The Commonwealth of Massachusetts Executive Office of Energy and Environmental Affairs 100 Cambridge Street, Suite 900 Boston, MA 02114 Charles D

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

June 19, 2020

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

PROJECT NAME : 780 Morrissey Boulevard PROJECT MUNICIPALITY : Boston PROJECT WATERSHED : Boston Harbor EEA NUMBER : 16205 PROJECT PROPONENT : Dorchester-Michaels LLC c/o The Michaels Organization DATE NOTICED IN MONITOR : May 20, 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 consists of the construction of a six-story, 163,885 square foot (sf), 206-unit residential development with 123 structured parking spaces and 13 surface parking spaces (136 total). The structured parking will be accessed from Freeport Street. Loading, delivery, trash and recycling pick-up will take place within the exterior parking area at the north end of the site. As described in the ENF, the exterior space is designed to accommodate a future connection to the proposed Neponset River Greenway multi-use path extension from Freeport Street, with connections to Dorchester Shores Reservation, Tenean Beach, and the waterfront. The project includes raising/filling portions of the site approximately 5 ft which will require the construction of a retaining wall along the structured parking area.

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Project Site

The 1.81-acre project site consists of a 196-space surface parking lot currently used to store cars from a nearby car dealership and a vacant two-story, 10,230 sf restaurant. The project site is bounded by Freeport Street and Morrissey Boulevard to the west, a surface parking lot to the north, Interstate 93 (I- 93) to the east, and a hotel (Ramada Inn) to the south. The site consists primarily of impervious surface. Existing elevations vary from an elevation of approximately 12 feet Boston City Base (BCB) (5.54 NAVD88) in the northwest corner of the existing parking lot to approximately 21 feet BCB (14.54 NAVD88) in the southwest corner of the site in front of the existing restaurant. There are no known wetland resources located on or immediately adjacent to the project site. According the most recent Flood Insurance Rate Map (FIRM) prepared by the Federal Emergency Management Agency (FEMA), the proposed limit of work of the project is not located within a mapped 100-year flood plain.

Approximately half of the project site includes filled tidelands of the Neponset River. However, only a small portion of those filled tidelands (4,193-square feet) is subject to the licensing requirements of c. 91 and the Waterways Regulations at 310 CMR 9.00, because they are located within 250-feet of the existing mean high-water mark or first public way. The remaining 0.71 acres are landlocked tidelands subject to the Public Benefits Determination requirements of An Act Relative to Licensing Requirements for Certain Tidelands (Chapter 168 of the Act of 2007).

The underlying zoning for the Project is Morrissey Boulevard Community Commercial Subdistrict within the Dorchester Neighborhood District. The project site is located in a Greenbelt Protection Overlay District (GPOD) resulting from Morrissey Boulevard’s status as a greenbelt corridor. Allowed uses include commercial uses such as retail/service and office.

Environmental Impacts and Mitigation

The project will result in the alteration of 1.81 acres of land. It is anticipated to generate 1,122 new average daily trips (adt), increase water demand by 27,600 gallons per day (gpd) and increase wastewater generation by 25,100 gpd.

Measures to avoid, minimize and mitigate environmental impacts include installation of a stormwater management system, increasing pervious area on the site by approximately 0.26 acres and incorporation of energy efficiency measures which will reduce greenhouse gas (GHG) emissions. Traffic Demand Management (TMD) measures will be implemented to reduce single occupancy vehicle (SOV) trips and associated transportation emissions.

Jurisdiction and Permitting

This project is subject to MEPA review and preparation of an ENF pursuant to 301 CMR 11.03(3)(b)(5) because it requires a State Agency Action and involves a new or existing unlicensed nonwater dependent use of waterways or tidelands. The project requires a Chapter 91 (c. 91) License from the Massachusetts Department of Environmental Protection (MassDEP), a Construction and Access Permit from DCR and an Access Permit from MassDOT.

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The project will require a National Pollution Discharge and Elimination System (NPDES) Construction General Permit (CGP) from the U.S. Environmental Protection Agency (EPA). The project is subject to Large Project Review in accordance with Article 80B of the Boston Zoning Code. The Project will also be required to comply with the Boston Planning and Development Agency (BPDA)’s Climate Resiliency Review process and Article 37 (Green Building) of the Zoning Code. The project will also require zoning relief under existing zoning regulations.

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.

Review of the ENF

The ENF provided a description of existing and proposed conditions, preliminary project plans, and an alternative analysis, and identified measures to avoid, minimize and mitigate environmental impacts. As discussed at the remote meeting held on May 28, 2020 and included in supplemental information distributed on May 29, 2020 (hereby referred to as the ENF), the project design is accounting for future sea level rise (SLR) by regrading portions of the project site above future flood plain projections and elevating the first floor residences consistent with BPDA’s design flood elevation recommendations. Comment letters from State Agencies did not identify any major concerns and provided guidance for addressing outstanding issues during the permitting process. I did receive a comment letter from a resident who expressed concerns with development within a future flood plain.

Alternatives Analysis

The ENF included an alternatives analysis which considered a No-Build Alternative, an As-of- Right Building Alternative (Alternative A), an 11-Story Multifamily Residential Building Alternative (Alternative B), and the Preferred Alternative, as described above. The No-Build Alternative would leave the site in its underutilized state. This alternative was dismissed because although it would not increase water demand, wastewater generation, GHG emissions and traffic trips, proposed stormwater management measures and pedestrian improvements would not be implemented, and the site would continue to be underutilized not meet the project goals of developing housing. Alternative A would involve the construction of an as-of-right building which would involve the construction of a two-story, 90,000 sf office building which would conform to existing zoning. This alternative would generate approximately 958 new adt and would increase water demand between 7,000-7,700 gpd. This alternative was dismissed because it would not meet the project goals of developing a residential use. Alternative B considered the development of an 11-story residential building with 268 units within 8 floors of residential use and 3 floors of parking. This alternative would consist of an approximately 316,000 sf development with 272 parking spaces. This alternative would increase water demand by 38,962 gpd and generate 35,420 gpd of wastewater and would generate 1,193 new adt. As described in the ENF, due to the expanded building footprint, there would not be room on the site to include the proposed link to the Neponset River Greenway, and the frontage along Freeport Street would not include any pedestrian amenities. Due to the increase in height, the resulting project would also have increased shadow impacts and would generally be out of scale with surrounding buildings. For these reasons, this alternative was dismissed. The Preferred Alternative was chosen by the Proponent because it adds to the

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housing supply within the neighborhood, reduces impacts as compared to the larger development contemplated in Alternative B, adds valuable pedestrian improvements and provides a connection to the Neponset Greenway.

Filled Tidelands

As described in MassDEP’s comment letter, roughly half of the 74,684-square foot project site includes filled tidelands of the Neponset River. However, only a small portion of those filled tidelands (4,193-square feet) are subject to the licensing requirements of M.G.L. Chapter 91 and the Waterways Regulations at 310 CMR 9.00, because it is located within 250-feet of the existing mean high water mark or public way. The remaining 0.71 acres of filled tidelands onsite are located greater than 250 feet from flowed tidelands, are separated from said tidelands by one or more interconnected public ways and therefore considered Landlocked Tidelands (as defined in M.G.L. Chapter 91, section 18 and 310 CMR 9.02). The Landlocked Tidelands are not subject to licensing but are subject to the provisions of An Act Relative to Licensing Requirements for Certain Tidelands (2007 Mass. Acts ch. 168) and the Public Benefit Determination regulations (301 CMR 13.00). The work proposed in non-landlocked filled tidelands which is subject to licensing includes the demolition and removal of existing pavement, excavation, placement of up to 5-feet of fill to elevate the existing grade, installation of a retaining wall, creation of 31 surface parking spaces, and a small landscaped area. MassDEP will review the project for its consistency with the Waterways Regulations 310 CMR 9.00. As noted in MassDEP’s comment letter, although the ENF indicates that the project is not subject to the building height provisions outlined at 310 CMR 9.51(3)(e), MassDEP notes that approximately 7-square feet of the building’s upper floor balconies are proposed to overhang filled private tidelands subject to licensing. As indicated in MassDEP’s comment letter, these portions of the building must comply with all applicable Waterways Regulations, including but not limited to the building height provisions at 310 CMR 9.51(3)(e).

The waterways regulations require that any nonwater-dependent use project located on tidelands “devote a reasonable portion of such lands to water -dependent use, including public access in the exercise of public rights in such lands.” In accordance with 310 CMR 9.52(2), projects that do not include a water-dependent use zone, shall provide “connecting public walkways or other public pedestrian facilities…” as necessary to ensure that the site is not poorly linked with those sites containing water-dependent use zones. The Project intends to meet this standard through direct access from Freeport Street, across the Project Site, to the planned Neponset River Greenway multi-use path.

As noted above, the project site is comprised of private filled landlocked tidelands and subject to the provisions of An Act Relative to Licensing Requirements for Certain Tidelands (2007 Mass. Acts ch. 168) and the Public Benefit Determination regulations (301 CMR 13.00). The Act provides me with the discretion to issue a Public Benefit Determination for projects that do not require an Environmental Impact Report (EIR). The project will redevelop an underutilized site into a residential development which will provided housing for the City of Boston. The project will result in a net increase of pervious area, improve pedestrian connections to and through the site, and will accommodate a future connection to the proposed DCR/MassDOT Neponset River Greenway multi-use path extension from Freeport Street, with connections to Dorchester Shores Reservation, Tenean Beach, and the waterfront. Based on the information contained in the ENF and pursuant to 301 CMR 13.02(2), I am declining to conduct an additional Public Benefit Review for the project.

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Water, Wastewater and Stormwater

As noted above, the project will increase water demand by 27,600 gpd and increase wastewater generation by 25,100 gpd. The project site will be serviced by the Boston Water and Sewer Commission (BWSC). The project site is served by BWSC separate storm drains and sanitary sewers. Sanitary flows from the project site are conveyed to a 12-inch BWSC sanitary sewer located in Morrissey Boulevard, west of the project site. Flows eventually enter BWSC’s Dorchester Interceptor at the intersection of Conley Street and Morrissey Boulevard. The Dorchester Interceptor conveys sanitary and combined sewer flows from large areas of Dorchester to Massachusetts Water Resources Authority (MWRA)’s Columbus Park Headworks for transport to the Deer Island Treatment Plant. In large storms high infiltration (groundwater) and inflow (stormwater) entering the BWSC system, along with combined sanitary and stormwater flows, can exceed the capacities of the BWSC and MWRA systems. This can contribute to system flooding in Dorchester and CSO overflows to the Fort Point Channel as well as MWRA’s South Boston CSO Storage Tunnel, which protects the South Boston beaches.

Stormwater runoff generated as a result of the project is designed to be collected and treated through a combination of Best Management Practices prior to discharge to the existing BWSC stormwater drainage infrastructure. The project will also result in an overall decrease in impervious area through the introduction of landscape and open space elements. The additional proposed pervious surface will reduce stormwater runoff and promote infiltration onsite. Stormwater runoff will be collected and treated, as necessary, on-site, and will be routed to infiltration systems sized per BWSC requirements. It is anticipated that underground infiltration systems and proprietary sediment removal structures will be utilized on-site, and pervious pavers will be utilized in the furnishing zone of the City of Boston Right-of-Way. The final design of the stormwater system will be consistent with MassDEP’ stormwater standards and will be subject to BWSC review and approval.

Traffic and Transportation

The project does not exceed transportation thresholds outlined in the MEPA Regulations (301 CMR 11.03(6)). The project requires a Construction and Access Permit from the DCR because the site will be accessed via Morrissey Boulevard which is under DCR’s jurisdiction. The project also requires a vehicular access permit from MassDOT because it abuts I-93. The existing site access, which intersects the west side of Freeport Street at its intersection with Morrissey Boulevard, will be closed and a new driveway will be provided onto Freeport Street approximately 250 feet north of the Morrissey Boulevard/Freeport Street intersection. The ENF includes a Transportation Impact Assessment (TIA) that generally conforms to MassDOT’s Transportation Impact Assessment (TIA) Guidelines.

The TIA includes the following intersections in the study area:

• Freeport Street at Victory Road (unsignalized)

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• Morrissey Boulevard at Victory Road (unsignalized) • Morrissey Boulevard at Freeport Street (unsignalized) • Morrissey Boulevard at Freeport Street/Tenean Street (unsignalized) • Freeport Street at the Project Site Driveway (unsignalized)

Trip Generation

Vehicle trip generation provided in the TIA is estimated using the Institute of Transportation Engineers (ITE) Trip Generation Manual (10th Edition). The project entails constructing 206 residential units and a restaurant. Land Use Code (LUC) 221: Multifamily Housing (Mid-rise) is used to approximate trip generation. Accordingly, the unadjusted trip generation totals 1,122 average weekday daily trips. Of these trips, 69 would occur in the morning peak hour, and 89 trips would take place in the evening peak hour.

The ENF indicates a mode split between vehicles, walking and bicycling, and transit as a result of planned on-site shuttle service to nearby MBTA stations and planned pedestrian and bicycle infrastructure improvements around the site. National Household Travel Survey data and travel mode data from the Boston Transportation Department were used to develop the splits. Based on this, it was determined that 5% of weekday daily trips would occur by transit, while 19% would occur by walking or bicycling.

When adjusting for mode split, the project is expected to generate 854 average weekday daily vehicle trips, with 49 trips in the morning peak hour and 64 trips in the evening peak hour. During the morning peak hour, 9 person trips will occur by transit and 14 will take place by walking or bicycling. In the evening peak hour, 11 trips will use transit and 18 will take place by walking or bicycling.

Operational Analysis

The TIA includes capacity and operational analyses for 2019 Existing, 2026 No-Build, and 2026 Build conditions for the study area intersections. A background growth rate of 0.5% was used. In addition to background growth and project-related trip generation, the Proponent incorporated anticipated traffic from three nearby projects in the development of future traffic conditions. The TIA also includes a queue length analysis and associated tables/graphs.

In 2019 Existing conditions, all of the turning movements at study area intersections operate at LOS C or better. There is no change in LOS between 2019 Existing conditions and 2026 No-Build conditions. Under 2026 Build conditions, most turning movements at the study area intersections continue to operate at the same LOS, though some with slightly increased delay. The only exception to this is the Morrissey Boulevard at Freeport Street and Tenean Street intersection, where morning peak hour LOS for the Freeport Street westbound right-turn drops from LOS C in 2026 No-Build conditions to LOS D in 2026 Build conditions. Comments from MassDOT indicate that based on this analysis, the MassDOT roadway system will be able to accommodate the project’s traffic generation. I encourage the Proponent to work with DCR to identify other measures that may be needed to mitigate traffic on Morrissey Boulevard, which is a heavily used roadway that is critical to the surrounding roadway network.

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Public Transportation

The site is not currently served directly by public transportation services, but several MBTA services are provided within the Dorchester neighborhood. The Fields Corner Station, Savin Hill Station and JFK/UMass Station on the MBTA Red Line are located within 1.25 to 1.75 miles of the project site. The Proponent has partnered with the owners of the neighboring Ramada Inn to expand their shuttle bus services to also serve residents of the project. Service will be provided to the JFK/UMass Station and Savin Hill Station on the Red Line, as well as to Logan International Airport and shopping and recreational destinations in the area.

Pedestrian and Multimodal Access

The Proponent plans to reconstruct the sidewalk and streetscape along the site frontage on Morrissey Boulevard and Freeport Street to provide better pedestrian access at and around the site. Approximately 206 bicycle parking space are proposed. As indicated in MassDOT’s comment letter, all external and internal site circulation must be consistent with a healthy transportation design approach that provides adequate and safe accommodation for all roadway users, including pedestrians, bicyclists, and public transit riders. Guidance on healthy transportation design is included in the MassDOT Project Development and Design Guide.

Additionally, the land at the north end of the project site has been designed to accommodate a potential future connection to the proposed DCR/MassDOT Neponset River Greenway multi-use path extension from Freeport Street, with connections to Dorchester Shores Reservation, Tenean Beach, and the waterfront. The Proponent has met with DCR and MassDOT to conceptually review the future connection. Based upon early conversations with DCR and MassDOT, the construction of the multi-use path extension is expected to occur concurrently with the Project. This connectivity will increase access to open space opportunities, and further encourage non-vehicular transportation modes to and from the site.

The TIA proposes a Transportation Demand Management (TDM) program intended to promote travel to and from the site by way of transit, biking, or walking. The following TDM measures were proposed in the TIA:

• A Transportation Coordinator will be assigned for the project and the name and contact information for said person will be provided to the Boston Transportation Department; • The owner or property manager will join the A Better City (ABC) Transportation Management Association (TMA) in order to facilitate and encourage healthy transportation options for residents of the project; • Information regarding public transportation services, maps, schedules and fare information will be posted in a central location and/or otherwise made available to residents; • A “welcome packet” will be provided to residents detailing available public transportation services, bicycle and walking alternatives, and commuter options available through the TMA; • Residents will be made aware of the Emergency Ride Home (ERH) program available through the TMA;

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• Sidewalks will be provided to link the residential building to the existing sidewalks along Freeport Street and Morrissey Boulevard; • A mail drop will be provided in a central location in the building; • Bicycle parking will be provided consisting of: i) secure bicycle parking conveniently located proximate to the building entrance; and ii) weather protected bicycle storage for a minimum of 206 bicycles to be located in a secure area within the building; • A Bluebike station will be provided in an appropriate location proximate to Freeport Street and Morrissey Boulevard; • Electric car sharing vehicles (such as ZipCar) will be placed at the project site for use by residents; and • Real-time transportation display technologies will be installed in building lobby. • Provide Shuttle Bus service with connections to nearby public transportation including the Red Line and Logan International Airport.

The Proponent should work with MassDOT to DCR to formulate a TDM monitoring program to assess effectiveness of these measures over time, including quantifying the reductions in vehicle trips and SOV trips attributable to TDM measures.

Climate Change

Executive Order 569: Establishing an Integrated Climate Change Strategy for the Commonwealth (EO 569; the Order) was issued on September 16, 2016. EO 569 recognizes the serious threat presented by climate change and directs 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 goals 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. The MEPA statute directs all State Agencies to consider reasonably foreseeable climate change impacts, including additional greenhouse gas emissions, and associated effects, when issuing permits, licenses and other administrative approvals and decisions. M.G.L. c. 30, § 61.

Greenhouse Gas (GHG) Emissions

While the project does not exceed the thresholds for application of MEPA’s GHG Policy and Protocol, it does involve the development of a new multifamily residential building that will add to GHG emissions from the building and transportation sector. As described in the ENF, the project is proposing full electrification and air sealing for compartmentalization to reduce the reliance on and use of fossil fuels. I applaud the Proponent for the incorporation of meaningful energy efficiency measures. I refer the Proponent to the Department of Energy Resources (DOER)’s comment letter with additional guidance related to energy efficiency including electrification and Passivehouse design standards.

The project will be meeting the City of Boston guidelines to provide 25% of spaces with EV stations and the remaining 75% as EV-ready. Boston guidelines allow for various equivalency options by utilizing different types of chargers, EV ride share programs, and other means that the Proponent is currently studying for implementation on the project. Therefore, the final number of spaces has not been

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determined. The Proponent will continue to work with the City of Boston to meet its guidelines as the design progresses.1

Climate Adaptation and Resiliency

As noted, the project site is not currently located with the FEMA 100-year floodplain. However, the project site is located within close proximity to the existing floodplain and is located within the BPDA Sea Level Rise Flood Hazard Area (SLR- FHA). The BPDA SLR-FHA identifies areas anticipated to be impacted by the 1% annual chance flood by 2070 assuming 40 inches of sea level rise. The BPDA SLR Base Flood Elevation for the project site is 19.5 BCB with a SLR-design flood elevation of 20.5 feet BCB. The site will be compliant with these standards, as it will raise first floor residences to 20.5 ft BCB with the garage entrance and secondary access at 18.5 ft BCB. The Critical systems and infrastructure will also be located at or above the 20.5 design flood elevation. The Proponent will analyze potential implementation of backflow prevention devices2 as the design progresses. I encourage the Proponent to consider additional resiliency measures in building and site design, including maximizing the use of ecosystem-based adaptation measures to reduce heat island effect and mitigate stormwater runoff, such as integration of tree canopy cover, rain gardens, and low impact development (LID) stormwater management techniques. The ENF indicates that DCR is proposing the reconstruction of Morrissey Boulevard DCR which may include raising the elevation of the Boulevard. The proposed raised site grades and building finished floor are intended to accommodate the future Morrissey Boulevard grades. As described in the ENF, the Proponent is committed to continuing to work with DCR as design of the Morrissey Boulevard upgrades progresses. I encourage the Proponent to engage meaningfully and contribute to these district level resiliency planning efforts, which will benefit all surrounding property owners.

Construction Period

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). 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.

1 Information provided by e-mail to the MEPA Office on 6/16/2020. 2 Blackflow prevention devices consist of plumbing devices used inside of the building to prevent stormwater from re-entering the building and flooding it in large storm events 9

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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.

June 19, 2020 ______Date Kathleen A. Theoharides

Comments received:

06/01/2020 Boston Water and Sewer Commission (BWSC) 06/08/2020 Massachusetts Department of Environmental Protection (MassDEP) Boston Office 06/09/2020 Massachusetts Department of Transportation (MassDOT) 06/09/2020 Massachusetts Water Resources Authority (MWRA) 06/10/2020 Maria Lyons

KAT/EFF/eff

Boston Water and Sewer Commission

980 Harrison Avenue Boston. MA02119-2540 617-989-7000

June 1,2020

Secretary Kathleen Theoharides Executive Office of Energy and Environmental Affairs Attention: MEPA Office Erin Flaherty, EEA No. 16205 100 Cambridge Street, Suite 900 Boston, MA 02114

Re: 780 Morrissey Boulevard Environmental Notification Form

Dear Secretary Theoharides:

The Boston Water and Sewer Commission (Commission) has reviewed the Environmental Notification Form (ENF) for the proposed development located at 780 Morrissey Boulevard in the Dorchester neighborhood of Boston. The Commission previously submitted comments on the PNF for this project to the Boston Planning and Development Agency (BPDA) on February 20, 2020. This letter restates the Commission’s PNF comments for the benefit of the MEPA office.

The proposed project site is approximately 78,877 square feet (sfl lot that is currently an underutilized surface parking lot and vacant restaurant and is bounded by Freeport Street and Morrissey Boulevard to the west, a surface parking lot to the north, 1-93 to the east, and the Ramada Inn to the south. The project proponent, Dorchester-Michaels LLC, proposes the development of the approximately 163,885 sf building that will contain approximately 206 residential units, residential amenities and approximately 136 garage and surface parking spaces.

For water service, the Commission owns and maintains a 12-inch Southern High DICL water main in Morrissey Boulevard that was installed in 2009.

The Commission’s wastewater system serving the project site is a 12-inch sanitary sewer in Morrissey Boulevard. There is a 12-inch storm drain in Morrissey Boulevard that is owned and maintained by the DCR.

The ENF states that the daily water demand for the proposed project is estimated to be 27,588 gallons per day (gpd) and wastewater generation will be 25,080 gpd.

The Commission has the following comments regarding the ENF: General

Prior to the initial phase of the site plan development, Dorchester-Michaels LLC, should meet with the Commission’s Design and Engineering Customer Services to review water main, sewer and storm drainage system availability and potential upgrades that could impact the development.

2. Prior to demolition of any buildings, all water, sewer and storm drain connections to the buildings must be cut and capped at the main pipe in accordance with the Commission’s requirements. The proponent must complete a Cut and Cap General Services Application, available from the Commission.

3. All new or relocated water mains, sewers and storm drains must be designed and constructed at Dorchester-Michaels LLC’s, expense. They must be designed and constructed in conformance with the Commission’s design standards, Water Distribution System and Sewer Use regulations, and Requirements for Site Plans. The site plan should include the locations of new, relocated and existing water mains, sewers and drains which serve the site, proposed service connections, water meter locations, as well as back flow prevention devices in the facilities that will require inspection. A General Service Application must also be submitted to the Commission with the site plan.

4. The Department of Environmental Protection (DEP), in cooperation with the Massachusetts Water Resources Authority and its member communities, is implementing a coordinated approach to flow control in the MWRA regional wastewater system, particularly the removal of extraneous clean water (e.g., infiltration/inflow (110) in the system. In April of 2014, the Massachusetts DEP promulgated new regulations regarding wastewater. The Commission has a National Pollutant Discharge Elimination System (NPDES) Permit for its combined sewer overflows and is subject to these new regulations [314 CMR 12.00, section 12.04(2)(d)]. This section requires all new sewer connections with design flows exceeding 15,000 gpd to mitigate the impacts of the development by removing four gallons of infiltration and inflow (UI) for each new gallon of wastewater flow. In this regard, any new connection or expansion of an existing connection that exceeds 15,000 gaLlonsper day of wastewater shall assist in the UI reduction effort to ensure that the additional wastewater flows are offset by the removal of UI. Currently, a minimum ratio of 4:1 for UI removal to new wastewater flow added is used. The Commission supports the policy, and will require proponent to develop a consistent inflow reduction plan. The 4:1 requirement should be addressed at least 90 days prior to activation of water service and will be based on the estimated sewage generation provided on the project site plan.

5. The design of the project should comply with the City of Boston’s Complete Streets Initiative, which requires incorporation of “green infrastructure” into street designs.

7 Green infrastructure includes greenscapes, such as trees, shrubs, grasses and other landscape plantings, as well as rain gardens and vegetative swales, infiltration basins, and paving materials and permeable surfaces. The proponent must develop a maintenance plan for the proposed green infrastructure. For more information on the Complete Streets Initiative see the City’s website at lntpJ/bo%tnconiplc[estrcc[.uni/

6. Dorchester-Michaels LLC should be aware that the US Environmental Protection Agency issued the Remediation General Permit (ROP) for Groundwater Remediation, Contaminated Construction Dewatering, and Miscellaneous Surface Water Discharges. If groundwater contaminated with petroleum products, for example, is encountered, Dorchester-Michaels LLC will be required to apply for a RGP to cover these discharges.

7. Dorchester-Michaels LLC is advised that the Commission will not allow buildings to be constructed over any of its water lines. Also, any plans to build over Commission sewer facilities are subject to review and approval by the Commission. The project must be designed so that access, including vehicular access, to the Commission’s water and sewer lines for the purpose of operation and maintenance is not inhibited.

8. The Commission will require Dorchester-Michaels LLC to undertake all necessary precautions to prevent damage or disruption of the existing active water and sewer lines on, or adjacent to, the project site during construction.

9. It is Dorchester-Michaels LLC’s responsibility to evaluate the capacity of the water, sewer and storm drain systems serving the project site to determine if the systems are adequate to meet future project demands. With the site plan, Dorchester-Michaels LLC must include a detailed capacity analysis for the water, sewer and storm drain systems serving the project site, as well as an analysis of the impacts the proposed project will have on the Commission’s water, sewer and storm drainage systems.

Water

Dorchester-Michaels LLC must provide separate estimates of peak and continuous maximum water demand for residential, commercial, industrial, irrigation of landscaped areas, and air-conditioning make-up water for the project with the site plan. Estimates should be based on full-site build-out of the proposed project. Dorchester-Michaels LLC should also provide the methodology used to estimate water demand for the proposed project.

2. Dorchester-Michaels LLC should explore opportunities for implementing water conservation measures in addition to those required by the State Plumbing Code. In particular, Dorchester-Michaels LLC should consider outdoor landscaping which requires minimal use of water to maintain. If Dorchester-Miehaels LLC plans to install in-ground sprinkler systems, the Commission recommends that timers, soil moisture

3 indicators and rainfall sensors be installed. The use of sensor-operated faucets and toilets in common areas of buildings should be considered.

3. Dorchester-Michaels LLC is required to obtain a Hydrant Permit for use of any hydrant during the construction phase of this project. The water used from the hydrant must be metered. Dorchester-Michaels LLC should contact the Commission’s Meter Department for information on and to obtain a Hydrant Permit.

4. The Commission is utilizing a Fixed Radio Meter Reading System to obtain water meter readings. For new water meters, the Commission will provide a Meter Transmitter Unit (MTU) and connect the device to the meter. For information regarding the installation of MTUs, Dorchester-Michaels LLC should contact the Commission’s Meter Department.

Sewage / Drainage

In conjunction with the Site Plan and the General Service Application Dorchester Michaels LLC will be required to submit a Stormwater Pollution Prevention Plan. The plan must:

• Identify specific best management measures for controlling erosion and preventing the discharge of sediment, contaminated stormwater or construction debris to the Commission’s drainage system when construction is underway.

• Include a site map which shows, at a minimum, existing drainage patterns and areas used for storage or treatment of contaminated soils, groundwater or stormwater, and the location of major control structures or treatment structures to be utilized during the construction.

• Specifically identify how the project will comply with the Department of Environmental Protection’s Performance Standards for Stormwater Management both during construction and after construction is complete.

2. Developers of projects involving disturbances of land of one acre or more will be required to obtain an NPDES General Permit for Construction from the Environmental Protection Agency and the Massachusetts Department of Environmental Protection. Dorchester-Michaels LLC is responsible for determining if such a permit is required and for obtaining the permit. If such a permit is required, it is required that a copy of the permit and any pollution prevention plan prepared pursuant to the permit be provided to the Commission’s Engineering Services Department, prior to the commencement of construction. The pollution prevention plan submitted pursuant to a NPDES Permit may be submitted in place of the pollution prevention plan required by the Commission

provided the Plan addresses the same components identified in item 1above.

4 3. The Commission encourages Dorchester-Michaels LLC to explore additional opportunities for protecting stormwater quality on site by minimizing sanding and the use of deicing chemicals, pesticides, and fertilizers.

4. The discharge of dewatering drainage to a sanitary sewer is prohibited by the Commission. Dorchester-Michaels LLC is advised that the discharge of any dewatering drainage to the storm drainage system requires a Drainage Discharge Permit from the Commission. If the dewatering drainage is contaminated with petroleum products, Dorchester-Michaels LLC will be required to obtain a Remediation General Permit from the Environmental Protection Agency (EPA) for the discharge.

5. Dorchester-Michaels LLC must fully investigate methods for retaining stormwater on- site before the Commission will consider a request to discharge stormwater to the Commission’s system. The site plan should indicate how storm drainage from roof drains will be handled and the feasibility of retaining their stormwater discharge on-site. All projects at or above 100,000 square feet of floor area are to retain, on site, a volume of runoff equal to 1.25 inches of rainfall times the impervious area. Under no circumstances will stormwater be allowed to discharge to a sanitary sewer.

6. The Massachusetts Department of Environmental Protection (MassDEP) established Stormwater Management Standards. The standards address water quality, water quantity and recharge. In addition to Commission standards, Dorchester-Michaels LLC will be required to meet MassDEP Stormwater Management Standards.

7. Sanitary sewage must be kept separate from stormwater and separate sanitary sewer and storm drain service connections must be provided. The Commission requires that existing stormwater and sanitary sewer service connections, which are to be re-used by the proposed project, be dye tested to confirm they are connected to the appropriate system.

8. The Commission requests that Dorchester-Michaels LLC install a permanent casting stating “Don’t Dump: Drains to Boston Harbor” next to any catch basin created or modified as part of this project. Dorchester-Michaels LLC should contact the Commission’s Operations Division for information regarding the purchase of the castings.

9. If a cafeteria or food service facility is built as part of this project, grease traps will be required in accordance with the Commission’s Sewer Use Regulations. Dorchester Michaels LLC is advised to consult with the Commission’s Operations Department with regards to grease traps.

10. The enclosed floors of a parking garage must drain through oil separators into the sewer system in accordance with the Commission’s Sewer Use Regulations. The

5 Commission’s Requirements for Site Plans, available by contacting the Engineering Services Department, include requirements for separators.

11. The Commission requires installation of particle separators on all new parking lots greater than 7,500 square feet in size. If it is determined that it is not possible to infiltrate all of the runoff from the new parking lot, the Commission will require the installation of a particle separator or a standard Type 5 catch basin with an outlet tee for the parking lot. Specifications for particle separators are provided in the Commission’s requirements for Site Plans.

Thank you for the opportunity to comment on this project.

Your truly,

JØhn P. Sullivan, P.E. “Chief Engineer

JPS/afh

cc: Jay Russo, Dorchester-Michaels LLC K. Ronan, MWRA via e-mail M. Zlody, BED via e-mail P. Larocque, BWSC via e-mail

Charles D. Baker Kathleen A. Theoharides Governor Secretary

Karyn E. Polito Martin Suuberg Lieutenant Governor Commissioner

Memorandum To: Erin Flaherty, MEPA

From: Frank Taormina, Waterways Regulation Program, MassDEP/Boston

Cc: Daniel Padien, Program Chief, Waterways Regulation Program, MassDEP/Boston

Re: Comments from the Chapter 91 Waterways Regulation Program ̶ EEA #16205; ENF ̶ 780 Morrissey Boulevard, (Dorchester) Boston, Suffolk County

Date: June 8, 2020

The Department of Environmental Protection Waterways Regulation Program (the “WRP”) has reviewed the referenced Environmental Notification Form (EENF) EEA #16205, submitted by Bohler Engineering on behalf of Dorchester-Michaels LLC (the “Proponent”) to demolish a vacant restaurant building and construct a 5- to 6-story residential building consisting of 206-residential units with associated amenities and ground level garage parking partially located on filled tidelands of the Neponset River at 780 William T. Morrissey Boulevard in (Dorchester) Boston, Suffolk County (the “project site”).

Chapter 91 Jurisdiction As shown in Appendix B of the ENF (Existing and Proposed Chapter 91 Aerials) roughly half of 74,684-square foot project site includes filled tidelands of the Neponset River. However, only a small portion of those filled tidelands (4,193-square feet) are subject to the licensing requirements of M.G.L. Chapter 91 and the Waterways Regulations at 310 CMR 9.00, because they are located within 250-feet of the existing mean high water mark (or to the first public way, whichever is further). The remaining filled tidelands onsite are located greater than 250 feet from flowed tidelands, are separated from said tidelands by one or more interconnected public ways and therefore considered Landlocked Tidelands (as defined in M.G.L. Chapter 91, section 18 and 310 CMR 9.02) and not subject to licensing. The small area of jurisdictional tidelands onsite will be reviewed under the applicable regulations at 310 CMR 9.00, including but not limited to the nonwater-dependent provisions of 310 CMR 9.51 through 9.52. The standards annumerated at 310 CMR 9.53 shall not apply as the site does not contain any Commonwealth Tidelands.

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

780 Morrissey Blvd / EEA #16205 / ENF MassDEP Waterways Comments June 8, 2020

Chapter 91 Regulatory Analysis The work proposed in filled tidelands subject to licensing (non-landlocked) includes the demolition and removal of existing pavement, excavation, placement of up to 5-feet of fill to elevate the existing grade, installation of a retaining wall, creation of 31 surface parking spaces, and a small landscaped area.

In the ENF, the Proponent stated that the nonwater-dependent building height provisions at 310 CMR 9.51(3)(e) is not applicable because – the project did not propose a new or expanded building within an area of Chapter 91 jurisdiction. However, a close review of the project concept indicates that approximately 7-square feet of the building’s upper floor balconies are proposed to overhang filled private tidelands subject to licensing. Therefore, these portions of the building must comply with all applicable Waterways Regulations, including but not limited to the building height provisions at 310 CMR 9.51(3)(e).

Based on the WRP review of the ENF and supporting materials and plans provided as attachments thereto, it appears that said work proposed within Chapter 91 jurisdiction complies with the various nonwater-dependent provisions. The WRP will perform a full technical review of the proposed project once detailed plans are submitted with the pending Chapter 91 Waterways License Application.

If you have any questions regarding the WRP’s comments, please feel free to contact me at [email protected]

June 9, 2020

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

RE: Boston: 780 Morrissey Boulevard – ENF (EEA #16205)

ATTN: MEPA Unit Erin Flaherty

Dear Secretary Theoharides:

On behalf of the Massachusetts Department of Transportation, I am submitting comments regarding the Environmental Notification Form Change for the 780 Morrissey Boulevard project in Boston, 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 [email protected].

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

Boston – 780 Morrissey Boulevard Page 2 6/09/20 cc: Jonathan Gulliver, Administrator, Highway Division Patricia Leavenworth, P.E., Chief Engineer, Highway Division John McInerney, P.E., District 6 Highway Director Neil Boudreau, Assistant Administrator of Traffic and Highway Safety Boston Planning and Development Agency Boston Region MPO

TO: David J. Mohler, Executive Director Office of Transportation Planning

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

DATE: June 9, 2020

RE: Boston: 780 Morrissey Boulevard– ENF (EEA #16205)

The Public/Private Development Unit (PPDU) has reviewed the Environmental Notification Form (ENF) submitted by Bohler on behalf of Dorchester-Michaels LLC (“the Proponent”) for the 780 Morrissey Boulevard project in Boston. Located at 780 Morrissey Boulevard, the 1.81 acre site currently consists of a parking lot and a vacant restaurant. The site is bounded by Freeport Street and Morrissey Boulevard to the west, a parking lot to the north, Interstate 93 (I-93) to the east, and the Ramada Inn to the south. The project proposes to redevelop the land into a multiuse building consisting of 206 residential units, associated residential amenities, and a one-story parking garage.

Based on the information presented in the ENF, the project is expected to generate 1,122 unadjusted weekday daily vehicle trips, which is below the MEPA threshold for trip generation. The project will also include 136 parking spaces.

The existing site access, which intersects the west side of Freeport Street at its intersection with Morrissey Boulevard, will be closed and a new driveway will be provided onto Freeport Street approximately 250 feet north of the Morrissey Boulevard/Freeport Street intersection. A State Highway Access Permit from MassDOT and a Driveway Permit form DCR will be required.

The ENF includes a Transportation Impact Assessment (TIA) performed by Vanasse & Associates, Inc. that generally confirms to MassDOT’s Transportation Impact Assessment (TIA) Guidelines. MassDOT offers the following comments on the TIA.

Study Area

The TIA includes the following intersections in the study area:

• Freeport Street at Victory Road (unsignalized) • Morrissey Boulevard at Victory Road (unsignalized) • Morrissey Boulevard at Freeport Street (unsignalized) • Morrissey Boulevard at Freeport Street/Tenean Street (unsignalized) • Freeport Street at the Project Site Driveway (unsignalized)

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

Boston– 780 Morrissey Boulevard Page 2 6/09/20

The study area is sufficient for capturing the transportation impacts of the project.

Trip Generation

The Proponent suggests a mode split between vehicles, walking and bicycling, and transit as a result of planned on-site shuttle service to nearby MBTA stations (discussed below) and planned pedestrian and bicycle infrastructure improvements around the site. National Household Travel Survey data and travel mode data from the Boston Transportation Department were used to develop the splits. Based on this, it was determined that 5% of weekday daily trips would occur by transit, while 19% would occur by walking or bicycling. MassDOT finds this methodology to be sufficient in estimating how many trips will take place by means other than a personal vehicle.

The adjusted vehicle trip generation would then be 854 average weekday daily trips, with 49 trips in the morning peak hour and 64 trips in the evening peak hour. During the morning peak hour, 9 person trips will occur by transit and 14 will take place by walking or bicycling. In the evening peak hour, 11 trips will use transit and 18 will take place by walking or bicycling. Since only a small portion of the trips are expected to use transit, a transit analysis was not conducted.

Trip Distribution

The directional distribution of vehicle trips to and from the project site was determined based on a review of origin-destination data provided by the Boston Transportation Department. When entering the site, 70% of trips will utilize Freeport Street from the north. Meanwhile, 30% of trips will use Morrissey Boulevard from the south to reach Freeport Street to then access the site. For exiting trips, 20% will use Freeport Street to go north, while 80% will use Freeport Street to go south. 50% of total trips will then use Morrissey Boulevard to go north, and 30% of total trips will use Morrissey Boulevard to go south.

Site Access

The existing site access, which intersects the west side of Freeport Street at its intersection with Morrissey Boulevard, will be closed and a new driveway will be provided onto Freeport Street approximately 250 feet north of the Morrissey Boulevard/Freeport Street intersection. The Proponent conducted a sight distance evaluation and found that the available

Boston– 780 Morrissey Boulevard Page 3 6/09/20 lines of sight at the proposed site driveway intersection exceed the recommended minimum sight distance to function in a safe manner.

Safety

None of the study area intersections are listed as Highway Safety Improvement Program (HSIP) High Crash Cluster locations. The Proponent should collect crash data for the study area intersections for the most recent five-year period available in order to compare the observed crash rates to statewide and MassDOT District 6 average crash rates. This can help determine if any safety-related mitigation is necessary.

Traffic Analysis

The TIA includes capacity analyses for 2019 Existing, 2026 No-Build, and 2026 Build conditions for the study area intersections. A background growth rate of .5% was used. In addition to background growth and project-related trip generation, the Proponent incorporated anticipated traffic from three nearby projects in the development of future traffic conditions. The TIA also includes a queue length analysis and associated tables/graphs.

In 2019 Existing conditions, all of the turning movements at study area intersections operate at LOS C or better. There is no change in LOS between 2019 Existing conditions and 2026 No-Build conditions. Under 2026 Build conditions, most turning movements at the study area intersections continue to operate at the same LOS, though some with slightly increased delay. The only exception to this is the Morrissey Boulevard at Freeport Street and Tenean Street intersection, where morning peak hour LOS for the Freeport Street westbound right-turn drops from LOS C in 2026 No-Build conditions to LOS D in 2026 Build conditions. Based on this analysis, the transportation network can adequately handle the site- generated traffic.

Transit

The site is not currently served directly by public transportation services, but several MBTA services are provided within the Dorchester neighborhood. The Fields Corner Station, Savin Hill Station and JFK/UMass Station on the MBTA Red Line are located within 1.25 to 1.75 miles of the project site. The Proponent has partnered with the owners of the neighboring Ramada Inn to expand their shuttle bus services to also serve residents of the project. They plan to provide service to the JFK/UMass Station and Savin Hill Station on the Red Line, as well as to Logan International Airport and shopping and recreational destinations in the area.

Multimodal Access and Facilities

The Proponent plans to reconstruct the sidewalk and streetscape along the site frontage on Morrissey Boulevard and Freeport Street to provide better pedestrian access at and around the site. Bicycle parking facilitates are also proposed. All external and internal site circulation must be consistent with a healthy transportation design approach that provides adequate and

Boston– 780 Morrissey Boulevard Page 4 6/09/20 safe accommodation for all roadway users, including pedestrians, bicyclists, and public transit riders. Guidance on healthy transportation design is included in the MassDOT Project Development and Design Guide.

Parking

Currently, the project site has 196 parking spaces. Redevelopment of the property will involve the removal of these spaces and the construction of 136 spaces in their place, a difference of 60 spaces. The Proponent should compare the amount of proposed parking spaces to the average demand for parking set forth in ITE’s Parking Generation Manual (4th edition). The Proponent should also ensure that the proposed number of parking is consistent with the City of Boston requirements for parking.

Transportation Demand Management Program

Boston– 780 Morrissey Boulevard Page 5 6/09/20

• Bicycle parking will be provided consisting of: i) secure bicycle parking conveniently located proximate to the building entrance; and ii) weather protected bicycle storage for a minimum of 206 bicycles to be located in a secure area within the building; • A station will be provided in an appropriate location proximate to Freeport Street and Morrissey Boulevard; • Electric car sharing vehicles will be placed at the project site for use by residents; and • Real-time transportation display technologies will be installed in building lobby.

The Proponent should also utilize a Traffic and Construction Management plan during construction, which will be coordinated with MassDOT and the City of Boston.

MassDOT recommends that no further environmental review be required based on transportation-related issues. The Proponent should continue to work with MassDOT and DCR to finalize plans for the Neponset River Greenway multi-use path extension. If you have any questions regarding these comments, please contact me at (857) 368-8862.

June 9, 2020

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

Subject: EOEEA #16205– Environmental Notification Form 780 Morrissey Boulevard, Boston, MA

Dear Secretary Theoharides,

The Massachusetts Water Resources Authority (MWRA) appreciates the opportunity to comment on the Environmental Notification Form (ENF) submitted by Dorchester-Michaels LLC c/o The Michaels Organization (the “Proponent”) for 780 Morrissey Boulevard (the “Project”) in the Dorchester neighborhood of Boston, Massachusetts. The 1.81 acre Project site currently consists of surface parking and a vacant restaurant. The Project involves the development of one building between five and six stories, which will total approximately 163,885 gross square feet. The building will contain 206 residential units including a mix of studio, one-bedroom and two-bedroom units, as well as residential amenities. The building will include one level of garage parking containing 123 spaces and 13 outdoor spaces.

Comments on the ENF relate to wastewater issues and the need for Infiltration/Inflow (I/I) Removal as well as Toxic Reduction and Control (TRAC) discharge permitting.

Wastewater

The ENF states that the Project will generate approximately 25,100 gallons per day (gpd) of new wastewater flow on the now vacant site. According to the Boston Water and Sewer Commission’s (BWSC) storm drain and sewer maps, the Project site is served by BWSC separate storm drains and sanitary sewers. Sanitary flows from the Project site are conveyed to a 12-inch BWSC sanitary sewer located in Morrissey Boulevard, west of the Project site. Flows eventually enter BWSC’s Dorchester Interceptor at the intersection of Conley Street and Morrissey Boulevard. The Dorchester Interceptor conveys sanitary and combined sewer flows from large areas of Dorchester to MWRA’s Columbus Park Headworks for transport to the Deer Island Treatment Plant. In large storms high infiltration (groundwater) and inflow (stormwater) entering the BWSC system, along with combined sanitary and stormwater flows, can exceed the capacities of the BWSC and MWRA systems. This can contribute to system flooding in Dorchester and CSO overflows to the Fort Point Channel as well as MWRA’s South Boston CSO Storage Tunnel, which protects the South Boston beaches.

To ensure that the Project’s new wastewater flow does not increase sewer system surcharging or overflows in large storms, the Proponent should continue to work with BWSC to develop a plan to ensure 4:1 offset of the Project’s wastewater flow, as required by Massachusetts Department of Environmental Protection regulations and BWSC policy. Increasing wastewater flow to the BWSC Dorchester Interceptor and MWRA’s Columbus Park Headworks without the required offset can contribute to more frequent or greater system flooding in Dorchester and can compromise the Fort Point Channel water quality benefits of MWRA’s $912 million region-wide CSO control plan and the performance of the South Boston CSO Storage Tunnel.

TRAC Discharge Permitting

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.

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 Project site has access to separate sewer and storm drain systems. Therefore, the discharge of groundwater or stormwater to the sanitary sewer system associated with this Project is prohibited.

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, DEP Adam Horst, BWSC

6/12/2020 Mail - Flaherty, Erin (EEA) - Outlook

Fw: Public Comment Filing # 16205 Czepiga, Page (EEA) on behalf of MEPA (EEA) Thu 6/11/2020 108 PM To: Flaherty, Erin (EEA) From: Maria Lyons Sent: Wednesday, June 10, 2020 5:30 PM To: MEPA (EEA) Subject: Public Comment Filing # 16205

CAUTION: This email originated from a sender outside of the Commonwealth of Massachusetts mail system. Do not click on links or open attachments unless you recognize the sender and know the content is safe. Public Comment on MEPA Filing #16205 780 Morrissey Boulevard, Dorchester Ma., 02122

Please send to the appropriate person in charge of this ﬁling.

To : MEPA

This letter is in regards to the MEPA filing for 730 Morrissey Boulevard project. I am on the BPDA neighborhood AIG for this project. There was no notification concerning this filing from the developers or BPDA to AIG members or neighborhood Civic Groups. The comment period needs to be extended until interested parties are notified and allowed time to comment. I understand this could be an oversight during the Covod -19 Virus Epidemic, but it needs to be rectified.

This project is asking to build on filled land, in a floodplain that is only going to get worse in the near future due to sea level rise and storm water runoff. If you examine the flood maps from Climate Ready Boston you will see that this area is inundated with water from both the sea and the land. It should be used as a water retention area not developed buildings. When the water drains into this area and is blocked by the building, where will it go? The storm water drains in this area are already overflowing with storms. Already this area of Morrissey Boulevard floods during storms.

This site is also directly across from the Neponset River Area of Environmental Concern. The height of the massive buildings will block migrating birds to and from the ocean, marshes and the Squantum Point Park area, an extremely important migratory and local bird nesting area.

The height of the buildings is 20 ft above the Boston Zoning restrictions.

The height and mass of the buildings will also further separate Dorchester from its waterfront. An environmental injustice that started many years ago with the trains and then Rt 93. The State has spent millions of dollars saving, revitalizing and protecting the coastal areas that are left. We should not be going backwards. This will be a detriment to the Community of https://outlook.ofﬁce365.com/mail/inbox/id/AAQkAGEyMGVjZjFlLWMwYjEtNGI3Ni1iYTdkLTZiMmVkNTZmMGQzOAAQAIxppgnx47dEuPgGdNJi73E%3D 1/2 6/12/2020 Mail - Flaherty, Erin (EEA) - Outlook Dorchester, blocking historical views of the ocean, sunrise, and of Dorchester from the sea. The mass and height of the buildings will also block the cooling summer sea breezes to the area.

The building proposed will set a bad precedent for others to do the same, Thereby changing the Dorchester Waterfront forever. We have seen what has happened to much of Boston’s coastline, especially East Boston, separating the rich from the poor along the waterfront, and do not want it here.

Sincerely,

Maria Lyons

Environmental Chairperson

Port Norfolk Civic Association

https://outlook.ofﬁce365.com/mail/inbox/id/AAQkAGEyMGVjZjFlLWMwYjEtNGI3Ni1iYTdkLTZiMmVkNTZmMGQzOAAQAIxppgnx47dEuPgGdNJi73E%3D 2/2 780 Morrissey Boulevard, EEA #16205 Boston, Massachusetts

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

June 16, 2020

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

RE: 780 Morrissey Boulevard, Boston, Massachusetts, EEA #16205

Cc: Maggie McCarey, Director of Energy Efficiency, Department of Energy Resources 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 one (1) residential building totaling approximately 163,885-sf with 206 total units. 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:

• Electrification of space and water heating;

• Passivehouse building standards;

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

• Avoiding glass curtain wall assemblies and excessive windows; Page 1 of 7

780 Morrissey Boulevard, EEA #16205 Boston, Massachusetts

• 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, and Solar Massachusetts Renewable Target (SMART) credits.

Codes

Massachusetts Stretch Code applies to this project. Stretch Code requires a 10% energy performance improvement over ASHRAE 90.1-2013-Appendix G plus Massachusetts amendments.

In August 2020, an update to the Stretch Code will take effect. The underlying code provisions will not change. The Stretch Code to take effect in August also uses ASHRAE 90.1-2013-Appendix G. However, there will be several new, or changed, Massachusetts amendments including: C402.1.5 (envelope), C405.3 and C405.4 (lighting), C405.10 (EV charging), and C406 (additional efficiency measures). In addition, the additional C406 measures are increased from 2 to 3.

Key Mitigation Strategies Explained

Electrification and Renewable Thermal Space and Water Heating

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:

• 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; and • 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 condensing natural gas equipment. Currently, efficient electric heating has approximately 45% lower emissions than condensing natural gas heating and, by 2050, efficient

Page 2 of 7

780 Morrissey Boulevard, EEA #16205 Boston, Massachusetts

electric heating is expected to have approximately 85% lower emissions than condensing natural gas heating.

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 electrified heating, as described above much smaller-sized 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 $0.75M 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.

The Passivehouse pathway accesses the most incentives, while also being the most affordable and efficient.

Passivehouse Examples

Page 3 of 7

780 Morrissey Boulevard, EEA #16205 Boston, Massachusetts

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

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.

Rooftop Solar PV

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780 Morrissey Boulevard, EEA #16205 Boston, Massachusetts

Rooftop PV can provide significant GHG benefits as well as significant financial benefits. Code currently requires that at least 50% of low-rise 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:

• 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 Page 5 of 7

780 Morrissey Boulevard, EEA #16205 Boston, Massachusetts

building tenants. For this reason, setting aside rooftop solar PV areas helps ensure that building owners’ ability to monetize the roof is not impacted.

Recommendations for the Surfside Crossing Project

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?

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

• Was efficient electrification considered? Air source systems are feasible for most building types and should be considered for all buildings. Was 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 above-code envelope performance used in all buildings? For all buildings, the proposed whole-assembly, aggregate U-value (also called “UA”) calculated should be smaller than the reference building, otherwise envelope performance is being traded-off, reversing mitigation gains. Tradeoffs should be avoided. The table below shows how to calculate whole-assembly U-value. It’s important to calculate whole-assembly U-value as it incorporates thermal performance of all assemblies. Information such as window-to-wall ratio (WWR) is not enough information to assess assembly performance.

Reference Building Proposed Building Percent of Percent of Vertical Envelope U value Vertical U value Vertical Area Area

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780 Morrissey Boulevard, EEA #16205 Boston, Massachusetts

Framed, insulated Wall % value % value Opaque glass, curtain wall, shadowbox, % value % value spandrel Vision glass % value % value

Whole Assembly Whole Assembly 100% 100% U-value U-value Whole assembly U-value (also known as “UA” value) is calculated as: (U1%1 + U2%2 + U3%3) where U is the respective thermal transmittance values and %1 is the percent area of framed insulated wall; %2 is the percent area of opaque glass, curtain, or shadowbox; and %3 is the percent area of vision glass. Only areas adjacent to conditioned space are counted, areas adjacent to unconditioned spaces (e.g. parking garages, mechanical penthouses) are not counted.

• 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.

• 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,

Brendan Place Paul F. Ormond, P.E. Clean Energy Engineer Energy Efficiency Engineer Massachusetts Department of Energy Massachusetts Department of Energy Resource Resources

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