The Commonwealth of Massachusetts Executive Office of Energy and Environmental Affairs 100 Cambridge Street, Suite 900 Boston, MA 02114 Charles D. Baker GOVERNOR Tel: (617) 626-1000 Karyn E. Polito Fax: (617) 626-1081 LIEUTENANT GOVERNOR http://www.mass.gov/eea Kathleen A.Theoharides SECRETARY October 23, 2020
CERTIFICATE OF THE SECRETARY OF ENERGY AND ENVIRONMENTAL AFFAIRS ON THE ENVIRONMENTAL NOTIFICATION FORM
PROJECT NAME : 1234 and 1240 Soldiers Field Road PROJECT MUNICIPALITY : Boston PROJECT WATERSHED : Charles River EEA NUMBER : 16272 PROJECT PROPONENT : TDC 1234 Owner, LLC and TDC 1240 Owner, LLC DATE NOTICED IN MONITOR : September 23, 2020
Pursuant to the Massachusetts Environmental Policy Act (M.G.L. c. 30, ss. 61-62I) and Section 11.03 of the MEPA Regulations (301 CMR 11.00), I hereby determine that this project requires the preparation of a mandatory Draft Environmental Impact Report (DEIR).
Project Description
As described in the Environmental Notification Form (ENF), the project consists of the construction of an approximately 723,000 square foot (sf) mixed use development on two adjacent parcels located at 1240 and 1234 Soldiers Field Road in Boston. The 1240 Soldiers Field Road project component consists of a 438,000 sf development comprised of 535 rental units and 10,500 sf of retail space, and 220 structured parking spaces. The 1234 Soldiers Field Road project component consists of an approximately 285,000 sf development comprised of 120 condominium units, 255 hotel rooms, 4,000 sf of retail and 185 structured parking spaces. A site drive will bisect the parcels and provide delivery and service vehicles access through the site from Western Avenue and Soldiers Field Road. The project includes bicycle and pedestrian improvements within the vicinity of the project and approximately 72,000 sf (1.65 acres) of on- site open space. Extending from the open space will be a new publicly accessible pedestrian path and ramp which will connect the southern end of the new Telford Street Bridge to Western Avenue. This pedestrian improvement will provide accessible public access over Soldiers Field Road to the Charles River Reservation including nearby Artesani Playground and Herter Park.
EEA# 16272 ENF Certificate October 23, 2020
Project Site
The project site encompasses two parcels of land totaling approximately 136,971 sf (3.143 acres) in total. The 1234 Site encompasses approximately 51,267 sf (1.18 acres) and the 1240 site encompasses approximately 85,650 sf (1.97 acres). The project site is bordered by Soldiers Field Road to the north, properties to the east owned by the City of Boston Department of Public Works and Harvard University, Western Avenue to the south and Telford Street to the west. Western Avenue and Telford Street are under the jurisdiction of the City of Boston and Soldiers Field Road is under the jurisdiction of the Commonwealth of Massachusetts Department of Conservation and Recreation (DCR). Existing uses at the 1234 Site include the Studio Allston Hotel and Casa Cana restaurant. Existing uses at the 1240 Site include The Skating Club of Boston. The project includes demolition of these existing structures.
The Skating Club of Boston is included in the Massachusetts Historical Commission (MHC)’s Inventory of Historic and Archaeological Assets of the Commonwealth (BOS.17074). The project site abuts Soldiers Field road, a historic parkway that is listed in the National Register of Historic Places (BOS.9602) and is near the Charles River Reservation/Metropolitan Park System of greater Boston (BOS.VE). The project does not include any wetland resource areas and it is not located within rare species habitat.
Environmental Impacts and Mitigation
Environmental impacts associated with the project include the disturbance of 3.14 acres of previously developed land, generation of 5,908 New average daily trips (adt) (7,438 adt total),1 creation of 241 New parking spaces (405 spaces total), increase in water demand by 114,323 gallons per day (gpd) (135,630 total) and an increase in wastewater generation of 103,930 gpd (123,300 gpd total). The project may have wind and shadow impacts on adjacent land and historic resources. Greenhouse Gas (GHG) emissions and other air pollutants are associated with on-site energy use and for vehicle trips generated by the project.
The project will minimize and mitigate environmental impacts by eliminating 0.32 acres of impervious area; enhancing pedestrian and bicycle access, providing open space on 1.65 acres of the site; providing improved connection to the Telford Street pedestrian bridge; implementing Transportation Demand Management (TDM) measures such as encouraging use of public transit and other alternate modes of travel; and construction of a stormwater management system with Best Management Practices (BMPs) to improve water quality, reduce flow rates and infiltrate stormwater. The DEIR should provide further analysis to demonstrate that the project includes measures to minimize stationary- and mobile-source GHG emissions generated by the project to the maximum extent practicable.
Jurisdiction and Permitting
The project is subject to the preparation of a Mandatory EIR pursuant to 301 CMR 11.03(6)(a)(6) because it requires State Agency Actions will generate 3,000 or more New adt on
1 As discussed below, total impact calculations include all project components including existing uses that will be demolished and replaced. The net “new” calculations exclude impacts from existing uses, which are still in use and already have impacts on the surrounding water/wastewater system and traffic network.
2 EEA# 16272 ENF Certificate October 23, 2020 roadways providing access to a single location. The project requires a Construction and Access Permit from DCR and a Section 8(m) Permit from the Massachusetts Water Resources Authority (MWRA). The project may require an Article 97 land transfer from DCR. The project is subject to review under the May 2010 MEPA Greenhouse Gas (GHG) Emissions Policy and Protocol (“the Policy”). It requires review by the Massachusetts Historical Commission (MHC) pursuant to M.G.L. Chapter 9, sections 26-27C (950 CMR 71.00).
The project requires Article 80 Large Project Review and Planned Development Area (PDA) Approval by the BPDA and a Transportation Access Plan Agreement (TAPA) and Construction Management Plan (CMP) approval from the Boston Transportation Department (BTD). The project requires site plan approval by the Boston Water and Sewer Commission (BWSC). The project requires a determination of no hazard to air navigation from the Federal Aviation Administration (FAA) and a National Pollutant Discharge Elimination System (NPDES) Stormwater General Permit from the Environmental Protection Agency (EPA).
Because the Proponent is not seeking State Financial Assistance, MEPA jurisdiction extends to those aspects of the project that are within the subject matter of required or potentially required Permits that are likely, directly or indirectly, to cause Damage to the Environment.
Review of the ENF
The ENF included a description of existing site conditions, project description and conceptual plans of proposed conditions. The ENF identified the project’s potential impacts on transportation, water and wastewater infrastructure, and stormwater and historic resources, but did not provide a detailed assessment of impacts or a comprehensive analysis of mitigation measures. Comments from DCR and the Massachusetts Department of Transportation (MassDOT) identify additional transportation analysis and information that should be provided in the DEIR. Comments from MHC identify additional impact analysis for historic structures that should be provided in the DEIR. Comments from DCR and the Charles River Watershed Association commend the project for its incorporation of green space and improved pedestrian and bicycle accommodations; further information on these issues should be provided in the DEIR as noted below. The DEIR should provide a more detailed description of existing and proposed conditions and a comprehensive review of the project’s impacts and measures to avoid, minimize and mitigate such impacts, as set forth in the Scope below.
SCOPE General
The DEIR should follow Section 11.07 of the MEPA regulations for outline and content and provide the information and analyses required in this Scope. It should clearly demonstrate that the Proponent has sought to avoid, minimize and mitigate Damage to the Environment to the maximum extent feasible.
Project Description and Permitting
The DEIR should include detailed site plans for existing and post-development conditions at a legible scale. Plans should clearly identify buildings, interior and exterior public areas, impervious areas, pedestrian and bicycle accommodations, and stormwater and utility
3 EEA# 16272 ENF Certificate October 23, 2020 infrastructure. The DEIR should describe the nature of the proposed improvements to the Telford pedestrian bridge including how the Proponent’s improvements will compliment improvements that may be undertaken by DCR. The DEIR should include a timeline of improvements proposed by both the Proponent and DCR to the extent this information is available.
The DEIR should describe the project and identify any changes since the filing of the ENF. It should identify and describe State, federal and local permitting and review requirements associated with the project and provide an update on the status of each of these pending actions. The DEIR should include a description and analysis of applicable statutory and regulatory standards and requirements, and a discussion of the project’s consistency with those standards. It should confirm that the height of the proposed building will comply with the Massachusetts Port Authority’s (Massport) Logan Airspace Map and any related FAA requirements.
The information and analyses identified in this Scope should be addressed within the main body of the DEIR and not in appendices. In general, appendices should be used only to provide raw data, such as drainage calculations, traffic counts, capacity analyses and energy modelling, that is otherwise adequately summarized with text, tables and figures within the main body of the DEIR. Information provided in appendices should be indexed with page numbers and separated by tabs, or, if provided in electronic format, include links to individual sections. Any references in the DEIR to materials provided in an appendix should include specific page numbers to facilitate review.
Alternatives Analysis
The ENF identified three alternatives including a No-Build Alternative, an As-of-Right Alternative and the Preferred Alternative as described above. The No-Build Alternative involved leaving both sites as is including the existing hotel and restaurant and The Skating Club of Boston. However, as described in the ENF, The Skating Club of Boston building would eventually become vacant, as the organization has already found an alternate site location in Norwood (EEA# 15911) and it is a single purpose building not easily repurposed for another use. The As-of-Right Alternative involved the redevelopment of both sites with a four-story 232,00 sf laboratory building with approximately 310 below-grade parking spaces and 68 surface parking spaces (378 spaces total). The As-of-Right Alternative would result in 2.69 acres of impervious area (same as Preferred Alternative), would generate 2,612 New adt and have water demand and wastewater generation similar to existing conditions. The Preferred Alternative will have significantly more traffic generation associated with the proposed uses; however, it will result in more open space. The ENF notes that various building configurations for the Preferred Alternative were considered but none resulted in as much open space as currently proposed for the Preferred Alternative and therefore were dismissed.
The DEIR should include an expanded alternatives analysis which includes a Reduced Build Alternative, alternative site configurations and various programming alternatives supporting the Preferred Alternative. Each alternative should document proposed conditions, quantify environmental impacts and provide a conceptual plan. It should compare the alternatives with respect to their impacts on traffic, open space, water use, wastewater generation, impervious area and stormwater management. The DEIR should provide a comparison of wind, shadow and GHG impacts and review climate change resiliency features of
4 EEA# 16272 ENF Certificate October 23, 2020 each alternative as applicable. The DEIR should clearly describe the criteria used to evaluate these alternatives and explain the reasons that the Preferred Alternative was chosen. The DEIR should address each alternative’s consistency with local and regional planning efforts including why residential/hotel uses align with market needs within the project area and why the existing hotel building needs to be demolished when the Preferred Alternative proposes the same use.
Land Use/Article 97
The DEIR should provide detailed plans, sections and elevations to accurately depict existing and proposed conditions, including proposed above- and below-ground structures and on- and-offsite open space and resiliency and other mitigation measures. The DEIR should include a review of the City’s zoning applicable to the site. The plans should include property lines and ownership of all parcels where project activities are proposed, including off-site parcels. The DEIR should identify and easements or land transfers necessary to construct the project and proposed mitigation measures including easements that will be provided to/from DCR for the pedestrian bridge access improvements.
The DEIR should confirm whether any easements will be required from DCR and whether it will require a land disposition requiring legislation pursuant to Article 97 of the amendments to the state constitution. As described in DCR’s comment letter, discussions regarding design for the Telford pedestrian bridge improvements between DCR and the Proponent are not final; however, the project may trigger an Article 97 land disposition if the south ramp of the new pedestrian bridge is placed in the same location as the existing south ramp or if the Proponent otherwise incorporates the area of the existing south ramp footing into the design of the project. In 1967, DCR’s predecessor agency, Metropolitan District Commission (“MDC”), by eminent domain, acquired the fee interest in an approximately 1,896 sf area of land adjacent to Telford Street for the south ramp of the existing Telford Street pedestrian bridge. If a transfer of ownership or an interest in the parcel on which the south ramp footing currently is located is required, the Proponent must obtain Article 97 Legislation.
Transfers of interests in state conservation property must also meet the requirements set forth in the Executive Office of Energy and Environmental Affairs (“EEA”) Article 97 Land Disposition Policy (the “Policy”). The Policy has the stated goal of ensuring no net loss of Article 97 lands under the ownership and control of the Commonwealth, and states as a general premise that EEA and its agencies shall not sell, transfer, or otherwise dispose of any right or interest in Article 97 lands. Transfer of ownership or interests therein may occur only under exceptional circumstances, as defined in the Policy, including the determination that no feasible alternative is available, and a minimum amount of land or an interest therein is being disposed for the proposed use. Transfer also requires authorization by the Massachusetts Legislature through a two-thirds supermajority roll call vote. Comments from DCR note that DCR will not issue a Construction and Access Permit that effectuates a change of use or involves a disposition of an interest in DCR property until these prerequisites for any required land disposition is complete. If applicable, the DEIR should identify how the project is consistency with EEA’s Article 97 Land Disposition Policy. The DEIR should include plans depicting Article 97 land and identify any mitigation proposed for the land disposition.
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Traffic and Transportation
The ENF included a preliminary traffic study prepared in general conformance with the EEA/MassDOT Transportation Impact Assessment (TIA) Guidelines issued in March 2014. The DEIR should include a revised TIA which responds to comments from DCR and MassDOT. I hereby incorporate by reference MassDOT’s comment letter dated October 14, 2020 and DCR’s comment letter dated October 21, 2020.
The project is expected to generate 7,438 unadjusted adt of which 5,908 adt are considered New. The project includes the construction of podium parking structures (i.e. parking located under the proposed hotel/residential uses). A total of 405 parking spaces will serve the project including 220 spaces for the apartment building and 185 spaces for the condominium/hotel uses. Approximately 260 of the parking spaces are considered new. Vehicular access to the parking areas will be from the new access road which will bisect the project site. According to the ENF, the Proponent will encourage the use of alternative modes of travel to the site by implementing a Transportation Demand Management (TDM) program and providing pedestrian and bicycle facilities, including a bicycle sharing station. The study area for the TIA included the following intersections:
• Western Avenue at Arsenal Street Leo Birmingham Parkway and Soldiers Field Road • Western Ave at Telford Street • Soldiers Field Road at Everett Street • Western Ave at Everett Street • Western Ave at North Harvard Street • Western Ave at Waverly Street • Everett Street at Holton Street • Soldiers Field Road at Telford Street
If necessary, the study area should be expanded if project-generated trips are anticipated to increase peak hour traffic volume by five percent or more or by more than 100 vehicles per hour at other locations.
The DEIR should fully describe and document existing and proposed pedestrian and bicycle facilities, transit operations and roadway and intersection conditions within the study area. The TIA should describe the project’s anticipated transportation impacts and identify appropriate mitigation measures. The TIA should identify whether each study area intersection falls under the jurisdiction of MassDOT, DCR or the City or falls under multiple jurisdictions. The TIA should identify potential mitigation measure to improve operations at impacted intersections. Any proposed roadway improvements, including bicycle/pedestrian facilities, that are recommended to mitigate traffic impacts or address safety issues should be consistent with Complete Streets design guidelines contained in the MassDOT Project Development and Design Guide.
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Trip Generation
The trip generation estimates in the ENF were based on trip rates published in the Institute of Transportation Engineers’ (ITE) Trip Generation Manual, 10th edition, using Land Use Codes (LUC) 220 (Multifamily Housing-Low-Rise), 310 (Hotel) and 820 (Shopping Center). The unadjusted trip generation estimate is 7,438 daily vehicle trips, with 432 vehicle trips during the weekday morning peak hour, and 570 vehicle trips during the weekday evening peak hour.
As described in the ENF, mode share for the proposed project is estimated based on BTD guidelines for the zone in which the project is located. The site currently contains a hotel, a restaurant and The Skating Club of Boston. The existing trip generation is estimated by using LUC 310 – Hotel and LUC 931 – Quality Restaurant. However, The Skating Club does not align with any ITE land use code and it generates a variable number of daily trips, with few trips during the peak periods; therefore, trips generated by The Skating Club are not included in the existing trip generation estimate. Accounting for mode share adjustments and the existing land uses the project is estimated to generate 2,778 adt, with 168 vehicle trips during the weekday morning peak hour, and 207 vehicle trips during the weekday evening peak hour. Comments from MassDOT note that, if available, driveway counts would be the preferred method for estimating existing trip generation and should be presented in the DEIR.
The DEIR should include an updated trip generation to reflect any changes to the project since the ENF including any adjustments for mode shares or existing uses, for each proposed use. For the total project and for each land use, the TIA should provide estimates of weekday daily, and weekday morning and evening peak period trips for each mode and describe and document any adjustment of these estimates using applicable methodologies from the most recent editions of ITE’s Trip Generation Manual and Trip Generation Handbook.
Traffic Operations
The TIA provides analysis of study area intersections for the 2020 existing, 2027 No- Build, and 2027 Build conditions. The existing 2020 volumes are based on counts collected in 2019, which are considered by MassDOT to reflect existing conditions because of the current reduced roadway volumes resulting from the Covid-19 pandemic. As described in the TIA, the 2027 No-Build analysis uses a compounded annual growth rate of 0.25% and incorporates background projects and roadway improvements. The DEIR should explain how Covid-19 conditions were incorporated into this growth rate.
As described in MassDOT’s comment letter, the improvements included at the intersection of Western Avenue/Arsenal Street at Birmingham Parkway and Soldiers Field Road were identified in the study conducted by the 530 Western Ave/Radius Apartments project. However, MassDOT is not aware of funding identified for these improvements or any plans to implement these improvements in the near-term. MassDOT asks that the DEIR include a revised No-Build and Build analysis without these improvements. Following this revised analysis, the Proponent should identify any mitigation measures that may be required. With the current analysis configurations, some movements at the intersection under partial MassDOT jurisdiction experience an improvement in level-of-service (LOS) between Existing and No-Build and then a decline in LOS between the No-Build and Build scenarios. The intersection of Western Avenue at North Harvard Street degrades in LOS during the evening peak hour between the No-Build
7 EEA# 16272 ENF Certificate October 23, 2020 and Build scenarios. Comments from DCR request additional analysis and clarifications including: automatic traffic recorder counts to estimate traffic volumes on Soldier Field Road; additional calculation for net new trips; using existing trips directly measured with driveway counts; Clarification on the calculated split between private and TNC (Transportation Network Company) vehicles; and additional information related to the proposed changes to Everett Street to clarify how the new geometries are considered in the No Build and Build capacity analyses. I refer the Proponent to further details as explained in the DCR comment letter, and encourage the Proponent to consult with DCR and MassDOT on traffic analysis methodology prior to filing the DEIR.
Pedestrian and Bicycle Facilities
The proposed site access will result in reduced curb cuts and an improved pedestrian experience. The Proponent will construct new ADA compliant sidewalks along the project frontages. The set-back along Western Avenue and Telford Street will be increased to create a large pedestrian zone. The set-back along Western Avenue will also maintain adequate width to support potential protected bike lanes or bus-only lanes along Western Avenue that the City of Boston may implement in the future.
The Proponent is coordinating with DCR on an assessment of a replacement pedestrian bridge over Soldiers Field Road at Telford Street. The Proponent has committed to replacing the pedestrian ramp on Telford Street with a new accessible pedestrian ramp to the bridge and constructing an additional accessible ramp to the bridge through the central green space of the project site. The project will provide a bikeshare station, 655 secure bicycle parking spaces for residents, 33 for hotel and retail employees, and 145 unsecured bicycle parking spaces for visitors and customers.
As noted in DCR’s comment letter, DCR appreciates the proposal to provide a BLUEbikes station on site. Addition of bicycle pumps and other bike maintenance features would benefit bicycle use of Herter Park and the Paul Dudley White Bike Path. DCR will coordinate with the Proponent on a MOA to cover funding, establishment of public easements, and maintenance considerations for bicycle and pedestrian improvements associated with the Project. The DEIR should identify commitments to these mitigation measures as applicable.
Transit Impacts
The ENF includes a transit analysis for MBTA Bus Routes 70 (Market Place Drive or Waltham Center - University Park) and 86 (Sullivan Square Station - Reservoir Station) which run along Western Avenue; there are no bus stops along the project frontage. The analysis demonstrates that the identified bus routes do not exceed capacity for these routes in the existing, No-Build, or Build scenarios. Comments from MassDOT request that the DEIR include an analysis compliant with the MBTA’s Office of Performance Management and Innovation’s (OPMI) methodology for calculating comfort metrics (as evaluated in the Service Delivery Policy (SDP)), in addition to a capacity analysis, for each bus route within the project’s study area. Mitigation should be proposed for any bus route receiving new passengers that falls below the 96% route-wise minimum for the SDP comfort metric, any trip for which the new passengers would cause the trip to exceed comfort metric threshold, and/or any trip which was already
8 EEA# 16272 ENF Certificate October 23, 2020 above the crowding threshold and which new passengers would be added to. The Proponent should consult with MassDOT and MBTA on the feasibility of providing new stops that would serve the site.
Safety
Comments from MassDOT indicate that the study area intersection of Western Avenue/Arsenal Street at Birmingham Parkway and Soldiers Field Road, is under joint jurisdiction by MassDOT, DCR, and the City of Boston. This location consists of three interconnected signalized intersections and experiences a crash rate above the MassDOT District 6 average. This intersection is also included in the MassDOT Highway Safety Improvement Program (HSIP) for crashes occurring between 2015-2017. Comments from MassDOT note that many of the pedestrian accommodations at this intersection are not American’s with Disabilities Act (ADA) compliant. Although the 530 Western Ave/Radius Apartments project studied this location, MassDOT asks that the Proponent coordinate with the MassDOT Safety Unit to determine if this location requires a Road Safety Audit (RSA). The DEIR should include a summary of the discussion with the MassDOT Safety Unit and a plan for how to improve safety at the intersection, potentially including advancing the design of improvements, based on the previous study, and partially funding the construction of mitigations.
Parking
The site currently contains 164 parking spaces for the Skating Club and the hotel. The project will result in an increase of 241 parking spaces, resulting in 405 total spaces. Parking is provided at a ratio of 0.41 spaces per apartment unit, one space per condominium unit, and 0.25 spaces per hotel room. The ENF explains that the residential parking ratios are aligned with the ratios for other residential projects recently approved near the project site. The DEIR should document how the project’s parking demand, including parking for uses adjacent to the site, was determined and compare the number of proposed spaces to the number required based on the ITE’s Parking Generation (4th edition) and local zoning requirements. The DEIR should identify whether and how many parking spaces that could be reduced through implementation of TDM measures. It should determine the number of parking spaces occupied at various times of the day and identify the periods of peak use, and evaluate opportunities for shared parking.
Transportation Demand Management (TDM)
The ENF identified potential TDM measures that will be implemented to minimize the number of single-occupancy vehicle (SOV) and TNC trips to the site by residents, employees and visitors. Measures identified in the ENF include installing a bicycle sharing station, designating a full-time transportation coordinator, encouraging tenants to offer on-site MBTA pass sales and transit subsidies and providing information on travel alternatives to residents, employees and visitors to the site.
The DEIR should include a commitment to implement a robust TDM program to minimize trips to the site by SOV and TNCs such as Uber and Lyft. At a minimum, the DEIR should evaluate measures recommended by MassDOT including limiting the parking supply, providing on-site amenities and conveniences to minimize the need for automobile travel,
9 EEA# 16272 ENF Certificate October 23, 2020 providing seamless pedestrian access to nearby transit hubs, and charging market rates for parking and uncoupling parking from residential leases. The DEIR should confirm the Proponent’s commitment to comply with the City’s Electric Vehicle Readiness Policy for New Developments, which requires projects undergoing Article 80 or TAPA review to provide electric vehicle (EV) charging stations for 25 percent of all parking spaces and to construct the remaining spaces to be EV-ready. The Proponent should consult with the Allston-Brighton Transportation Management Association (TMA) regarding successful TDM measures used at similar projects in the project vicinty and evaluate the potential effectiveness of these measures for the project.
Transportation Monitoring Program
The DEIR should include a draft traffic monitoring program to evaluate the assumptions made in the traffic study and the adequacy of the transportation mitigation measures and the TDM program in mitigating traffic congestion and meeting mode share goals. The program should include annual traffic monitoring for a period of five years beginning six months after the first Certificate of Occupancy for the project is issued. The monitoring program should include:
• Simultaneous automatic traffic recorder (ATR) counts at each parking entrance for a continuous 24-hour period on a typical weekday; • Travel survey of employees, patrons, and residents at the site (to be administered by the Transportation Coordinator); • Weekday AM and PM peak hour turning movement counts (TMCs) and operations analysis at “mitigated” intersections, including those involving parking entrances; and • An update on TDM effectiveness and transit ridership.
To the extent the TDM monitoring program shows a significant deviation between anticipated and actual traffic and SOV numbers, the DEIR should address how the Proponent would evaluate and implement revised mitigation commitments that may be necessary, and/or intends to impose such requirements on future occupants of the site through legally binding agreements.
Water, Wastewater and Stormwater
The project will use 135,300 gpd of water when including existing uses to be replaced (114,323 gpd net new) and generate 123,300 total gpd of wastewater (103,930 gpd net new). Water, sewer and drainage is provided by the BWSC. Water service is provided on Soldiers Field Road by an 8-inch Northern Low cement lined ductile iron water main installed in 2014; on Western Avenue by a 16-inch Northern Low pit cast iron water main most recently improved in 2005; and on Telford Street by an 8-inch Northern low cast-iron main most recently improved in 2005. For sewer service the project is served on Western Avenue by a 10-inch and 36 by 38- inch sewer main and on Telford Street by a 12-inch sewer main. For drainage, the project site is served by a 12-inch storm drain located on the eastbound side of Western Avenue; and by a 66- inch storm drain located on Telford Street. Drainage from the project site ultimately discharges to the Charles River. The MWRA owns a 54-inch steel water main and a 54-inch sewer main on Western Avenue.
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The ENF did not describe the condition or capacity of the water and sewer infrastructure serving the site; however, the systems will undergo a design review process with BWSC to determine the condition and capacity of existing infrastructure. The DEIR should describe the location and size of infrastructure and connections to the BWSC’s water and sewer systems. It should document that adequate water and sewer capacity exist to serve the site. The DEIR should identify and describe water conservation measures that will be incorporated into design and operations. At a minimum, the DEIR should review the feasibility of installing low-flow fixtures and using rainwater or gray water for irrigation and other purposes.
According to comments from the MWRA and BWSC, the project site is served by separate storm drains and sanitary sewers. The BWSC sanitary sewer in Western Avenue conveys flows to MWRA’s Charles River Valley Sewer (CRVS) in Western Avenue. The CRVS collects wastewater flows from combined sewer areas and separate sanitary sewer areas in parts of Boston, Brookline, Newton, Watertown and Waltham and conveys these flows to MWRA’s Ward Street Headworks in Roxbury, which directs flows into MWRA’s Boston Main Drainage Tunnel for transport to the Deer Island Treatment Plant. In large storms, the capacity of the combined systems may be exceeded, resulting in the discharge of combined sewer overflows (CSO). The project will be required to mitigate its contribution of flow into the City’s sanitary system. MassDEP regulations at 314 CMR 12.04(2)(d) specify that communities with CSOs, such as Boston, must require projects generating 15,000 gpd or more of new wastewater flow to remove four gallons of infiltration and inflow (I/I) for each gallon of wastewater. The Proponent should consult with the BWSC to identify appropriate I/I mitigation for this project. The DEIR should include a commitment to I/I removal and identify any mitigation projects or monetary contribution by the Proponent. As noted by the MWRA, groundwater discharges into the sanitary system are prohibited. The DEIR should include a commitment to use oil/gas separators in the parking garage drainage systems.
The project will result in a reduction of impervious surface by 0.32 acres. A stormwater management system will be constructed to treat, detain and infiltrate stormwater runoff to maintain the existing hydrology of the Project Site. It is expected that a subsurface, stormwater infiltration system will be constructed that can infiltrate the first 1.25 inch of runoff from the Project Site’s impervious areas. Rooftop runoff will be piped directly to the stormwater infiltration system. Stormwater runoff from paved areas will be captured by deep sump, hooded catch basins and provided pretreatment prior to being directed to the stormwater infiltration system. The infiltration system is expected to be provided with a bypass structure that allows overflow during larger storm events to be directed to the BWSC 66-inch storm drain in Telford Street. Comments from the Charles River Watershed Association (CRWA) commend the project for its incorporation of green space and reduced impervious area. Comments from CRWA acknowledges the stormwater BMPs that have been incorporated into the project design. However, CRWA urges the Proponent to prioritize the incorporation of green infrastructure to provide additional co-benefits to the community. Low impact development (LID) stormwater measures should be extensively incorporated into parking lots and other paved areas to treat stormwater generated by impervious surfaces and provide cooling benefits for residents. The DEIR should include additional stormwater management plans detailing system sizing, type and location along with calculations demonstrating that the project complies with total maximum daily loads (TMDL).
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Cultural Resources
According to the ENF and comments from MHC, the project includes the demolition of The Skating Club of Boston which is included in MHC’s Inventory of Historic and Archaeological Assets of the Commonwealth (BOS.17074). The project site abuts Soldiers Field road, a historic parkway that is listed in the National Register of Historical Places (BOS.9602) and is in close proximity to the Charles River Reservation/Metropolitan Park System of greater Boston (BOS.VE). The DEIR should provide the information requested by MHC to facilitate its review of the project and so that it can determine the potential effect of size, scale, and massing of the new buildings on the character and setting of the State and National Register listed properties. Information and analyses requested by MHC include:
• An analysis of the visual impact of the proposed building on State Register properties and districts, including pedestrian-level perspectives of the project from various vantage points and views of the building from historic resources throughout the city; • A shadow analysis of the proposed building design, including maps showing shadows under existing and proposed conditions and all historical resources in areas affected by shadows; • A wind study that provides anticipated wind conditions at or near historic properties in the impacted area; and, • A description of the project's area of potential effect.
Air Quality
The Proponent must conduct an air quality analysis in accordance with MassDEP Guidelines for Performing Mesoscale Analysis of Indirect Sources. The purpose of the analysis is to determine whether and to what extent the project will increase the amount of volatile organic compounds (VOC) and nitrogen oxides (NOx) emitted in the project area and to determine consistency with regional targets identified in the State Implementation Plan (SIP) for the Commonwealth . The analysis should model emissions under No Build and Build conditions, based on the study area identified through the traffic study. Appropriate mitigation measures must be identified, including a TDM Program.
Climate Change
Governor Baker’s Executive Order 569: Establishing an Integrated Climate Change Strategy for the Commonwealth (EO 569; the Order) was issued on September 16, 2016. The Order recognizes the serious threat presented by climate change and directs Executive Branch agencies to develop and implement an integrated strategy that leverages state resources to combat climate change and prepare for its impacts. The Order seeks to ensure that Massachusetts will meet GHG emissions reduction limits established under the Global Warming Solution Act of 2008 (GWSA) and will work to prepare state government and cities and towns for the impacts of climate change. I note that the MEPA statute directs all State Agencies to consider reasonably foreseeable climate change impacts, including additional greenhouse gas emissions, and effects, such as predicted sea level rise, when issuing permits, licenses and other administrative approvals and decisions.
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The GHG Policy and requirements to analyze the effects of climate change through EIR review play an important role in this statewide strategy. These analyses advance proponents’ understanding of a project’s contribution and vulnerability to climate change. I encourage the Proponent to consider complementary approaches – such as Passivehouse design, incorporation of renewable energy generation and inclusion of low impact development in site design - which can improve the project’s resiliency, reduce GHG emissions and conserve and sustainably employ the natural resources of the Commonwealth.
Adaptation and Resiliency
The region’s climate is expected to experience higher temperatures and more frequent and intense storms. The Northeast Climate Science Center at the University of Massachusetts at Amherst has developed projections of changes in temperature, precipitation and sea level rise for Massachusetts. This data is available through the Climate Change Clearinghouse for the Commonwealth at www.resilientMA.org. By the end of the century, the average annual temperature in the Boston Harbor Basin is projected to rise by 3.5 to 10.8 degrees Fahrenheit (F), including an increase in the number of days with temperatures over 90 F from 8 days documented in the 1971-2000 baseline period to up to 75 days. During the same time span, the average annual precipitation is projected to increase by 1.1 to 9.0 inches, which may be associated with more frequent and more intense storms.
The City is a participant in the Commonwealth’s Municipal Vulnerability Preparedness (MVP) program. The MVP program is a community-driven process to define natural and climate-related hazards, identify existing and future vulnerabilities and strengths of infrastructure, environmental resources and vulnerable populations, and develop, prioritize and implement specific actions the City can take to reduce risk and build resilience. The Climate Ready Boston report (December 2016) identifies the City’s vulnerabilities to climate change and potential measures to increase its resilience and the City is currently preparing resiliency reports for each of the City’s neighborhoods that will include recommendations for promoting the neighborhood’s resilience. The DEIR should provide a review of the City’s extensive studies on climate vulnerabilities and potential solutions.
Although the project site is not currently located within the 100-yr floodplain the project is in close proximity to the Charles River which may be impacted by climate change impacts as indicated in the City’s Climate Ready Boston report. The DEIR should identify the design life of the proposed project and include a comprehensive discussion of the potential effects of climate change on the project site and describe features incorporated into the project design that will increase the resiliency of the site to these changes. It should provide a review of the City’s resiliency plans and those of the City of Cambridge as pertaining to the project’s location along the Charles River. The DEIR should identify the projected climate conditions and assumptions, such as temperature, sea level rise and precipitation rates, that will be used to design the project’s resiliency measures. The Massachusetts Flood Risk Model (MC-FRM) will be available shortly and may update available information regarding the extent of sea level rise and anticipated flooding along the New England coastline. I encourage the Proponent to consult the most updated climate data in making design choices for the project. The DEIR should address whether data from the MC-FRM, if available, differ from current climate projections incorporated into project design, and, if so, what if any design adjustments could be made to address any such revised projections. The DEIR should identify opportunities to increase resilience through
13 EEA# 16272 ENF Certificate October 23, 2020 enhancement of the site, including increased open space and permeable surfaces. It should review district-wide solutions identified in City planning studies, evaluate the potential benefits of those measures to the site and describe how the project will be designed to be consistent with potential district-wide measures.
In addition to the site design measures identified above, the DEIR should evaluate incorporating the following potential resiliency and adaption features into the project design:
• Ecosystem-based adaptation measures to reduce heat island effect and mitigate stormwater runoff, such as integration of tree canopy cover, rain gardens, and LID stormwater management techniques; • Stormwater management system design that will accommodate rainfall under projected climate conditions; • Use of on-site renewable energy systems that may provide added resiliency during periods of power loss during storms; • Protection of emergency generator fuel supplies from effects of extreme weather and flood-proofing of parking garages and other structures; • Elevation of first-floor residential areas and critical infrastructure above base flood elevations as determined based on climate change projections; and • Expansion of the size of emergency generators to allow for select common areas and other emergency and life safety systems to remain operational for a period of time beyond code requirements.
Greenhouse Gas (GHG) Emissions
This project is subject to review under the May 5, 2010 MEPA GHG Policy. The Policy requires Proponents to quantify carbon dioxide (CO2) emissions and identify measures to avoid, minimize or mitigate such emissions. The analysis should quantify the direct and indirect CO2 emissions of the project's energy use (stationary sources) and transportation-related emissions (mobile sources). Direct emissions include on-site stationary sources, which typically emit GHGs by burning fossil fuel for heat, hot water, steam and other processes. Indirect emissions result from the consumption of energy, such as electricity, that is generated off-site by burning of fossil fuels, and from emissions from vehicles used by employees, vendors, customers and others.
The DEIR should include a GHG analysis prepared in accordance with the GHG Policy, guidance provided in the comment letter submitted by the Department of Energy Resources (DOER), which is incorporated in this Certificate in its entirety, and this Scope.
Stationary Sources
The DEIR should include an analysis that calculates and compares GHG emissions associated with: 1) a Base Case that conforms to the 9th Edition of the Massachusetts Building Code, which references the American Society of Heating, Refrigerating and Air-Conditioning Engineers (ASHRAE) 90.1-2013 and the International Energy Conservation Code (IECC) 2015 and 2) a Preferred Alternative that achieves greater reductions in GHG emissions. The City has adopted the Massachusetts Stretch Energy Code (SC). Therefore, the project will be required to
14 EEA# 16272 ENF Certificate October 23, 2020 meet the applicable version of the SC in effect at the time of construction. The SC increases the energy efficiency code requirements for new construction (both residential and commercial) and for major residential renovations or additions in municipalities that adopt it. The current SC requires a reduction in energy use of 10 percent compared to that achieved by complying with the baseline energy provisions of the State Building Code. As noted by DOER, an updated Building Code will take effect in November 2020 including new and modified Massachusetts amendments. The Stretch Code to take effect in November continues to use ASHRAE 90.1- 2013-Appendix G. To accurately evaluate mitigation measures for this project, and considering the imminency of these amendments, the Base Case should be established based on the updated Code scheduled to take effect in November 2020.
The GHG analysis should clearly demonstrate consistency with the key objective of MEPA review, which is to document the means by which Damage to the Environment can be avoided, minimized and mitigated to the maximum extent feasible. The DEIR should identify the model used to analyze GHG emissions, clearly state modeling assumptions, explicitly note which GHG reduction measures have been modeled, and identify whether certain building design or operational GHG reduction measures will be mandated by the Proponent to future occupants or merely encouraged for adoption and implementation. The commercial and residential portions of the building should be analyzed separately. The DEIR should include the modeling printouts for each alternative and emission tables that compare base case emissions in tons per year (tpy) with the Preferred Alternative showing the anticipated reduction in tpy and percentage by emissions source. Other tables and graphs, such as the table of mitigation measures recommended by DOER, may also be included to convey the GHG emissions and potential reductions associated with various mitigation measures as necessary. The DEIR should provide data and analysis in the format requested in DOER’s letter.
The DEIR should present an evaluation of mitigation measures identified in DOER’s comment letter. In particular, the feasibility of each of the mitigation measures outlined below should be assessed for each of the major project elements, and if feasible, GHG emissions reduction potential associated with major mitigation elements should be evaluated to assess the relative benefits of each measure. The DEIR should explain, in reasonable detail, why certain measures that could provide significant GHG reductions were not selected – either because it is not applicable to the project or is deemed technically or financially infeasible. If financial infeasible, the DEIR should describe the cost effectiveness metrics that were used to evaluate feasibility, whether energy savings that would accrue to future tenants were considered, and what “payback period” the Proponent would deem to be reasonable given the financial constraints identified. It should include a review of available financial incentives potentially available for the project, as described in DOER’s comment letter. At a minimum, the DEIR should consider the following GHG mitigation measures:
• Design of the residential and hotel portion of the project in conformance with Passivehouse standards; • Above-Code continuous roof and wall insulation and avoiding glass curtain wall assemblies to minimize heat loss and uncontrolled infiltration through the building envelope; • Efficient electrification of space and water heating in all buildings, including electric space heating and water heating using air source heat pumps (ASHP),
15 EEA# 16272 ENF Certificate October 23, 2020
variable refrigerant flow (VRF), ground source heat pumps (GSHP) and/or solar thermal systems; • High-albedo roofing materials, external shading and windows with improved solar heat gain coefficient (SHGC); • Energy recovery ventilation and wastewater systems; • Rooftop solar photovoltaic (PV) systems and/or solar-ready roofs; and, • LED lighting, both exterior and interior.
The residential (both condominium and apartments) and hotel portion of the building are well-suited to Passivehouse design, which would include energy-efficient building envelope and heating and cooling systems that minimize GHG emissions and reduce utility costs for future residents. As noted by DOER, recent studies have demonstrated that buildings constructed to Passivehouse design standards are economically feasible and may be eligible for financial incentives. At a minimum, the DEIR should analyze an alternative project design that includes Passivehouse design for the residential and hotel uses. The Proponent should consult with staff from DOER and MEPA prior to submitting the DEIR. I note that a significant and aggressive commitment to Passivehouse design with electrification may be sufficient to avoid the need for extensive modeling and analysis of other components of the residential and hotel building designs.
The DEIR should include all analyses requested in DOER’s comment letter, including the use of solar thermal to supply domestic hot water, installation of rooftop solar PV systems, the use of external shading and windows with low SHGC to minimize cooling needs and financial incentives available from Alternative Energy Credits (AEC), MassSave and the Solar Massachusetts Renewable Target (SMART) program.
Mobile sources
The GHG analysis should include an evaluation of potential GHG emissions associated with mobile emissions sources. The DEIR should follow the guidance provided in the GHG Policy for Indirect Emissions from Transportation to determine mobile emissions for Existing Conditions, Build Conditions, and Build Conditions with Mitigation. The Proponent should thoroughly explore means to reduce overall single occupancy vehicle trips. The DEIR should also review measures to promote the use of low-emissions vehicles, including installing electric vehicle charging stations and providing designated parking spaces for these vehicles in accordance with the City’s Electric Vehicle Readiness Policy for New Developments. More information on electric vehicle infrastructure can be obtained from the MassEVolves program at www.massevolves.org. The Build with Mitigation model should incorporate TDM measures and any roadway improvements implemented by the project and document the reductions in GHG emissions associated with the mitigation. The DEIR should explain how TDM measures will be monitored and adjusted over time and provide a methodology for quantifying emission reductions impacts rather than an assumed percentage reduction.
GHG Self-Certification
The DEIR should include a commitment to provide a GHG self-certification to the MEPA Office upon construction of the project. It should be signed by an appropriate
16 EEA# 16272 ENF Certificate October 23, 2020 professional (e.g. engineer, architect, transportation planner, general contractor) indicating that all of the GHG mitigation measures, or equivalent measures that are designed to collectively achieve identified reductions in stationary source GHG emission and transportation-related measures, have been incorporated into the project. If equivalent measures are adopted, the project is encouraged to commit to achieving the same level of GHG emissions (i.e., “carbon footprint”) identified in the Preferred Alternative expressed as a volumetric measure (tpy) in addition to a percentage GHG reduction from Base Case.
Construction Period
The DEIR should provide a comprehensive review of the project’s construction-period impacts and mitigation relative to noise, air quality, water quality, and transportation, including pedestrians, bicyclists and transit riders. The DEIR should include measures that will minimize damage to the site and adjacent areas that could result from coastal storms during the construction period. It should identify the schedule for construction of various project elements, including open space. It should confirm that the project will require its construction contractors to use Ultra Low Sulfur Diesel fuel, and discuss the use of after-engine emissions controls, such as oxidation catalysts or diesel particulate filters. More information regarding construction- period diesel emission mitigation may be found on MassDEP’s web site at http://www.mass.gov/dep/air/diesel/conretro.pdf.
The DEIR should provide more information regarding the project’s generation, handling, recycling, and disposal of construction and demolition debris (C&D) and identify measures to reduce solid waste generated by the project. I encourage the Proponent to commit to C&D recycling activities as a sustainable measure for the project. The DEIR should review procedures to be used for the removal and disposal of any asbestos at the site. It should describe how contaminated soil or groundwater encountered during construction will be managed in accordance with M.G.L. c. 21E and the Massachusetts Contingency Plan (MCP).
The project will be required to develop a Stormwater Pollution Prevention Plan (SWPP) in accordance with its NPDES CGP to manage stormwater during the construction period. The DEIR should describe stormwater management measures that will be implemented during construction. It should describe potential construction period dewatering requirements, discuss how dewatering will be conducted in a manner consistent with MWRA regulations/guidelines, and identify any necessary permits.
Mitigation and Draft Section 61 Findings
The DEIR should include a separate chapter summarizing all proposed mitigation measures, including construction-period measures. This chapter should also include draft Section 61 Findings for each permit to be issued by State Agencies. The DEIR should contain clear commitments to implement these mitigation measures, estimate the individual costs of each proposed measure, identify the parties responsible for implementation, and a schedule for implementation. The DEIR should clearly indicate which mitigation measures will be constructed or implemented based upon project phasing, either tying mitigation commitments to overall project square footage/phase or environmental impact thresholds, to ensure that adequate measures are in place to mitigate impacts associated with each development phase.
17 EEA# 16272 ENF Certificate October 23, 2020
Responses to Comments
The DEIR should contain a copy of this Certificate and a copy of each comment letter received. It should include a comprehensive response to comments on the ENF that specifically address each issue raised in the comment letter; references to a chapter or sections of the DEIR alone are not adequate and should only be used, with reference to specific page numbers, to support a direct response. This directive is not intended to, and shall not be construed to, enlarge the Scope of the DEIR beyond what has been expressly identified in this certificate.
Circulation
The Proponent should circulate the DEIR to those parties who commented on the ENF, to any State Agencies from which the Proponent will seek permits or approvals, to any parties specified in section 11.16 of the MEPA regulations and make a copy available for review at the Boston Public Library. 2 The Proponent should consult with the MEPA Office prior to filing the DEIR to determine whether additional distribution requirements may be warranted to surrounding local communities. Per 301 CMR 11.16(5), the Proponent may circulate copies of the EIR to commenters in CD-ROM format or by directing commenters to a project website address. However, the Proponent must make a reasonable number of hard copies available to accommodate those without convenient access to a computer and distribute these upon request on a first-come, first-served basis. The Proponent should send correspondence accompanying the CD-ROM or website address indicating that hard copies are available upon request, noting relevant comment deadlines, and appropriate addresses for submission of comments. The DEIR submitted to the MEPA office should include a digital copy of the complete document.
October 23, 2020 ______Date Kathleen A. Theoharides
Comments received:
09/30/2020 Boston Water and Sewer Commission (BWSC) 10/08/2020 Massachusetts Historical Commission (MHC) 10/13/2020 Charles River Watershed Association (CRWA) 10/13/2020 Massachusetts Department of Environmental Protection (MassDEP) Northeast Regional Office (NERO) 10/13/2020 Massachusetts Water Resources Authority (MWRA)
2 Requirements for hard copy distribution or mailings will be suspended during the Commonwealth’s COVID-19 response. 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.
18 EEA# 16272 ENF Certificate October 23, 2020
10/14/2020 Massachusetts Department of Transportation (MassDOT) 10/20/2020 Department of Energy Resources (DOER) 10/21/2020 Department of Conservation and Recreation (DCR)
KAT/EFF/eff
19 Boston Water and Sewer Commission
980 HarrisonAvenue Boston, MA02119-2540 617-989-7000 September 30, 2020
Secretary Kalhleen A. Iheoharides Executive Officeof Energy and Environmental Affairs Attn: MEPA Office Erin Flaherty No. 16272 100 Cambridge Street, Suite 900 Boston, MA 02114
Re: 1234-I240 Soldiers Field Road ENF
Dear Secretary Theoharides:
The Boston Water and Sewer Commission (Commission) has reviewed the Environmental Notification Form (ENF) for the above referenced Project (Project). The Project site is located in the Allston neighborhood of Boston. The Project site is bordered by Soldiers Field Road to the north, private properties to the east owned by the City of Boston Department of Public Works and Harvard University, Western Avenue to the south and Telford Street to the west.
The Project comprises two components. The 1240 site will be redeveloped with a new residential building containing approximately 535 rental residential units, approximately 10,500 square feet (sfl of ground floor retail space, and an enclosed garage that is partially above grade for approximately 220 vehicles. The 1234 site will be redeveloped with a residential building containing approximately 120 residential condominiums, and a hotel building with approximately 225 hotel rooms, approximately 4,000 sfof ground floor retail space, and a shared underground garage below both buildings for approximately 185 vehicles. Separating the two Project components will be a new internal roadway, so that all Project- related delivery, pick-up/drop off activities and vehicular access can occur within the Project site, and not on nearby existing public roadways.
Extending from the central open space of the Project will be the improvement of an elevated pedestrian connection for the public across Soldiers Field Road to the DCR-owned Telford Street pedestrian bridge, which is a key pedestrian corridor from the Allston neighborhood to the Charles River Reservation.
Water, sewer, and storm drain service for the Project site is provided by the Boston Water and Sewer Commission. Also, on Western Avenue there is a 54-inch steel water main owned by the Massachusetts Water Resources Authority (MWRA) and the 54-inch Charles River Valley Sewer also owned by MWRA.
According to the ENF, water demand for the project is estimated at 135,630 gallons per day (gpd), which is an increase oF 114,323 gpd over the existing water demand estimate of2 1,307 gpd. For water service the Project site is served on Soldiers Field Road by an 8-inch Northern Low cement lined ductile iron water main installed in 2014; on Western Avenue by a 16-inchNorthern Low pit cast iron water main installed in 1900 and cleaned and lined 2005; and on Telford Street by an 8-inch Northern Low cast iron water main installed in 1948and cleaned and lined in 2005. According to the ENF, proposed sewage generation for the Project is estimated at 123,300,which is an increase of 103,930gpd over the existing sewer generationestimate of 19,370gpd. For sewer service the Projectsite is served on Western Avenue by a 10-inch,and a 36 by 38-inch sewer main; and on Telford Street by a 12-inchsewer main.
For drainage the Project site is served by a 12-inchstorm drain located on the eastbound side of Western Avenue; by a 54-inch stonn drain locatedon the westbound side of Western Avenue; and by a 66-inch storm drain located on Telford Street. Drainage from the Project site ultimately discharges to the Charles River.
The Commission comments regarding the Projectare provided below.
General
I. The Proponent must submit a site plan and General Service Applicationto the Commission for the proposed Project. Prior to the initial phase of the site plan development, the Proponentshould meet with the Commission’s Designand EngineeringCustomer Servicesto review water main, sewer and storm drainage system availabilityand potential upgrades that could impact the Project’s development.
2. Any new or relocated water mains, sewers and storm drains must be designed and constructed at the Proponent’sexpense. They must be designed and constructed in conformance with the Commission’s design standards. Water DistributionSystem and Sewer Use Regulations,and Requirementsfor site Plans. Thc site plan should includethe locationsof new, relocated and existing water mains, sewers and drains which serve the site, proposed service connections, water meter locations,as well as back flow preventiondevices in the facilitiesthat will require inspection.
3. \Vith the site plan the Proponentmust provide detailed estimates for water demand (including water required for landscape irrigation),wastewalergeneration, and stormwaterrunoff for the Project. The Proponent should provide separate estimates of peak and continuous maximum water demand for retail, irrigation and air-conditioningmake-upwater for the Project. Estimatesshould be based on full-site build-out of the Project.
4. It is the Proponent’sresponsibilityto evaluate the capacity of the water and sewer system serving the Project site to determine if the systems are adequate to meet future Project demands. With the site plan the Proponent must includea detailed capacity analysis for the water and sewer systems serving the Project site, as well as an analysis of the impactthe Project will have on the Commission’s systems and the MWRA’ssystems overall. The analysis should identify specific measures that will be implementedto offset the impacts ofthe anticipated flows on the Commissionand MWRA sewer systems.
5. Developers of projects involvingdisturbancesof land of one acre or more are required to obtain an NPDES General Permit for Construction from the EnvironmentalProtection Agency. The Proponent is responsible for determining if such a permit is required and for obtaining the permit. If such a permit is required for the proposed Project, a copy of the Notice of Intent and any pollution prevention plan submitted to EPA pursuantto the permit must be provided to the Commission’s EngineeringServices Departmentprior to the commencementof construction.
6. The design of the Project must comply with the City of Boston’s Complete Streets Initiative,which requires incorporationof “green infrastructure”into street designs. Green infrastructureincludes
7 greenscapes, such as trees, shrubs, grasses and other landscape plantings, as well as rain gardens and vegetative swales. infiltrationbasins, and paving materialsand permeable surfaces. The proponent must develop a maintenanceplan for the proposed green infrastructure. For more information on the Complete Streets Initiativesee the City’s website at hap:!!hostoncomnletestreets.onz/
7. Before the Proponentdemolishes any existing structuresthe existing water, sewer and drain connections that won’t be re-usd must be cut and capped in accordance with Commission standards. The Proponent must complete a TerminationVerificationApproval Form for a Demolition Permit, available from the Commission. Sewage/fl ramae
8. The Departmentof EnvironmentalProtection(DEP), in cooperation with the Massachusetts Water Resources Authority(MWRA) and its member communities are implementinga coordinated approach to flow control in the MWRA regional wastewatersystem, particularly the removal of extraneous clean water (e.g., infiltration!inflow(“Ill”)) in the system. Pursuant to the policy new developments with design flow exceeding 15,000gpd of wastewaterare subject to the Departmentof Environmental Protection’sregulation314 CMR 12.00,section 12.04(2)(d). This regulation requires all new sewer connectionswith design flowsexceeding 15,000gpd to mitigate the impacts of the development by removing four gallons of infiltrationand inflow(Ill) for each new gallon of wastewater flow added. The Commissionwill require the Proponentto develop an inflow reduction plan consistent with the regulation. The 4:1 reduction should be addressed at least 90 days prior to activation of water sen’ice and will be based on the estimated sewage generation provided with the Project site plan.
9. Oil traps are required on drainage systems discharging from enclosed parking garages. Discharges from the oil traps must be directed to a building sewer and must not be mixed with roolor other surface runoff. The requirementsfor oil traps are provided in the Commission’s Requirementsfor Site Plans.
10. Grease traps will be required in any food service facility in the new development in accordance with the Commission’s Sewer Use Regulations. The proponent is advised to consult with the Commission before preparing plans for food service facilities.
I 1. Sanitary sewage must be kept separate from stormwater at aLltimes and separate sanitary’sewer and storm drain service connections must be provided. Under no circumstanceswill stormwaler be allowed to discharge to a sanitary sewer. The Commissionrequires that existing stormwaterand sanitary sewer service connections, if any are to be re-used by the Project, be dye tested to confirm they are connected to the appropriate system.
12. The discharge of dewateringdrainage to a sanitary sewer is prohibited by the Commission and the MWRA. The discharge of any dewateringdrainage to the storm drainage system requires a Drainage Discharge Permit from the Commission. If the dewateringdrainage is contaminated with petroleum products for example, the Proponent will be required to obtain a RemediationGenera) Permit from the EPA for the discharge.
13. A Total Maximum Daily Load (TMDL) for Nutrients has been established for the Lower Charles River Watershed by the MassachusettsDepartmentof EnvironmentalProtection(DEP). In order to achieve the reductions in phosphorus loadingsrequired by the TMDL phosphorusconcentrations in stomiwater dischargesto the lower Charles River from Boston mtistbe reduced by 64%. To
3 accomplish the necessary reductions in phosphorusthe Commission requires developers of projects in the lower Charles River watershedto infiltratestonnwater discharging from imperviousareas in accordance with DEP requirements. Withthe site plan the Proponentmust submit a phosphorus reduction plan for the Project.
11. The Proponent must !iilly investigatemethods for infiltratingstormwateron-site before the Commission will consider a request to discharge stonnwater to the Commission’s system. The site plan must indicate how storm drainage from rooftops and other impervioussurfaces will be managed. All projects at or above 100,000square feet of floor area are required to retain, on site, a volume of runoff equal to 1.25inches of rainfall times the imperviousarea. A feasibilityassessment for infiltrating stormwateron-site must be submitted with the site plan for the Project.
15. The Massachusetts Departmentof EnvironmentalProtection (Ma5sDEP)has established Performance Standards for Stormwater Management,The Standards address stormwater quality, quantity and recharge. In addition to Commissionstandards, the proposed Projectwill be required to meet Mas5DEP’sStormwatcrManagementStandards.
16. In conjunction with the site plan and General Service Application the Proponentwill be required to submit a Stormwater PollutionPrevention Plan. The plan must:
• Specifically identify how the Project will comply with the Departmentof Environmental Protection’s PerformanceStandards for StormwaterManagementboth during constructionand after construction is complete.
- Identify specific best managementmeasures for controlling erosion and preventingthe discharge of sediment, contaminatedstormwater or construction debris to the Commission’sdrainage system when construction is underway.
• Include a site map which shows, at a minimum,edsting drainage patterns and areas used for storage or treatment of contaminated soils, groundwateror stormwater. and the locationof major control or treatment structuresto be utilized during construction.
17. The Commission requests that the Proponent installa permanent casting stating: “Don’t Dump: Drains to Charles River” next to any new catch basin installedas pail of the Project. The Proponent nay contact the Commission’sOperations Division for informationregardingthe purchase of the castings.
18. The Commission encourages the Proponentto explore additional opportunities for protecting stomiwater quality by minimizingsanding and the use of deicing chemicals, pesticides and fertilizers. Water
19. The Proponent is required to obtain a Hydrant Permit for use of any hydrant during construction of the Project. The water used from the hydrant must be metered. The Proponent should contact the Commission’s Operations Departmentfor informationon obtaining a Hydrant Permit.
20. The Commission utilizes a Fixed Radio Meter Reading System to obtain water meter readings. Where a new water meter is needed, the Commissionwill provide a Meter Transmitter Unit (MTU) and connect the device to the meter. For informationregarding the installationof MTUs. the Proponent should contact the Commission’s Meter InstallationDepartment.
4 21. The Proponent should explore opportunities for implementingwater conservation measures in addition to those required by the State PlumbingCode. In particular the Proponent should consider indoor and outdoor landscapingwhich requires minimal use of water to maintain. Ifihe Proponent plans to install in-ground sprinkler systems, the Commission recommends that timers, soil moisture indicators and rainfall sensors be installed. The use of sensor-operated faucets and toilets in common areas of buildings should also be considered.
Thank you for the opportunityto comment on this
P.E. Chief Engineerand Operations Officer
JPS/as cc: M. Cantalupa, the Davis Companies K. Ronan. Mass. Water Resources Authority via email M. Zlody, Boston EnvironmentDepartment via email P. Larocque. BWSC via email
5
October 13, 2020
Via Email
Erin Flaherty Environmental Analyst, MEPA Office Executive Office of Energy and Environmental Affairs 100 Cambridge Street, Suite 900 Boston, MA 02114 [email protected]
Re: ENF for 1234 and 1240 Soldiers Field Road, Boston, MA
Dear Erin:
Charles River Watershed Association (“CRWA”) submits the following comments on the Environmental Notification Form (“ENF”) for the 1234 and 1240 Soldiers Field Road properties in Boston, Massachusetts filed with the MEPA Office on September 15, 2020. This project is located on 3.143 acres of developed land that has primarily been used for commercial purposes. The proposed project involves redevelopment of the 1240 property to a new residential building with 535 residential units, 10,500 sf of ground floor retail space, and a garage for 220 vehicles. The proposed project also involves redevelopment of the 1234 property to a residential building with 125 residential condominium units, a hotel with 225 hotel rooms, 4,000 sf of ground floor retail space, and a garage for 185 vehicles, in addition to a new internal roadway and landscape improvements to the boarding streets.
CRWA supports the creation of 72,000 sf of new open space on the property as it can maximize environmental benefits on site for future residents and the surrounding community. Climate change is causing increased heavy rainfalls, more drought, and hotter temperatures. By minimizing impervious surfaces, maximizing the functioning of natural ecosystems, and employing green infrastructure, this project can help to mitigate the effects of climate change and result in a healthier environment for residents and the environmental justice community present.
Impervious Surface & Stormwater
CRWA appreciates that the ENF notes the project will utilize BMPs however CRWA encourages on surface green infrastructure be prioritized to provide additional co-benefits to the community. Green infrastructure should be extensively incorporated into parking lots and other paved areas to treat stormwater generated by impervious surfaces and provide cooling benefits for residents. Impervious surfaces exacerbate stormwater pollution and runoff and contribute to
Charles River Watershed Association 190 Park Road Weston, MA 02493 t 781 788 0007 f 781 788 0057 www.charlesriver.org heat island effects. Opportunities for groundwater recharge should be maximized as well to offset the expected increase of wastewater generated on site.
The ENF notes that the project will meet BWSC’s stormwater management regulations but does not specifically demonstrate how compliance will be achieved. Additional stormwater management plans detailing system sizing, type, and location should be provided, along with calculations showing that the project complies with the TMDL, which requires no additional inputs of phosphorus to the river and a significant reduction from existing development. Additionally, according to the National Climate Assessment, the amount of precipitation falling in very heavy events increased by 71% in New England from 1958 to 2012. The ability of stormwater management systems to handle current and predicted future rainfall amounts using the best available science should be evaluated.
Trees & Vegetation
CRWA appreciates the increase of available open space on the site as it would provide critical environmental benefits in a community where they are particularly needed and can assist with increasing access and connections to Herter Park for residences. Trees and other vegetation protect air and water quality, help to control stormwater runoff and flooding, and provide natural cooling. Native trees and shrubs should be planted on site along proposed roadways and in proposed landscape improvement areas wherever possible. Maximizing vegetation will contribute to resiliency zoning efforts and assist with flooding. Additionally improvements along connector streets of Western Avenue should align with current goals of the Western Avenue corridor study to create green streets and green connector streets and improve public realm.
Water Conservation
The Project is estimated to require 114,323 net new gallons per day of water. The strain on our water resources is only increasing, and we need to prepare for increased drought in the future. We therefore encourage the proponent to do as much as possible to limit all outdoor watering. Low flow appliances should be prioritized as well as potable water for any outdoor watering. Additionally drought resistant native plants should be selected to reduce water use.
Thank you for considering these comments, and please do not hesitate to reach out with any questions. cc. Ebony DaRosa, Boston Planning & Development Agency
Sincerely,
Nishaila Porter
2
Program Associate [email protected] 781-788-0007 x 247
3
Charles D. Baker Kathleen A. Theoharides Governor Secretary
Karyn E. Polito Martin Suuberg Lieutenant Governor Commissioner
October 13, 2020
Kathleen A. Theoharides, Secretary RE: Boston Executive Office of 1234 and 1240 Soldiers Field Road Energy & Environmental Affairs EEA# 16270 100 Cambridge Street Boston MA, 02114
Attn: MEPA Unit
Dear Secretary Theoharides:
The Massachusetts Department of Environmental Protection Northeast Regional Office (MassDEP-NERO) has reviewed the Environmental Notification Form (ENF) for the proposed 1234 and 1240 Soldiers Field Road in Boston. MassDEP provides the following comments.
Solid Waste
MassDEP’s current Massachusetts 2010-2020 Solid Waste Master Plan1 –Pathway to Zero Waste, issued in April 2013 identifies a key goal to reduce solid waste disposal by 30% by 2020, from 6,550,000 tons of disposal in 2008 to 4,550,000 tons of disposal by 2020. MassDEP encourages the Proponent to review the plan to identify project management and operations practices that will assist the Commonwealth in meeting its material management goals. More information on the Solid Waste Master Plan and yearly update reports can be found at: https://www.mass.gov/guides/solid-waste-master-plan.
1 Note the Draft 2020-2030 Solid Waste Master Plan is in review and may be finalized in late 2020.
This information is available in alternate format. Contact Michelle Waters-Ekanem, Director of Diversity/Civil Rights at 617-292-5751. TTY# MassRelay Service 1-800-439-2370 MassDEP Website: www.mass.gov/dep Printed on Recycled Paper
Waste Ban
Section 310 CMR 19.017 Waste Bans of the Massachusetts Solid Waste regulations prohibit the disposal of certain construction-related wastes in Massachusetts, including, but not limited to, metal, wood, asphalt pavement, brick, concrete, clean gypsum wallboard. Further guidance can be found at: https://www.mass.gov/guides/massdep-waste-disposal-bans.
MassDEP regulations also ban disposal of food and other organic wastes from businesses and institutions that dispose of more than one ton of these materials per week. The ban is one of MassDEP’s initiatives for diverting at least 35% of all food waste from disposal statewide by 2020. Diverted food waste may be composted, converted to energy (through anaerobic digestion), recycled, or reused. Additional information on the Commercial Food Material Disposal Ban can be found at: https://www.mass.gov/guides/commercial-food-material-disposal-ban.
C&D Recycling
Many construction and demolition materials are currently banned from disposal or transfer for disposal in Massachusetts (https://www.mass.gov/guides/massdep-waste-disposal-bans). Therefore, MassDEP encourages the Proponent to make a significant commitment to construction and demolition (C&D) waste recycling activities as a sustainable measure for the project and to assist in complying with waste ban requirements. MassDEP considers an asphalt, brick, and concrete (ABC) rubble processing or recycling facility (pursuant to the provisions of Section (2)(b) under 310 CMR 16.03), the Site Assignment regulations for solid waste management facilities), to be exempt from the site assignment requirements, if the ABC rubble at such facilities is separated from other solid waste materials at the point of generation. In accordance with 310 CMR 16.03(2)(b), ABC can be crushed on-site with a 30-day notification to MassDEP. However, the asphalt is limited to weathered bituminous concrete (no roofing asphalt), and the brick and concrete must be uncoated or not impregnated with materials such as roofing epoxy. If the brick and concrete are not clean, the material is defined as C&D waste and requires either a Beneficial Use Determination (BUD) or a Site Assignment and permit before it can be crushed.
Pursuant to the requirements of 310 CMR 7.02 of the Air Pollution Control regulations, if the ABC crushing activities are projected to result in the emission of one ton or more of particulate matter or other pollutant to the ambient air per year, and/or if the crushing equipment employs a diesel oil fired engine with an energy input capacity of three million or more British thermal units per hour for either mechanical or electrical power which will remain on-site for twelve or more months, then a plan application must be submitted to MassDEP for written approval prior to installation and operation of the crushing equipment.
Asbestos
Pursuant to 310 CMR 7.15 the removal of asbestos from the buildings must adhere to the special safeguards defined in the Air Pollution Control regulations. An asbestos survey to identify all asbestos containing materials (ACM) shall be conducted by a Massachusetts Department of Labor Standards certified Asbestos Inspector. All identified ACM shall be abated prior to demolition activities. The Proponent is required to submit to MassDEP an Asbestos Removal
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Notification (Form AQ04 (ANF-001)) at least 10 working days prior to initiating work for any project involving asbestos abatement, removal, or disposal. If any ACM will need to be abated through non-traditional abatement methods, the Proponent must apply for and obtain approval from MassDEP, through Application BWP AQ36 - Application for Non-Traditional Asbestos Abatement Work Practice Approval.
Pursuant to 310 CMR 7.09, for any Construction and Demolition, except in a residential building with fewer than 20 units, the Proponent is required to submit to MassDEP a Construction/Demolition Notification (Form BWP AQ06) at least 10 working days prior to initiating work. MassDEP Asbestos, Construction and Demolition Notifications can be found at: https://www.mass.gov/guides/massdep-asbestos-construction-demolition-notifications.
Pursuant to 310 CMR 19.061, disposal of ACWM within the Commonwealth must be at a facility specifically approved by MassDEP. The Proponent is advised that asbestos containing waste materials (ACWM) are a special waste as defined in the Solid Waste Management regulations. There are specific ACWM disposal exceptions for intact vinyl asbestos tile (VAT) and asphaltic-asbestos felt and shingles. The disposal of the ACWM outside the jurisdictional boundaries of the Commonwealth must comply with all the applicable laws and regulations of the state receiving the material. Pursuant to 310 CMR 16.05, ACM including VAT, and/or asphaltic- asbestos felts or shingles may not be disposed of at a facility operating as a recycling facility.
Recycling Infrastructure
MassDEP supports voluntary initiatives to institutionalize source reduction and recycling into operations. Adapting the design, infrastructure, and contractual requirements necessary to incorporate reduction, recycling and recycled products into existing large-scale developments has presented significant challenges to recycling proponents. Integrating those components into developments during the planning and design stage enables the project’s management and occupants to establish and maintain effective waste diversion programs.
The MassDEP appreciates the opportunity to comment on this proposed project. Please contact [email protected] at (978) 694-3262 for further information on Construction, Demolition, Asbestos and Recycling. If you have any general questions regarding these comments, please contact me at [email protected] or at (978) 694-3304.
Sincerely,
John D. Viola Deputy Regional Director cc: Brona Simon, Massachusetts Historical Commission Eric Worrall, John MacAuley, MassDEP-NERO
3
October 13, 2020
Kathleen A. Theoharides, Secretary Executive Office of Energy and Environmental Affairs 100 Cambridge St, Suite 900 Attn: MEPA Office, Erin Flaherty Boston, MA 02114
Subject: EOEEA #16272– Environmental Notification Form 1234 and 1240 Soldiers Field Road, Boston, MA
Dear Secretary Theoharides,
The Massachusetts Water Resources Authority (MWRA) appreciates the opportunity to comment on the Environmental Notification Form (ENF) submitted by TDC 1234 Owner, LLC and TDC 1240 Owner LLC, each of which are affiliates of the Davis Companies (the “Proponent”) for 1234 and 1240 Soldiers Field Road (the “Project”) in Boston, Massachusetts. The Project site consists of two parcels that currently contain a hotel, restaurant, The Skating Club of Boston facility, and associate parking. The Project involves removal of all existing structures and the construction of a residential and hotel development spanning three separate buildings. Overall, the Project will include approximately 655 residential units, a 255-room hotel, approximately 4,000 square feet of ground floor retail space, an underground garage containing 185 vehicles and publicly accessible open space.
Comments on the ENF relate to wastewater issues and the need for Infiltration/Inflow (I/I) Removal, Toxic Reduction and Control (TRAC) discharge permitting and MWRA Enabling Statue Section 8(m) permitting.
Wastewater
The ENF reports that the Project will increase wastewater flow by 103,930 gallons per day (gpd), from an existing wastewater flow of 19,370 gpd to 123,300 gpd. According to the Boston Water and Sewer Commission’s (BWSC) storm drain and sewer maps, the Project site is served by BWSC separate storm drains and sanitary sewers. The BWSC sanitary sewer in Western Avenue conveys flows to MWRA’s Charles River Valley Sewer (CRVS) in Western Avenue. The CRVS collects wastewater flows from combined sewer areas and separate sanitary sewer areas in parts of Boston, Brookline, Newton, Watertown and Waltham and conveys these flows to MWRA’s Ward Street Headworks in Roxbury, which directs flows into MWRA’s Boston Main Drainage Tunnel for transport to the Deer Island Treatment Plant. Due to infiltration (groundwater) and inflow (rainwater) (“I/I”) that can enter tributary community sanitary sewers and stormwater that enters tributary community combined sewers, combined flows in large storms can exceed the capacity of the MWRA system and contribute to combined sewer overflows (“CSO”) to the Charles River Basin, most notably from MWRA’s Cottage Farm CSO treatment facility on the Cambridge side of the river.
To ensure that the Project’s wastewater flow does not increase system surcharging or overflows in large storms, the Proponent and BWSC should effect a 4:1 offset of the Project’s new wastewater flow by removing stormwater and/or I/I 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 Massachusetts Department of Environmental Protection regulation and BWSC I/I policy. Increasing wastewater flow to the BWSC and MWRA sewer systems without the required offset can compromise the sewer system benefits and Charles River water quality benefits of MWRA’s recently completed $912 million region-wide CSO control plan.
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 a storm drain and is not located in a combined sewer area. Therefore, the discharge of groundwater or stormwater to the sanitary sewer system associated with this Project is prohibited.
An MWRA Sewer Use Discharge Permit is required prior to discharging wastewater from any laundry operations associated with hotels on the Project site into the MWRA sanitary sewer system. For assistance in obtaining this permit, the Proponent or a representative from the proposed hotel should contact Keary Simmerman, MWRA Industrial Coordinator, in the TRAC Department at (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.
Section 8(m) Permitting Section 8(m) of Chapter 372 of the Acts of 1984, MWRA’s Enabling Legislation, allows the MWRA to issue permits to build, construct, excavate, or cross within or near an easement or other property interest held by the MWRA, with the goal of protecting Authority-owned infrastructure. Due to the proximity of MWRA water and wastewater infrastructure in the vicinity of the Project, an 8(m) permit will be required. The Proponent should coordinate with Kevin McKenna in the Operations Permitting Group at 1 (617) 305-5956 for assistance in this process.
On behalf of the MWRA, thank you for the opportunity to provide comments on this Project. Please do not hesitate to contact me at 1 (617) 788-4958 with any questions or concerns.
Sincerely,
Bethany Card Director Environmental and Regulatory Affairs cc: John Viola, MassDEP Adam Horst, BWSC
October 14, 2020
Kathleen Theoharides, Secretary Executive Office of Energy and Environmental Affairs 100 Cambridge Street, Suite 900 Boston, MA 02114-2150
RE: Boston: 1234 and 1240 Soldiers Field Road – ENF (EEA #16272)
ATTN: MEPA Unit Erin Flaherty
Dear Secretary Theoharides:
On behalf of the Massachusetts Department of Transportation, I am submitting comments regarding the Environmental Notification Form for the 1234 and 1240 Soldiers Field Road mixed- use 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
1234 and 1240 Soldiers Field Road Page 2 10/14/2020 cc: Jonathan Gulliver, Administrator, Highway Division Patricia Leavenworth, P.E., Chief Engineer, Highway Division John McInerney, District 6 Highway Director Neil Boudreau, Assistant Administrator of Traffic and Highway Safety Metropolitan Area Planning Council Massachusetts Bay Transportation Authority Boston Planning and Development Authority, City of Boston Boston Transportation Department
MEMORANDUM
TO: David Mohler, Executive Director Office of Transportation Planning
FROM: J. Lionel Lucien, P.E, Manager Public/Private Development Unit
DATE: October 14, 2020
RE: 1234 and 1240 Soldiers Field Road – ENF (EEA # 16272)
The Public/Private Development Unit (PPDU) has reviewed the Environmental Notification Form (ENF) for the proposed 1234 and 1240 Soldiers Field Road mixed use project in Boston. The project site consists of approximately 3.14 acres of land bounded by Soldiers Field Road to the north, properties owned by the City of Boston Department of public Works and Harvard University to the east, Western Avenue to the south, and Telford Street to the east. The site presently consists of a 117-room hotel and a 2,000 square foot restaurant at the 1234 site and The Skating Club of Boston at the 1240 site, served by a total of 164 surface parking spaces.
The project would entail the removal of all existing structures and the construction of approximately 723,000 square feet (sf) of development space across three buildings, including 535 rental residential units, 120 condominium residential units, a hotel with 255 rooms, and 14,500 sf of retail space. The project includes provisions for 405 parking spaces in garages beneath the buildings. Access to the site would be provided via three driveways, one each on Soldiers Field Road, Western Avenue, and Telford Street. The Soldiers Field Road and Western Avenue driveways will be connected by a new private site drive that will be open to the public. Soldiers Field Road is under the jurisdiction of the Department of Conservation and Recreation (DCR). The project does not require a Vehicular Access Permit from MassDOT, but MassDOT provides comments on the ENF because one of the intersections in the project’s study area is under MassDOT jurisdiction and the project anticipates a substantial transit mode share.
The project is expected to generate 7,438 unadjusted daily vehicle trips, 5,908 of which would be new trips, exceeding the Massachusetts Environmental Policy Act (MEPA) trip generation threshold for an Environmental Impact Report (EIR). The ENF includes a Transportation Impact Assessment (TIA) prepared in general conformance with the current MassDOT/EOEEA Transportation Impact Assessment Guidelines. The Draft Environmental Impact Report (DEIR) should address the comments on the TIA raised in this letter.
Ten Park Plaza, Suite 4150, Boston, MA 02116 Tel: 857-368-4636, TTY: 857-368-0655 www.mass.gov/massdot
1234 and 1240 Soldiers Field Road Page 2 10/14/2020
Trip Generation
The TIA includes trip generation rates that were calculated using the Institute of Transportation Engineers (ITE)’s Trip Generation Manual (10th Edition). The initial trip generation was calculated based on ITE trip rates for Land Use Codes (LUC) 220 – Multifamily Housing Low-Rise, LUC 310 – Hotel, and LUC 820 – Shopping Center. The unadjusted trip generation estimate is 7,438 daily vehicle trips, with 432 vehicle trips during the weekday morning peak hour, and 570 vehicle trips during the weekday evening peak hour.
Mode share for the proposed project is estimated based on the Boston Transportation Department (BTD) guidelines for the zone in which the project is located. The site currently contains a hotel, a restaurant and the Skating Club of Boston. The existing trip generation is estimated by using LUC 310 – Hotel and LUC 931 – Quality Restaurant. However, the Skating Club does not align with any ITE LUC and it generates a variable number of daily trips, with few trips during the peak periods, therefore trips generated by the Skating Club are not included in the existing trip generation estimate. Accounting for mode share adjustments and the existing land uses the project is estimated to generate 2,778 daily vehicle trips, with 168 vehicle trips during the weekday morning peak hour, and 207 vehicle trips during the weekday evening peak hour. MassDOT notes that, if available, driveway counts would be the preferred method for estimating existing trip generation and should be presented in the DEIR.
Safety
The Proponent obtained crash data for the continuous five-year period of 2015 through 2019 at all study area intersections from MassDOT and the Boston Vision Zero Database. The data through 2017 is considered complete but the data beyond 2017 is considered incomplete by MassDOT because the records have not been verified and closed by municipal departments. The ENF summarizes and compares crash rates against the MassDOT District 6 averages. One of the study locations, the intersection of Western Avenue/Arsenal Street at Birmingham Parkway and Soldiers Field Road, is under joint jurisdiction by MassDOT, DCR, and the City of Boston. This location consists of three interconnected signalized intersections and experiences a crash rate above the MassDOT District 6 average. Although no comparison was made to statewide averages, the statewide averages are higher than District 6 and therefore such comparison would not reveal any new intersections with safety deficiencies.
The intersection of Western Avenue/Arsenal Street at Birmingham Parkway and Soldiers Field Road is also included in the MassDOT Highway Safety Improvement Program (HSIP) for crashes occurring between 2015-2017, although this is not noted in the ENF. MassDOT notes that many of the pedestrian accommodations at this intersection are not American’s with Disabilities Act (ADA) compliant. Although the 530 Western Ave/Radius Apartments project studied this location, MassDOT asks that the Proponent coordinate with the MassDOT Safety Unit to determine if this location requires a Road Safety Audit (RSA). The DEIR or subsequent MEPA documentation should include a summary of the discussion with the MassDOT Safety Unit and a plan for how to improve safety at the intersection,
1234 and 1240 Soldiers Field Road Page 3 10/14/2020 potentially including advancing the design of improvements, based on the previous study, and partially funding the construction of mitigations.
Traffic Operations
In the ENF, the Proponent provides a comprehensive analysis of study area intersections for the 2020 existing, 2027 No-Build, and 2027 Build conditions. The existing 2020 volumes are based on counts collected in 2019, considered by MassDOT to be existing conditions because of the current atypical roadway volumes. The 2027 No-Build analysis uses a compounded annual growth rate of 0.25% and incorporates background projects and roadway improvements.
The improvements included at the intersection of Western Avenue/Arsenal Street at Birmingham Parkway and Soldiers Field Road were identified in the study conducted by the 530 Western Ave/Radius Apartments project. However, MassDOT is not aware of funding identified for these improvements or plans to implement these improvements in the near-term. MassDOT asks that the DEIR include a revised No-Build and Build analysis without these improvements. Following this revised analysis, the Proponent should identify any mitigations that may be required.
Project trips were distributed onto the network according to BTD data for the zone in which the project is located. With the current analysis configurations, some movements at the intersection under partial MassDOT jurisdiction experience an improvement in level-of- service (LOS) between Existing and No-Build and then a decline in LOS between No-Build and Build. The intersection of Western Avenue at North Harvard Street degrades in LOS during the evening peak hour between the No-Build and Build scenarios.
Parking
The site currently contains 164 parking spaces for the Skating Club and the hotel. The project will result in an increase of 241 parking spaces, resulting in 405 total spaces. Parking is provided at a ratio of 0.41 spaces per apartment unit, one space per condominium unit, and 0.25 spaces per hotel room. The ENF explains that the residential parking ratios are aligned with the ratios for other residential projects recently approved near the project site.
Transit
The ENF includes a transit analysis for the MBTA bus Routes 70 (Market Place Drive or Waltham Center - University Park) and 86 (Sullivan Square Station - Reservoir Station), which run along Western Avenue, although there are no stops along the project frontage. The analysis demonstrates that the analyzed bus routes do not exceed the policy capacity in the existing, No-Build, or Build scenarios. MassDOT asks that the DEIR include an analysis compliant with the MBTA’s Office of Performance Management and Innovation’s (OPMI) methodology for calculating comfort metrics (as evaluated in the Service Delivery Policy [SDP]), in addition to capacity analysis, for each bus route within the project’s study area.
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Mitigation should be proposed for any bus route receiving new passengers that falls below the 96% route-wise minimum for the SDP comfort metric, any trip for which the new passengers would cause the trip to exceed the threshold, and/or any trip which was already above the crowding threshold and which new passengers would be added to. The Proponent should consult with the MBTA on the feasibility of providing new stops that would serve the site.
Multimodal Access and Facilities
The proposed site access will result in reduced curb cuts and an improved pedestrian experience. The Proponent will construct new ADA compliant sidewalks along the project frontages. The set-back along Western Avenue and Telford Street will be increased to create a large pedestrian zone. The set-back along Western Avenue will also maintain adequate width to support potential protected bike lanes or bus-only lanes along Western Avenue that the City of Boston may implement in the future.
The Proponent is coordinating with DCR on their assessment of a replacement pedestrian bridge over Soldiers Field Road at Telford Street. The Proponent has committed to replacing the pedestrian ramp on Telford Street with a new accessible pedestrian ramp to the bridge and constructing an additional accessible ramp to the bridge through the central green space of the project site.
The project will provide a bikeshare station, 655 secure bicycle parking spaces for residents, 33 for hotel and retail employees, and 145 unsecured bicycle parking spaces for visitors and customers.
Transportation Demand Management (TDM) Program
To reduce site trip generation, the ENF includes a robust TDM program. The goal of the TDM program should be to minimize single occupancy vehicle (SOV) and Transportation Network Company (TNC, i.e. Uber and Lyft) trip generation. The Proponent details the following TDM measures in the ENF with the goal of reducing vehicle trips by employees, residents, and visitors of the project:
Designation of a TDM Coordinator for the site; Membership in the Allston-Brighton Transportation Management Association (TMA); Provision of orientation packets for new tenants with information on transit service, vehicle sharing, and bicycle sharing; Collaboration with commercial tenants to raise awareness of transit, bicycling, and walking; Provision of an annual newsletter summarizing transportation and TDM options; Provision of an annual event to encourage active transportation; Provision of information about transportation options in each building lobby and on a website; Provision of secured and unsecured bicycle storage;
1234 and 1240 Soldiers Field Road Page 5 10/14/2020
Provision of showers for employees who walk or bicycle; Potential provision of a bikeshare station; Provision of real-time transit information in each building lobby; Requiring that employers subsidize purchase of monthly transit passes for on-site full- time employees; Provision of unbundled parking; Provision of at least one on-site carshare space; Provision of information about carpool, vanpool, and registration in the ride-matching program through the Allston-Brighton TMA; and Encouragement to tenants to organize an internal ride-matching 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. It should include:
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); Weekday AM and PM and Saturday peak hour turning movement counts (TMCs) and operations analysis at “mitigated” intersections, including those involving site driveways; and Transit Ridership counts.
The goals of the monitoring program would be to evaluate the assumptions made in the EIR 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 units, including PPDU and the District 6 Office, to discuss preparation of the DEIR. If you have any questions regarding these comments, please contact me or Catrina Meyer at [email protected].
COMMONWEALTH OF MASSACHUSETTS EXECUTIVE OFFICE OF ENERGY AND ENVIRONMENTAL AFFAIRS DEPARTMENT OF ENERGY RESOURCES 100 CAMBRIDGE ST., SUITE 1020 BOSTON, MA 02114 Telephone: 617-626-7300 Facsimile: 617-727-0030
Charles D. Baker Kathleen A. Theoharides Governor Secretary
Karyn E. Polito Patrick Woodcock Lt. Governor Commissioner
20 October 2020
Kathleen Theoharides, Secretary Executive Office of Energy & Environmental Affairs 100 Cambridge Street Boston, Massachusetts 02114 Attn: MEPA Unit
RE: 1234 and 1240 Soldiers Field Road, Boston, MA, EEA #16272
Cc: Maggie McCarey, Director of Energy Efficiency, Department of Energy Resource Patrick Woodcock, Commissioner, Department of Energy Resources
Dear Secretary Theoharides:
We’ve reviewed the Environmental Notification Form (ENF) for the proposed project. The project includes 535 rental units, 120 condominium units, 255 hotel units, and 14,500-sf of retail space. Total project size is 723,000-sf. For this project we expect key mitigation measures to include:
• Passivehouse for the residential rental, condominium and hotel;
• Efficient electrification of space heating;
• Maintaining envelope integrity with framed, insulated walls with continuous insulation;
• Avoiding glass curtain wall assemblies and excessive windows;
• External shading and reduced solar heat gain coefficient;
• Energy recovery.
Experience has shown that the above deliver 50 to 80% less emissions than projects built to Code while improving affordability and resilience. In addition, significant incentives may be available,
1234 and 1240 Soldiers Field Road, Boston, MA, EEA #16272 Boston MA as well, including MassSave® incentives, Alternative Energy Credits (AECs), and Solar Massachusetts Renewable Target (SMART) credits. For this project, just the MassSave® Passivehouse incentive for the residential portions of the project could be about $2M.
Key Mitigation Strategies Explained
Passivehouse
Passivehouse is an energy efficiency building standard that results in an ultra-low energy building requiring little energy use for space heating and cooling. This is achieved by focusing on envelope performance, airtightness, and energy recovery. Passivehouse projects also typically have efficient electrified heating, described further below, and much smaller-sized HVAC systems. Published studies show that in low-rise and mid-rise construction, Passivehouse doesn’t necessarily cost more to build because improvements to envelope are offset by reductions in HVAC1. In high-rise construction, Passivehouse costs nominally more2 to construct. However, cost savings usually exceed the amortized cost premium.
Passivehouse is an energy code standard which is unlike other energy efficient building approaches in that its truly performance based by requiring mandatory, rigorous in-field tests to confirm that strict standards are being met. Passivehouse methods are recognized by both Massachusetts building Code, MassSave®3, and incentives under Massachusetts’ Alternative Portfolio Standard (APS). For qualifying multifamily buildings, MassSave® incentive for Passivehouse is approximately $3,000 per dwelling unit, or about $2M when applied across this project.
Passivehouse also delivers:
• Significant reduction in utility costs: thus is much more affordable to residents;
• Improved resiliency: Passivehouse buildings can stay warm (or cool, in the summer) for extended periods of time even with loss of power.
The Passivehouse pathway accesses the most incentives, while also being the most affordable and efficient.
At this time there are over 5,000 passivehouse units being designed or under construction in eastern Massachusetts. Additionally, upon completion of Winthrop Square Tower, Boston will be home to a 750,000-sf office space certified passivehouse.
1 Pennsylvania Housing and Finance Association. Passivehouse Cost Comparison Data set 2015, 2016, 2018 [Data Set] 2 Feasibility Study to Implement the Passivehaus Standard on Tall Residential Buildings, FXcollaborative, 30 March 2017, Prepared for NYSERDA 3 MassSave® is a consortium of Massachusetts utility companies designed to deliver energy efficiency throughout the Commonwealth of Massachusetts. Page 2 of 11
1234 and 1240 Soldiers Field Road, Boston, MA, EEA #16272 Boston MA
Passivehouse Examples
Bunker Hill Housing Development Newton Riverside Charlestown, MA Newton, MA
Vancouvere Passivehouse Tower 515 East 86th Street Vancouver, BC New York, NY
Integrity of Building Envelope
High-performing envelope is essential to successful GHG mitigation, affordability, and resilience. Key strategies for maintaining integrity of envelope are:
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1234 and 1240 Soldiers Field Road, Boston, MA, EEA #16272 Boston MA
• Continuous insulation; • Reducing air infiltration; • Eliminating thermal bridges; • Limiting or eliminating use of glass “curtain wall” and spandrel assemblies; • Maximizing framed, insulated walls sections; • Avoiding excessive window areas.
The thermal performance of windows, curtain walls, and spandrels is typically about 70 to 80% less than the thermal performance of the framed, insulated wall assemblies. Accordingly, buildings which use extensive curtain wall, spandrel, and windows have compromised envelope performance which impacts energy consumption, emissions, resiliency, and affordability.
Efficient Electrification
Efficient electrification and renewable thermal space and water heating entails the swapping of fossil fuels (natural gas, oil, and propane) or electric resistance systems with one or more of the following:
• Cold-climate air source heat pumps and variable refrigerant flow (VRF) for space heating; • Air source heat pumps for water heating; • Ground source heat pumps; • Solar thermal.
Electrification of space and water heating is a key mitigation strategy with significant short- and long-term implications on GHG emissions. Massachusetts grid emissions rates continue to decline with the implementation of clean energy policies that increase renewable electricity sources. The implication is that efficient electric space and water heating with cold climate air source heat pump and VRF equipment have lower emissions than other fossil-fuel based heating options, including best-in-class (95% efficient) condensing natural gas equipment. Currently, efficient electric heating has approximately 50% lower emissions in Massachusetts than condensing natural gas heating. By 2050, efficient electric heating is expected to have approximately 85% lower emissions in Massachusetts than condensing natural gas heating. See illustration below.
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1234 and 1240 Soldiers Field Road, Boston, MA, EEA #16272 Boston MA
Electrifying Space Heating in Tower Setting
The DOER recognizes that it may be more challenging to electrify a tower than a small to mid- rise building. However, other projects have successfully overcome these challenges showing that it is feasible. In fact, electric heating equipment manufacturers design manuals describe what to do for towers, showing that electrification of space in towers is not unusual (more below).
Industry experts were able to provide the DOER examples of constructed towers up to 44 floors in height which are fully heated and cooled with air source systems, including examples of projects built over 15 years ago.
Industry experts also provided the DOER a design manual that shows a design solution for application of variable- refrigerant-flow (VRF) heat pumps in tall buildings (see insert). The solution is to split the tower into two vertical sections, with the upper portion of the tower served by condensing units on the roof and the lower portion of the Application of air source efficient tower served by condensing units near ground level. electric heating to tower
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1234 and 1240 Soldiers Field Road, Boston, MA, EEA #16272 Boston MA
Another innovative solution for towers is to locate the outdoor equipment on each floor. This works well in Passivehouse setting because the high-performance envelope and small peak loads means that each floor-plate can be served by relatively small outdoor equipment.
This approach is demonstrated by the Cornell Tech Tower project. This tower is entirely heated and cooled with electric VRF systems. Each floor has only two, relatively small (10-ton +/-) exterior condensers. The condensers are The 26-story Cornell Tech Tower is entirely heated and cooled with VRF systems. entirely inconspicuous, hidden Condensers (2 per floor) are entirely hidden behind the louvers shown in the behind louvers shown in arrow above. illustration on the right.
Heat Pump Water Heating
Water heating can be accomplished in many ways, common technologies include fossil fuel boilers and electric resistance systems. There are approaches that utilize air-source heat pumps, as well. These applications include centrally located systems that distribute hot water to the units, or unit- based heat pump water heaters.
DOER recognizes that heat pumps in dense, residential applications (condominium and hotel) are challenging but encourages the proponent to analyze and review all opportunities for electrification, including heat pump water heaters for the building. For retail, air source heat pumps can be readily incorporated.
External Shading and Solar Heat Gain Coefficient (SHGC)
To limit solar heat gains, 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.)
Solar PV
Rooftop PV can provide significant GHG benefits as well as significant financial benefits. The project should review opportunities to maximize on-site PV by set-aside as much roof space as possible for future rooftop PV.
Even if PV is not installed during building construction, it’s important to plan the project to ensure that roof space is set aside for PV and that roof space doesn’t become unnecessarily encroached with HVAC appurtenances, diminishing the opportunities for future PV. Electrification of heating and Passivehouse can both contribute to enabling more PV as these approaches can reduce rooftop equipment associated with conventional code HVAC.
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Incentives
Buildings which incorporate the above strategies can qualify for significant incentives:
• MassSave® performance-based incentives4 offer incentives for every kWh or therm saved compared to a program-provided energy model. The above energy efficiency strategies offer opportunities for large kWh and therm savings.
• MassSave® Passivehouse incentives5 are available to multifamily buildings which meet either PHI or PHIUS Passivehouse certification. In addition to a $3,000/unit incentive, MassSave® also funds pre-construction feasibility and modeling. The incentive structure is as follows:
• Alternative Energy Credits (AECs)6 offer incentives to electrify building space heating using heat pumps and/or VRF. This program also includes multipliers which increase value if the building meets Passivehouse standards or buildings built to HERs 50 or less. These credits may be distributed on a quarterly basis over time; or, may be distributed in a lump sum to the developer if certain conditions are met.
• Massachusetts SMART program7 provides significant incentives for solar development on top of federal and state tax incentives. SMART includes pathways which allow solar production to be sold without off-takers. This may be of potential interest to building developers as this allows them to develop rooftop solar without necessarily engaging with building tenants. For this reason, setting aside rooftop solar PV areas helps ensure that building owners’ ability to monetize the roof is not impacted.
4 https://www.masssave.com/en/saving/business-rebates/new-buildings-and-major-renovations/ 5 https://www.masssave.com/saving/residential-rebates/passive-house-incentives 6 https://www.mass.gov/guides/aps-renewable-thermal-statement-of-qualification-application 7 https://www.mass.gov/solar-massachusetts-renewable-target-smart Page 7 of 11
1234 and 1240 Soldiers Field Road, Boston, MA, EEA #16272 Boston MA
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.
In November 2020, an update to the Stretch Code will take effect. The Stretch Code to take effect in November also uses ASHRAE 90.1-2013-Appendix G. However, there will be several new, or changed, Massachusetts amendments including: C402.1.5 (envelope), C405.3 and C405.4 (lighting), C405.10 (EV charging), and C406 (additional efficiency measures). In addition, the additional C406 measures are increased from 2 to 3.
To accurately estimate Mitigation Level for this project, we recommend that the baseline for this project be set at the Stretch Code provisions which will be required in November 2020 as this will likely be the code that will be used for building construction.
Recommendations for the Next Submission
Recommendations are as follows:
1. Conduct separate models for residential (apartments and condominiums), hotel, and retail portions of the buildings.
2. Ensure baseline building scenario meets all requirements including relevant MA amendments. Clearly indicate which three C406 measures are being used in the baseline.
3. Separately for all scenarios of residential (apartments and condominiums), hotel, and retail, develop two UA analysis tables, as follows:
a. One table that shows how the baseline complies with Table 5.5-5 of ASHRAE 90.1 2013 Appendix G plus Massachusetts Amendment C401.2.4.
b. A second table that shows how the proposed complies with 2018 IECC Tables C- 402.1.3, C402.1.4, and C-402.4. Fenestration limit should be 30% when calculating minimum performance requirements.
4. Above-code envelope should be used throughout. In summary:
a. Above code-threshold envelope is recommended (vertical walls, windows, roofs and exposed lower level floors). Priority should be given to increasing continuous insulation and framed insulated wall sections. Distinguish between R value of batt and R value of continuous insulation. Continuous insulation necessarily means insulation that is uninterrupted by hangers, studs, etc. Indicate planned wall assembly U value and wall construction type (mass, wood, metal stud, etc). Confirm that the relationship between R-value and assembly U-factor conform to Appendix A of the Code. Page 8 of 11
1234 and 1240 Soldiers Field Road, Boston, MA, EEA #16272 Boston MA
b. Glass curtain wall/spandrel systems should be avoided as these are the lowest performing wall systems.
c. Reducing air infiltration is recommended, along with field tests to confirm integrity.
d. Recommended envelope, in summary, is an envelope with a 15% improved UA over IECC C402.1.5 minimum plus Passivehouse level air infiltration limit of 0.08 cfm at 75 Pa.
5. At a minimum, develop the following scenarios:
a. Condominium and apartments residential: Improved envelope as described above. Downsize the HVAC as much as possible. Efficient electric (electric air source heat pump/VRF) space heating and gas water heating. External shading and improved solar heat gain coefficient windows to control space cooling loads. We expect GHG mitigation to come primarily from reductions in heating, cooling, pumping, and fan energy. Mitigation from lighting should be limited to common areas.
b. Condominium and apartments residential should be Passivehouse with efficient electric space heating (electric air source heat pump/VRF) and gas water heating. This study should be performed by a qualified Passivehouse consultant using MassSave® funded feasibility study and modeling.
c. Hotel: Same as (a) and (b) above but with hotel use.
d. Retail portion should include improved envelope as described above. Downsize the HVAC as much as possible. Efficient electric (electric air source heat pump/VRF) space heating and electric air source heat pump hot water. Energy reduction shall be attributable to reductions in heating, cooling, fan, ventilation, and pumping. We expect GHG mitigation to come primarily from reductions in heating, cooling, pumping, and fan energy over reductions in lighting and miscellaneous energy reduction.
6. For both the residential and commercial portions, evaluate incentives, including
a. Estimate of Alternative Energy Credits
b. Estimates of MassSave® incentives, based on meeting with utility.
7. Evaluate rooftop solar PV. This should include building roof plans showing location of planned solar and location of roof HVAC equipment and other appurtenances.
8. Submit project modeling files to the DOER on a flash drive.
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1234 and 1240 Soldiers Field Road, Boston, MA, EEA #16272 Boston MA
9. Compare model results total and individual end uses with representative, prototype buildings developed by Pacific Northwest National Labs/Department of Energy found at the link below. Provide a summary explaining potential differences.
▪ https://www.energycodes.gov/sites/default/files/documents/BECP_901_2013_Progress_Indicator_ 0_0.pdf
▪ http://www.energycodes.gov/sites/default/files/documents/2013EndUseTables.zip
▪ https://www.energycodes.gov/commercial-energy-cost-savings-analysis
10. Include a table similar to the example below. For “code value” ensure that the value incorporates any improved efficiency per requirements of Section C406.1 of the Massachusetts’ amendments.
Measure/Area Base Code Proposed % Change Comment
AC Efficiency (EER) Bldg 1 code value design value % Bldg 2 code value design value %
ERV Effectiveness (%)
Bldg 1 code value design value % Bldg 2 code value design value % Boiler (% efficiency)
Bldg 1 code value design value %
Bldg 2 code value design value % LPD (Watts/sq ft)
Bldg 1 code value design value %
Bldg 2 code value design value % (continue to include service water, equipment, etc)
Sincerely,
Paul F. Ormond, P.E. Energy Efficiency Engineer Massachusetts Department of Energy Resources
Page 10 of 11
1234 and 1240 Soldiers Field Road, Boston, MA, EEA #16272 Boston MA
Brendan Place Clean Energy Engineer Massachusetts Department of Energy Resource
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October 20, 2020 Secretary Kathleen A. Theoharides Executive Office of Energy and Environmental Affairs Attn: Erin Flaherty, MEPA Office 100 Cambridge Street, Suite 900 Boston, Massachusetts 02114 Re: EOEEA #16272 1234 and 1240 Soldiers Field Road ENF
Dear Secretary Theoharides: The Department of Conservation and Recreation (“DCR” or “Department”) is pleased to submit the following comments in response to the Environmental Notification Form (“ENF”) submitted by Epsilon Associates on behalf of The Davis Companies (the “Proponent”) for the 1234 and 1240 Soldiers Field Road project (the “Project”). As described in the ENF, the project comprises two components. The 1240 Site will be redeveloped with a new residential building containing approximately 535 rental residential units, retail space, and an enclosed garage. The 1234 Site will be redeveloped with a residential building containing approximately 120 residential condominiums, a hotel building with approximately 225 hotel rooms, retail space, and a shared underground garage below both buildings. The Project is located off Soldiers Field Road, which is under DCR jurisdiction. DCR is also responsible for management of the adjacent Charles River Reservation. The Charles River Reservation is an important recreational resource for pedestrian and bicycle users and provides access to canoe and kayak boat launching facilities. The ENF states that a DCR Construction and Access Permit will be required for the Project. The Project will require the filing of an Environmental Impact Report (“EIR”). DCR is pleased to submit the following comments on the Project: Transportation Along Soldiers Field Road, the number of the Project Site’s curb-cuts will be reduced from two curb-cuts, which total approximately 80 feet, to one curb-cut, which will be approximately 24 feet wide. Consequently, approximately 55 more linear feet of sidewalk will be created that does not traverse a curb- cut. A new private Site Drive, open to public travel, will be created between Western Avenue and Soldiers Field Road, providing access and egress to the Project’s parking facilities and loading dock areas. The location and direction of this Site Drive largely mirrors an existing vehicular passageway on the 1234 Soldiers Field Road site. Drop-off / pick-up activity will also occur along the Site Drive serving taxicabs and transportation network company (“TNC”) vehicles, such as Uber and Lyft. A new pedestrian path, open to public travel, will be created to connect the southern end of the new Telford Street Bridge to Western Avenue. This public access, as well as the right, but not the obligation, for DCR to maintain the pedestrian path and the southern ramp, will be secured by the grant of an easement from the Proponent to DCR.
COMMONWEALTH OF MASSACHUSETTS · EXECUTIVE OFFICE OF ENERGY & ENVIRONMENTAL AFFAIRS Department of Conservation and Recreation Charles D. Baker Kathleen A. Theoharides, Secretary, 251 Causeway Street, Suite 600 Governor Executive Office of Energy & Environmental Affairs Boston MA 02114-2119 617-626-1250 617-626-1351 Fax Karyn E. Polito Jim Montgomery, Commissioner www.mass.gov/orgs/department-of-conservation-recreation Lt. Governor Department of Conservation & Recreation
EEA #16272 ENF Page 2 of 3
The Proponent is committed to implementing Transportation Demand Management measures to reduce residents’ dependence on automobiles. TDM measures to be undertaken by the Proponent include promoting transit services in marketing and orientation materials, providing adequate secure bicycle storage, joining the Allston Transportation Management Association (“TMA”), and designating an on-site transportation coordinator. DCR reviewed the traffic and pedestrian aspects of the Project. Additional information provided in the DEIR will facilitate DCR’s assessment of traffic impacts to the Parkway: • DCR requests Automatic Traffic Recorder Counts to estimate traffic volumes on the parkway mainline. • DCR requests a section assessing the effects of Covid-19 on travel: explaining how the horizon year was determined, taking telework and changes in mode shift and time shift into account. • DCR requests clarification of the traffic data in relation to the given timeframes. Counts were taken in April 2019, but the Existing Conditions year was “set” to 2020. It is unclear if any growth was applied between 2019 and 2020. • DCR requests an additional calculation for net new trips, using existing trips directly measured with driveway counts. • DCR requests clarification on the calculated split between private and TNC vehicles. • DCR requests additional information related to the proposed changes to Everett Street to clarify how the new geometries are considered in the No Build and Build capacity analyses.
Charles River Reservation – Bicycle and Pedestrian Connections Extending from the Project’s central open space is a prominent organizational driver of the Project: the improvement of an elevated pedestrian connection for the public across Soldiers Field Road with the replacement of the existing DCR-owned Telford Street pedestrian bridge. This is a key pedestrian corridor from the Allston neighborhood to the Charles River Reservation, including nearby Artesani Playground and Herter Park. The Proponent proposes to construct, own, and maintain, as part of the 1240 Component, a new, universally accessible south ramp to/from Telford Street, as well as stairs leading to Soldiers Field Road. DCR will construct, own, and maintain the main span and north ramp of the replacement pedestrian bridge. The Proponent’s construction work will require approval from DCR, as owner of the current Telford Street pedestrian bridge and Soldiers Field Road, via a DCR Construction and Access Permit. The Proponent has engaged in early discussions with DCR regarding the design and construction of the proposed new bridge connections. DCR looks forward to coordinating with the Proponent on aspects of the project envisioned in the Charles River Basin Connectivity Study. DCR notes that the Project proposes a new pedestrian ramp to the Telford Bridge. DCR appreciates the proposal to provide a BLUEbikes station on site. Addition of bicycle pumps and other bike maintenance features would benefit bicycle use of Herter Park and the Paul Dudley White Bike Path. DCR will coordinate with the Proponent on a MOA to cover funding, establishment of public easements, and maintenance considerations for bicycle and pedestrian improvements associated with the Project.
EEA #16272 ENF Page 3 of 3
Article 97 Land Disposition While design decisions between DCR and the Proponent are not final, the Project may trigger an Article 97 disposition if the south ramp of the new pedestrian bridge is placed in the same location as the existing south ramp or if the Proponent otherwise incorporates the area of the existing south ramp footing into the design of the Project. In 1967, DCR’s predecessor agency, Metropolitan District Commission (“MDC”), by eminent domain, acquired the fee interest in 1,896+/- square feet of land adjacent to Telford Street for the south ramp of the existing Telford Street pedestrian bridge. If a disposition of the parcel, or an interest in the parcel, on which the south ramp footing currently is located is required, the Proponent must obtain authorization from the General Court. Transfers of interests in state conservation property must meet the requirements set forth in the Executive Office of Energy and Environmental Affairs (“EEA”) Article 97 Land Disposition Policy (the “Policy”). The Policy has the stated goal of ensuring no net loss of Article 97 lands under the ownership and control of the Commonwealth, and states as a general premise that EEA and its agencies shall not sell, transfer, or otherwise dispose of any right or interest in Article 97 lands. Transfer of ownership or interests therein may occur only under exceptional circumstances, as defined in the Policy, including the determination that no feasible alternative is available, and a minimum amount of land or an interest therein is being disposed for the proposed use. Transfer also requires authorization by the Massachusetts Legislature through a two-thirds supermajority roll-call vote. DCR will not issue a Construction and Access Permit that effectuates a change of use, involves a disposition of an interest or installation of private infrastructure in DCR property until at least that time that Article 97 legislation has been enacted.
Thank you for the opportunity to comment on the ENF. Questions related to transportation can be directed to Jason Santos at [email protected]. Questions regarding pedestrian and bicycle connections can be directed to Ginna Johnson at [email protected]. Please contact the Director of Construction & Access Permitting, Sean Casey at [email protected] regarding the required DCR Construction and Access Permit. Questions regarding Article 97 can be directed to Jennifer Howard at [email protected].
Sincerely,
Jim Montgomery Commissioner
cc: Patrice Kish, Priscilla Geigis, Tom LaRosa, Jeff Parenti, Jason Santos, Ginna Johnson (DCR)