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

May 15, 2020

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

PROJECT NAME : Yards PROJECT MUNICIPALITY : Boston (Allston) PROJECT WATERSHED : EEA NUMBER : 15995 PROJECT PROPONENT : Stop & Shop Supermarket Company LLC and New England Development DATE NOTICED IN MONITOR : April 8, 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 Draft Environmental Impact Report (DEIR) and hereby determine that it adequately and properly complies with MEPA and its implementing regulations. The Proponent must prepare and submit for review a Final Environmental Impact Report (FEIR) in accordance with the Scope provided in this Certificate.

Project Description

As described in the DEIR, the redevelopment project has been revised since the Expanded Environmental Notification Form (EENF) was filed and includes the construction of an approximately 1.23 million-square foot (sf) mixed-use, transit-oriented development on a 10.6-acre site in the neighborhood of Allston. The overall development will include office/lab space (350,000 sf), a grocery store (67,000 sf), ground floor retail/restaurant (50,000 sf), and residential uses (764,000 sf; 868 units). The project also includes a one-acre public open space EEA# 15995 DEIR Certificate May 15, 2020

referred to as the community green, roadway improvements, and a new at-grade direct connection to the Boston Landing commuter rail station, including improved access for pedestrians, bicyclists, vehicles, and buses. The project will consist of the following four buildings (Buildings A-D):

. Building A: 85-foot (ft) tall building located on the southern portion of the site with 176 residential units, and approximately 87,200 sf of retail space, including a grocery store. The building will include approximately 300 structured parking spaces and construction of approximately 24 surface spaces along Guest Street Extension. . Building B: 188-ft tall building located in the northeastern corner of the site with approximately 350,000 sf of office space (including approximately 10,000 sf of community/artist space) with approximately 11,500 sf of retail space. It also includes 4 levels of structured parking totaling approximately 550 spaces. . Building C: 232-ft tall building in the center of the northern portion of the site with approximately 386 residential units and 9,600 sf of retail space and approximately 200 structured parking spaces. . Building D: 167-ft tall building in the northwestern corner of the site with approximately 306 residential units and 8,700 sf of ground-floor retail space and approximately 150 structured parking spaces.

The project will be developed in phases. The first phase will include Building A and all infrastructure necessary to support full-build, including the community green, Guest Street Extension, East Street, West Street, Braintree Street Extension, and pedestrian and bicycle accommodations throughout the site. It will also include the construction of two signalized intersections (Guest Street Extension/Everett Street and Guest Street Extension/Arthur Street). Phased development of the remaining buildings will occur over an eight to ten year period dependent upon market conditions.

Project Site

The project site is located at 60 Everett Street in Boston and is generally bounded by the Massachusetts Bay Transportation Authority (MBTA) Framingham/Worcester commuter rail line to the north, Everett Street to the east, commercial properties to the south, and the Boston Landing development (EEA# 14909) to the west. The Boston Landing commuter rail station is located immediately adjacent to and north of project site. The majority of the site is developed with impervious area (10.4 acres) and contains 100,000 total sf of retail space, including a Stop and Shop grocery store, smaller ancillary retail space, and a 450-space surface parking lot. The project site does not contain any filled tidelands, wetlands, or designated rare species habitat.

Environmental Impacts and Mitigation

Potential environmental impacts associated with the project include: alteration of 10.6 acres of land, creation of 34,848 sf of impervious area (9.6 total acres), generation of 7,990 unadjusted average daily vehicle trips (adt), an increase in water demand of 194,633 gallons per

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day (gpd), and an increase in wastewater flows of 176,939 gpd. Greenhouse gas (GHG) emissions are associated with the project's energy use and trip generation.

Measures to avoid, minimize, and mitigate impacts include: redevelopment of a site in close proximity to transit; design of a building that can be certified by the U.S. Green Building Council’s Leadership in Energy and Environmental Design (LEED) program; improved connections to the Boston Landing commuter station; installation of transit signal priority components, new bus stops, and bus rerouting; development of a Transportation Demand Management (TDM) program; pedestrian and bicycle improvements; provision of a 1.0-acre publicly accessible centralized open space; and incorporation of energy efficiency measures to reduce the project’s GHG emissions.

Jurisdiction and Permitting

The project is undergoing MEPA review and is subject to a Mandatory EIR pursuant to 301 CMR 11.03(6)(a)(6) because it requires State Agency Actions and will generate 3,000 or more average daily vehicle trips (adt) with access to a single location. The project will require a Vehicular Access Permit, Approval for Construction on Former Railroad Land under M.G.L. c.30, sec. 54A, and work within a highway easement area from MassDOT. It will also require a License Agreement from the MBTA to improve pedestrian connections to the Boston Landing commuter rail station and to construct Braintree Street Extension. It may require a Construction Dewatering Permit and/or 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”).

The project requires a NPDES Construction General Permit and NPDES Remediation 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 is subject to review by several City of Boston agencies, including, but not limited to: Article 80B Large Project review by the Boston Planning and Development Agency (BPDA), Design Review by the Boston Civic Design Commission (BCDC), and Site Plan Review by the Boston Water and Sewer Commission (BWSC). The DEIR indicated the project completed the BPDA’s Article 80 Large Project Review process and that the Boston Zoning Commission approved a Planned Development Area (PDA) Master Plan and Individual Development Plans for the project. The Proponent will prepare and submit a Transportation Access Plan Agreement (TAPA) and a Construction Management Plan (CMP) in coordination with the Boston Transportation Department (BTD) for the project.

In 2016, MassDOT and the MBTA terminated certain easements, sidetracks, and box culvert rights located throughout the project site for an affiliate of the Proponent. Because development plans had not been identified at that time, the Proponent’s affiliate executed a Compliance Agreement that required disclosure of this Land Transfer and required completion of MEPA review for any work or activities proposed on the site within five years. Because portions of the project site were subject to a Land Transfer from MassDOT and the MBTA, MEPA jurisdiction is broad and extends to all aspects of the conveyance within the area subject to the Land Transfer that are likely, directly or indirectly, to cause Damage to the Environment as

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defined in the MEPA regulations. Therefore, MEPA jurisdiction is broad and extends to all aspects of the project that are likely, directly or indirectly, to cause Damage to the Environment as defined in the MEPA regulations.

Review of the DEIR

The DEIR described changes to the project since the filing of the EENF, identified existing conditions, described potential environmental impacts, generally identified mitigation measures, and provided a brief discussion of project alternatives. The DEIR provided updated conceptual site plans for existing and proposed conditions and clarified which portions of the roadway network would be built with Building A during Phase 1. It provided a brief description of applicable statutory and regulatory standards and requirements, and described how the project will meet those standards. It included a list of required State Permits, Financial Assistance, or other State approvals and provided an update on the status of each of these pending actions.

The DEIR identified project revisions that have occurred since the EENF was filed based on continued consultation with the community, the City of Boston, and state agencies. Project changes include the reduction of office use in Building B (from 375,000 sf to 350,000 sf), elimination of 27 residential units (from 895 units to 868 units), reduction in building heights, reduction of office parking for Building B (by 164 spaces), incorporation of Electric Vehicle (EV) charging stations and EV-ready spaces, revisions to Guest Street Extension to facilitate bus access, and improved connections from the site to Boston Landing commuter rail station (including a two-way protected cycle track and pedestrian pathways along Braintree Street).

As previously described in the EENF, Building B (office use) may be replaced by approximately 340 residential units. As requested in the Scope, the DEIR identified and compared the transportation, water, and wastewater impacts of both uses. When compared to the residential use, the office use generates additional trips (3,830 unadjusted adt vs 1,550 unadjusted adt) and reduced water use (28,875 gpd vs 59,411 gpd) and wastewater generation (26,250 gpd vs 54,010 gpd). The impact analysis carried throughout the DEIR assumes that Building B will be developed as office space since this use is more impactful from a transportation and transit perspective. Additionally, the Proponent anticipates constructing Building B as office space given current market conditions and the office use was advanced through the local permitting process (and approved by the BPDA).

Alternatives Analysis

The Scope requested that the Proponent consider additional revisions to the Preferred Alternative to reduce impacts, including, but not limited to, reductions in the size of the project to reduce impervious area and traffic impacts. The DEIR identified additional design and mitigation measures that were incorporated into the project to further reduce impacts including narrowing the street network to reduce impervious area and a reduction in parking spaces.

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Traffic/Transportation

Section 3 of the DEIR included a Transportation Impact Assessment (TIA). The TIA described anticipated trip generation rates of the project, parking supply, crash rate data, site access improvements, and multimodal access and facilities. The TIA also included an analysis that evaluated the project’s impact on the MBTA transit system. The TIA described public transportation, pedestrian, and bicycle opportunities within the study area. The DEIR included a conceptual graphic depicting vehicular, pedestrian, and bicycle circulation patterns and connection points to adjacent parcels and access roadways. Comments from MassDOT are supportive of the Proponent’s approach to a mitigation program that is primarily focused on alternative modes of transportation.

The number of intersections requiring a Road Safety Audit (RSA) has increased since the EENF was filed (from two to the following ten locations) as a result of additional consultation with BTD and the : . Market Street at Leo M. Birmingham Parkway/Lincoln Street; . Market Street at North Beacon Street; . Market Street at Faneuil Street; . Market Street at Sparhawk Street/Arlington Street; . Cambridge Street at Harvard Avenue/Franklin Street; . Cambridge Street at Gordon Street; . Cambridge Street at Denby Road; . North Beacon Street/Brighton Avenue at Cambridge Street; . North Beacon Street at Everett Street/KFC Driveway; and . Everett Street at Western Avenue.

The RSAs were conducted at these locations on February 26 and 28, 2020 and the resulting reports have been submitted to MassDOT. The DEIR indicated that the Proponent has committed to implement the resulting low-cost improvements resulting from the RSAs, even though the full extent and details of the improvements are not yet known. An update on these improvements is required in the FEIR. As requested by MassDOT, the Proponent should continue consultation with the City of Boston on the need to implement additional safety improvements.

Site Access Improvements

The DEIR indicated that design of the internal roadway network, Guest Street Extension, and Braintree Street Extension has continued to advance based on ongoing consultation with the BPDA, BTD, MassDOT and MBTA. The DEIR described revisions to the design of Guest Street Extension, the intersection of Everett Street/Guest Street Extension/Old Everett Street, Everett Street Bridge Access, and Braintree Street Extension. Specifically, Guest Street Extension has been revised to facilitate the rerouting of the MBTA Bus Route 64 through the site and along the roadway. These revisions include replacing the westbound exclusive left-turn lane onto Arthur Street with a center median island which could later be removed to provide pavement width necessary to provide an eastbound exclusive bus lane. Bus pull-over areas were also eliminated from Guest Street Extension and the curb line was extended to the edge of the travel lanes to

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allow the bus to temporarily stop in the through travel lane in both directions. This will eliminate delays associated with having the bus turning from the travel lane and reentering the traffic stream. The project includes revisions to improve bicycle and pedestrian accommodations at the intersection of Everett Street/Guest Street Extension/Old Everett Street, including extension of separated bicycle lanes, additional striping and pavement markings, and wider sidewalks. As MassDOT’s request, the DEIR provided renderings of the Everett Street bridge underpass at the Braintree Street site driveway. The project will install a wall between Building B and the wing wall of the Everett Street Bridge, widen the existing sidewalk, and install street trees along the street edge. The DEIR indicates the proposed improvements will not impact MassDOT’s ability to inspect the bridge structure. As requested by MassDOT, the Proponent should continue coordination with the Highway Division District 6 on this issue during the permitting process.

Braintree Street Extension will provide a new at-grade and direct connection between the project site and MBTA’s Boston Landing commuter rail station. A two-way separated bike lane has been added to the north of the street which will run for almost the entire length of the road before transitioning to standard bike lanes just west of the Old Everett Street/Braintree Street intersection to the east and connecting to Arthur Street Extension to the west. This change was made to address concerns regarding potential conflicts between bicyclists and vehicles turning to and from the curb cuts on the south of the street. Additionally, the previously proposed “kiss- and-ride” pick-up/drop-off area has been relocated from Braintree Street Extension to two new separate areas on the east side of both East Street and West Street. The DEIR identified other changes to the proposed connections to the which were made based on consultation with MBTA. These include shifting the bike lanes and fencing to be a minimum of 15-ft from the centerline of the MBTA tracks, elimination of plantings along Braintree Street Extension/MBTA frontage, and provision of an access gate for MBTA maintenance activities at the easterly end of the Braintree Street Extension next to the Everett Street overpass. The DEIR indicated this work will occur on approximately 10,000 SF of MBTA’s land and that it is detailed in a Memorandum of Agreement (MOA) between the Proponent and the MBTA. The MOA provides that the parties will execute a License Agreement prior to construction of these improvements. Additional information on this work is required in the FEIR.

Parking Supply

The project will provide 1,200 structured parking spaces, with an additional 24 surface parking spaces along Guest Street extension. The parking supply has been reduced by 163 spaces since the EENF was filed through elimination of a floor of the office parking garage in Building B. The DEIR explained the derivation of the parking supply for the project and compared the proposed parking supply (1,224 spaces) to the ITE adjusted parking demand (1,021 spaces). The residential parking ratio is 0.5 spaces per residential unit and the office/commercial ratio is approximately 1.56 spaces per 1,000 sf. I note comments from the Metropolitan Area Planning Council (MAPC) indicate the parking ratio for the office use exceeds BTD’s guidelines (0.75 to 1.25 spaces per 1,000 sf). According to the DEIR, the low residential and retail parking ratios and phased nature of the project’s construction limits opportunities for shared parking. The DEIR included a commitment to unbundle parking from residences and noted that “reverse commuter” passes may be made available to residents. The Proponent will reconsider a shared parking approach for future phases based on monitoring data regarding parking demand. All structured

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parking will be constructed with flat floor plates to facilitate converting the space to commercial or retail use in the future should parking demand decline. The DEIR noted the Proponent is also considering an autonomous parking system which would reduce the square footage dedicated to structured parking and facilitate reusing the space for residential or commercial uses in the future. I refer the Proponent to comments from the Metropolitan Area Planning Council (MAPC) and which encourage the Proponent to evaluate additional measures to reduce parking supply and to consider further reductions in on-site parking for the office use.

The DEIR included a commitment to install EV charging stations at ten-percent of the non-short-term parking spaces (e.g. office and residential) parking spaces and to provide fifteen- percent of these spaces as EV-ready. It is unclear whether these percentages are intended to apply only to the 1,200 structured parking spaces or whether they include the 24 surface parking spaces. This should be clarified in the FEIR. According to the DEIR, the location for the EV charging stations will be determined as project design progresses. The DEIR indicated the TAPA will incorporate annual monitoring that will inform when, and how many EV charging stations should be installed, up to 25% of the non-short term spaces, based on observed usage at the time.

Trip Generation/Distribution

According to the DEIR, the revised project will generate approximately 18,300 total unadjusted adt (7,990 New unadjusted adt) on an average weekday. This estimate was calculated using trip generation rates for Land Use Codes (LUC) 222 (Multi-family housing: high-rise), 710 (General Office Building), 820 (Shopping Center), and 850 (Supermarket) as published in the Institute of Transportation Engineers (ITE) Trip Generation Handbook, 10th Edition. The TIA provided the adjusted trip generation data which reflects credits for mode share (transit, bike/walk, and vehicle) based on the BTD guidelines for this location. On a daily basis, the project will generate 1,912 transit trips, 2,545 walking/bicycle trips, and 4,870 vehicle trips. As requested by MassDOT, the DEIR provided a detailed summary of the trip distribution and assignment for the residential and commercial components of the project along Braintree Street within the study area. Approximately eighteen- and sixteen-percent of the respective residential and commercial project components will use Braintree Street to travel to and from the site. The DEIR confirmed that this was accounted for in the traffic volume networks and resulting trip assignments provided in the EENF.

Transit

The project site is located adjacent to the Boston Landing commuter rail station and eight MBTA bus routes all operate within a half-mile of the site. The project will create a direct pedestrian connection to the Boston Landing commuter rail station at the western terminus of Braintree Street Extension. Comments from MassDOT indicate their support for this connection and request the Proponent continue to coordinate with MassDOT and the MBTA’s Capital Delivery Department regarding the connection.

The MBTA’s bus route 64 will be relocated through the site to enhance connections between the Boston Landing Station and MBTA’s nearby bus network. This will require relocating the existing bus stop at the Guest Street/Arthur Street intersection to the new Guest

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Street Extension and elimination of the bus stop at the North Beacon Street/Saunders Street intersection. Riders currently using that stop can use the new Guest Street Extension bus stop or the existing North Beacon Street/Cambridge Street stop located approximately 925 ft east. I refer the Proponent MassDOT’s comment which continues to identify concerns that the reconfiguration of the Everett Street/Guest Street Extension/Old Everett Street/Blaine Street intersection may not adequately accommodate bus turning movements. The Proponent should continue working with MassDOT to address this issue.

The DEIR include a revised transit analysis which was developed based on consultation with the MBTA. The additional ridership generated by the project will cause two commuter rail trips and sixty-one bus trips to exceed capacity in the future build condition. The Proponent has committed to provide an operating subsidy to the MBTA to be used to enhance bus and commuter rail service within the project area. Specifically, the Proponent has committed to provide a total subsidy of $2,392,355.17 ($1,457,484.29 for bus impacts and $934,870.88 for commuter rail impacts) over a period of fifteen years which is equivalent to a $133,413.18 contribution in year one (2020) compounding annually 2.5 percent per year. The proportional component of the subsidy for each building will be paid starting with the issuance of a building permit for each building. Comments from MassDOT confirm their acceptance of this methodology. The DEIR did not identify how the operating subsidy will be used by MBTA to mitigate project-related impacts. Comments from MassDOT note that the Agency will use the subsidy to address local concerns to the Allston Yards neighborhood, such as increased Commuter Rail service or vehicle procurement/operating assistance for bus routes which will be used to access the project, as well as for projects which are actionable in the short-term. I refer the Proponent to comments from MassDOT which note that a code analysis of the Boston Landing commuter rail station may be necessary to ensure the station can safely accommodate the additional passengers.

Bicycle and Pedestrian Facilities

The DEIR described existing and proposed bicycle and pedestrian facilities near the project site and evaluated primary travel routes between the site and nearby MBTA transit facilities. The Proponent has committed to update deficient sections of the sidewalk and curb ramps where merited, particularly along Braintree Street. The project includes a two-way separated bike lane along the north side of Braintree Street Extension, adjacent to the MBTA Boston Landing commuter station, which will facilitate improved pedestrian and bicycle access to the station. New sidewalks and separated bike lanes are also proposed on Arthur Street. I refer the Proponent to comments from MassDOT which urge the Proponent to be mindful of bicycle accommodations along Everett Street.

Transportation Demand Management and Monitoring Program

The Proponent will implement a TDM plan to reduce single-occupancy-vehicle (SOV) trips and encourage alternative modes of travel to and from the site. The TDM program presented in the DEIR did not identify mode share goals and is substantially similar to that described in the EENF. I refer the Proponent to comments from MassDOT which note the Proponent must join or include in its tenant’s lease agreements specific requirements to join the

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MBTA Perq Program. Comments from MAPC and MassDOT also encourage the Proponent to strengthen the proposed TDM plan and identify additional TDM measures for consideration. The DEIR indicated the Proponent will conduct transportation monitoring to evaluate the effectiveness of the TDM plan. The monitoring program will commence six months after each individual building is occupied and will include 24-hour automatic traffic recorder counts at site driveways and turning movement counts at mitigated intersections. The traffic monitoring also will record the parking demand for each building through driveway counts or other records.

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 agencies within the administration to develop and implement an integrated strategy that leverages state resources to combat climate change and prepare for its impacts. The Order seeks to ensure that Massachusetts will meet GHG emissions reduction limits established under the Global Warming Solution Act of 2008 (GWSA) and will work to prepare state government and cities and towns for the impacts of climate change. The MEPA statute directs all State Agencies to consider reasonably foreseeable climate change impacts, including additional greenhouse gas emissions, and effects, such as predicted sea level rise, when issuing permits, licenses and other administrative approvals and decisions. M.G.L. c. 30, § 61.

The GHG Policy and requirements to analyze the effects of climate change through EIR review is an important part of a statewide strategy. These analyses advance proponents’ understanding of the projects contribution and vulnerability to climate change.

Greenhouse Gas Emissions

The DEIR included an updated GHG analysis based on the MEPA Greenhouse Gas Policy and Protocol (the Policy). The Policy requires projects to quantify carbon dioxide (CO2) emissions and identify measures to avoid, minimize and mitigate such emissions. The analysis quantified the direct and indirect CO2 emissions associated with the project's energy use (stationary sources) and transportation-related emissions (mobile sources). The DEIR outlined and committed to mitigation measures to reduce GHG emissions.

The stationary source GHG analysis evaluated CO2 emissions for two alternatives as required by the Policy, a Base Case and the Preferred Alternative. The Base Case was designed to meet the minimum energy requirements of the 9th Edition of the Massachusetts Building Code (the Base Code). The City of Boston has adopted the Massachusetts Stretch Energy Code (SC). Therefore, the project will be required to meet the applicable version of the SC in effect at the time of construction. I refer the Proponent to comments from DOER which indicate that the SC will include several new amendments that will become effective in August of this year. Mobile GHG emissions were estimated using the standard methodology in the EEA/MassDOT Guidelines for EIR/EIS Traffic Impact Assessments and MOVES CO2 emission factors. Mobile source GHG emissions remain unchanged from the EENF.

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The GHG analysis used eQuest modeling software to quantify stationary source emissions from the project. The DEIR included a summary of modeling inputs (e.g., R-values, U-values, efficiencies, lighting power density, etc.) for both the Base Case and Preferred Alternative. The DEIR indicated that the Base Case energy model was revised to incorporate two measures required by Section C406.1 of the Building Code (specifically, more efficient HVAC equipment and reduced lighting power density). The Preferred Alternative energy model for Building A was revised to incorporate air source heat pumps (ASHP) with 95-percent efficient condensing boiler per unit in the residential spaces. The DEIR indicated that all other model inputs remain unchanged from those previously presented in the EENF. The DEIR included an analyses of the aggregate vertical envelope for each building which demonstrated the proposed building envelopes will perform seven- to nine-percent better than the Base Case envelopes. I refer the Proponent to comments from DOER which indicate that the energy performance improvements over current Building Code requirements are minimal and that the buildings may not meet the minimum Building Code standards that will become effective in August 2020. I note the project will be required to meet the version of the Building Code in effect at the time of construction and remind the Proponent that the GHG analysis presented in the FEIR should clearly demonstrate consistency with the objectives of MEPA review, one of which is to avoid, minimize, or mitigate Damage to the Environment to the maximum extent feasible.

The project will be constructed in phases and the ownership structure may change as the project progresses from construction and development to operations. The DEIR clarified which building-related mitigation measures will be implemented by the Proponent or building owner and which measures tenants may be responsible for implementing. This is summarized in the table below. The DEIR included a draft Tenant Manual that provided a description of sustainable design and operation features of the project and incorporated the below table.

Building Proposed Mitigation Measure Responsible Party Buildings High Performance Windows Owner A,B,C,D Building A Air Source Heat Pumps in Residential Spaces Owner Buildings A,C,D High Efficiency Water Source Heat Pumps Owner Buildings A,C,D Energy Recovery Ventilation Serving Residential Owner Units Building B Higher Efficiency Energy Recovery Ventilation Owner Buildings High Efficiency Condensing Boilers Owner A,B,C,D Building B Reduced Lighting Power Density Tenant

The DEIR evaluated an all-electric scenario for each building which would eliminate natural gas consumption and use all-electric building systems. In this scenario, the residential buildings would use air source heat pumps and packaged VAV with heat pump heating, office buildings would use a VRF system, the supermarket would be conditioned by a packaged rooftop unit with heat pump heating, and all hot water would be heated by electric resistance coilers. The DEIR indicated the all-electric building scenario would result in greater reductions in GHG emissions compared to the Preferred Alternative. The DEIR included an economic analysis on

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the all-electric scenario for Building A since the design has been advanced further than other buildings. Based on the result of this analysis, the use of ASHPs in Building A was determined to be economically feasible and was incorporated into the Preferred Alternative. Comments from DOER indicate that there may be an error in the residential building’s model as indicated by the output which appears unusually high-performing considering the minimal envelope improvements. I note this issue was also identified by DOER in their prior comments on the EENF. The FEIR requires the Proponent to reexamine the results of the energy models for the residential buildings.

The DEIR included an all-electric Passive House evaluation for the residential and office components of all four buildings. The Passive House alternatives included a reduced window-to- wall ratio, increased envelope insulation, improved air sealing, and reduced lighting power density and equipment loads. The Passive House alternative would generate 4,223 tons per year (tpy) of GHG which reduces GHG emission by an additional emissions 108 tpy compared to the current Preferred Alternative. Comments from DOER note this comparison may be flawed as the Preferred Alternative appears to over-estimate energy reduction (as noted above). The DEIR also included a cost analysis of the Passive House alternative which used out of date MassSave incentives. The Proponent provided an updated financial analyses on May 1, 2020 which was based on current MassSave incentives. The financial analyses determined the Passive House alternative would result in an incremental cost of $3.78 per square foot or net capital incremental cost of $681,560. The revised analyses does not appear to be reflected in comments from DOER. Additional analysis of Passive House is required in the Scope for the FEIR.

The DEIR included a preliminary feasibility analysis of a photovoltaic (PV) system on the project’s southern facing walls and rooftop areas. The DEIR indicated that solar PV was not considered feasible for installation on the lower portions of Buildings B, C, and D based on the results of a shading study. The DEIR identified 29,401 total SF as suitable for installation of a solar PV system. Based on this analysis, the project could accommodate an aggregate 462 kW PV system, which would generate approximately 513,090 kWh per year and reduce GHG emissions by 182 tpy. The Proponent has committed to installing solar PV on Building A. It is unclear whether this commitment includes both rooftop PV and façade-mounted PV. This should be clarified in the FEIR. Building A could include an aggregate 181 kW PV system (164 KW rooftop PV and 17 kW façade-mounted PV) would generate approximately 189,987 kWh per year and reduce GHG emissions by 67 tpy.

The GHG analysis indicates that the Base Case for the entire project will generate approximately 7,609 tpy of GHG emissions, consisting of 5,319 tpy of stationary source emissions and 2,290 tpy of mobile source emissions.1 The Preferred Alternative will reduce stationary source emissions by 988 tpy, an approximate 18.6% reduction, and will reduce mobile source emissions by 1,003 tpy, an approximate 44% reduction. Overall emissions will be reduced by 1,991 tpy for an approximate 26% reduction. As previously described in the EENF, reductions to mobile source emissions are associated with implementation of the TDM plan (46 tpy) and traffic signal timing adjustments at three intersections along Market Street (957 tpy).

1 The Base Case project-related mobile source GHG emissions are 2,290 tpy; which represents the net difference in mobile source emissions between the 2025 No-Build and 2025Build-Conditions. 11

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Adaptation and Resiliency

The DEIR provided an updated analysis and discussion of vulnerabilities of the site to the potential effects of climate change, including increased frequency, and intensity of precipitation events, and extreme heat events. The analysis used data from the EEA’s Massachusetts Statewide and Major Basins/Climate Change Protections Report (March 2018). The Boston Harbor basin, where the project is located, is expected to experience increased average, seasonal, and extreme high temperatures, as well as increased number of days with extreme heat/temperatures greater than 90°F and 100°F throughout the 21st century. The DEIR indicated the site is not expected to experience flooding due to future sea level rise as the finished grade of the project site is significantly higher (approximately thirty-ft) than the Sea Level Rise – Base Flood Elevation (SLR-BFE) identified for Charles River located north of the project.

The DEIR indicated the project will capture and infiltrate 1.25-inches of stormwater over the impervious areas of the site. According to the DEIR, the stormwater management system will be designed with a bypass for heavy rain events to protect the site from flooding. The DEIR did not specify whether the design of the stormwater management system accounts for the projected future increase in rainfall volumes. The project will include new shade trees and light-colored paving materials to minimize the heat island effect. Residential units will be designed with operable windows to provide natural ventilation during power outages. The Scope requested that the Proponent specifically address and evaluate the benefits of Passive House construction standards on the resiliency of the proposed buildings. The DEIR acknowledged that Passive House structures are inherently more resilient because they can retain comfortable temperatures for a longer period of time during a power outage. Additional analysis of the Passive House alternative is required in the FEIR.

Sustainable Design

The Proponent has increased the commitments regarding the building’s LEED ratings since the EENF was filed. At a minimum, each building will be designed to be certifiable at the silver level by the LEED (version 4; v4) rating system. Building B (office) will achieve the LEEDv4 Core & Shell (C&S) Gold level and will target LEEDv4 C&S Platinum level; the grocery store will achieve the LEED v4 Commercial Interior Silver level and will target the Commercial Interior Gold level, and one or more of the three residential buildings (Buildings A, C, and D) will achieve the LEEDv4 New Construction Gold level.

Stormwater

The DEIR described existing stormwater facilities on the project site. The project site is almost entirely impervious. Stormwater is collected through a series of catch basins, directed through a water quality unit, and conveyed to the BWSC infrastructure on Everett Street which ultimately discharges to the Charles River. The DEIR indicated the project will improve stormwater runoff quality and reduce peak flows by increasing pervious area on the site and through the use of treatment and infiltration systems including deep sump catch basins and permeable pavers. The DEIR indicates that additional LID measures such as rain gardens and swales were considered but dismissed due to their increased maintenance requirements and poor

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performance during winter months. According to the DEIR, the stormwater management system will achieve 92% removal of Total Phosphorous prior to discharging to the City’s stormwater system. The DEIR did not include additional information on the design of the stormwater system to demonstrate how this will be achieved. The DEIR indicated the Geotechncial Engineer has recommended that existing fill material in the proposed infiltration system locations be excavated and replaced with granular backfill or crushed stone to promote and improve infiltration on-site. It is unclear whether this has been incorporated into the design of the stormwater management system. This should be clarified in the FEIR.

Water/Wastewater

According to the DEIR, the project will increase water demand by 189,793 gpd (198,153 total gpd) and wastewater flows from the site by 172,539 gpd (180,139 total gpd). The DEIR also identified maximum peak demand for wastewater flow (862,695 gpd) and water demand (948,965 gpd). The project will be served by BWSC water and sewer infrastructure. The project will use low-flow plumbing fixtures to reduce water usage a minimum of twenty-percent over the baseline to comply with Article 37 of the Boston Zoning Code. The project will mitigate its impact on the BWSC’s sewer system by complying with MassDEP and BWSC’s Inflow/Infiltration (I/I) removal policy. The policy requires new projects that generate more than 15,000 gpd of new wastewater flow to offset I/I at a ratio of 4:1 relative to the new wastewater generated. The DEIR indicate the Proponent intends to make a monetary contribution to the BWSC’s I/I mitigation fund to address this requirement. The BWSC will review and confirm the appropriate mitigation volume and value of compensation to the I/I mitigation fund as each building proceeds through their site plan approval process.

Solid/Hazardous Waste

The project site is regulated under M.G.L. c.21E and the Massachusetts Contingency Plan (MCP; 310 CMR 40.0000). The DEIR identified and described the four Release Tracking Numbers (RTNs) associated with the project site and their status of remediation.2 The DEIR indicated that all but one of these releases has been brought to regulatory closure, and the last should be brought to regulatory closure in the near future. The DEIR indicated that no additional sampling or site assessment activities have occurred on the site since the EENF was filed. A Release Abatement Measure (RAM) Plan will be employed during earthwork activities to ensure that soil is managed in accordance with the MCP. The DEIR indicated that sub-slab depressurization systems will be used to mitigate impacts to indoor air quality. The need for vapor intrusion controls will be evaluated as part of final building design.

Construction Period

According to the DEIR, the project will be constructed in phases. The construction duration and phasing is as follows: Phase 1: Building A (32 months), Phase 2: Building B (30 months), Phase 3: Building C (30 months), Phase 4: Building D (36 months). The DEIR indicated that building construction may proceed in multiple, sequential or concurrent phases or

2 RTN 3-2332 (incorporating RTN 3-14097), RTN 3-12447 (linked to RTN 3-15227), RTN 3-33943, and RTN 3- 28924 which was erroneously omitted from the EENF. 13

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subphases. Construction hours will be restricted from 7:00 AM to 3:30 PM from Monday through Friday. Weekend or off-hour activities may occur as needed for certain activities such as maximizing tower crane usage or delivery of large construction equipment. The DEIR provided information on the number of parking spaces that will be provided as the phased development is constructed. Approximately 180 temporary parking spaces will be provided adjacent to the existing grocery store during construction of Phase 1. The pads for Buildings B, C, and D may be used for temporary, interim parking during construction of subsequent phases.

The DEIR include a Draft Construction Management Plan (Appendix D) that outlined mitigation measures that will be implemented during the project to avoid or minimize impacts associated with construction traffic, noise, stormwater, air quality, pedestrian access, and other impacts. Mitigation measures identified in the DEIR include: erosion and sedimentation control measures, designated truck routes, scheduling deliveries during non-peak hours, off-site construction parking, odor and noise control measures, dust control measures, prohibition of excessive idling of construction equipment to comply with M.G.L. c.90 § 16A and 310 CMR 7.11 which prohibit vehicle idling, and a commitment to reuse or recycle a minimum of 75- percent of construction debris. Construction-period impacts to pedestrians and traffic will be mitigated in accordance with the TAPA to be developed with the BTD. The TAPA and/or CMP will include signage and police details to maintain safe pedestrian access on sidewalks, designated staging areas, and construction hours.

Conclusion

Based on a review of the DEIR, comment letters, and consultation with State Agencies, I have determined that the DEIR adequately and properly complies with MEPA and its implementing regulations notwithstanding the additional analysis and information that must be included in the FEIR. The Proponent must prepare and submit for review a FEIR in response to the Scope included below.

SCOPE

General

The FEIR should follow Section 11.07 of the MEPA regulations for outline and content, as modified by this Scope. Additional recommendations provided in this Certificate may result in a modified design that enhances the project’s ability to avoid, minimize, or mitigate Damage to the Environment. The FEIR should discuss the steps the Proponent has taken to further reduce the impacts since the filing of the DEIR, or, if certain measures are infeasible, the FEIR should discuss why these measures will not be adopted.

Project Description and Permitting

The FEIR should include an updated description of the proposed project and describe any changes to the project since the filing of the DEIR. The FEIR should identify, describe, and assess the environmental impacts of any changes in the project that have occurred between the

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preparation of the DEIR and FEIR. The FEIR should include updated site plans for existing and post-development conditions at a legible scale. The FEIR should provide a brief description and analysis of applicable statutory and regulatory standards and requirements, and describe how the project will meet those standards. It should include a list of required State Permits, Financial Assistance, or other State approvals and provide an update on the status of each of these pending actions. The FEIR should include an update on any meetings or discussion's with MassDOT, MBTA or the City on proposed transportation and/or transit improvements. I highly recommend that the Proponent consult with MassDOT during the preparation of the FEIR.

I refer the Proponent to comments from the Charles River Watershed Association (CRWA) regarding the established water quality standards in the applicable Charles River TMDLs. The FEIR should provide a detailed discussion of stormwater conveyance from the project site to the Charles River and other sufficient information to demonstrate that the stormwater management system will be designed to address the water quality impairments covered by the TMDL.

Traffic/Transportation

The FEIR should provide the information and analyses identified in MassDOT’s comment letter in order to fully document the project’s transportation impacts and to identify appropriate mitigation measures. I hereby incorporate by reference MassDOT’s comment letter, dated May 8, 2020, into the FEIR Scope. The FEIR should provide an update on the completion of the RSAs and identify additional low-cost improvements resulting from RSAs which the Proponent has committed to implement. The FEIR should clarify the total number of parking spaces that will be provided with EV charging stations and the number that will be provided as EV-ready, including whether this commitment applies to the 24 surface parking spaces. Prior to submitting the FEIR, the Proponent should consult with the MBTA regarding the need for a code analysis of the Boston Landing Station. The FEIR should provide an update on this analysis and should identify the timeframe for completion of the code analysis if it is determined to be necessary. The draft Section 61 Findings should be revised accordingly. The FEIR should also demonstrate that access to the bus stops and the MBTA commuter train will not be impeded at intermediate stages of development.

The FEIR should provide a revised conceptual design for the reconfiguration of the Everett Street/Guest Street Extension/Old Everett Street/Blaine Street intersection that is better able to accommodate buses turning right from the Guest Street Extension towards Everett Street. If a design that addresses the safety and operational concerns at this location as identified by MassDOT cannot be achieved, then the MBTA will not reroute the Bus Route 64 and the Proponent will need to reevaluate transit access to the site. In this instance, the FEIR should include a conceptual plan and narrative that describes how transit users will access the site from the existing Route 64 bus stops at North Beacon Street/Saunders Street and North Beacon Street/Cambridge Street. This should include an evaluation of improvements to facilitate safe and accessible access between the site and existing bus stops.

The FEIR should clearly identify and describe improvements on MassDOT and MBTA property, including but not limited to: Braintree Street Extension and sidewalk, fence removal,

15 EEA# 15995 DEIR Certificate May 15, 2020

pedestrian plaza at Arthur Street/Braintree Street Extension, re-located bus stops, and transit signal priority components (as applicable). The FEIR should provide plans that identify the limit of work located on MassDOT/MBTA land and a narrative that clearly describes the proposed work. It should confirm that this work will be addressed via a License Agreement from the MBTA and clarify whether an easement is necessary. It should also include a copy of the draft MOA between the Proponent and the MBTA regarding these improvements.

As noted above, the Proponent has committed to provide an operating subsidy to be used to enhance bus and commuter rail service within the project area. The FEIR should clarify the mechanism that will ensure the funding will be applied to transit-related improvements that will specifically mitigate the additional ridership generated by the project. The FEIR should address how MassDOT/MBTA and the Proponent will work together to ensure that delivery of transit improvements funded by the operating subsidy occurs commensurate with the scope and scale of project impacts as each building is constructed.

While the residential parking ratio is significantly lower than the BTD’s residential parking guidelines, the office space parking ratio continues to exceed BTD’s guidelines. The FEIR should evaluate other measures to reduce the office parking supply, including but not limited to: providing cash-out incentives for employees, metering any on-street parking, and fees for structured parking. Based on this analysis, the FEIR should propose the minimum parking supply necessary to meet demand. I note that this was requested in the Scope for the DEIR and was not provided. The FEIR should also identify any incentives within local land use approvals that encourage the productive reuse of parking structures.

The FEIR should clearly state mode share goals (vehicular, commuter rail, bus, bicycling and walking). This was requested in the Scope for the DEIR and was not provided. The DEIR indicated the traffic monitoring program will record the parking demand for each building through driveway counts or other records. The FEIR should identify triggers for implementing shared parking strategies or otherwise reducing parking, if warranted based on the results of the monitoring program. The FEIR should clarify how information regarding the number of transit riders generated by the project will be monitored. The FEIR should identify and clearly distinguish the roles and responsibilities of the Allston-Bright TMA, the Proponent, and tenants/residents in implementing TDM measures. The Proponent should work with MassDOT to revise the monitoring program, and incorporate any relevant measures into draft Section 61 findings.

Greenhouse Gas Emissions

The FEIR should include a revised GHG analysis which reflects any changes to the project since the DEIR. The FEIR should address the issues raised in DOER’s comment letter. To provide an opportunity for public review and comment, the DEIR should include the revised Passive House cost analyses and other information that was provided by the Proponent during the MEPA review period (on May 1, 2020). New construction offers many opportunities for building shell and mechanical system improvements and I expect the Proponent will evaluate these measures to maximize the potential benefits of this new construction. The project will be required to meet the version of the Building Code in effect at the time of construction. As noted

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by DOER, an update to the Stretch Code will become effective in August 2020. The underlying code provisions will not change. The Stretch Code to take effect in August is based on ASHRAE 90.1-2013-Appendix G. However, there will be several new, or changed, Massachusetts amendments including: C402.1.5. (envelope backstop), C405.3 and C405.4 (lighting), C405.10 (EV charging), and C406 (additional efficiency measures). The C406 measures are increased from 2 to 3. The amendments will also require that baseline residential buildings set maximum fenestration to 24%.

To accurately evaluate mitigation measures for this project, and in light of the immanency of these amendments, I encourage the Proponent to utilize the updated Stretch Code in updating its GHG emissions calculations and associated mitigation measures. I remind the Proponent that the GHG analysis presented in the FEIR should clearly demonstrate consistency with the objectives of MEPA review, which are to avoid, minimize, or mitigate Damage to the Environment to the maximum extent feasible. Accordingly, updates to lighting, envelope, and additional efficiency measures will be required and should be evaluated as part of the FEIR.

As described in DOER’s comment letter, high-performing envelope is essential to successful GHG mitigation. The FEIR should continue to incorporate the following measures to the maximum extent practicable: . The use of continuous insulation; . Reducing air infiltration; . Limiting or eliminating use of glass “curtain wall” and spandrel assemblies; . Maximizing framed, insulated walls sections; . Maintaining window at code levels; and . Reducing thermal bridges.

The FEIR should also evaluate the effect of targeted Solar Heat Gain Coefficient (SHGC) and external shading considering variability of exposure to sun, building self-shading, and shadows from other building. Where certain measures are not considered, a clear explanation of the reasons for rejecting the alternative should be provided. The FEIR should study whether beyond code-minimum improvements to the envelope could potentially eliminate or reduce the need for perimeter heating in office and residential buildings. As described in DOER’s comment letter, the reduction of perimeter heating could potentially result in significant construction cost savings, improved comfort, and reduced maintenance and make full electrification more feasible.

Comments from DOER indicate that there may be an error in the residential building’s model as indicated by the output which appears unusually high-performing considering the minimal envelope improvements. The Proponent should re-examine the residential energy models. As requested by DOER, the performance of the residential energy model for the mitigated scenario should be confirmed with a WUFI model. I note that this approach is consistent with that used recently during review of the Riverside Station Redevelopment (EEA# 16024) and Bunker Hill Housing Redevelopment (EEA# 15584) projects. Funding to evaluate Passive House, including the use of a WUFI model, may be available through the MassSaves incentive program.3 The FEIR should provide the results of the WUFI model and include a revised Passive House cost analysis that compares the Passive House alternative to the WUFI

3 https://www.masssave.com/saving/residential-rebates/passive-house-incentives 17 EEA# 15995 DEIR Certificate May 15, 2020

model. I refer the Proponent to DOER’s comment letter for additional guidance. I note that structures built to Passivehouse standards will be quieter and better insulated from noise associated with the adjacent and active commuter rail line, which is a particularly important consideration for this site. These structures are also inherently more resilient because they can retain comfortable temperatures for a longer period of time during a power outage. In the last year, Proponents have committed to thousands of Passive House multi- family units through the MEPA process. I urge the Proponent to commit to Passivehouse design for residential and office spaces.

The FEIR should clarify the size and capacity of the PV system that will be installed on Building A, including whether it will utilize the building façade or be limited to the rooftop. The FEIR should quantify and include figures identifying rooftop areas that will be provided as “solar ready” to comply with Building Code and areas that will be provided as “solar ready” as a mitigation measure (beyond what is required by Building Code). Commitments regarding provision of “solar ready” roof areas, beyond what is required by Building Code, should be incorporated into the draft Section 61 Findings. The FEIR should explain how prospective tenants will be notified of this design feature, provided with the solar PV financial analysis performed to date, and otherwise encouraged to implement solar PV.

The project will be constructed in phases and the ownership structure may change as the project progresses from construction to operations. The FEIR should clearly identify how the commitments made by the Proponent will transfer to the new responsible parties. The FEIR should also clarify how the Tenant Manual will ensure that fit out of tenant spaces are equal to or better in performance than currently specified elements in order to achieve the identified GHG reduction goals in this scenario. The FEIR should clarify how the Self-Certification documents will be provided by the MEPA Office (i.e. for each building, or by ownership).

The FEIR should include a revised mobile source GHG analysis to reflect any changes to traffic mitigation (roadway improvements, signal timing, public transportation, etc.) since the FEIR. The FEIR should identify appropriate monitoring measures and indicate a clear commitment to report on any changed or reduced GHG mitigation measures through GHG self- certifications to be provided to the MEPA Office.

Mitigation and Draft Section 61 Findings

The FEIR should include a separate chapter summarizing proposed mitigation measures. This chapter should also include draft Section 61 Findings for each Permit or Land Transfer to be issued or granted by State Agencies. I note the DEIR did not provide draft Section 61 Findings for use by MWRA or the MBTA. The FEIR should contain clear commitments to implement mitigation measures, estimate the individual costs of each proposed measure, identify the parties responsible for implementation (either funding design and construction or performing actual construction), and contain a schedule for implementation. The mitigation implementation schedule should clearly note how mitigation will be provided in relation to project phasing; either tying commitments to overall project square footage/phase or environmental impact thresholds, to ensure that measure are in place to mitigate the anticipated impact associated with each development phase.

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To ensure that all GHG emissions reduction measures adopted by the Proponent in the Preferred Alternative are actually constructed or performed by the Proponent, I require Proponents to provide a self-certification to the MEPA Office indicating that all of the required mitigation measures, or their equivalent, have been completed. The commitment to provide this self-certification in the manner outlined above should be incorporated into the draft Section 61 Findings. It should address how self-certifications will be provided in the context of this phased development (e.g., by building by building basis, ownership basis, etc.) and how progress towards achieving project-wide mitigation commitments (LEED Certifiable Buildings, EV charging parking spaces, etc.) will be monitored.

Response to Comments

The FEIR should contain a copy of this Certificate and a copy of each comment letter received. In order to ensure that the issues raised by commenters are addressed, the FEIR should include direct responses to comments to the extent that they are within MEPA jurisdiction. This directive is not intended, and shall not be construed, to enlarge the scope of the FEIR beyond what has been expressly identified in this certificate.

Circulation

The Proponent should circulate the FEIR to those parties who commented on the DEIR, to any State Agencies from which the Proponent will seek permits or approvals, and to any parties specified in Section 11.16 of the MEPA regulations. The FEIR submitted to the MEPA office should include a digital copy (e.g., CD-ROM, USB drive) of the complete document. In addition, the FEIR should be made available for review at the Brighton and Allston branches of the .4

May 15, 2020 Date Kathleen A. Theoharides

Comments received:

04/10/2020 Charles River Watershed Association (CRWA) 05/08/2020 Massachusetts Water Resources Authority (MWRA) 05/08/2020 Metropolitan Area Planning Council (MAPC) 05/08/2020 Massachusetts Department of Transportation (MassDOT) 05/11/2020 Department of Energy Resources (DOER)

KAT/PRC/prc

4 Requirements for hard copy distribution or mailings will be suspended during the Commonwealth’s COVID-19 responses. Please consult the MEPA website for further details on interim procedures during this emergency period: https://www.mass.gov/orgs/massachusetts-environmental-policy-act-office. 19

May 8, 2020

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

RE: Boston: Allston Yards – DEIR (EEA #15995)

ATTN: MEPA Unit Page Czepiga

Dear Secretary Theoharides:

On behalf of the Massachusetts Department of Transportation, I am submitting comments regarding the Draft Environmental Impact Report for the Allston Yards 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 (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

Boston – Allston Yards Page 2 5/8/2020 cc: Jonathan Gulliver, Administrator, Highway Division Steve Poftak, General Manager, MBTA 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 Boston Planning and Development Agency Boston Region Metropolitan Planning Organization

MEMORANDUM

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

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

DATE: May 8, 2020

RE: Boston– Allston Yards (EEA #15995)

The Public/Private Development Unit (PPDU) has reviewed the Draft Environmental Impact Report (DEIR) for the proposed Allston Yards project in Boston submitted by the Stop & Shop Supermarket Company LLC with New England Development as Master Developer (together, the “Proponent”). The 10.6-acre site, located at 60 Everett Street, currently consists of 112,350 square feet of retail space, including a 77,764 square foot grocery store. The Proponent plans to raze all existing infrastructure to redevelop the site with the construction of 868 new residential units, 350,000 square feet of office space, 50,000 square feet of supporting retail/restaurant space, and a 67,000 square foot grocery store. The development program has slightly changed since the review of the Expanded Environmental Notification Form (EENF).

Based on the information presented in the DEIR, the project is expected to generate 7,990 net new unadjusted trips on a typical weekday and 5,600 net new unadjusted trips on an average Saturday, with 365 new trips occurring during the weekday morning peak hour, 835 new trips occurring during the weekday evening peak hour, and 720 new trips occurring during the Saturday midday peak hour. Provision for 1,200 structured parking spaces is proposed.

The project site is bounded by the Massachusetts Bay Transportation Authority (MBTA) Framingham/Worcester Commuter Rail line to the north, Everett Street to the east, commercial properties to the south, and the existing Boston Landing development to the west. A Vehicular Access Permit from MassDOT will be required because the project site abuts I-90 (Massachusetts Turnpike), a state-owned roadway.

The Proponent requests that the DEIR be rolled over to the Final Environmental Impact Report (FEIR); however, due to some outstanding issues regarding adequate design to accommodate MBTA buses and a request for a station code analysis, we recommend that a Final EIR be required. The DEIR generally addresses the following comments raised in MassDOT’s response letter to the EENF. Comments on the outstanding transit issues are reflected in these comments.

Ten Park Plaza, Suite 4150, Boston, MA 02116 Tel: 857-368-4636, TTY: 857-368-0655 www.mass.gov/massdot Boston– Allston Yards Page 2 5/8/2020

Trip Distribution

The DEIR updates the project’s trip distribution to place a portion of project-generated trips on Braintree Street east of the project site, as traffic accessing the project site would be destined for the Braintree Street Extension in order to access several of the parking facilities associated with the project. The capacity analyses provided in the EENF have been updated to reflect the change in the project’s trip distribution; MassDOT continues to be supportive of the Proponent’s approach to a mitigation program primarily focused on alternative modes of transportation.

Safety

The intersections of North Beacon Street/Brighton Avenue at Cambridge Street and Cambridge Street at Hano Street are each listed as Highway Safety Improvement Program (HSIP)-eligible intersections based on the 2006-2015 HSIP bicycle cluster listing at the time of the EENF’s publication. Since then, the Proponent has reached out to the Boston Police Department to obtain crash records to conduct the required Road Safety Audits (RSAs) at these intersections. Following coordination between MassDOT and the Boston Police Department, the number of RSA locations has increased to ten intersections, for which the RSAs were conducted on February 26, and 28, 2020. The RSA reports were submitted to MassDOT and the Proponent has committed to implement all the resulting low-cost improvements as summarized in the Draft Section 61 Finding. The Proponent should continue consultation with the City of Boston on the need to implement additional safety improvements.

Site Access Improvements

The DEIR includes a cross-section depicting the proposed condition between Building B and the Everett Street Bridge approach wingwall. The cross-section shows the expansion of the sidewalk width along the southbound side of Everett Street, which has been designed in a way to continue to allow for MassDOT inspection and maintenance access to the existing bridge approach wingwall. The Proponent should continue coordination with the Highway Division District 6 on this issue during the permitting process for the Project.

Multimodal Access and Facilities

The DEIR includes an updated inventory of bicycle and pedestrian facilities in the project’s study area. The Proponent has committed to updating deficient sections of sidewalk and curb ramps where merited, particularly along Braintree Street. Additionally, the DEIR includes a proposal for a shared-use pathway on the north side of the Braintree Street Extension, adjacent to the MBTA Boston Landing Commuter Rail station, facilitating improved pedestrian and bicycle access to the station.

We continue to urge the Proponent to be mindful of bicycle accommodations along Everett Street; the EENF has proposed to downgrade Everett Street’s bicycle accommodations from a bicycle lane in the northerly direction and a shared lane in the southerly direction to Boston– Allston Yards Page 3 5/8/2020

shared lanes in each direction. In the DEIR, the Proponent has presented a modified design of Everett Street from that allows for the existing northbound bicycle lane to be maintained.

Public Transportation

The DEIR includes an updated methodology to evaluate existing transit services within the study area, particularly for Commuter Rail services. Given the crowding impacts anticipated on several bus routes in the study area and on two morning inbound runs of the MBTA Framingham/Worcester Commuter Rail line, the Proponent has proposed a transit subsidy in lieu of infrastructural or service-centric mitigation to offset project-related impacts. Using per- passenger subsidies reported by the MBTA to the National Transit Database, which account for the difference between per passenger operating costs and farebox revenues, an Operating Subsidy per Passenger was calculated by the Proponent. This subsidy was attached to the number of passengers on each MBTA service that exceeds policy capacity in the future Build condition and carried out to 15 years, with a 2.5 percent inflation estimate, similar to other subsidy methodologies employed by MEPA projects reviewed by MassDOT. The total amount over 15 years came out to be $2,392,355.17 ($1,457,484.29 for bus impacts and $934,870.88 for Commuter Rail impacts), reflecting a year one subsidy (in 2020 dollars) of $133,413.18.

MassDOT accepts the Proponent’s methodology and justification for providing an operating subsidy for transit services. In evaluating the proposal, MassDOT corresponded with the MBTA regarding appropriate means to expend this money. MassDOT is committed to using the subsidy to address local concerns to the Allston Yards neighborhood, such as increased Commuter Rail service or vehicle procurement/operating assistance for bus routes which will be used to access the project, as well as for projects which are actionable in the short-term. Targets of funding for the subsidy may emerge from local projects and service-related initiatives to be identified in MassDOT and the MBTA’s Bus Network Redesign and Rail Vision efforts.

Route 64 Improvements

MassDOT continues to note that the proposed reconfiguration of the Everett Street/Guest Street Extension/Old Everett Street/Blaine Street intersection may not adequately accommodate buses turning right from the Guest Street Extension towards Everett Street, as the proposed design includes a stop line set back from the intersection, a very tight curb radius, and a narrow receiving lane. This would hinder a bus driver's ability to make the turn, and the set-back stop line would not likely be obeyed by drivers.

The Proponent has had ongoing meetings with the MBTA and BTD regarding this issue, and despite these design challenges, it has been agreed that the rerouting of the MBTA Route 64 bus along Everett Street would be beneficial. The Proponent has exchanged several detailed conceptual plans for improvements to accommodate the Route 64 turning movement into Everett Street during the DEIR review. At this stage, we believe that these concepts and any other design details would be better worked out during the design process with BTD and the MBTA, and the Proponent has committed to make sure all concerns are addressed. If a design that satisfactorily Boston– Allston Yards Page 4 5/8/2020

addresses these safety and operational concerns cannot be achieved, the MBTA will not reroute the Route 64 Bus and the Proponent has to reevaluate transit access to the site.

MBTA Boston Landing Commuter Rail Station Connection

The project site is located adjacent to the MBTA Boston Landing Commuter Rail Station. A direct connection to the station does not currently exist; current visitors are guided to the Arthur Street connection to the west of the project site or the stairwell at the eastern end of the station to Everett Street, walking to/from the project site along Everett Street. The Proponent has continued to coordinate with the MBTA’s Capital Delivery Department to determine the specifics of a future connection between the project site and the station and the parties have agreed to relocate the existing chain link fence which extends along the northerly side of the property’s boundary. The Proponent has proposed to construct a new sidewalk along the northerly side of the Braintree Street Extension within the MBTA-controlled property and provide a 100-foot long short-term pick-up/drop-off area along the northerly side of the Braintree Street Extension. The exact type of easement and the exact dimensions of the area to be used had not yet been finalized. Access and egress through this easement should be evaluated and provided in a way which accommodates expected increases in usage of the Commuter Rail station.

MassDOT is supportive of the currently constituted proposal to provide access from the project site to the MBTA Boston Landing Commuter Rail station. The MBTA Real Estate Department anticipates reviewing a license application and granting a license to the Proponent for the portion of land on the MBTA right of way, on which the Proponent would build the access path to the Boston Landing Station. MBTA Real Estate is working on a Memorandum of Agreement that will make provision for the future license agreement. The Proponent should continue to coordinate with MassDOT and the MBTA’s Capital Delivery Department regarding this connection. The Proponent should be aware that usage of MBTA property associated with relocation of the existing fence may require review and concurrence with the MBTA Legal, Real Estate, and Railroad Operations departments.

One aspect of the Boston Landing Commuter Rail Station’s interactions with the project site detailed in the TIA is the connection from the stairwell on Everett Street. The TIA notes that widening of the sidewalks in this area would require the construction of a new narrow adjoining bridge structure to support an expanded sidewalk, which would involve substantial infrastructure changes including additional bridge girders and modifications to the existing bridge piers. This may have a related benefit of providing increased roadway width for improved bicycle accommodations. The Proponent has indicated that this mitigation alternative is beyond the capacity of this project and has proposed instead an at-grade connection alternative that would help divert pedestrian traffic from the existing access points to the station on the Everett Street Bridge to Braintree Street and the enhanced Station connection, which will include an enclosed, secure bicycle area.

Boston– Allston Yards Page 5 5/8/2020

Station Code Analysis

The MBTA Capital Delivery is concerned that a code analysis of the station has not been performed to ensure the station can safely accommodate the additional passengers. If the State Inspector has an action associated with this development, it could trigger a code review of the station that is likely to result in significant upgrades. The Proponent should discuss with the MBTA the need for the analysis and the timing of completion of the analysis.

Parking

The DEIR proposes provision for 1,200 parking spaces, a reduction from the 1,409 proposed in the EENF. The parking provision corresponds to a ratio of 0.5 spaces per residential unit, approximately 1.56 spaces per 1,000 square feet of office space, and approximately 2.7 spaces per 1,000 square feet of grocery/retail space.

The EENF noted that the Proponent intended to pursue a shared parking strategy to decrease the need for parking spaces on-site, particularly given the differing peak periods of parking utilization between the office and residential uses. Incentives such as a “reverse- commuter” pass for residents to park during evening hours were noted to be evaluated as the project is developed and adapts over time. Residential parking would be unbundled from the purchase or lease of a unit as well. Parking needs would be re-evaluated as the project develops on a phased basis over multiple years.

The DEIR provides further detail on shared parking arrangements, access to car sharing vehicles, and evaluate the feasibility of future conversion of parking garage space to other uses. The Proponent has committed to exploring further opportunities to share or reduce parking as tenants are secured and parking is monitored.

Transportation Demand Management (TDM)

To reduce site trip generation, the TIA includes a TDM program. The Proponent has committed to the following TDM measures in the EENF with the goal of reducing vehicle trips by visitors of the project:

• Assignment of an on-site TDM coordinator to oversee all TDM programs for each building; • Provision of a central commuter information center within the project site, near the MBTA Boston Landing Commuter Rail station, to provide travel information to employees, residents, and visitors; • Provision of secured, covered bicycle parking within each building, as well as changing rooms and shower facilities; • Provision of bicycle racks throughout the project site; • Provision of a transit subsidy of 50% for grocery store employees; • Provision of parking spaces for a shared vehicle service, such as Zipcar; Boston– Allston Yards Page 6 5/8/2020

• Provision of electric vehicle charging stations within structured parking areas, as well as spaces which can be outfitted with charging stations as demand grows; • Provision of preferential parking spaces for carpool and vanpool parking within the office parking garage and near office building entrances; • Provision of ride-matching assistance by the TDM coordinator; • Sponsorship of vanpools and subsidized expenses; and • Hosting of promotional events for transit riders, cyclists, and pedestrians;

The Proponent must join or include in its tenant’s lease agreements specific requirements to join the MBTA Perq Program.

The Proponent should further work toward identifying the details of these measures as well as developing additional programs. We encourage further exploration of transit subsidies tied to future leasing of the project’s office usage, as well as the consideration of one or more Bluebikes stations on the project site with incentives for users of the project site to utilize. The items outlined in the “Parking” section above can also be considered a means to encourage multimodal travel to and from the project site. The Proponent should consult with Allston the Brighton Transportation Management Association to help implement the TDM program.

Transportation Monitoring Program

The Proponent will be required to conduct an annual traffic monitoring program for a period of five years, beginning six months after occupancy of the Full-Build project. If the project is phased, the Proponent should work with MassDOT to devise an appropriate schedule. The monitoring program should include at a minimum:

• Simultaneous automatic traffic recorder (ATR) counts at each site driveway for a continuous 24-hour period on a typical weekday and Saturday; • Travel survey of employees and patrons at the site (to be administered by the Transportation Coordinator); and • Weekday morning, weekday evening, and Saturday peak hour turning movement counts (TMCs) and operations analysis at “mitigated” intersections, including those involving site driveways. • Transit ridership counts

The goals of the monitoring program will be to evaluate the assumptions made in the EENF and EIRs and the adequacy of the mitigation measures, as well as to determine the effectiveness of the TDM program.

. The Proponent should continue consultation with appropriate MassDOT divisions, including the Public/Private Development Unit, the Highway Division District 6 Office and the MBTA and prepare a limited transportation study to address the concerns related to rerouting the Route 64 bus and the request for a station code analysis. The Proponent should then update the draft Section Finding to address revisions, if any, of the mitigation commitment. If you have any questions regarding these comments, please contact me at (857) 368-8862. 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

11 May 2020

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

RE: Allston Yards, Allston, Massachusetts, EEA #15995

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

Dear Secretary Theoharides:

We’ve reviewed the Draft Environmental Impact Report (DEIR) for the above project. The proposed project consists of about 811,000-sf of residential multifamily and 400,000-sf of office. Supermarket and some retail is also proposed on ground floor.

Executive Summary

• Current commitments include air source systems for one of the residential buildings and the office.

• Model outputs for the residential “mitigated” scenario appear unusually high performing and may be erroneous. As a result:

o We do not know what the Mitigation Level is for these buildings. Based on the limited proposed improvements, it appears that the Mitigation Level could be relatively small.

o Comparisons of this potentially erroneous “mitigated” scenario to Passivehouse scenarios may be greatly underestimating benefits of Passivehouse.

Allston Yards, EEA #15995 Allston, Massachusetts

• All buildings’ envelope performance is minimally improved over code. In fact, some or all buildings may just meet, or not meet, minimum code standards planned to go into effect August 2020. All buildings would likely benefit from improved envelope.

Pathway to 28% Mitigation Level

Using the model output reported in the DEIR, Mitigation Level1 (all buildings) would be about 11%. However, this value may be overestimating Mitigation Level given the potential error in the residential energy performance.

Examining some of the alternatives provided, Mitigation Level for electrification, Passivehouse, and solar PV options would be as follows:

• Committing to electrification described in the submission would result in a ML of about 4%. • Passivehouse for the three residential building improves ML to 27%; • Installing solar PV on the rooftop space described in the submission improves ML to 28%.

1 Mitigation Level is the percent GHG reduction beyond the reduction that would occur as a result of following state and local building codes. A Mitigation Level of 0% means that no mitigation is proposed.

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Allston Yards, EEA #15995 Allston, Massachusetts

Codes and Baseline

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. Accordingly, the baseline for this project should be based on ASHRAE 90.1-2013 plus Massachusetts amendments. The project is using this baseline.

In August 2020, an update to the Massachusetts Stretch Code is planned to take effect. The underlying code provisions will not change. The Stretch Code planned to take effect in August also uses ASHRAE 90.1-2013-Appendix G and the 10% improvement remains unchanged. 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 while the list of additional measures to choose from are expanded.

To accurately estimate Mitigation Level for this project, we recommend that the baseline for this project be set at the Stretch Code provisions planned to take effect in August 2020 as this will likely be the code that will be used for building construction. In accordance with the MEPA GHG Policy, the project is welcome to continue to compare to the baseline that existed at the time of the ENF, as well.

Potential Error in Residential Model Output

The residential buildings’ “mitigated” model output appears unusually high-performing considering the minimal envelope improvements proposed. The model shows a 85% reduction in heating consumption. In fact, heating consumption for the “mitigated” scenario is comparable to Passivehouse level performance.

The illustration on the next page shows code-performance energy consumption (left), the modeled “mitigated” performance (middle), and the results from a similar, nearby residential apartment project2 (right). As shown, the proposed mitigated has near-identical performance as the nearby project which has substantially more envelope commitments.

2 MEPA project number 16024 “Riverside Station Redevelopment”, Newton. Information can be accessed here: http://eeaonline.eea.state.ma.us/eea/emepa/searcharchive.aspx

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Allston Yards, EEA #15995 Allston, Massachusetts

Proponent Mitigated Nearby Project Mitigated Minimum Code Baseline Value Improvement Value Improvement Roof R30c.i R30c.i. None R-78c.i. 61% better Wall U-0.055 U-0.055 None U-0.036 34% better Window U-0.42 U-0.38 10% better U-0.22 48% better % Fenestration 40% 40% None 40% None Vertical UA 0.20 0.19 7% better 0.11 46% better Infiltration (cfm/sf) 97% less 0.4 0.4 Same leakage 0.014 leakage Infiltration Field Confirmed Not required No Yes Heating Efficiency (%) 88 91- 125 (1) 3-42% better 320 264% better Emissions per 1 MMBtu of 5% worse to 133 113 – 140 (1) 62 53% better space heating (lbs) (2) 15% better Exhaust Air Recovery (3) 50% effective 70% effective 40% better 70% effective 40% better Verified with WUFII Not required No Yes

1. Range varies based on amount of simultaneous heating and cooling. 2. Source emissions required (lbs CO2) to deliver 1 MMBtu of space heating (in 2020) 3. Where required by Code.

The tables above present the corresponding inputs for both projects and shows the performance improvements over Code.

• For the subject project, envelope improvement is limited to a 10% improvement in window performance and no improvement over code for walls. The resulting vertical UA performance is only 7% improved over code. No roof improvements are planned and there is no improvement to air-infiltration over Code minimum standard.

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Allston Yards, EEA #15995 Allston, Massachusetts

• In contrast, the nearby project is planning 34% higher-performing windows and 48% higher-performing walls, resulting in a vertical UA improvement of 46%. (This vertical UA performance improvement is more than x6 proposed project’s UA improvement.) The roof is planned to be 61% higher-performing than Code. Critically, the nearby project will have 97% less air leakage than Code-allowed threshold and will be confirming this with field verification.

The nearby project heating equipment is also substantially higher efficiency than proposed. For the subject project’s residential buildings C and D, a water source heat pump system supplied by an 95% efficient boiler is planned. The heating efficiency of this combined water source/boiler system is about 91 to 125% (range depends upon amount of concurrent heating and cooling). In contrast, the heating efficiency of the nearby project is 320%. Ventilation improvements are the same for both projects.

In summary, the performance of the residential buildings appears unusually high performing. Nearly all the performance improvement for the “mitigated’ case is attributable to reduction in heating end use which are estimated to approach Passivehouse heating end use reductions, despite minimal improvements to envelope. These results appear to be erroneous.

Since the original EENF, the proponent provided the results of an exercise showing reduction in heating end use due to various improvements. However, this exercise was itself based on the same potentially erroneous model. To resolve this issue, we recommend conducting a separate, independent analysis using a WUFI model.

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

Planned Massachusetts amendments require that baseline residential buildings set maximum fenestration to 24% from current 40% default. We recommend that the project update the residential baselines to reflect this requirement.

In addition, Massachusetts amendments will also require conformance with 2018 IECC Section C402.1.5 which mandates that the aggregate performance of all above-grade surfaces perform at least as well as the envelope performance factors in IECC Table C402.1.4 and C402.4 and the fenestration values in C402.4.1 and C402.4.3. It is not clear whether the buildings (both office and residential) meet this requirement.

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Allston Yards, EEA #15995 Allston, Massachusetts

Envelope performance improvements over current code requirements are minimal. For the residential buildings:

• Vertical UA performance is 7% over current code requirements; • Roof performance is the same as code; • Infiltration limits are the same as code.

As described above, other projects use significantly more envelope improvements to achieve the EUI and heating end use reductions anticipated for this project.

For the office building:

• Vertical UA performance is 8% over current code requirements; • Roof performance is the same as code; • Infiltration limits are the same as code.

The office project may benefit from further improving envelope performance, particularly if perimeter heating can be eliminated (see below).

Building Envelope and Perimeter Heating

The residential and office buildings have vertical wall performance at-code (0.055) albeit all with improved windows. We recommend the proponent to also examine whether further wall and/or window improvements could potentially eliminate or reduce the need for perimeter heating for these buildings.

Elimination/reduction of perimeter heating could potentially result in significant construction cost savings, improved comfort, and reduced maintenance. Also, elimination/reduction of perimeter heating may also make full electrification more feasible and thus improve GHG reduction.

External Shading and Solar Heat Gain Coefficient (SHGC)

External shading and solar heat gain coefficient (SHGC) have not been analyzed yet, consistent with the level of design of the project at this time. As the project moves forward, we encourage examination of building self-shading, external shading, and varying SHGC as a function of exposure. (For example, targeting lower SHGC-rated glass for building sides and areas more exposed to sun and/or less shaded.)

Passivehouse

The project performed a thorough analysis of Passivehouse, including various alternatives with efficient electric air source heat pump systems and electric and gas service water systems. These analyses appear complete and show Passivehouse would yield buildings with very low emissions and energy use.

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Allston Yards, EEA #15995 Allston, Massachusetts

The analyses also included a comparison of Passivehouse to currently-proposed mitigation. For the three residential buildings, this analysis appears impacted because:

• The currently-proposed mitigation scenario appears to be significantly over-estimating energy reduction, as described above, and;

• The financial analyses does not include up to date MassSave® incentives.

Both result in an analysis which significantly underestimates the value of Passivehouse.

Passivehouse Incentive

MassSave® Passivehouse incentive is $3,000 per dwelling unit. The incentive value used in the submission was about $200 per dwelling unit.

In addition to above, funding for feasibility, modeling, and an additional “net performance bonus” is available. Feasibility and modeling has a value of up to $25,000 and the net performance bonus can add several hundred more dollars per unit. For the purpose of this analysis we have assumed no net performance bonus.

Total Passivehouse incentive (at $3,000 per unit) for this project could reach $2.6M if applied to all planned residential units.

Potential Errors in Passivehouse “Pro Forma”

The submission also included a “pro forma” showing an 80 year payback. However, this appears impacted as described above. Using Building A as an example, this is based on:

• Annual operating savings just $19,480 per year. This saving estimate is very low because of the likely error in overestimating performance of the mitigated scenario, discussed above.

• Underestimating MassSave® incentive by $0.54M (for just Building A).

Corrected “Pro Forma”

Applied across all three residential building, Passivehouse would have the following estimated benefits:

• Annual operating cost savings of $0.53M. This is a 36% reduction in operating costs; • MassSave rebate value of $2.6M; • Simple payback of 8.6 years.

Potential value of Alternative Energy Credits (AECs) are not included in the above.

Page 7 of 11

Allston Yards, EEA #15995 Allston, Massachusetts

Examining Passivehouse on a cash-flow basis where the additional net costs are financed over 30 years at 5% interest, Passivehouse would cost $0.24M less to own and operate.

Note, this is the opposite of what was found in in the DEIR due to the two potential errors described above. The DEIR shows an increase in costs to own and operate.

In summary, Passivehouse would deliver superior windows, comfort, resilience, emissions reduction, and cost less.

Fossil-Fuel Reduction and Efficient Electrification

Efficient electrification of space and service water heating is an effective strategy for GHG mitigation. Electrification entails swapping from gas-fueled equipment to air source electric heat pumps and VRF systems.

There is a statement in the submission, as follows:

“Due to the increased carbon intensity of electricity consumption compared to natural gas consumption, the GHG emissions reductions fall comparatively short of the energy savings. It is estimated that carbon intensity of electricity consumption will decrease in the coming decades as a “greener” grid is built, which is anticipated beyond the completion date of the Project.”

While the proponent is correct that grid emissions rates are expected to decline over time, there are GHG benefits for electrification today in Massachusetts. In fact,

Page 8 of 11

Allston Yards, EEA #15995 Allston, Massachusetts

• Today, in 2020, space heating with heat pump/VRF heating has:

o almost 50% less emissions than best-in-class, highest-efficiency, condensing gas systems.

o Between 45 and 56% less emissions than water source heat pumps served by best- in-class, highest efficiency condensing gas systems. (The range depends upon how much concurrent heating and cooling exists.)

• By 2050, with continued addition of renewable inputs to the electric grid, heat pump/VRF heating is expected to have

o 85% less emissions than best-in-class, highest-efficiency, condensing gas systems.

o Between 78 and 83% less emissions than water source heat pumps served by best- in-class, highest efficiency condensing gas systems. (The range depends upon how much concurrent heating and cooling exists.)

Accordingly, the project would see an immediate benefit to carbon reduction which will only increase over time. For this reason, efficient electrification of space heating is recommended for this project.

The project is making strides towards efficient electrification of space heating, including:

• fully electrifying space heating for Building A residence with air source heat pumps

• fully electrifying space heating for Building B office with air source VRF systems

The submission states that the project will continue to evaluate electrification for buildings C and D. Given the emissions and other benefits, we recommend efficient electrification of space heating be made a commitment for this project.

For water heating, all the buildings are planned to use condensing gas systems.

Solar PV

Solar PV can provide significant GHG benefits as well as significant financial benefits. The proponent completed a detailed analysis for rooftop PV space including shadow analysis and evaluations of innovative façade mounted PV systems. The analysis shows space available for 330 kW of rooftop mounted PV and 130 kW of facade mounted. We recommend that the project be committed to making rooftops solar ready for at least 330 kW of horizontal rooftop PV.

Page 9 of 11

Allston Yards, EEA #15995 Allston, Massachusetts

Supermarket

The supermarket portion of the development (67,000-sf) is committing to use many of the measures described in the Advanced Energy Design Guide for supermarkets published by ASHRAE3 including LED lighting, VFD fans, and refrigerant leak detection systems,

Recommendations for Subsequent Submission

Recommendations are as follows:

1. Perform independent analysis of residential buildings using WUFI model. It’s anticipated that to achieve the anticipated performance, residential envelope performance will have to be improved to levels in line with the nearby project described above.

2. Upon completion of (1) above, update Passivehouse alternative. It’s anticipated that an updated analysis will show significant emissions reduction and that Passivehouse will cost less to own and operate and thus should be made a commitment.

3. Update project baseline to reflect August 2020 building codes with Massachusetts amendments, including fenestration limits for multifamily residential to be included in the Baseline.

4. Confirm that all the buildings’ planned above grade envelope meets the requirement of 2018 IECC Section C402.1.5.

5. Expand efficient electrification of space heating to all buildings (air source heat pumps and VRF).

6. For the office, examine improved envelope scenarios which could result in elimination of perimeter heating systems.

7. Examine effect of targeted SHGC and external shading considering variability of exposure to sun, building self-shading, and shadows from other buildings.

8. Confirm that the project is committing readiness to house 330kW of PV on roofs.

Sincerely,

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

3 https://www.ashrae.org/technical-resources/aedgs

Page 10 of 11

Allston Yards, EEA #15995 Allston, Massachusetts

Brendan Place Clean Energy Engineer Massachusetts Department of Energy Resources

Page 11 of 11

May 8, 2020

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

Subject: EOEEA #15995 – Draft Environmental Impact Report Allston Yards, Boston, MA

Dear Secretary Beaton,

The Massachusetts Water Resources Authority (MWRA) appreciates the opportunity to comment on the Draft Environmental Impact Report (DEIR) submitted by Stop & Shop Supermarket Company LLC with New England Development (together the “Proponent”) for Allston Yards (the “Project”) in Boston, Massachusetts. The Project site currently contains 100,000 gross square feet (gsf) of retail space including a Stop and Shop grocery store, smaller ancillary retail space, and a 450 space surface parking lot. The proposed Project includes the mixed-use, transit-oriented redevelopment of the site to include residential units, office/high- tech/R&D/laboratory space and ground floor retail/restaurant space. The Project will also include a flagship grocery store, associated parking and approximately 1-acre of public open space. Construction is proposed through a long-term, multi-phased approach, however infrastructure supporting the full build out will be completed as part of the first phase of the Project. The DEIR identifies reduction in the number of residential units, building height, and parking spaces from the previously reviewed Expanded Environmental Notification Form (EENF).

MWRA previously commented on the Project EENF on April 5, 2019. Comments on this DEIR continue to relate to wastewater issues and the need for Infiltration/Inflow (I/I) Removal as well as Toxic Reduction and Control (TRAC) discharge permitting.

Wastewater

MWRA’s comments on the EENF noted the need to ensure that the Project’s wastewater flow does not increase sewer system surcharging or combined sewer overflows in large storms. It was also noted that the Proponent, together with BWSC, should effect a 4:1 offset of the Project’s new wastewater flow by removing I/I or stormwater from a hydraulically related sewer system(s). Four gallons of extraneous flow should be removed for every gallon of new wastewater flow, in compliance with MassDEP regulation and related BWSC I/I mitigation policy. The DEIR states that as design is advanced and approval is sought BWSC will review and confirm the appropriate mitigation volume, and confirms that the Proponent will provide the appropriate value of compensation to the BWSC I/I mitigation fund. The proponent will commit to the specific compensation value as part of each building’s BWSC site plan approval process.

TRAC Discharge Permitting

MWRA prohibits the discharge of groundwater and stormwater into the sanitary sewer system, pursuant to 360 C.M.R. 10.023(1) except in a combined sewer area when permitted by the Authority and the local community. The 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. The DEIR confirms that the Project design does not include any groundwater or stormwater discharges into the sanitary sewer system.

A Sewer Use Discharge Permit is required prior to discharging laboratory wastewater or photoprocessing wastewater from office, high-tech, R&D, laboratory or commercial space 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 Keary Simmerman, Industrial Coordinator, in the TRAC Department at 1 (617) 305-5638.

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.

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

April 10th 2020

Kathleen Theoharides Executive Office of Energy and Environmental Affairs Attn: Page Czepiga, MEPA Office 100 Cambridge St, Suite 900 Boston, MA 02114

RE: Allston Yards Project, EEA #15995

Dear Secretary Theoharides,

The Charles River Watershed Association (CRWA) has reviewed the above referenced Draft Environmental Impact Report (DEIR) and offers the comments below for your consideration.

CRWA is encouraged by the proponent’s commitment that the Project will capture and infiltrate 1.25-inches of stormwater over the impervious areas of the applicable block. Additionally, the Master Plan’s site design takes into consideration a landscape design that allows for infiltration and below grade storage structures to manage the majority of storm rainwater on site and address possible short-term flood-like situations.1

The Project is expected to improve stormwater runoff quality and reduce peak flows by increasing pervious area across the Project Site, including the addition of the 1-acre Community Green, new landscaping, permeable pavers and street trees in the furnishing zone of all proposed streets, and through the use of treatment and infiltration facilities as part of the new drainage system.2 However, the DEIR lacks a clear commitment to meeting the Charles River’s Total Daily Maximum Load (TMDL) targets.

In fact the proponent has outright rejected the use of numerous green infrastructure strategies in the DEIR. “LID measures, such as rain gardens and grass swales, were considered to capture sidewalk and excess street runoff, but the Project ultimately chose permeable pavers because raingardens and swales require additional plant maintenance and function poorly during winter conditions when the

1 DEIR Pg. 5-2 2 DEIR Pg. 6-2

Charles River Watershed Association 190 Park Road Weston, MA 02493 t 781 788 0007 f 781 788 0057 e [email protected] www.charlesriver.org

roads and sidewalks are salted.”3 There are no BMP design details or drainage calculations included in the DEIR that would indicate how the Project is expected to perform in terms of achieving its phosphorous reduction targets.

CRWA therefore expects that the above concerns will be addressed by the proponent in the FEIR. In addition to that we expect to see appropriate documentation of the design of all the green infrastructure BMPs that will be used with corresponding drainage calculations and demonstrated compliance with the TMDL. Please feel free to contact me at (781) 788-0007 ext-232 or via email if you have any questions.

Sincerely,

Pallavi Kalia Mande Director of Watershed Resilience, CRWA [email protected]

3 DEIR Pg. 6-3

Charles River Watershed Association 190 Park Road Weston, MA 02493 t 781 788 0007 f 781 788 0057 e [email protected] www.charlesriver.org

May 8, 2020

Kathleen Theoharides, Secretary Executive Office of Energy & Environmental Affairs Attention: MEPA Office – Page Czepiga, MEPA #15995 100 Cambridge Street, Suite 900 Boston, MA 02114

RE: Allston Yards, MEPA #15995

Dear Secretary Theoharides:

The Metropolitan Area Planning Council (MAPC) regularly reviews proposals deemed to have regional impacts. The Council reviews proposed projects for consistency with MetroFuture, the regional policy plan for the Boston metropolitan area, the Commonwealth’s Sustainable Development Principles, consistency with Complete Streets policies and design approaches, as well as impacts on the environment.

MAPC has a long-term interest in alleviating regional traffic and environmental impacts, consistent with the goals of MetroFuture. Furthermore, the Commonwealth encourages an increased role for bicycling, transit and walking to meet our transportation needs while reducing traffic congestion and vehicle emissions. Additionally, the Commonwealth has a statutory obligation to reduce greenhouse gas emissions (GHG) by 25% from 1990 levels by 2020 and by 80% from 1990 levels by 2050.

A Draft Environmental Impact Report (DEIR) has been filed with the EOEEA by the Stop & Shop Supermarket Company LLC with New England Development (together, the Proponent). The Proponent proposes to redevelop the existing retail center located at 60 Everett Street in the Allston neighborhood of Boston. Allston Yards (the Project) lies within the Allston neighborhood just south of the Massachusetts Turnpike and is bounded by the Everett Street bridge to the east, Arthur Street to the west, along with a mix of other uses that front on North Beacon Street to the south. The Project is located adjacent to the MBTA Boston Landing commuter rail station. Eight bus routes - 51, 57/57A, 64, 66, 70/70A, 86, 501, and 503 - all operate within a half mile of the Project site and the MBTA Green Line “B” route is located approximately three-quarters of a mile from the site.

The Project site currently houses approximately 100,000 square feet (sf) of retail space, including a 65,000 sf Stop & Shop constructed with smaller ancillary retailers in a one-story building with a 450-space surface parking lot. The Proponent proposes to redevelop the 10.6-acre Project site with an approximate 1.25 million sf mixed-use, transit- oriented development (TOD) comprising approximately:

➢ 350,000 sf of office/research space; ➢ 868 residential units; ➢ 117,000 sf of retail space, including a 67,000-square foot grocery store; and ➢ Public open space comprising one acre.

At full-build, the Project is expected to generate an estimated 4,150 adjusted trips per day1 and will include up to 1,200 parking spaces.

MAPC is pleased that the Proponent has outlined a comprehensive mitigation program as well as a robust Transportation Demand Management (TDM) program. However, we have concerns that pertain to the amount of proposed parking spaces and the need to include mode share goals.

1 Unadjusted daily trips are 8,360.

Parking

The Proponent proposes an overall residential parking ratio of 0.5 spaces per residential unit and 1.56 spaces per 1,000 sf of office space. While the residential parking ratio is between 33-60%2 lower than the Boston Transportation Department’s (BTDs) residential parking guidelines, the office space parking ratio exceeds BTD’s guidelines. BTD’s parking ratio guidelines for office use near an MBTA station in Allston range between .75 to 1.25 spaces per 1,000 sf.

We recognize the Proponent proposes to unbundle parking from the leasing or purchase of residential units, and the Proponent further plans for future reuse of space through structured parking. However, the Proponent did not follow the EENF Certificate’s requirement to evaluate measures to reduce parking supply that include providing cash-out incentives for employees, metering on-street parking, and fees for structured parking3. MAPC respectfully requests the Secretary to require the Proponent to reevaluate reducing the number of office parking spaces.

We also note that while the DEIR mentions the proposed project's land use approvals include incentives to convert parking space to usable space in the future, the DEIR does not identify what these incentives are. We would like the Proponent to clarify.

Mode Share Goals

The Proponent has committed to a monitoring program but has omitted any discussion of mode share goals. The EENF Certificate directed the Proponent to “clearly state mode share goals and discuss how the TDM program is designed to meet these goals.4” The Proponent needs to define mode share goals clearly (vehicular, commuter rail, bus, bicycling and walking) for residents and employees as part of their commitment to conduct monitoring and reporting. Mode share goals should result in an increase of public transportation (bus and rail), walking, and bicycling, and a decrease for single-occupancy vehicle (SOV) use.

MAPC respectfully requests that the Secretary incorporate our comments as part of the Certificate issuance and the forthcoming Section 61 Findings.

Thank you for the opportunity to comment on this project.

Sincerely,

Marc D. Draisen Executive Director

cc: Vineet Gupta, City of Boston, Boston Transportation Department Tad Read, Boston Planning and Development Agency David Mohler, MassDOT

2 BTD’s residential parking guidelines in Allston/Brighton near an MBTA station are between 0.75 – 1.25 spaces per unit. 3 EENF Certificate, April 12, 2019, page 15. 4 EENF Certificate, April 12, 2019, pages 16-17. ______Kathleen Theoharides, Secretary, Executive Office of Energy and Environmental Affairs May 8, 2020 RE: Allston Yards, DEIR, MEPA #15995 P. 2 of 2