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 Matthew A. Beaton SECRETARY

October 2, 2020

CERTIFICATE OF THE SECRETARY OF ENERGY AND ENVIRONMENTAL AFFAIRS ON THE SINGLE ENVIRONMENTAL IMPACT REPORT

PROJECT NAME : CambridgeSide 2.0 PROJECT MUNICIPALITY : Cambridge PROJECT WATERSHED : Charles River EEA NUMBER : 16176 PROJECT PROPONENT : New England Development DATE NOTICED IN MONITOR : August 26, 2020

Pursuant to the Massachusetts Environmental Policy Act (MEPA; M.G. L. c. 30, ss. 61- 62I) and Section 11.08 of the MEPA regulations (301 CMR 11.00), I have reviewed the Single Environmental Impact Report (Single EIR) and hereby determine that it adequately and properly complies with MEPA and its implementing regulations.

Project Description

As previously described in the Expanded Environmental Notification Form (EENF), the project involves the redevelopment of the CambridgeSide Galleria mall (“CambridgeSide”) in the City of Cambridge (the “City”) from the current footprint of 1,090 million-square foot (msf) into an approximately 1.665 msf mixed-use development. This will be achieved primarily through redevelopment of the former anchor stores and above-ground parking garage and an addition of 575,000 net new square feet (sf) of building space. The project will maintain the public sky-lit atrium open space and the active retail and office uses within the mall.

The project is consistent with a new Planned Unit Development 8 (PUD-8) Zoning District approved by the City allowing for retail, office, laboratory and restaurant uses; in addition, 30 percent of net new floor area is required to be reserved for residential uses. The existing Upper Garage, an above-ground parking structure accessed from First Street, is EEA# 16176 Single EIR Certificate October 2, 2020

proposed to be removed. Street-level retail and restaurant uses are proposed along the project’s frontage on First Street to activate the corridor in favor of pedestrian and bicycle uses. The new 575,000 sf to be added to the site will consist of approximately 175,000 sf of residential and 400,000 sf of commercial uses, and the construction program will consist of 210,000 sf of office space, 665,000 sf of research and development (R&D) space, and about 200 residential units (175,000 sf). Approximately 320,000 sf or 50 percent of the current retail space (associated with the anchor stores) is proposed to be removed.

Project Site

The 8.2-acre project site contains the 1.1-msf CambridgeSide mall located in the Lechmere Triangle neighborhood in Cambridge. The project site is generally bounded by Edwin H. Land Boulevard to the north, Charles Park to the east, First Street to the south, and Lechmere Canal and Canal Park to the west. Land Boulevard is a DCR roadway and the O’Brien Highway (Route 28) is under the jurisdiction of MassDOT. The Land Boulevard Bridge over Lechmere Canal is a MassDOT bridge, and the underpass beneath Land Boulevard adjacent to the Lechmere Canal is under the jurisdiction of DCR. The underpass serves as a critical link for access to the Charles River Reservation from the project site. The mall includes a three-story retail and office core surrounded by three retail anchors and a six-level above-grade parking structure (the Upper Garage) (795 spaces). A three-level below-grade parking garage (the Lower Garage) with 1,695 spaces also serves the site. The mall includes a central sky-lit atrium that functions as an extension of the proximate open space system and connects Canal Park and Charles Park. The mall underwent prior MEPA review (EEA# 3007, CambridgeSide Galleria at Riverside) which concluded in the 1990’s.

The project site is comprised of 8.2 acres of filled private tidelands subject to Chapter 91 (c. 91) jurisdiction and the Waterways Regulations (310 CMR 9.00). The project site is not located in Priority and/or Estimated Habitat as mapped by the Division of Fisheries and Wildlife’s (DFW) Natural Heritage and Endangered Species Program (NHESP) or an Area of Critical Environmental Concern (ACEC). The site does not contain any structures listed in the State Register of Historic Places or the Massachusetts Historical Commission’s (MHC) Inventory of Historic and Archaeological Assets of the Commonwealth.

Environmental Impacts and Mitigation

Potential environmental impacts associated with the redevelopment project include: generation of 10,276 unadjusted average daily vehicle trips (adt) (2,618 adjusted adt),1 an increase in water demand of 115,270 gallons per day (gpd), and an increase in wastewater flows of 104,770 gpd. Greenhouse gas (GHG) emissions are associated with the project’s energy use and trip generation.

1 As described in the Certificate on the EENF, the traffic impacts, after considering mode-share splits and anticipated reductions in retail and parking, were originally estimated to fall below the ENF 2,000 adt threshold. As described below, the reductions credited for removal of parking availability were adjusted in the Single EIR, such that total adjusted adt for the project is now estimated to be 2,618 adt.

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Measures to avoid, minimize, and mitigate impacts include: redevelopment of a site in close proximity to transit; signal coordination using Adaptive Signal Control Technologies; enhancement of a Transportation Demand Management (TDM) program; pedestrian and bicycle improvements; improvements to open space, mobility and connectivity to the Charles River; and incorporation of measures to reduce the project’s GHG emissions and enhance the project’s resilience to the impacts of climate change.

Jurisdiction and Permitting

The project is undergoing MEPA review and is subject to a mandatory EIR pursuant to 301 CMR 11.03(3)(a)(5) because it requires Agency Actions and will result in New or Expansion of an existing non-water dependent structure that occupies one or more acres of waterways or tidelands. The project also exceeds the EIR threshold at 301 CMR 11.03(6)(a)(6) as it will generate 3,000 or more New (unadjusted) adt , and the ENF threshold at 301 CMR 11.03(5)(b)(4)(a) as it will result in a New discharge or Expansion in discharge to a sewer system of 100,000 or more gpd of sewage.2 The project will require Chapter 91 License (c.91) from the Massachusetts Department of Environmental Protection (MassDEP), in addition to a Vehicle Access Permit from the Department of Conservation and Recreation (DCR) and a Highway Access Permit from the Massachusetts Department of Transportation (MassDOT) to implement traffic improvements. It also requires a Section 8(m) Permit and Construction Dewatering Permit and may require a Sewer Use Discharge Permit from the Massachusetts Water Resources Authority (MWRA). The project is subject to the May 5, 2010 MEPA Greenhouse Gas Policy and Protocol (the “GHG Policy”), and requires a Public Benefit Determination under M.G.L. c. 91, § 18B and 301 CMR 13.00.

The project requires a National Pollutant Discharge Elimination System (NPDES) Construction General Permit from the U.S. Environmental Protection Agency (EPA) and a Determination of No Hazard to Air Navigation from the Federal Aviation Administration (FAA). The project also requires Special Permits from the Cambridge Planning Board, a number of approvals from the Cambridge Department of Public Works (DPW) (including but not limited to Stormwater Control Permit, Sewer Connection Permit, Stormwater and Wastewater Infrastructure Permit, Land Disturbance Permit), and approval from the Cambridge Inspectional Services Department (Demolition Permit, Building/Occupancy Permits, Trench Permit, and Curb Cut Permit).

Because the project requires a c.91 License that applies to the entirety of the site, subject matter jurisdiction is functionally equivalent to full scope jurisdiction in accordance with 301 CMR 11.01(2)(a)(3), and therefore extends to all aspects of the project that may cause Damage to the Environment.

Review of the Single EIR

The Single EIR was generally responsive to the Scope, which focused on wetlands/waterways, public benefit determination, traffic/transportation, stormwater, climate

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change, and revisions to mitigation measures and draft Section 61 Findings. The Single EIR included a description of the project, identified existing conditions, and described potential environmental impacts and mitigation measures. The Single EIR indicated that the project remains unchanged from that presented in the EENF. It included a discussion of permitting requirements for the project and generally discussed how the project will be constructed in accordance with applicable regulatory performance standards. The Single EIR included a list of required State Permits, Financial Assistance, or other State approvals and an update on the status of each pending action. It included a revised traffic analysis, revised GHG analysis, an updated stormwater technical appendix, a draft construction management plan, responses to comments, and revised draft Section 61 Findings.

Comments from MassDOT indicate general agreement with traffic and transit mitigation measures, but request ongoing collaboration on future monitoring to determine the need for any additional mitigation, including measures to address congestion along Route 28. The Proponent has agreed to place funds in escrow to allow for future mitigation measures as needed, and will continue to work with MassDOT, DCR, and the City to determine specific measures that could be considered other than signal timing improvements. Comments from the Massachusetts Department of Energy Resources (DOER) commend the project for energy efficiency measures, including efficient electrification for residential space heating and building envelope improvements, but continue to encourage consideration of Passivehouse design which has the potential to make deep GHG reductions and will result in cost savings for tenants over time. Particularly in light of the state’s aggressive goals for reducing statewide GHG emissions by 2050 and the benefits that could accrue to tenants of affordable housing from energy bill savings, I encourage the Proponent to commit to taking all feasible measures to minimize the carbon footprint of this development. State Agency comments do not otherwise request additional analysis in the form of a Supplemental EIR.

Chapter 91 Waterways

As requested in the Scope for the EENF, the Single EIR responded to MassDEP’s comments regarding the licensing approach for the project under c. 91 regulations. The Single EIR reiterates that the Proponent intends to seek a new license to cover all parcels, except the former Sears building, to authorize residential use and building heights that exceed the maximum elevation of 104.5 NGVD 29 authorized in existing License #1829. For the Sears building, the Proponent will seek to amend License #1829 to allow for redevelopment of the building into an approximately 85-foot tall office and laboratory building, which is consistent with the maximum building elevation authorized under the license but would exceed that allowed under regulatory provisions that went into effect after the project’s opening in 1990. Comments from MassDEP acknowledge that, although the construction period specified in License #1829 has expired and the licensee only constructed the Sears building to 55-feet high, the existing building could be increased to 85-feet high by amending the license since this would not constitute a substantial structural alteration per 310 CMR 9.02. The Proponent should continue to work with MassDEP to resolve outstanding issues during the c.91 licensing process.

The Single EIR provided other details requested by MassDEP relative to compliance with c. 91 regulations, including documentation to demonstrate that the width of the regulatory “water

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dependent use zone” (WDUZ) on the intervening adjacent City-owned Canal Park parcel is about 25 feet and therefore does not spill onto the project site; that the heights proposed for all residential buildings planned along First Street (80, 90 or 110 First Street) will comply with current c. 91 regulations (though a new license will be required as stated above); and that open space/lot coverage requirements of the c. 91 regulations will be met “to the maximum extent practicable” as is allowed for reuse/redevelopment projects, including by decreasing occupancy of filled private tidelands through reduced building footprints and without taking credit for off- site open space improvements. The Single EIR clarified that the project is not located in the area with low groundwater levels as stated in 301 CMR 11.05(4)(b), and indicated that this provision may not apply as the site is not located in landlocked tidelands (though it is bordered by them).

Several commenters on the EENF, including the City and Charles River Watershed Association (CRWA), requested information about ground-floor retail uses and the potential for user conflicts and interference with access and enjoyment of open space by the general public. The Single EIR reiterates that the project will make substantial contributions towards expanding open space and public access to Lechmere Canal. On-site improvements will include increased building setback for new buildings along First Street to accommodate a wider sidewalk; improved plantings and furnishings and other pedestrian and bicycle amenities; as well as the addition of two pocket parks along First Street to provide additional opportunities for the public to enjoy open space in an otherwise urban environment. The Proponent has committed to establishing an Open Space and Retail Advisory Committee, which will include members of the public, to help program the various active, ground-floor uses throughout the project site so as to provide ample opportunities for public access to the canal and other open space without creating user conflicts. The committee will include representatives from the City’s Community Development Department and the East Cambridge neighborhood.

Public Benefit Determination

The entire 8.2-acre site is comprised of filled private tidelands subject to the provisions of An Act Relative to Licensing Requirements for Certain Tidelands (2007 Mass. Acts ch. 168) (the “Act”) and the Public Benefit Determination regulations (301 CMR 13.00). Consistent with Section 8 of the legislation, I must conduct a Public Benefits Review as part of the EIR review of projects located on landlocked tidelands that entail new use or modification of an existing use.

Section 3 of the Act requires any project that is subject to MEPA review and that proposes a new use or structure or modification of an existing use or structure within landlocked tidelands to address the project’s impacts on tidelands. It indicates that the analysis “shall include an explanation of the project’s impact on the public’s right to access, use and enjoy tidelands that are protected by chapter 91, and identify measures to avoid, minimize or mitigate any adverse impacts on such rights set forth herein.” The legislation notes that these provisions apply to the filing of an EIR if one is required.

The Single EIR identified the following key public benefits of the project:

• Enhanced open space and activation of first floor uses • Public space for local civic organizations and nonprofits

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• Community engagement events in or within the vicinity of the project • Establishment of an Open Space and Retail Advisory Committee to provide input on the programming of local retail and open spaces • $1,000,000 contribution to the City’s Tree Replacement Fund • $6,9000,000 contribution towards traffic and transit improvements • Dedication of 65% of residential uses for affordable units • Removal of Approximately 400,000 gallons of stormwater runoff from the MWRA combined sewer system, thereby contribution to infiltration/inflow mitigation • Reduction of emissions through energy efficiency measures • Climate resiliency measures such as sheltering during extreme winter storm events

I did not receive comments specifically addressing the public benefits outlined in the Single EIR. Based on a review of the Single EIR and in consultation with State Agencies, I will issue a Public Benefits Determination within 30 days of the issuance of this Certificate.

Traffic/Transportation

Revised Traffic Study

The Single EIR included a revised traffic analysis responding to comments from MassDOT and the City. The revised analysis adjusted downward the assumptions about the percent of non-tenant monthly parkers who would be removed from the traffic network due to the removal of 750 dedicated parking spaces from the site. This number was adjusted from an assumed 100% to 58% of parkers, who are now assumed likely to move to a transit mode of transportation; the other 42% are assumed likely to move to other parking garages available in the area including the First Street Garage with over 1,100 available spaces. This adjustment increased the total net New adt estimated for the project from 1,744 to 2,618 adjusted adt. Even with this adjustment, the additional intersections identified by MassDOT did not trigger the required levels (increase of 100+ vehicles or more than 5 percent of the intersection’s existing traffic during the peak hour) to warrant inclusion in the traffic study. MassDOT comments concur with this analysis and agree that additional intersections need not be studied.

Impacts to levels of service (LOS) at study area intersections were analyzed using the revised trip generation numbers described above. This analysis showed that two additional intersections (not under state jurisdiction) would experience degraded LOS conditions beyond those identified in the original study—namely, Cambridge Street at First Street/North First Street (LOS C to LOS D during weekday evening peak hour with delays increased from 35 to 38 seconds) and Binney Street at First Street (LOS D to LOS E during weekday morning peak hour with increased delay from 54 to 57 seconds; and LOS C to LOS D during weekday evening peak hour with increased delay from 31 to 36 seconds). These additional intersections, along with others that would remain at LOS E from No-Build to Build Conditions, were identified for future improvements to be determined by the City through its First Street/Second Street Corridor Study.

The traffic study also added a queue length analysis to demonstrate that queues can be accommodated with available queue storage. This analysis showed four intersections at which an increase in 50th percentile queues (queue storage likely to be exceeded in 50% of peak hour) or

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95th percentile queues (queue storage likely to be exceeded in 5% of peak hour) were likely to exceed available storage. Namely, the intersections at Cambridge Street at First Street/North First Street (morning peak), Cambridge Street at First Street/North First Street (evening peak), and Binney Street at Second Street (evening peak) have 95th percentile queues that would exceed queue storage lengths, and the intersection of Land Boulevard at Cambridgeside Place/Hotel Driveway (morning peak) has a 50th percentile queue that would exceed queue storage length. These intersections, except for Binney Street at Second Street, are the same as those identified for signal improvements based on the LOS analysis. Comments from MassDOT indicate that these instances of exceedances of queue storage at some lanes already exist and are not directly related to the addition of project traffic.

The traffic study was updated to include a new scenario assuming that anticipated improvements to the Red and Green Line would not be completed prior to construction of this project. Transit impacts were also analyzed based on the procedures defined in the MBTA’s Service Delivery Policy (SDP) that was approved in 2017 by the MBTA Fiscal and Management Control Board. The analysis indicated that sufficient capacity exists on the bus routes and subway lines to accommodate the expected ridership increases due to the project both without and with the proposed future improvements to the Green Line and Red Line. Increases in volume to capacity (v/c) ratios pertaining to line volume were shown to be at or below 0.05 for all affected bus routes, with the highest v/c ratio of the Green Line at 0.71 including the project volume but without future transit improvements. In addition, all bus routes (69, 80, 87, 88) were shown to operate with at least 95% of passenger minutes spent within 125% (off peak) or 140% (peak) passenger-to-seat ratios, based on SDP methodology. These revised analyses did not change the conclusion presented in the EENF that the project will not have significant impacts on the transit system. MassDOT comments concur with this conclusion.

Traffic/Transit Mitigation

As required by the Scope, the Single EIR provided details on agency consultations that occurred after the filing of the EENF to refine traffic and transit mitigation commitments based on revised analyses. The EENF proposed that Adaptive Signal Control Technologies (ASCT) be installed at 11 intersections in the study area to improve traffic conditions. At the request of MassDOT, the Proponent considered additional mitigation for O’Brien Highway (Route 28)/Charles River Dam Road at Land Boulevard/Charlestown Avenue intersection. According to the Single EIR, MassDOT indicated that ASCT was previously studied as part of the Route 28 Corridor Project but rejected. Thus, in lieu of this mitigation, the Proponent intends to replace signal equipment and improve pedestrian connectivity and access along the project’s Land Boulevard frontage (under DCR jurisdiction) and at the intersection of Land Boulevard with Cambridgeside Place and the Hotel Sonesta driveway. Signal upgrades will include hybrid video/radar cameras for detection of pedestrians, bicycles and vehicles, as well as audible countdown timers and light touch Accessible Pedestrian Signal (APS) pushbuttons. Comments from DCR acknowledge and agree with these measures.

MassDOT comments acknowledge that conditions at the O’Brien Highway (Route 28)/Charles River Dam Road at Land Boulevard/Charlestown Avenue intersection are expected to be at LOS F even without the project, and will continue at LOS F under Build conditions.

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Nevertheless, the Proponent has agreed to a traffic and transit monitoring program (further described below) with a commitment to reserve certain amounts in escrow for future mitigation that may be required as a result of monitoring. The Single EIR proposed that $60,000 would be set aside in escrow to support a Signal Corridor Timing Study (SCTS) for the Route 28 corridor between Third Street and Museum Way and for the Land Boulevard corridor between Route 28 and Binney Street. An additional $360,000 would then be made available for implementation of signal timing modifications as warranted, based on the results of the SCTS. These funds would be returned to the Proponent for other potential improvements, if funds remain at the earlier of two years after completion of the project, or ten years following issuance of the building permit for the first building.

Comments from MassDOT and the City reiterate that the use of ASCT has not proven to be an effective strategy for reducing vehicle/SOV usage. MassDOT indicates that the escrowed amounts could be used for the following additional strategies:

• Installation of transit-signal priority equipment along the corridor at locations to be determined by MassDOT and the MBTA; • Installation of in-floating bus stops on Route 28 near Rufo Road; • Extension of the separated bicycle lane on Route 28 northwesterly from Third Street to the Squires Bridge, and southerly from Land Boulevard to Craigie Bridge; and • Upgrading the sidewalks on Route 28 from Third Street to Squires Bridge to provide and ADA-compliant path of travel for pedestrians.

Comments from the City also recommend that escrow funds be dedicated to bus, bicycle and pedestrian improvements.

During the review period, the Proponent committed to coordinating with MassDOT, DCR, and the City to identify specific mitigation measures that could be implemented as the project is built and occupied over time. This collaboration will identify how the total escrow funds of $420,000 could be spent, as a signal corridor timing study does not appear to be needed in light of comments from the City and MassDOT. In addition, the Proponent has committed to providing funding towards the City’s planning efforts to assess the feasibility of bus priority lanes on First Street, dedicated bicycles lanes on Second Street, and expanded transit/bus service along other local street. The City’s comments confirm that collaboration on the First Street/Second Street Corridor Study is anticipated, and the Proponent has indicated that it has signed a contract to fund this study. As noted above, specific implementation measures recommended by this study would replace the signal improvements originally planned at the intersections under City jurisdiction anticipated to experience degradation in LOS. The Proponent should also work with the City to finalize the parking management and operation plan so as to meet the City’s parking ratios and related requirements.

As noted above, the Single EIR did not identify significant transit impacts. The Proponent has committed to expanding the frequency and ridership capacity of the CambridgeSide shuttle bus, which currently provides free shuttle service from the Kendall Square T stop to the Galleria for an 11-hour period (9:00 AM to 8:00 PM) Monday through Saturday and for a 7-hour period (12:00 PM to 7:00 PM) on Sunday. The Proponent also intends

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to continue to work with the Charles River Transportation Management Association (CRTMA) to consider consolidating and/or coordinating service with the EZRide Shuttle Bus, which operates between North Station and Kendall Square but does not pass by Cambridgeside Mall during the midday period and does not operate on weekends. Comments from the City strongly support this consolidation of the CambridgeSide and EZRide shuttles, indicating that a consolidated and well-marketed shuttle system could provide improved connections and economies of scale. The City indicates that a successful consolidation would require a funding commitment on the part of the Proponent.

Transportation Demand Management (TDM)

The Proponent has committed to the following revised list of TDM measures:

• A ridesharing service provided through the CRTMA; • Sponsorship of BLUEBikes station on Charles Park, near front entrance to CambridgeSide; • Additional strategies including promotion of pedestrian and bicycle facilities, charging market rates for parking, and encouraging employers to work with the Cambridge Office of Workforce Development to hire Cambridge residents, as Cambridge residents are the most likely to use alternative transportation; • Expanded BLUEBikes Sponsorship to include Gold-level corporate membership for a 10-year period for all tenants to encourage biking to the site; and • Language included in lease documents identifying that employers are required to subsidize employees’ public transportation costs up to the federal monthly maximum amount.

Comments from the City indicate that the Proponent’s TDM plan does not meet the City’s standards for comparable projects and is missing key details such as the following:

• Clarifying that employees will be charged directly for parking at market rates, rather than allowing employers to pay the parking fees. Fees paid directly by employees are significantly more effective in reducing drive-alone trips. • Consideration of charging employee parking fees by day instead of monthly to give flexibility to employees who are able to reduce the number of days they drive per week. • Clarifying that lease language requiring employers to subsidize employees' public transportation costs will be provided at 100% up to the federal monthly maximum. • Offering Gold-level corporate Bluebikes membership to all employees with no expiration date, rather than the proposed 10-year duration, because the need to support a bicycle commute will remain in the future • Offering a ride-matching service, regardless of which organization it is associated with. • In addition to subsidizing public transportation to the maximum level allowed by regulation, there should be a commitment to subsidize bicycle transportation.

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I strongly encourage the Proponent to clarify and enhance its TDM program, which will have GHG reduction benefits as well as traffic improvement, during final design. The City has indicated that measures related to bicycle parking should not be counted as a mitigation measures, as they are already required by zoning.

The Proponent has committed to a traffic and TDM monitoring program, including the following components:

• Survey of customers and employees (including tenants) to determine travel modes, times of arrival and departure, home location, and preferences for ride sharing among other information; • Provision of garage and parking counts for a one-week period on an annual basis; • Updates of tenants, leased building area, employee totals, and year-to-year mode split comparison, including the calculation of the Employee and Patron SOV rate; and • Updates of the usage of required TDM measures including status of Emergency Ride Home (ERH), loaner bikes for Hotel Marlowe, and Electric Vehicle (EV) charging stations on site.

This reporting will be provided to the City as part of the TDM Annual Report Summary, which has been provided since 2011. The monitoring program will apply to all tenants on an annual basis and will commence one year after issuance of a certificate of occupancy. As discussed above, the Proponent has agreed to reserve amounts in escrow to support additional traffic signalization measures if certain thresholds are exceeded through monitoring. Namely, additional measures will be required if the SOV mode split percentages as identified in the revised traffic study are not achieved as of two years following the later of issuance of a certificate of occupancy for the second building, or the issuance of a certificate of occupancy for more than 325,000 sf of new gross floor area. I note that, to the extent the results of monitoring result in material changes to project design or mitigation measures beyond the scope of disclosures made in this Single EIR, a Notice of Project Change (NPC) filing may be required.

Stormwater and Wastewater

As required by the Scope, the Single EIR provided additional analysis of stormwater and wastewater connections proposed for the project. As previously described in the EENF, the project proposes to disconnect five existing storm drain connections to the MWRA Marginal Conduit on Land Boulevard, and re-direct the runoff to a newly constructed storm drain that will convey stormwater to Outfall CAM017 at Binney Street, which ultimately discharges to the Charles River. Because this project proposes to disconnect stormwater flows from the MWRA combined sewer conduit, it is presented as a mitigation measure that will contribute to meeting the infiltration and/or inflow (I/I) removal requirements imposed by the City pursuant to 314 CMR 12.04 for the addition of new wastewater flows to the City’s sewer system.3

3 As described in the Single EIR, City ordinances and DEP regulations at 314 CMR 12.04 require, for new sewer discharges exceeding 15,000 gpd, that four (4) gallons of I/I be removed from the system for each gallon of new wastewater discharge. Thus, with an increase of 104,770 gpd of wastewater for the project, I/I removal of 419,080 gallons is required.

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According to the Single EIR, it was discovered during project design that the City of Cambridge Department of Public Works (DPW) has a long-pending I/I removal plan to remove stormwater connections to the MWRA Marginal Conduit on Land Boulevard. The project is therefore consistent with these City plans. The Single EIR confirms that, based on the 1-year, 6- hour storm event (1.72 inches of rain) required to be assessed by MassDEP regulations, an estimated 393,629 gallons of stormwater runoff will be removed from the MWRA combined sewer system. This is almost the total volume needed to meet the City’s I/I requirements, and is expected to provide enough I/I mitigation for the core mall and three redeveloped buildings. The Proponent expects to deliver what it called the “Land Boulevard mitigation project” (i.e., placement of interceptor drains on Land Boulevard to redirect stormwater away from the MWRA combined sewer) prior to the final certificate of occupancy for the first new ground-up building. At the beginning of the new First Street buildings (i.e. 80 & 90 and 110 First Street), the Proponent will review actual occupancy of the core mall and 20 CambridgeSide and 60 First Street buildings (which will be built in the initial phases) to determine if additional mitigation is still needed. If so, the Proponent will work with the City to locate another City I/I removal project to remove the additional required 25,451 gallons.

The Single EIR also evaluated the hydraulic capacity of the project’s stormwater drainage system in light of 2-year, 10-year, 25-year, and 100-year storm conditions in accordance with City of Cambridge and MassDEP requirements. The drainage system on Land Boulevard (currently connected to the MWRA combined sewer) can handle between 845,000 to 2.3 million gallons of peak runoff in these storm ranges. Under proposed conditions, the newly constructed storm drains are anticipated to handle 950,000 to 2.2 million gallons of peak runoff between 2- year to 100-year storm conditions. This indicates that the peak runoff in higher storm events (10, 25, and 100-year storms) that will be delivered to CAM017 and the Charles River will be reduced by 4 to 8%, as compared to stormwater flows currently connecting to the MWRA conduit (indicating that more water will be infiltrated prior to discharge). The Single EIR concludes that approximately 1.5 million of stormwater runoff would be diverted from the MWRA Marginal Conduit and the combined sewer system. This, in turn, is expected to free up the equivalent volume at the Marginal Conduit to accommodate overflows from other locations such as the Binney Street overflow conduct, and thereby reduce secondary overflows of untreated sewer discharge to the Binney Street regular at the CAM017 outfall to the Charles River (which currently occurs under intense storm events).

The Single EIR described the water quality benefits associated with design of the interceptor drainage system at Land Boulevard. While the system’s nominal design capacity is the 10-year storm, it is oversized in order to have settling velocities in small (street-washer) storms and could carry the 25-year storm without surcharging from connected catch basins. This design promotes low velocities during small rainfall events which allows for longer residence times in the infiltration pipe sections with higher resulting infiltration percentages. According to the Single EIR, the initial analysis has shown that significant removal of particles associated with phosphorous and bacteria in the infiltrated stormwater will occur and will meet the City’s 65% phosphorous load reduction requirement. The Stormwater Management Technical Analysis attached to the Single EIR indicates that all other stormwater standards of MassDEP will be met, and that Total Suspended Solids (TSS) removal will be achieved through best management

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practices such as deep sump/hooded catch basins, treebox filters, and infiltration trenches (such as the ones in the Land Boulevard mitigation project) to promote infiltration and treatment of stormwater prior to discharge. The project is not adding new impervious surface, so MassDEP’s standards for redevelopment projects would apply.

Comments from MWRA acknowledge the benefits of I/I removal associated with disconnecting stormwater connections from the MWRA Marginal Conduit on Land Boulevard. The current work plan schedule is to start the new drain construction in April or May 2021 as soon as permits have been approved and the road can be opened. Drain construction is scheduled to be completed by November 2021. The Proponent should coordinate with MWRA and the City on construction permitting and schedule. MWRA indicates that any discharge of groundwater and/or stormwater to the sewer system during construction activities such as pile drilling is prohibited if discharge to an existing or project storm drain is a feasible option, pursuant to 360 C.M.R. 10.091-10. A Sewer Use Discharge Permit may be required to the extent the project may discharge laboratory wastewater and or/photoprocessing wastewater into the MWRA sanitary sewer system. Due to the project’s proximity to MWRA infrastructure, it will require permitting under Section 8(m) of Chapter 372 of the Acts of 1984, which enables the MWRA to issue permits to build, construct, excavate, or cross within or near an easement or other property interest held by the MWRA, with the goal of protecting MWRA-owned infrastructure.

Climate Change

Greenhouse Gas Emissions (GHG)

The Single EIR responded to several comments from the Massachusetts Department of Energy Resources (DOER) indicating disagreement with modeling assumptions used in the GHG analysis submitted by the Proponent. In particular, DOER and the City noted in prior comments that there may be an error in the energy model as indicated by the output which appears to under- predict the building’s energy use (and therefore overstate the energy reductions achieved by the Mitigation Case). The Single EIR appears to adjust downward the assumption of a 98% reduction in energy use for heating in residential buildings to 32% after considering the need for supplemental heat and ventilation fans. The Single EIR also acknowledges that heating energy consumption under the Mitigation Case is not lower than the expected energy use with Passivehouse standards, and has adjusted downward the “fenestration” rate (% of window area) from 40% to 24% for baseline modeling, as requested by DOER. The overall mitigation for stationary sources has been adjusted downward to 13.8% from the 15.2% claimed in the DEIR, as compared to Base Case.

Comments from DOER continue to indicate that the proposed energy efficiency measures are likely to deliver mitigation of only 7-8%, especially when considering the 10% reduction already required by the Stretch Code (for which the Proponent takes credit in its modeling). DOER indicates that adoption of Passivehouse design for residential buildings would increase mitigation levels for the residential component of the project to 39%, and adoption of efficiency electrification for all components together with Passivehouse design for residential and solar-PV would increase overall mitigation to 26% for the entire project. DOER indicates that Passivehouse design would produce cost savings for the building occupants, even when

EEA# 16176 Single EIR Certificate October 2, 2020

considering the up-front premium cost of building to Passivehouse standards. This analysis assumes a financing period of 30 years, 5% interest, and considers the value of MassSave incentive for Passivehouse ($3,000/unit); the value of Alternative Energy Credits was not considered but would add additional value to the Passivehouse scenarios. DOER acknowledges that the project is making key commitments to improve building envelope and reduce heating and cooling loads, in particular, by committing to providing residential space heating through electric air source heat pumps/VRF and by committing to set aside 50% of net roof area for solar PV (corresponding to 19,500 sf or 252 kW). I commend the Proponent for taking proactive energy efficiency measures, and encourage further consideration of Passivehouse design.

As required by the Scope, the Single FEIR evaluated the feasibility of purchasing steam energy from the Vicinity Energy (VE) district steam network for the project’s commercial buildings. The emission analysis compared the CO2 emissions associated with heating commercial buildings 1, 2 and 3 with the proposed high-efficiency (97%) condensing gas-fired boilers to the use of process steam delivered to the site by VE. While the difference is small (+10%), the results suggest district steam would have higher GHG emissions than on-site high- efficiency condensing boilers. The Proponent therefore has not elected to purchase steam energy but will continue to explore this option for future phases.

According to the Single EIR, the residential components of the project will commence in later phases, likely starting in 2023. The Proponent commits to evaluating Passivehouse design again at the time of implementation in light of “technological advancements and further adoption by the industry construction trades” that may be anticipated by that time. Given the clear GHG benefits of Passivehouse design and the apparent cost effectiveness of this strategy when considering available incentives, I strongly encourage the Proponent to consider this option for all residential buildings.

Adaptation and Resiliency

As required by the Scope, the Single EIR provided a justification for use of 2070 as the planning horizon for the project. The Proponent indicates that 50 years is more than the economic life of the proposed buildings and more than the physical life of most building mechanical systems. This planning horizon is also consistent with the City of Cambridge Climate Vulnerability Assessment (CCVA) and Climate Change Preparedness and Resilience Plan (CCPR). The Proponent is elevating structures to comply with these local standards, and commits to continuing to evaluate Passivehouse for future phases.

Construction Period

The Single EIR provided details regarding construction phasing and procedures, including by attaching a draft Construction Management Plan (CMP). Permitting for the project is anticipated to be completed by the end of 2020, with initial buildings to be completed between 2021-23 and remaining phases to occur beyond 2023. Each phase will be accompanied by a CMP that will address material management, staging and delivery routes; pedestrian and bicycle safety; noise impacts and work hours; waste management, demolition, dust control and asbestos regulation; and site work, off road vehicles and emissions.

EEA# 16176 Single EIR Certificate October 2, 2020

Measures proposed to avoid, minimize and mitigate construction period impacts include the measures listed below:

• The limits of the construction zones will be fenced and secured to properly maintain safety between the construction zone and the community. • Designated truck routes will be established in coordination with the Cambridge Traffic, Parking & Transportation Department to govern how trucks access the Project site. • Pedestrian routes will be shifted, as necessary, into existing vehicle travel lanes. In those cases, pedestrian lanes will be protected by jersey barriers and fencing, and ADA accommodations will be provided. Additionally, signage and temporary crosswalk will be created, if needed, to redirect pedestrian traffic around the site. • Every reasonable effort to minimize noise impact from Project construction activities will be considered and implemented, including (but not limited to) use of appropriate mufflers on all equipment and on-going maintenance of intake and exhaust mufflers, and alternative items of equipment when possible; turning off idling equipment; use of less noisy construction operations and techniques where feasible (e.g., mixing concrete off-site instead of on-site); and scheduling equipment operations to keep average levels low, such as by synchronizing noisiest operations with times of highest ambient levels, and to maintain relatively uniform noise levels. • Construction and demolition waste will be removed from the site via licensed waste haulers to a licensed recycling center for separation, reprocessing, and recycling. For materials that cannot be recycled, solid waste will be transported in covered trucks to an approved solid waste facility, in accordance with MassDEP regulations. • General contractors will be required to adhere to best management practices, including the use of wetting agents to keep dust at a minimum and covering or treating exposed soil. • While it is not anticipated that asbestos containing materials will be encountered, should any be discovered during any pre-demolition surveys or during the course of demolition, they will be abated by a licensed contractor in accordance with MassDEP asbestos regulations.

As described in the Single EIR, throughout the construction of the Project, development team members will regularly communicate status of the construction and associated impacts through a variety of means, including publicly noticed meetings and project website updates.

Mitigation and Draft Section 61 Findings

The Single EIR contained a separate chapter on mitigation measures and draft Section 61 Findings for each Agency taking action on the project. It described mitigation measures and contained a table demonstrating the responsible party for implementing mitigation, monetary amounts where applicable, and a schedule for implementation. The draft Section 61 Findings will serve as the primary template for State Agency Permit conditions, and should be revised or updated as appropriate based on comments received and further consultation with Agencies after issuance of this Certificate (particularly, in relation to traffic/transit mitigation commitments). As

EEA# 16176 Single EIR Certificate October 2, 2020

described in the Single EIR and prior MEPA documents, the Proponent has committed to implement the following measures to avoid, minimize, and mitigate environmental impacts (also see Table 7-1 Summary of Proposed Mitigation Measures):

Chapter 91 Waterways

• Incorporation of an increased building setback for new buildings along First Street to accommodate wider sidewalk, improved plantings and furnishings and other pedestrian and bicycle amenities; • Phased contribution of $1,000,000 to the City of Cambridge’s Tree Replacement Fund; • Installation of new pocket parks on First Street to provide additional on-site open space and to encourage pedestrian engagement with the project; • Establishment of an Open Space and Retail Advisory Committee to provide input on the programming of the local retail and open spaces at the Project; • Hosting of community engagement events in or within the vicinity of the Project on a regular basis, which may include a seasonal farmer’s market and installation of winter garden(s); and • Upgrading many of the open spaces in and around the Project site, including upgrades to Canal Park, Thorndike Way, First Street and Cambridgeside Place, to further enhance activation and public use of those spaces.

Traffic and Transit

• Physical improvements to intersection of Land Boulevard with Cambridgeside Place and the Hotel Sonesta driveway to upgrade traffic signal equipment; • Expansion of CS Shuttle to provide increased frequency and ridership capacity, doubling the size and number of buses as well as their hours of operation; • Continue to work with the CRTMA on consolidation and/or expansion of services with the EZRide shuttle and the other services offered by the CRTMA; • TDM Strategies including those listed in above sections; • Support for the City’s transit planning efforts, including First Street/Second Street Corridor Study and East Cambridge Transit Expansion Program; • Comprehensive Traffic and TDM Monitoring Plan (detailed above), including commitments to escrow up to $60,000 for Signal Corridor Timing Study and up to $360,000 for Signal Timing Optimization/Adaptive Signal Control Technology Installation if conditions warrant based on monitoring; and • As part of a maintenance agreement between the Proponent and the City of Cambridge, improve and maintain pathways adjacent to the Lechmere Canal in order make the area under the Land Boulevard Bridge (under MassDOT jurisdiction) more attractive.

Stormwater and Wastewater

• Land Boulevard I/I removal project to disconnect the City’s storm drainage systems from the MWRA Marginal Conduit. Per the DEP 314 CMR 12.00 regulations this removes an average of 393,629 gallons.

EEA# 16176 Single EIR Certificate October 2, 2020

• In larger storm events this mitigation could remove more than 1,500,000 gallons and reduces overflows at the MWRA Prison Point CSO. • The elimination of storm flows from the MWRA Marginal Conduit frees up an equivalent volume for the marginal conduit to accommodate overflows from the Binney Street overflow conduit. • The gained capacity in the MWRA Marginal Conduit reduces secondary overflows at the Binney Street regulator at the CAM 017 outfall to the Charles River. • The project will otherwise comply with MassDEP’s stormwater management standards and will implement best management practices to enhance infiltration and treatment prior to discharge.

GHG Emissions

• Using higher efficiency than Code roof insulation, and window glass; • Installing cool roofs with a light-colored material; • Using cold-climate air source heat pumps with variable refrigerant flow (VRF) in the residential building; • Using higher efficiency than Code heating and cooling systems; • Using energy recovery ventilation (ERV) systems in all new buildings; • Using higher efficiency than Code domestic/non-domestic hot water systems; • Interior and exterior lighting systems with a lower light power density than Code; • Sealing, insulating, and testing HVAC supply ducts; • Energy management systems; • Using Energy STAR electric appliances, where possible; • Providing solar-ready roof space on the new roofs (50% of net roof area); • TDM strategies including those detailed above; and • Commitment to provide a self-certification to the MEPA Office, signed by an appropriate professional, upon construction of the project. The certification will identify either of the following: (1) all of the energy efficiency mitigation measures adopted by the Project as part of the Mitigation Alternative have been implemented; or (2) an equivalent set of energy efficiency mitigation measures, which together are designed to achieve the same percentage reduction in CO2 emissions as the Mitigation Alternative, when compared to the Base Case, based on the same modeling assumptions in the GHG Report, have been adopted.

Construction Period • See above

Conclusion

Based on a review of the Single EIR, comment letters, and consultation with State Agencies, I find that the Single EIR adequately and properly complies with MEPA and its implementing regulations. MassDOT/MBTA and other State Agencies shall forward their final Section 61 Findings for publication in the Environmental Monitor.

EEA# 16176 Single EIR Certificate October 2, 2020

October 2, 2020 ______Date Kathleen A. Theoharides

Comments received:

9/25/20 City of Cambridge 9/25/20 Massachusetts Water Resources Authority (MWRA) 9/25/20 Massachusetts Department of Transportation (MassDOT) 9/25/20 Massachusetts Department of Conservation and Recreation (DCR) 9/25/20 Massachusetts Department of Environmental Protection (MassDEP) 9/29/20 Massachusetts Department of Energy Resources (DOER)

KAT/TTK/ttk

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 C. Woodcock Lt. Governor Commissioner

29 September 2020

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

RE: Cambridgeside 2.0, Cambridge, Massachusetts, EEA #16176

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 Single Environmental Impact Report (SEIR) for the above project. The proposed project consists of about 775,000 square feet of office/laboratory and 175,000 square feet of residential (200 residential units).

Executive Summary

The SEIR analyses show that Passivehouse for the residential and efficient electrification of the office would yield significant emissions reduction and be cost effective. However, neither of these measures were committed to by the proponent. We recommend that these measures be made commitments (Passivehouse for residential and efficient electrification for residential and office).

Notably, the project is committing to efficient electrification (air source heat pumps/VRF) for residential building space heating. The project is also committing to significant envelope improvements in both buildings. We commend the project for these significant mitigation measures.

Cambridgeside 2.0, EEA #16176 Cambridge, Massachusetts

Passivehouse

Focusing on just the residential portion of the project, Passivehouse would improve emissions reduction by about x5. In summary:

• The currently-committed efficiency strategies deliver a Mitigation Level (ML) of 8%. This is accomplished with improved windows, roof, and efficient electrification.

• Mitigation Level can be improved to 39% by building to Passivehouse standards.

Passivehouse is also much more affordable than currently proposed, as illustrated below:

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Cambridgeside 2.0, EEA #16176 Cambridge, Massachusetts

Referencing above, currently proposed improvements would reduce annual heating and cooling costs by about $135 per residential unit compared to Code.

In contrast, a Passivehouse option would reduce each unit’s annual heating and cooling costs by up to $527 considering even the additional cost to build to Passivheouse standards. Over 30 years, this translates to more than $3.1M in reduced costs for the building residents.

The above shows utility costs (the blue portion of the bar) and, for the Passivehouse scenarios, the cost of financing Passivehouse improvements (the red portion). The SEIR submission uses a Passivehouse “premium” cost of 3% (or $6.90/sf) which is consistent with experience with low rise Passivehouse1. Also shown in the illustration is a scenario with premium cost of 3.8% (or $8.88/sf) which is consistent with experience in high-rise multifamily2. We included both to demonstrate likely low and high range of costs. The results demonstrate that Passivehouse is more affordable than currently proposed even if the premium costs approach high-end range.

The above also assumes a financing period of 30 years, 5% interest, and considers the value of MassSave incentive for Passivehouse ($3,000/unit). The above does not consider the value of Alternative Energy Credits which could provide additional value to the Passivehouse scenarios.

In summary, Passivehouse should be a committed measure for the residential units given the emissions and cost benefits.

Pathway to 26% Mitigation Level – Whole Project

Examining all buildings (both residential and office):

• The currently-committed efficiency strategies deliver a Mitigation Level (ML) of 7%. This is accomplished with improved windows (all buildings), improved roof insulation (all buildings), and efficient electrification of the residential building. Notably, the project is already committing to efficient electrification (air source heat pumps/VRF) for residential building space heating. We commend the project for this significant mitigation measure.

• Mitigation Level can be improved to 38% as follows:

o Efficient electrification of the office would increase ML to 11% o Passivehouse for the residential improves ML to 21% o Installing solar PV on committed PV-ready areas improves ML to 26%.

1 Reference 1 -data set used in following article: https://www.post- gazette.com/business/development/2018/12/31/pa-affordable-housing-tax-credits-pennsylvania-housing-finance- agency-passive-house-design/stories/201812190012 2 Reference 2- http://www.fxcollaborative.com/projects/182/feasibility-study-to-implement-the-passivhaus- standard-on-tall-residential-buildings/

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Cambridgeside 2.0, EEA #16176 Cambridge, Massachusetts

Building Envelope Performance

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

• Continuous insulation; • Reducing air infiltration; • Reducing thermal bridges; • Limiting or eliminating use of glass “curtain wall” and spandrel assemblies; • Maximizing framed, insulated walls sections; • Maintaining window at code levels.

Beginning in August 2020, Massachusetts energy code amendments require conformance with 2018 IECC Section C402.1.5 which mandates that the aggregate performance of all above-grade surfaces conform to the wall performance factors in IECC Table C402.1.4 and C402.4 and fenestration values in C402.4.1 and C402.4.3.

Per the SEIR, the project is committing to the following:

• All buildings, including the lab/office, are completely avoiding glass curtain wall/spandrel assemblies. All vertical faces are either built, insulated wall (R-0.055) or window (R-0.27 for the residential and 0.29 for the commercial).

• All buildings are committing to R-36c.i. roofs.

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Cambridgeside 2.0, EEA #16176 Cambridge, Massachusetts

Committed vertical envelope performance (vertical walls and windows) for the buildings are shown below. For comparison, vertical envelope performance required for code starting in November 2020 is also shown. Values shown are aggregate values and incorporate effect of windows and walls. Note, the project is committing to no curtain wall in either building as shown in the SEIR.

Building November 2020 Committed Improvement in U- Code minimum value performance (Aggregate U value) (Aggregate U value) Residential 0.16 0.11 32% Lab/office 0.16 0.13 23% Vertical U value

Rooftop Solar PV

Rooftop PV can provide significant GHG benefits as well as significant financial benefits. The SIER clarified its commitment to solar ready roofs as follows:

• Total roof area is 59,000-sf. This area may change pending final building footprint approval from the City, according to the submission.

• A detailed analysis shows that after accounting for mechanical equipment, shading, setbacks, vents, etc about 39,000-sf of space exists to house PV. This is called the “net roof area”.

• The project is committing to ensure that 50% of the net roof area remains solar ready. Accordingly, 19,500-sf of area will be set aside to be solar ready. This area could accommodate 242 kW of solar PV.

Key Mitigation Commitments

Key commitments in the SEIR are as follows:

1. No curtain wall assemblies will be used on the project.

2. Aggregate vertical U will be:

a. Residential: U-0.11. b. Office buildings: U-0.13

3. Roof performance will be R-36c.i. for all buildings

4. Residential space heating will be electric air source heat pump/VRF and natural gas will not be used for space heating in the residential building.

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Cambridgeside 2.0, EEA #16176 Cambridge, Massachusetts

5. Rooftop solar readiness will be 19,500-sf (252 kW)

6. Residential building performance will be 26 kBtu/sf-yr or about 29% lower than a baseline of ASHRAE 90.1-2013 plus three additional C406 measures. We noted in our EENF comments that 25 kBtu/sf-yr appears relatively low for the improvements being considered. The SEIR affirms the accuracy of 26 kBtu/sf-yr, however.

7. Office building performance will be 28 kBtu/sf-yr or about 13% lower than a baseline of ASHRAE 90.1-2013 plus three additional C406 measures. We noted in our EENF comments that 28 kBtu/sf-yr appears relatively low for the improvements being considered. The SEIR affirms the accuracy of 28 kBtu/sf-yr, however.

Addition Recommended Mitigation Commitments

We recommend the following mitigation measures be also included, based on their emissions reduction and cost effectiveness.

1. Passivehouse for the residential building.

2. Expand electric air source heat pump/VRF space heating to the office portions of the project. Remove natural gas for space heating from the office.

Sincerely,

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

Brendan Place Clean Energy Engineer Massachusetts Department of Energy Resources

Page 6 of 6

September 25, 2020

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

Subject: EOEEA #16176 – Single Environmental Impact Report CambridgeSide 2.0, Cambridge, MA

Dear Secretary Theoharides:

The Massachusetts Water Resources Authority (MWRA) appreciates the opportunity to comment on the Single Environmental Impact Report (SEIR) submitted New England Development (the “Proponent”) for CambridgeSide 2.0 (the “Project”). The Project involves the mixed-use redevelopment of the existing CambridgeSide development (the Project site) in East Cambridge, which was built in 1990 and includes the Galleria mall, office uses, hotel space and open space known as Canal Park. The Project will retain existing active retail and office uses as well as the public sky-lit atrium. Former anchor stores and the above ground garage will be redeveloped to generate an additional 575,000 net new square feet (sf), expanding the existing approximately 1.09 million sf retail destination to an approximately 1.67 million sf mixed-use development. Approximately 175,000 net new sf will be devoted to residential uses and 400,000 net new sf will be devoted to commercial space anticipated to include a combination of office, laboratory, restaurant and retail uses.

MWRA previously comments on the Project Expanded Environmental Notification Form (EENF) on April 24, 2020. MWRA’s comments on the SEIR continue to address stormwater issues, wastewater flows and the need for Infiltration and Inflow (“I/I”) removal, Toxic Reduction and Control (TRAC) discharge permitting, and MWRA Enabling Statue Section 8(m) permitting.

Stormwater and Wastewater

Section 4.4.1 of the SEIR summarizes I/I mitigation proposed for the Project. The entire Land Boulevard mitigation project will be delivered prior to the final certificate of occupancy of the first new ground-up building. At the beginning of the subsequent phase, the Proponent will review the actual occupancy to determine if additional mitigation is needed. If so, the Proponent will work with the City to locate another City I/I removal project that the Proponent would implement to meet any additional I/I requirements in connection with development of the subsequent phase buildings on First Street.

The SEIR states the proposed interceptor storm drain in Land Boulevard that will remove the City drains from the MWRA’s Marginal Conduit is under design. Design and construction discussions will continue with the MWRA and the Cambridge Department Public Works. The design work includes the necessary permit applications scheduled for submission by the end of 2020. The current work plan schedule is to start the new drain construction in April or May 2021 as soon as permits have been approved and the road can be opened. Drain construction is scheduled to be completed by November 2021. The first two buildings scheduled for construction, 60 First Street (the former Sears) and 20 CambridgeSide Place (the former Macy’s) are both reconstruction projects leaving the underground garage and lower floors in place. There is no site excavation or general dewatering proposed. The only possible groundwater discharges could be from artesian seepages from the pile insertion holes drilled through the lower garage floor and underlying structural mat.

TRAC Discharge Permitting

The Project site is served by separate municipal sewer and storm drain systems. However, stormwater generated on parts of the Project site currently enters the combined sewer system. The discharge of groundwater and/or stormwater to the sewer system during construction activities such as pile drilling is prohibited if discharge to an existing or project storm drain is a feasible option, pursuant to 360 C.M.R. 10.091-10.

A Sewer Use Discharge Permit is required prior to discharging laboratory wastewater, and or/photoprocessing wastewater associated with the Project into the MWRA sanitary sewer system. For assistance in obtaining this permit, a representative from the proposed laboratory and commercial space should contact John Norton, Industrial Coordinator, in the TRAC Department at (617) 305-5656. The SEIR states that the buildings and its mechanical and plumbing systems will meet the requirements for office/laboratory buildings and will allow for the installation of pretrement that might be required. If a tenant requiring a Sewer Use Discharge permit is secured during final design, the Proponent and Tenant will apply. If no tenant is under agreement before the buildings are constructed, future tenants must coordinate with MWRA directly to obtain this permit if necessary.

Section 8(m) Permitting

Section 8(m) of Chapter 372 of the Acts of 1984, MWRA’s Enabling Legislation, enables the MWRA to issue permits to build, construct, excavate, or cross within or near an easement or other property interest held by the MWRA, with the goal of protecting Authority-owned infrastructure. Due to the proximity of MWRA infrastructure, utility work in Land Boulevard associated with the Project will require an 8(m) permit. As noted in the SEIR, the Proponent should continue to coordinate with Kevin McKenna in the Wastewater Operations Permitting Group at (617) 305-5956 for assistance related to this matter.

2

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

Sincerely,

Beth Card Director Environmental and Regulatory Affairs

cc: John Viola, DEP Katherine Watkins, Assistant Commissioner for Engineering, City of Cambridge Catherine Daly-Woodbury, Engineering Project Coordinator, City of Cambridge

3

September 25, 2020

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

RE: Cambridge: CambridgeSide 2.0 – SEIR (EEA #16167)

ATTN: MEPA Unit Tori Kim

Dear Secretary Theoharides:

On behalf of the Massachusetts Department of Transportation, I am submitting comments regarding the Single Environmental Impact Report for the CambridgeSide 2.0 project in Cambridge, as prepared by the Office of Transportation Planning. If you have any questions regarding these comments, please contact J. Lionel Lucien, P.E., Manager of the Public/Private Development Unit, at (857) 368-8862.

Sincerely,

David J. Mohler Executive Director Office of Transportation Planning

DJM/jll

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

Cambridge – CambridgeSide 2.0 Page 2 9/25/2020 cc: Jonathan Gulliver, Administrator, Highway Division Patricia Leavenworth, P.E., Chief Engineer, Highway Division John McInerney, P.E., District 6 Highway Director Charles Clayton, Director, Transit-Oriented Development, MBTA Neil Boudreau, Assistant Administrator of Traffic and Highway Safety Planning Department, City of Cambridge Boston Region Metropolitan Planning Organization

MEMORANDUM

TO: David Mohler, Executive Director Office of Transportation Planning

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

DATE: September 25, 2020

RE: Cambridge: CambridgeSide 2.0 – SEIR (EEA #16176)

The Public/Private Development Unit (PPDU) has reviewed the Single Environmental Impact Report (SEIR) submitted by New England Development (“the Proponent”) for the CambridgeSide 2.0 project in Cambridge. The proposed project is an expansion of the existing CambridgeSide Galleria Mall, an approximately 1.1 million square foot retail development with 2,490 parking spaces. The project involves the repurposing of square footage and parking space. The redevelopment would result in 200 residential units, 210,000 square feet of office space, and 665,000 square feet of research and development space (the “Project”). The project site is located at 100 CambridgeSide Place, 106-108 First Street, and 60-68 First Street in Cambridge. The site is bounded by Lechmere Canal Park to the north, Edwin H. Land Boulevard to the south and east, and commercial and residential development to the west.

Based on the information presented in the SEIR, the unadjusted trip generation estimate is 10,276 daily trips, which exceeds the Massachusetts Environmental Policy Act (MEPA) threshold for trip generation (3,000 new trips). Accordingly, the Project is categorically included for the preparation of an Environmental Impact Report (EIR). When applying mode share, existing trips, and reallocation of space, the Project is expected to generate 1,744 adjusted weekday daily vehicle trips. This would bring the total trips generated by the site from 5,758 to 7,502 daily trips. The Project also involves the removal of 795 vehicle parking spaces, leaving a total of 1,695 parking spaces.

The Project may require a Vehicular Access Permit from MassDOT if proposed traffic signal improvements along O’Brien Highway (Route 28) are approved in the future.

The SEIR includes an updated Transportation Impact Assessment (TIA) prepared in general conformance with the current MassDOT/EEA Transportation Impact Assessment Guidelines. The SEIR includes a comprehensive mitigation program consisting of the following:

Ten Park Plaza, Suite 4150, Boston, MA 02116 Tel: 857-368-4636, TTY: 857-368-0655 www.mass.gov/massdot Cambridge- CambridgeSide 2.0 Page 2 9/25/2020

• on-site and off-site roadway improvements; • transit, bicycle and pedestrian improvements to facilitate access to the site; • alternative transit services; • an Transportation Demand Management program; and • a Transportation Monitoring Program.

The SEIR includes an update to the transportation study to address the following issues reflected in the MassDOT comment letter on the Expanded Environmental Notification Form (EENF).

Study Area

The SEIR includes revised trip distribution and assignment and provides sufficient justification for not adding the following intersections to the study area.

• Main Street at Vassar Street at Galileo Galilei Way; • Galileo Galilei Way at Broadway; • The right turn from the Longfellow Bridge to Land Boulevard Southbound; • The right turn from Land Boulevard Southbound to Main Street; and • The U-turn from Land Boulevard Southbound to Land Boulevard Northbound.

We concur that the project trip generation at these intersections is not significant enough to require analysis for the purpose of this TIA.

Transit Analysis

The SEIR includes a revised transit analysis with a detailed presentation of the project’s impacts on the surrounding transit system with summary tables for the anticipated demand in terms of the MBTA’s Service Delivery Policy for transit and bus services. The Proponent consulted with the MBTA during the preparation of the SEIR on the appropriate methodology and metrics to use for the different transit modes to conduct the analysis. The revised transit analysis is based on comfort metrics for the bus lines and on volume to capacity (V/C) for the transit lines. The analysis indicates that both the Red and Green Lines would continue to have sufficient capacity to accommodate the additional trips associated with this project and the bus lines indicates that all routes exceed the SDP minimum for bus passenger minutes during comfortable conditions.

Network Operations

The updated TIA has addressed the comments raised in the EENF comment letter regarding the queuing analysis, lane configuration at the O’Brien Highway/Third Street/Private Driveway intersection, and mitigation at the O’Brien Highway/Charles River Dam Road at Land Boulevard/Charlestown Avenue intersection. Accordingly, the TIA includes revised analyses that indicate that the study area intersections would not result in a Cambridge- CambridgeSide 2.0 Page 3 9/25/2020

significant increase in average or maximum queues as compared to the 2027 No-build conditions. A few instances of exceedances of queue storage at some lanes already exist and are not directly related to the addition of project traffic. Regarding the lane configuration at the O’Brien Highway/Third Street/Private Driveway intersection, it was determined that the driveway was not part of the signal operations; therefore, the traffic analysis does not need to be revised. Lastly, the O’Brien Highway/Charles River Dam Road at Land Boulevard/Charlestown Avenue intersection is currently and is expected to continue to operate at Level of Service F in the future irrespective of site trip generation.

As overall mitigation for the project study area, the Proponent has committed to fund a Signal Corridor Timing Study (SCTS) for the Route 28 Corridor between Third Street and Museum Way and for the Land Boulevard Corridor between O’Brien Highway and Binney Street. The study will review the effectiveness of modified timing or phasing of traffic signals on these corridors to improve traffic flow, recognizing that improvements to signal equipment and detection are proposed to be implemented by others prior to CambridgeSide’s proposed completion. The SCTS can also review the applicability of Adaptive Signal Control Technology (ASCT) to these corridors, after the improvements by others have been constructed. The Proponent has committed approximately $420,000 towards the study and implementation of these improvements. However, MassDOT does not believe at this time that an ASCT system would provide significant benefit to the Route 28 corridor. We would suggest that these funds be redirected towards non-SOV strategies that would have more lasting and significant impacts along this corridor. These strategies to be further developed with MassDOT, DCR, and the City of Cambridge as the project is built may include the following:

• Installation of transit-signal priority equipment along the corridor at locations to be determined by MassDOT and the MBTA; • Installation of in-floating bus stops on Route 28 near Rufo Road; • Extension of the separated bicycle lane on Route 28 northwesterly from Third Street to the Squires Bridge, and southerly from Land Boulevard to Craigie Bridge; and • Upgrading the sidewalks on Route 28 from Third Street to Squires Bridge to provide and ADA-compliant path of travel for pedestrians.

These strategies should be further developed and discussed with MassDOT, DCR, and the City of Cambridge as the project is built and occupied over time.

Draft Section 61 Finding

The SEIR includes a draft Section 61 Finding that summarizes the mitigation measures committed to by the Proponent, including the TDM and the Transportation Monitoring programs. The draft Section 61 Findings outlines the required timing of all mitigation measures associated with the Project and also clarifies how some of the commitments are tied to the monitoring program. The draft Section 61 Finding would be the basis for MassDOT to issue a final Section 61 Finding for the project. Cambridge- CambridgeSide 2.0 Page 4 9/25/2020

MassDOT recommends that no further environmental review be required based on transportation issues. The Proponent should continue consultation with appropriate MassDOT divisions, including the Public/Private Development Unit, the Highway Division District 6 Office and the MBTA prior to the issuance of the Section 61 Finding. If you have any questions regarding these comments, please contact me at [email protected].

Charles D. Baker Kathleen A. Theoharides Governor Secretary

Karyn E. Polito Martin Suuberg Lieutenant Governor Commissioner

Memorandum

To: Anne Canaday, 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 #16176; SEIR ̶ CambridgeSide 2.0, Cambridge, Middlesex County

Date: September 25, 2020

The Department of Environmental Protection Waterways Regulation Program (the “WRP”) has reviewed the above referenced Single Environmental Impact Report (SEIR) EEA #16176, submitted by Tetra Tech, Goulston & Storrs, and Elkus/Manfredi on behalf of New England Development (the “Proponent”) to redevelop and expand the existing CambridgeSide Galleria Mall (“CambridgeSide 2.0”) located on filled tidelands of the Charles River (Lechmere Canal) at 100 Cambridgeside Place, 106-108 First Street, 60-68 First Street in Cambridge, Middlesex County.

Chapter 91 Jurisdiction The proposed changes to the existing licensed project (previously authorized in Waterways License No. 1829 issued in 1988) will require authorization through M.G.L Chapter 91 and the Waterways Regulations at 310 CMR 9.00, as the entire 8.2-acre project site (1.6-acres less than what was previously licensed) is located on filled Private Tidelands of the Charles River (Lechmere Canal) in Cambridge. The proposed project will be reviewed under the Waterways Regulations, including but not limited to the nonwater-dependent provisions of 310 CMR 9.51 through 9.52. 310 CMR 9.53 shall not apply as there are no Commonwealth Tidelands onsite.

Chapter 91 Regulatory Analysis The SEIR has addressed the questions/concerns raised in the WRP’s comment letter for the prior EENF filing, as detailed below: 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

CambridgeSide 2.0 / EEA #16176 / SEIR Page 2 of 2 MassDEP Waterways Comments September 25, 2020

Water Dependent Use Zone: Although the project site does not front the Lechmere Canal and does not have a project shoreline, the Proponent must calculate the weighted average Water Dependent Use Zone (WDUZ) per 310 CMR 9.51(3)(c) on the intervening parcels to confirm whether or not the WDUZ extends into the project site. On Figure 2-2 of the SEIR filing the Proponent calculated the weighted average distance of the WDUZ on the intervening properties and determined that the WDUZ is 25-feet wide. After review of the Proponents weighted average calculations, the Department concurs that the WDUZ does not encroach onto the proposed project site and all existing and proposed nonwater-dependent buildings onsite are outside of the WDUZ.

Nonwater-Dependent Building Height: The Proponent is proposing new residential buildings with varying building heights on top of the existing licensed building footprint. On Figure 2-6 an 2-8 of the SEIR filing, the Proponent provided a plan showing the proposed residential building additions each with setback distances from mean high water to each of the proposed building heights. As shown on Figures 2-6 and 2-7, all the proposed building additions, to be authorized under a new Chapter 91 License, will comply with the present nonwater-dependent building height regulations at 310 CMR 9.51(3)(e), except for the Sears Building (60-68 First Street).

Although the proposed addition on the Sears Building does not meet the present nonwater- dependent building height requirements, the Proponent identifies that Chapter 91 Waterways License No. 1829 issued on August 2, 1988 (prior to promulgation of the nonwater-dependent use regulations in 1990) permitted the Sears Building to be built up to 102 feet above the Ordinary High Water (104.5 NGVD29) or up to 95 feet high, but currently was only built to 55-feet high. Now, the Proponent proposes to construct an addition on the Sear Building up to 85-feet high by amending License No. 1829, which is higher than that which exists but lower than that which was previously authorized. The Proponent points out that the proposed building addition does not trigger a “substantial structural alteration” as defined in 310 CMR 9.02 as changes in the dimensions of a principal building or structure is not increasing more than 10% the height or ground coverage of the building or structure specified in the authorization or license. Although the construction period specified in said License expired and the Licensee only constructed the building to 55-feet high, the Department acknowledges that the existing building can be increased to 85-feet high by amending said License because it does not constitute a substantial structural alteration per 310 CMR 9.02.

The WRP looks forward to receiving a complete Waterways License Application and a Waterways License Amendment Application for the work detailed in the SEIR. If you have any questions, please feel free to contact me at [email protected]