MEPA Certificate for the I-90 Allston Interchange Project Environmental Notification Form ABC Summary January 12, 2015, revised February 25, 2015
On October 31, 2014, MassDOT filed a 172-page Environmental Notification Form (ENF) with the Environmental Policy Act (MEPA) Office for the I-90 Allston Interchange Project (Project). The MEPA Office is under the Executive Office of Energy and Environmental Affairs (EOEA), and the ENF is the first of what for large projects is often a three-stage environmental review process. The EOEA completed its review of that ENF and issued a (so-called) Secretary’s MEPA Certificate for the Project on December 24, 2014. The Secretary’s Certificate at 39 pages contains a wide range of findings and determinations, suggestions and requirements for MassDOT to consider as it takes the Project forward in the environmental review and final design process. A Better City has reviewed the Secretary’s Certificate and has prepared the attached Table of Contents and Summary. The Secretary determined that the project requires preparation of an Environmental Impact Report (EIR) because it exceeds the thresholds that trigger this requirement. The Certificate provides a project description, summarizes environmental impacts, describes jurisdiction and permitting requirements, reviews the ENF, outlines the scope required for the EIR, and lists the authors of comments received by the MEPA Office. The most critical part of the Certificate for future actions by MassDOT, the project proponent, is the scope for the EIR. Our summary of the scope follows the outline of the Certificate and is keyed to references in the Certificate that include the exact language of the Secretary’s letter. Two comments submitted by ABC are specifically attributed to ABC: . We commented on the Urban Ring proposed alignment that crosses the project site, and the Certificate states that the DEIR should discuss the design and funding status of the Urban Ring and how the proposed I-90 project can accommodate or not preclude potential implementation of the Urban Ring. . We recommended construction staging strategies, and the Certificate requests that MassDOT evaluate the feasibility of these recommendations. Many other comments submitted by ABC and also other commenters were also included in the EIR scope.
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TABLE OF CONTENTS
TOPIC PAGE 1. MEPA Review…………………………………...... 1 2. Project Benefits…………………………………...... 1 3. Note on Project Funding………………………...... 1 4. Project Description……………………………...... 1 5. Project Site [and Ownership]…………………...... 2 6. Environmental Benefits ………………………...... 2 7. Jurisdiction and Permitting...…………………...... 2 8. No-Build Alternative…………………………...... 3 9. Project Elements Needing Further Evaluation and Analysis...... 3 10. DEIR Scope: A. General...... 3 B: Alternatives Analysis...... 4 C: Land Impacts...... 5 D: Traffic and Transportation...... 6 E: Air Quality [Including Noise and Vibration]...... 8 F: Wetlands, Waterways and Tidelands...... 8 G: Stormwater...... 9 H: Water Supply and Wastewater...... 9 I: Greenhouse Gas Emissions...... 9 J: Climate Change Adaptation and Resiliency...... 9 K: Historic Resources...... 9 L: Hazardous Materials...... 9 M: Construction Period...... 9 N: Mitigation...... 10
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1 MEPA REVIEW This Project requires the preparation of an Environmental Impact Report. MassDOT should submit a Draft EIR (DEIR) in accordance with the Scope set forth in this Secretary’s Certificate. See Page 1, Para. 1.
2 PROJECT BENEFITS This Project offers a tremendous opportunity to address longstanding transportation capacity and safety issues, increase access to transit, expand and enhance parkland and support redevelopment of a large swath of Allston into a transit-oriented mixed-used development. See Page 1, Para. 2.
3 NOTE ON PROJECT FUNDING The current state of transportation funding threatens our ability to maintain safe roads and bridges, and major new projects will be difficult to advance
with available funding. The ability to deliver this Project is likely linked to the ability of MassDOT, the City of Boston, and Harvard University to work cooperatively to identify a fair share of responsibility for construction and
maintenance costs, and to develop public-private partnerships for financing. See Page 1, Para. 3. MassDOT proposes to fund Project by Metropolitan Highway System (MHS) Funds and other non-federal aid funding. See Page 7, Para. 1.
4 PROJECT DESCRIPTION The project has the following components:
a. I-90 Highway Re-alignment Upon removal of the Allston toll plaza (under a separate MassDOT construction project), the highway will be realigned to the south on a new, large radius. Within the interchange itself, the four-lane I-90 in each travel direction will drop a lane for the exit to Allston and then add a lane for traffic entering the highway. See Page 2, Para. 1. Also see Page 8, Para. 2.
b. I-90 Viaduct MassDOT proposes to complete reconstruct 2,500 feet of viaduct to modern interstate design standards, and to increase the viaduct width to accommodate four travel lanes, shoulders, and a breakdown lane in each direction. The viaduct will be completely removed and replaced with a new viaduct in approximately the same location. See Page 2, Para. 2. Also see Page 8, Para. 2. MassDOT proposes that it has concluded that I-90 traffic must be maintained within the viaduct corridor during the construction period and cannot be detoured. See Page 8, Para. 3. MassDOT proposes that because of existing railroad lines under the viaduct and underground utilities, it has dismissed reconstructing I-90 at-grade or in a shallow tunnel due to unacceptable project risk, schedule impact, and implementation challenges. See Page 8, Para. 3.
c. Soldiers Field Road Re- MassDOT proposes cantilevering the new viaduct over Soldiers Field Road alignment (SFR) eastbound, which could facilitate moving a portion of SFR away from the Charles River resulting in the creation of additional parkland along the Charles and Paul Dudley White bike path. See Page 2, Para. 2. Also see Page 8, Para. 2.
d. Allston/ Brighton MassDOT proposes an urban-style interchange reconfigured to meet modern Interchange interstate highway design standards. Three interchange variants will be explored as part of the DEIR. These variants known as Alternative 3J, differ in
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their final design of Cambridge Street and its connections to/from I-90. See Page 2, Para. 3.
e. West Station MassDOT will design and construct a new MBTA commuter rail station along the Framingham/Worcester commuter rail tracks. West Station will also accommodate potential future two-track service along the Grand Junction Railroad branch into Cambridge. MassDOT proposes this station will have local connections to its south for pedestrians and bicycles to Malvern Street and Babcock Street, and to its north a busport with connections to the I-90 interchange via an elevated loop road. See Page 3, Para. 1. Also see Page 8, Para. 2.
f. Commuter Rail Layover MassDOT will construct a commuter rail layover facility, and though included Facility in this Project this facility is intended as part of the South Station Expansion (SSX) Project. The facility will provide storage for up to 20 eight-car train sets and include a pit track, a wheel truing facility, crew quarters, a train car wash, power substation, and crew parking lots. See Page 3, Para. 2. See Page 8, Para. 2.
g. Cambridge Street MassDOT will rebuild Cambridge Street in accordance with MassDOT and City of Boston Complete Streets Guidelines. MassDOT proposes sidewalks on either side of the street separated by a planted buffer from a proposed cycle track, a separate parking lane (with bus stops in spots), and travel and/or turning lanes as needed. See Page 3, Para. 3.
h. Multi-Modal Improvements MassDOT will incorporate bicycle and pedestrian access including: bicycle and pedestrian accommodations on new Cambridge Street, new roadways south of Cambridge Street, and new roadways to West Station. See Page 3, Para. 4. A new bicycle and pedestrian bridge over I-90 will be constructed from the Franklin Street/Lincoln Street area to Cambridge Street. See Page 8, Para. 2.
5 PROJECT SITE [AND The 150-acre project site includes the former Beacon Park Yards. MassDOT OWNERSHIP] states that most of the land within the project area is owned by Harvard University. The existing highway and railway facilities are located within easements. MassDOT states that it and MBTA will need to acquire from Harvard, new easement rights to build certain portions of the Project. See Page 4, Para. 1.
6 ENVIRONMENTAL BENEFITS MassDOT states existing I-90 Interchange ADT (average daily trips) is 147,000, and an estimated 7,000 ADT will be added based on predicted 0.25% annual growth. See Page 5, Para. 6.
7 JURISDICTION AND The Project will require a variety of permits from local, state, and federal PERMITTING agencies and government. Of note, needed permits include: Permit from Department of Conservation and Recreation (DCR) Chapter 91 License from Massachusetts Department of Environmental Protection (MassDEP) Review by Massachusetts Historical Commission Order of Conditions from Boston Conservation Commission
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National Pollution Discharge Elimination System (NPDES) permits from the US Environmental Protection Agency (EPA) Section 4(f) review and NEPA review by Federal Highway Administration/Federal Transit Administration. See Page 6, Para. 2.
8 NO-BUILD ALTERNATIVE The ENF also described a No-Build Alternative, which includes the new Commuter Rail Layover Facility, removal of the existing toll plaza, and the construction of Stadium Way by Harvard University. See Page 11, Para. 1.
9 PROJECT ELEMENTS MassDOT acknowledges conceptual design for the Project is currently only NEEDING FURTHER five (5) percent complete. Advancement of the project will require further EVALUATION AND ANALYSIS evaluation and analysis of numerous project features and potential environmental impacts, including: Shared-use pathway location, width, features, etc.; Replacement of the pedestrian bridge over I-90; Sidewalk and cycle treatment along Cambridge Street and other facilities; Travel/lanes/intersection layout for Cambridge Street; Other roadways, including parallel roadways north and south of Cambridge Street; Location of bicycle/pedestrian bridge over Soldiers Field Road (SFR); Extent of relocation of SFR; Allocation of open space within the area of relocated SFR; West Station (including connections north and south); Rail layover yard configuration and operations; Viaduct configuration; Approach streets to West Station; Incorporation of Central Transportation Planning (CTPS) regional traffic study; Noise, vibration, and air quality analysis; Providing a design that could support and does not preclude a two-track Grand Junction Railroad crossing; Stormwater treatment and Best Management Practices (BMPs); State Highway “No Access” limits on connecting roadways; and Construction staging concepts. See Page 11, Para. 3.
10 DEIR SCOPE: As MassDOT prepares its required Draft Environmental Impact Report (DEIR), it should follow and implement a wide variety of design concepts, A. GENERAL studies, and procedures. Highlights of what the DEIR should incorporate include:
1) Land Ownership and Graphics that clearly delineate and describe either existing land ownership or Rights acquisitions, easements, and associated rights required for project construction and final design. See Page 13, Para. 1.
2) Article 97 Parklands Plans at a reasonable scale to discern limits of roadway rights-of-way and adjacent Article 97 and/or parkland/open space, particularly in the area within
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and adjacent to SFR between the BU Bridge and the Cambridge Street/River Street intersection. See Page 13, Para. 1.
3) No-Build Clarification Clarification of whether the No-Build Alternative would include the Commuter Rail Layover Facility, something Harvard University (the landowner) apparently disputes at this time. See Page 13, Para. 1.
4) EJ Impacts Although this Project is not subject to the EOEA Environmental Justice (EJ) Policy, MassDOT has committed to evaluate the Project for potential impacts to EJ Communities and the effects, positive and negative, should be evaluated. See Page 13, Para. 4.
5) Consistency with Local and EOEA “strongly encourage[s]” Harvard University and the BRA to work Regional Planning cooperatively with MassDOT on land use assumptions. EOEA appears to suggest MassDOT “commence…” a visioning process concurrent with the development of those land use assumptions to support advancement of the project and subsequent further MEPA review. See Page 14, Para. 1.
6) Task Force Continuation MassDOT should include a proposed format and protocols for future input by a Task Force as additional components of the Project are analyzed and enter preliminary design, either as part of the MEPA review process or upon commencement of further design and construction efforts. See Page 14, Para. 2.
B. ALTERNATIVES ANALYSIS For purposes of comparison, the DEIR should:
1) I-90 Interchange and Discuss potential design refinements to the preferred interchange configuration Cambridge Street known as Alternative 3J, including: Making the East Drive Connector at-grade and elevating Stadium Way Connector Explore ways to limit roadway elevation changes to maximize accessibility to West Station and potential north-south connections across the site between the BU area and Cambridge Street and the Charles River Option 3J-1: Two-Way Cambridge Street Option 3J-2: One-Way Parallel Option 3J-3: Two-Way Parallel Street See Page 15, Para. 2.
2) I-90 Viaduct: location of The project includes opportunities to expand open space and bicycle and realigned SFR pedestrian access and accommodations to the Charles River and beyond. The DEIR should include an alternatives analysis that explores the feasibility of cantilevering the I-90 viaduct over realigned Soldiers Field Road (SFR), and include, at a minimum: A configuration that extends over a portion of a relocated SFR; and A configuration wherein SFR is relocated in its entirety under a new I-90 viaduct. See Page 15, Para. 4.
3) I-90 Viaduct: at-grade in Identify in more detail why removal of the viaduct and reconstruction of I-90
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final design at-grade was dismissed as a viable alternative. See Page 15, Para. 4.
4) I-90 Viaduct: cross-section Discuss and include: Proposed viaduct cross-section widths, including consistency with standards; Design implications of seeking design exceptions; An alternative based on reconstruction within the current cross-section, noting the potential benefits and potential designs exceptions for shoulders, land width, etc., and describe the types and locations of other MassDOT projects with design exceptions and their overall performance with regard to operations and safety. See Page 15, Para. 5.
5) Open Space EOEA noted the conceptual designs created as part of the Boston Society of Architect’s charrette relative to the opportunities for the Project to significantly expand and enhance parkland along the Charles River, facilitated by a relocated SFR. MassDOT’s DEIR should: Seek to maximize publicly accessible open space to the extent practicable between the BU Bridge and River Street Bridge. Consider whether shifting SFR to expand open spaces might result in improved traffic operations and provide opportunities to reduce the SFR cross-section at other intersections near the Charles River. See Page 16, Para. 1.
6) Bicycle and Pedestrian Bicycle and pedestrian connections within and through the project area are Accommodations critical to advancing MassDOT’s mode share goals for the Commonwealth. The DEIR should describe route width, separation of bicycles and pedestrians (if any), elevations and slopes, and need for bridges or tunnels to reduce conflicts with vehicles or train operations as they relate to the following routes: Crossing SFR to the Paul Dudley White Bike Path (including connections to potential bicycle/pedestrian access across the Grand Junction Railroad); Connections north to south across the site (Commonwealth Avenue area to North Allston and SFR); and A dedicated corridor from west to east (the “People’s Pike”). EOEA notes the desire to connect North Allston neighborhoods (near the Lincoln Street/Cambridge Street intersection) to SFR, and the DEIR should seek to design the path in a manner that prioritizes bicycle and pedestrian modes of travel (e.g., separate bicycle signals, etc.) for all user types and limit conflicts with vehicles (particularly at intersection). Identify opportunities to expand the width of the Paul Dudley White Bike Path within the project area based upon the configuration of the relocated SFR and I-90 viaduct placement;
See Page 16, Para. 2 & 3. Also see Page 17, Para. 1 & 2.
C. LAND IMPACTS A key opportunity associated with the project is to improve access to underdeveloped land within the vicinity of the interchange, however MassDOT has no control over the development decisions on the land
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principally owned by Harvard University. Therefore, EOEA states: See Page 17, Para. 4.
1) Land Use Assumptions It is imperative that MassDOT, Harvard University, the City of Boston, and relevant stakeholders work together in advance of preparation of the DEIR to establish future land use development assumptions. These assumptions will be critical to inform 2035 future build traffic analysis, air quality analysis, and ongoing Commonwealth efforts to meet travel mode shift goals and GHG emissions mitigation. These design assumptions should be clearly stated in the DEIR, take note of the City of Boston comment letter, and include: Density (floor-to-area “FAR” ratios) Heights Block sizes Open Space Parking ratios
See Page 18, Para. 1.
2) Decking Discuss opportunities to deck over the Commuter Rail Layover Facility and West Station to facilitate future air rights development by Harvard University, including: How the Project may be constructed to accommodate support structures and decking in the future; Benefits and challenges of constructing decking concurrent with, or after completion of, the Project; Development cost implications (present and future); Opportunities for public/private partnerships; Potential constraints on MassDOT rail operations. See Page 18, Para. 2.
3) Article 97 Land Project components may result in direct impacts to land held in accordance with Article 97 of the Amendments to the Constitution of the Commonwealth. The DEIR should identify: Extent and boundaries of Article 97 land and easements; Potential amount and location of parkland impact; How project seeks to minimize impacts to these designated open spaces. Compliance with EOEA’s Article 97 Land Disposition Policy.
See Page 19, Para. 1.
D. TRAFFIC AND The DEIR should include a Traffic Impact and Access Study (TIAS) prepared TRANSPORTATION in accordance with EOEA/MassDOT Guidelines, and examine existing and future 2020 and 2035 No Build and Build alternative transportation conditions. The DEIR should also analyze: See Page 19, Para. 3.
1) Transit Operations Impacts on ridership (positive and negative) to connecting subway and bus
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routes, most notably the Green Line’s B Branch. See Page 19, Para. 5.
2) Stadium Way and East Drive The ENF indicated that Stadium Way and East Drive will be constructed by Harvard University. The DEIR should include a comparative analysis of study area traffic operations (vehicle, bicycle, pedestrian) if these two roads are not completed prior to the I-90 project opening date of 2020. See Page 20, Para. 3.
3) Vehicle Connection from The DEIR should analyze the feasibility of such a connection including the West Station to potential impacts and benefits, including environmental impacts, traffic Commonwealth Avenue distribution and LOS, transit connection improvements, grading and elevation challenges, land takings to accommodate roadways or bridge abutments to span the commuter rail tracks, and impacts to railroad operations. See Page 20, Para. 5.
4) I-90 Viaduct and Interchange The DEIR should identify any potential changes to LOS, queuing or safety along the I-90 viaduct between a cross-section that meets standards and studied alternatives that implement design exceptions (i.e., limited shoulders, etc.) See Page 20, Para. 6.
5) West Station More detailed plans for West Station should be provided in the DEIR and should:
Discuss how the proposed station design is consistent with Harvard University’s desire to optimize the potential for future air rights development that is both technically feasible and economically viable. See Page 21, Para. 3.
Include an analysis of current bus routes and how they may be altered to provide direct connections to other bus routes or commute rail service at West Station. See Page 21, Para. 4.
Evaluate how the West Station design and access loop will provide adequate capacity for future transit and shuttle vehicles based upon future ridership estimates for the facility. See Page 21, Para. 4.
Include a feasibility analysis of a two-way bus/shuttle loop and/or use of bus priority lanes or signalization. See Page 21, Para. 4.
Identify location of “kiss-and-ride” accommodations. If a vehicular drop- off/pick-up location is not located on the south side of West Station (near Ashford/Malvern/Babcock Streets), the DEIR should discuss how a lack of such an area in this location may impact ridership and traffic patterns and
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congestion within the neighborhood. See Page 21, Para. 5.
As no commuter parking is proposed at West Station, the DEIR should describe existing or potential parking control measures that may be implemented to mitigate commuter parking on neighborhood streets. See Page 21, Para. 5.
6) Future Rail and Transit The DEIR should discuss how West Station and proposed Commuter Rail Service Layover Facility will be designed to: Preserve alternatives for future projects (such as potential DMU service to Kendall Station) and anticipated future Amtrak service in 2035; Support potential bicycle and pedestrian connections using Grand Junction Railroad bridge; Accommodate existing freight service. See Page 22, Para. 2.
7) Urban Bus Rapid Transit EOEA took note of comments from ABC identifying proposed alignment for Route 6 the Urban Ring Bus Rapid Transit (BRT) route 6 crossing the site. The DEIR should discuss the design and funding status of the Urban Ring project and how the proposed I-90 Project can accommodate, or at a minimum, not preclude potential implementation. See Page 22, Para. 3.
8) Grand Junction Railroad The DEIR should describe existing rail operations, ownership, and legal rights related to sidings and the Grand Junction Railroad, and discuss the feasibility of alternative locations or changes in elevation of the Grand Junction tracks to facilitate project construction and operations. See Page 22, Para. 4.
9) Houghton Chemical The DEIR should describe the current condition, ownership, and use of the rail Company connection to Houghton Chemical Company, and indicate whether this connection will be retained in place, relocated, or abandoned. It should also discuss the legal and permitting ramifications of relocating or abandoning this rail connection, if necessary, on continuing Houghton operations. See Page 22, Para. 5.
10) Bicycle and Pedestrian The DEIR should explore additional route and cross-section alternatives of Accommodations bicycle and pedestrian facilities within the Project study area. See Page 23, Para. 1.
E. AIR QUALITY [INCLUDING EOEA strongly encourages the DEIR’s noise and vibration impact analyses NOISE AND VIBRATION] include study receptors in the Cambridgeport neighborhood, even if such locations are not required by other procedures or protocols. See Page 23, Para. 2.
F. WETLANDS, WATERWAYS Project-related stormwater infrastructure (most notably discharge outfalls) and
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AND TIDELANDS the bicycle/pedestrian bridge connection to the Paul Dudley White Bike Path are potential sources of wetland resource area impacts. The DEIR should discuss how the project complies with the Public Benefits Determination criteria established for non-water dependent projects located within tidelands or landlocked tidelands. See Page 25, Para. 2.
G. STORMWATER EOEA notes that compliance with Boston’s Complete Streets Initiative suggests MassDOT must incorporate green infrastructure into street design (e.g., landscape plantings, rain gardens and vegetative swales, infiltration basins, and paving materials and permeable surfaces). The DEIR should explore opportunities for stormwater management within the proposed multi- use path that extends from west to east across the site. See Page 27, Para. 1.
H. WATER SUPPLY AND The DEIR should: provide an estimate of wastewater generation and water WASTEWATER usage by use and location, confirm availability of sufficient water and sewer conveyance capacity for each project alternative, identify easements associated with existing infrastructure and note if relocation will be necessary, coordinate with MWRA and BWSC, clarify if the project includes construction of new water mains and wastewater infrastructure in Cambridge Street and the proposed urban street grid, clarify the use and category of water used in the rail layover facility, and indicate whether the project will be required to offset new flows by assisting in removal of inflow and infiltration in the sewer system. MassDOT’s plans should include provisions for a variety of drought-tolerant, native species to limit or eliminate demand for irrigation. See Page 27, Para. 4. Also see Page 28, Para. 1.
I. GREENHOUSE GAS The DEIR should specifically address how the project advances MassDOT’s EMISSIONS targeted 7.6 % decrease in transportation sector GHG emissions by 2020, and should consider expanding that analysis to assess consistency with MassDEP’s additional goal of 12.3 % GHG reductions by 2050. See Page 30, Para. 1.
J. CLIMATE CHANGE The DEIR should provide an analysis and discussion of potential impacts to ADAPTATION AND the project site associated with predicted sea level rise, increased frequency RESILIENCY and intensity of precipitation events and extreme heat events. Modifications to SFR, I-90 viaduct and interchange, roadway grid, adjacent parklands, and stormwater management infrastructure (including outfalls to Charles River) should be implemented in a manner to promote climate change resiliency and adaptation. See Page 30, Para. 3. Also see Page 31, Para. 2.
K. HISTORIC RESOURCES The DEIR should: Address conflicting information provided by the Massachusetts Historic Commission (MHC) and the Department of Conservation and Recreation (DCR) regarding the contributory status of SFR to the Charles River Parkway District.
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Discuss the impacts and benefits to historic resources associated with the
realignment of SFR and pedestrian and bicycle bridge to the Paul Dudley White Bike Path. Include results of consultations conducted with MHC with regard to Section 106 of the National Historic Preservation Act of 1966. EOEA notes impacts associated with the project may be unavoidable, and encourages MassDOT to work with MHC and interested parties to develop appropriate mitigation measures to minimize or mitigate impacts to historic resources. The DEIR should include possible mitigation measures to be considered as part of the State Register and Section 106 Review processes, which may include drafting a Memorandum of Agreement (MOA) between affected parties. See Page 31, Para. 3. Also see Page 32, Para. 1.
L. HAZARDOUS MATERIALS The DEIR should: characterize, describe the location, review status, and responsible party for the two identified Massachusetts Contingency Plan sites in the project area; clarify the responsible parties for remedying known oil and hazardous materials spills, identifying remediation schedules, and describe anticipated coordination efforts between MassDOT and the responsible parties. See Page 32, Para. 3 and 4
M. CONSTRUCTION PERIOD MassDOT proposes to provide travel lane and rail track availability during construction as follows: I-90. Three (3) lanes in each travel direction on I-90 during daytime peak travel periods for the duration of construction. Two (2) lanes in each direction will be provided at night. SFR. Two (2) lanes in each travel direction during daytime peak travel periods. It appears the ENF made no commitment as to lane availability at night. Rail. One (1) mainline commuter rail track, the Grand Junction Railroad line, and the Houghton Chemical Company rail spur will remain in operation, presumably 24/7. See Page 32, Para. 4.
1) Phasing Plans and Traffic The DEIR should include conceptual construction phasing plans for each Analysis project element, noting times of concurrent activity and estimated length of each construction phase. The DEIR should provide additional justification for the phasing [and lane] assumptions in the ENF and identify the duration of any lane closures and need to implement off-peak detours of SFR. See Page 33, Para. 1.
2) Traffic Mitigation Plans Lane and other closures can be expected to result in reduced roadway and intersection LOS throughout the construction period. Given the critical nature of the Masspike and the I-90 interchange within the local and regional traffic system, the DEIR should address potential operational impacts of extended lane closures and identify measures to mitigate their impact. See Page 33, Para. 1.
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3) ABC Construction Staging EOEA took note of construction staging recommendations provided in the Alternatives comment letter from A Better City (ABC) and requested that MassDOT evaluate the feasibility of these recommendations as part of the DEIR. See Page 33, Para. 1.
N. MITIGATION The DEIR should include a separate chapter summarizing proposed mitigation measures. It should contain clear commitments to implement mitigation measures, estimate the individual costs of each proposed measure, identify the parties responsible for implementation, and contain a schedule for implementation. See Page 34, Para. 2.
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