upgrade the existing sidewalk to provide a 10-foot wide multi-use path for both pedestrian and bicycle traffic. The project will also include a new sidewalk along the Vale Street and Boston Street frontages and a bike lane along the Locust Street frontage from Vale Street to the project driveway, through the project site along the internal roadway, connecting to Route 16. The internal roadway between Route 16 and Locust Street is designed based on a shared street model with bollards rather than curbs defining the vehicle space and chicanes to slow vehicle speeds. The site design includes space for a bikeshare station, bicycle racks, and bicycle storage.

At Route 16 at Vale Street, the TIA notes that during the weekday evening peak hour, the northbound approach experiences longer delays in the No-Build and Build scenarios. The TIA mentions that, if appropriate, the Proponent is committed to implementing signal timing modifications. The Proponent should coordinate with MassDOT to assess the need for making these modifications.

Transportation Demand Management (TDM) Program

The ENF states that the Proponent is committed to implementing a comprehensive TDM program. The Proponent plans to join the City of Everett’s Transportation Management Association in accordance with the City’s TDM Ordinance. The goal of the plan should be to minimize single-occupancy vehicle (SOV) travel and Transportation Network Company (TNC, i.e. Uber and Lyft) trip generation and encourage walking, biking, and riding transit. The TIA includes the following TDM measures:

 On-site amenities such as postal service, retail, and restaurant;

1690 Revere Beach Parkway Page 2 10/14/2020

 Provision of bicycle racks;  Provision of transit information in new tenant welcome packets;  Construction of a Transportation Information Center in the lobby with transit schedules, maps, and locations of bikeshare stations, bicycle parking, and carshare locations; and  Assignment of a Transportation Coordinator.

MassDOT encourages the Proponent to also consider provision of subsidized transit passes and unbundled parking.

The Proponent should continue consultation with the Cities of Everett and Chelsea and appropriate MassDOT units, including PPDU and the District 4 and 6 Offices. MassDOT believes that any issues that may arise can be adequately addressed through the District permit process and recommends that no further environmental review be required based on transportation issues. If you have any questions regarding these comments, please contact me or Catrina Meyer at [email protected].

October 13, 2020

Kathleen A. Theoharides, Secretary Executive Office of Energy and Environmental Affairs 100 Cambridge St, Suite 900 Attn: MEPA Office, Eva Murray Boston, MA 02114

Subject: EOEEA #16270– Environmental Notification Form 1690 Revere Beach Parkway, Everett and Chelsea, MA

Dear Secretary Theoharides,

The Massachusetts Water Resources Authority (MWRA) appreciates the opportunity to comment on the Environmental Notification Form (ENF) submitted by Everett Land Holdings LLC, c/o The Grossman Companies, Inc. (the “Proponent”) for 1690 Revere Beach Parkway (the “Project”) in Everett and Chelsea, Massachusetts. The 6.9 acre Project site is located on the boarder of Everett and Chelsea and currently contains a grocery store and associated paved surface parking areas. The Project involves construction of three new residential buildings in Everett ranging from seven to eleven stories with first floor commercial space as well as a one-story retail building in Chelsea. The Project will also include 906 garaged and surface parking spaces.

Comments on the ENF relate to stormwater, wastewater issues and the need for Infiltration/Inflow (I/I) Removal, Toxic Reduction and Control (TRAC) discharge permitting and MWRA Enabling Statue Section 8(m) permitting.

Stormwater

The ENF reports that stormwater generated on the Project Site will be discharged to existing City of Everett drainage infrastructure. MWRA requests that the Proponent confirm the locations of stormwater discharge to receiving water(s) and that no stormwater generated on the Project Site will enter a sewer system.

Wastewater

The ENF reports that the Project will increase wastewater flow by approximately 104,087 gallons per day (gpd), from an existing wastewater flow of 6,878 gpd to 110,965 gpd. The Project site is served by a sanitary sewer system owned and operated by the City of Everett that conveys the wastewater flows to MWRA’s North Metropolitan Sewer, which conveys flows to MWRA’s Chelsea Creek Headworks and ultimately to the Deer Island Treatment Plant. Due to high infiltration and inflow (“I/I”) volumes entering tributary community systems and because tributary local systems to downstream portions of the MWRA system serve combined sewer areas, wet weather flows can exceed the capacities of the MWRA system and contribute to system surcharging and overflows, including combined sewer overflows (“CSO”) to the Mystic River and Mystic/Chelsea Confluence in large storms.

To ensure that the Project’s large wastewater flow does not increase surcharging and overflows in large storms and does not compromise the environmental benefits of MWRA’s $912 million CSO control program, including water quality benefits for the Mystic River and Mystic/Chelsea Confluence, the Proponent should fully offset the Project’s wastewater flow impacts with infiltration and inflow (“I/I”) removal in compliance with Massachusetts Department of Environmental Protection regulations and associated local I/I policy. In the ENF, the Proponent commits to working with City of Everett officials “to determine the best approach to meet the required 4:1 removal ratio.”

TRAC Discharge Permitting

MWRA prohibits the discharge of groundwater and stormwater into the sanitary sewer system, pursuant to 360 C.M.R. 10.023(1) except in a combined sewer area when permitted by the Authority and the local community. The ENF reports the potential need for a construction dewatering permit from MWRA. However, the Project site has access to a storm drain and is not located in a combined sewer area. Therefore, the discharge of groundwater or stormwater to the sanitary sewer system associated with this Project is prohibited and a construction dewatering permit from MWRA cannot be issued.

Any gas/oil separators in parking garages associated with the Project must comply with 360 C.M.R. 10.016 and State Plumbing Code. Installation of the proposed gas/oil separator(s) may not be back filled until inspected and approved by the MWRA and the Local Plumbing Inspector. For assistance in obtaining an inspection, the Proponent should contact John Feeney, Source Coordinator, in the TRAC Department at 1 (617) 305-5631.

Section 8(m) Permitting Section 8(m) of Chapter 372 of the Acts of 1984, MWRA’s Enabling Legislation, allows the MWRA to issue permits to build, construct, excavate, or cross within or near an easement or other property interest held by the MWRA, with the goal of protecting Authority-owned infrastructure. Due to the proximity of MWRA water infrastructure in the vicinity of the Project, an 8(m) permit will be required. The Proponent should continue to coordinate with Ralph Francesconi in the Water Operations Permitting Group at 1 (617) 305-5827 for assistance in this process.

On behalf of the MWRA, thank you for the opportunity to provide comments on this Project. Please do not hesitate to contact me at 1 (617) 788-4958 with any questions or concerns.

Sincerely,

Bethany Card Director Environmental and Regulatory Affairs

cc: John Viola, MassDEP