16343 Enf Boynton Gateway Somerville.Pdf

The Commonwealth of Massachusetts Executive Office of Energy and Environmental Affairs 100 Cambridge Street, Suite 900

Boston, MA 02114

Charles D. Baker GOVERNOR

Karyn E. Polito LIEUTENANT GOVERNOR Tel: (617) 626-1000 Kathleen A. Theoharides Fax: (617) 626-1181 SECRETARY http://www.mass.gov/eea

April 23, 2021

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

PROJECT NAME : Boynton Gateway PROJECT MUNICIPALITY : Somerville PROJECT WATERSHED : Charles River EEA NUMBER : 16343 PROJECT PROPONENT : Boynton Gateway Owner LLC DATE NOTICED IN MONITOR : March 24, 2021

Pursuant to the Massachusetts Environmental Policy Act (MEPA; M.G. L. c. 30, ss. 61- 62I) and Section 11.06 of the MEPA regulations (301 CMR 11.00), I hereby determine that this project does not require the preparation of an Environmental Impact Report (EIR).

Project Description

As described in the Environmental Notification Form (ENF), the project consists of the construction of approximately 339,000 square feet (sf) of commercial development including 136,400 sf of lab uses, 201,600 sf of office/research and development (R&D) uses, and 1,000 sf of tenant-space retail amenity1. The project will increase the parking supply on site by 150

1 The ENF contained discrepancies regarding the description of the retail space. Specifically, it was described as both a tenant accessory (and accounted for in the general office land use when calculating trip generation) and as general accessory retail to encourage a vibrant and active pedestrian environment. An email from the Proponent’ consultant sent to the MEPA Office and Massachusetts Department of Transportation (MassDOT) on April 15, 2021 clarified the retail space will be a tenant focused amenity without its own dedicated storefront. This clarification is discussed in greater detail in the Traffic Section of the Certificate.

EEA# 16343 ENF Certificate April 23, 2021 spaces, resulting in 200 parking spaces provided in a parking structure under the proposed building.

The development program includes two distinct parts of the building. In the northwest corner of the project site fronting on both Webster Avenue and Columbia Street, the mid-rise portion of the building will reach a maximum height of four stories that resembles the height of the current low-rise and mid-rise buildings to the south and west. In the east and south of the project site the high-rise portion of the building will reach a maximum height of 12 occupiable stories and will be set back from Webster Avenue and the 80 Webster Avenue 46-unit Condominium property. The first floor of the building will house lab, lab support, tenant focused retail, arts/creative enterprise uses, and lobby areas. Floors 2-12 will include office/R&D/lab uses, and tenant amenity space. There will be two levels of below-grade parking beneath the building. Access to the structured parking will be provided from Beach Avenue, internal to the project site, which will connect with Webster Avenue to provide access and egress for passenger vehicles and with Columbia Street to provide egress for service and loading vehicles only.

The project will provide approximately 2,500 sf of public open space, including a landscaped courtyard that will serve as a publicly accessible open space and a buffer between the project building program and the abutting 80 Webster Avenue 46-unit Condominium property. The open space will useable exterior space for the building’s tenants as well as the residents of 80 Webster Avenue and the public. The publicly accessible courtyard will be accessed from Beach Avenue.

Project Site

The project site consists of approximately 1.15 acres of land bounded by Columbia Street to the north and east, Beach Avenue and an existing parking garage to the south, and Webster Avenue and an existing residential building (80 Webster Avenue) to the west. The project is located at 495 Columbia Street.

The project site is located on former railroad land owned by the Massachusetts Bay Transportation Authority (MBTA). The site is entirely covered by impervious area and includes seven one-story buildings including 20,200 sf of auto repair uses, a 10,700-sf moving/storage facility, and surface parking. A part of the site is comprised of landlocked tidelands. The site also contains the O’Neill, J.P. Coal Company Truck Garage, included in the Inventory of Historical and Archaeological Assets of the Commonwealth (Inventory) located in the northwestern corner of the site. According to the ENF, the building has been significantly modified and no longer retains significance as a historic building.

The project site is located within two different zoning districts. Approximately 0.77 acres of the project site is located within the High-Rise (HR) District and approximately 0.38 acres of the project site are located within the Mid-Rise 5 (MR5) District. The project will be constructed and operated as one building with shared mechanical systems. However, for the purposes of local zoning, the project will be located on two legal building lots with zero lot lines in which the structure comes up to the edge of the property line. The massing of the building will comply with the dimensional standards within each respective zoning district.

Environmental Impacts and Mitigation

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Potential environmental impacts of the project include generation of 2,994 average daily trips (adt); construction of 150 new parking spaces (200 spaces total); use of approximately 48,317 gallons per day (gpd) of water; and generation of approximately 43,925 gpd of wastewater.

The project will minimize and mitigate transportation-related impacts through implementation of Transportation Demand Management (TDM) measures such as encouraging use of public transit and other alternate modes of travel. It will provide approximately 2,500 sf of public open space and a new streetscape with improved bicycle and pedestrian facilities. The project design includes a stormwater management system with Best Management Practices (BMPs) to improve water quality, reduce flow rates and infiltrate stormwater. The project will employ measures to conserve water and contribute to Infiltration/Inflow (I/I) reduction to preserve sewer capacity.

Permitting and Jurisdiction

The project is undergoing MEPA review and preparation of an ENF pursuant to Section 11.03(6)(b)(13) of the MEPA regulations because it requires State Agency Actions and will generate 2,000 or more new adt on roadways providing access to a single location. The project requires an approval from the Massachusetts Department of Transportation (MassDOT) pursuant to MGL c. 40 s.54A for the use of land formerly used as a railroad right-of-way (ROW). It also requires a Temporary Construction Dewatering Permit and a Sewer Use Discharge Permit from the Massachusetts Water Resources Authority (MWRA).

The project requires Master Plan Special Permit and Site Plan Approval by the Somerville Planning Board and a National Pollutant Discharge Elimination System (NPDES) Stormwater General Permit from the United States Environmental Protection Agency (EPA). It may require a determination of no hazard to air navigation related to construction cranes from the Federal Aviation Administration (FAA).

Because the Proponent is not seeking Financial Assistance from the Commonwealth for the project, MEPA jurisdiction extends to those aspects of the project that are within the subject matter of required or potentially required State Agency Actions and that may cause Damage to the Environment as defined in the MEPA regulations.

Review of the ENF

The ENF described existing site conditions, provided a basic project description and conceptual plans and reviewed alternatives to the project. It identified the project’s impacts on transportation, water and wastewater infrastructure, stormwater, and identified potential measures to mitigate these impacts. The ENF included a limited a Transportation Impact Assessment (TIA).

Alternatives Analysis

The ENF included a comparison of the Preferred Alternative to a No Build Alternative and an Increased Build Alternative. The No Build alternative would continue existing conditions

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and uses and the current level of trip generation, water use and wastewater generation, which are lower than either of the build alternatives.

The proposed build-out under the Increased Build Alternative would be constructed within the same building footprint as the proposed project; however, the maximum occupiable building height would increase by approximately 45 feet (three additional floors) for a total of 227 feet to the top of the structural roof. The layout and footprint of the buildings would be similar to the Preferred Alternative but would mainly consist of office space with limited lab space. Similar to the Preferred Alternative, this Increased Build Alternative assumes that a Special Permit will be required to take advantage of unlimited building height of the superseding overlay zoning within the Boynton Yards Master Planned District. It would offer similar open space and streetscape improvements as proposed in the Preferred Alternative, but would have greater impacts, including 455 parking spaces and generation of 4,058 adt. The Zoning Ordinance would permit the Increased Build Alternative to provide up to 455 parking spaces. This increased parking would result in increased traffic impacts, and does not support the City’s vision of the neighborhood poised to become a transit-oriented district. In contrast, the Preferred Alternative will be providing a lower than typical parking ratio for the office/R&D/lab tenants, resulting in only 200 proposed parking spaces. The Increased Build Alternative was dismissed because of the increased environmental impacts, and the fact that the current market does not have demand for this increase in office space.

According to the ENF, the Preferred Alternative meets the City’s planning goals articulated in the Union Square Neighborhood Plan (USNP), which envisions approximately 4.25 million sf of commercial space and increased open space.

Land

The ENF summarized the City’s planning efforts for the Union Square neighborhood, including the project site, which is within the Boynton Yards sub-neighborhood of Union Square. The City’s SomerVision Comprehensive Plan was completed in 2012. It identifies Union Square as one of several growth districts in the City where transit-oriented mixed-use development would provide opportunities for economic development. The project site is located within the Union Square Urban Revitalization Plan (URP) area established in 2012. The URP was reviewed by MEPA in an ENF submitted in 2013 (EEA# 15032). In a Certificate issued on April 19, 2013, the Secretary determined that the URP did not require additional MEPA review and that individual development projects within the URP area may require MEPA review.

The entire 1.15 acres site is currently covered by impervious surfaces. The project will provide approximately 2,500 sf of public open space.

Traffic and Transportation

According to comments from MassDOT the ENF included a limited a Transportation Impact Assessment (TIA) generally consistent with the MassDOT/EEA Transportation Impact Assessment Guidelines. The TIA adequately discusses the transportation impacts of the project and includes a comprehensive multimodal mitigation program to address the Project’s impacts.

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The ENF included a trip generation estimate and identified the number of parking spaces to be provided. It included a description of existing and proposed multimodal accommodations, roadways and intersections studied, mode share and trip distribution.

Trip Generation

According to information in the ENF, the Project is expected to generate 2,994 net new unadjusted vehicle trips per day and 886 net new adjusted vehicle trips per day. This is based on application of the Institute of Transportation Engineers (ITE) Trip Generation Manual (10th Edition) Land Use Codes (LUCs) 710 – General Office and 760 – R&D Center. The trip generation calculations in the ENF omit LUC 820 – Shopping Center for the retail portion of the development. The ENF contained discrepancies regarding the description of the retail space. Specifically, it was described as both a tenant accessory and accounted for in the general office LUC when calculating trip generation and also described as general accessory retail to encourage a vibrant and active pedestrian environment in the ENF. If the retail space was considered as general accessory retail and LUC 820 – Shopping Center had been applied to the 1,000 sf retail component, the project is estimated to generate in excess of 3,000 unadjusted vehicle trips on an average weekday which would require the preparation of an EIR.

The Proponent’s consultant provided supplemental information after the close of the comment period which clarified that retail space will only be a tenant-space retail amenity. According to this supplemental information, the retail space will be a tenant focused amenity that is integrated into the lobby with no external dedicated storefront. MassDOT provided an amended comment that confirms the project will not exceed a mandatory EIR threshold if the proposed retail space is designed as a tenant-space amenity and is not generally accessible to the public. The Proponent should submit the local land use approvals to MassDOT and the MEPA Office to confirm the final use of the retail space. Additionally, the Proponent is required to submit a Notice of Project Change (NPC) should the building program materially change from what was presented during MEPA review.

The ENF also includes an adjusted trip generation that reflects mode share. The mode share estimates are based on U.S. Census data for the census tract in which the project is located. The mode share used for the project is as follows: 38 percent personal vehicle, two percent taxi, 30 percent transit, 14 percent bicycle, and 16 percent walk. These adjustments result in a trip generation of 1,364 vehicle trips on an average weekday, including 114 vehicle trips during the weekday morning peak hour and 116 vehicle trips during the weekday evening peak hour.

The site currently contains six auto repair facilities (20,200 sf) and a 10,700-sf moving/storage facility, all of which are still in operation. To estimate trips generated by the existing uses, the Proponent used ITE trip rates for LUCs 151 – Mini-Warehouse and 942 – Automobile Care Center. Given that the existing land uses are auto-oriented, no mode share reduction was applied. Subtracting the existing trip generation from the proposed project adjusted trip generation results in 874 net new vehicle trips on an average weekday, including 70 vehicle trips during the weekday morning peak hour and 54 vehicle trips during the weekday evening peak hour.

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Multimodal Facilities

The ENF describes improvements to sidewalks along the project frontages. Beach Avenue is currently a historic access easement owned almost entirely by the Proponent and will be improved as part of the project. Beach Avenue will run east-west through the project site and will be transformed into a curbless drive to accommodate all modes of transportation, and provide vehicular access to the parking garage, service, and loading. Along Beach Avenue, two- way travel will be allowed at the Webster Avenue side of the drive, which will be used as the passenger vehicle entrance and exit. Beyond the parking garage entrance on Beach Avenue and continuing to Columbia Street, the Beach Avenue circulation will change to one-way to allow service and loading vehicles to exit the project site.

The pedestrian improvements on Beach Avenue will continue along the Webster Avenue project frontage and the frontage of the 80 Webster Avenue apartment building. The proposed public realm along Webster Avenue will be 14 feet wide. Where Webster Avenue intersects Beach Avenue the Proponent will construct a pedestrian prioritized flush driveway providing vehicular and pedestrian access to Beach Avenue. At the intersection of Webster Avenue and Columbia Avenue the Proponent will construct new curb ramps and a crosswalk.

Along Columbia Street the Proponent will construct 18-foot sidewalks with new curbs, furnishing zones, and concrete pedestrian zones. At the northeastern corner of the project side, along Columbia Street there will be a building entrance with an expanded hardscape plaza. Where Columbia Street intersects Beach Avenue, the Proponent will construct a pedestrian prioritized flush driveway providing vehicular access to the loading dock.

The site design also includes a pedestrian pathway located between the project site and 80 Webster Avenue, extending north-south from Beach Avenue to an alleyway between the project site and the existing parking garage.

Public Transportation

The project is located within one-half mile of the upcoming Union Square MBTA Green Line Station. The station will open as part of the Green Line Extension (GLX) project planned for completion in December 2021. Several MBTA bus routes stop in the vicinity of the project site including routes 69, 85, 86, 87, 88, 91, and CT2. As requested by MassDOT, the ENF includes a transit analysis compliant with the MBTA’s Office of Performance Management and Innovation’s (OPMI) methodology for calculating the existing, future No- Build, and future Build comfort metrics (as evaluated in the Service Delivery Policy [SDP]) for each bus route within the project study area. According to the transit analysis, two bus routes, Route 85 and Route 88, are expecting to experience overcrowding as a result of background development and the additional ridership associated with the Project within the study area. Some of these proposed developments, more specifically the Boynton Yards and the US 2 Development are expected to provide comprehensive mitigation to address transit impacts in the study area. When considered without the background development projects, this project alone is expected to have minimal impacts to current transit operations. Notwithstanding, the Proponent has committed to provide the City of Somerville with transit funding to implement transit improvements in the vicinity of the project.

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Parking

The ENF describes a proposed parking supply of 200 spaces. Given the project’s 339,000 sf program, a ratio of approximately 0.6 parking spaces per 1,000 sf of built space is planned. Since motor vehicle parking has been identified as the most important factor in determining automobile mode share in new development, the City supports all efforts to minimize new parking supply.

Comments from the City of Sommerville note that new off-street parking is prohibited from being designated as “accessory” to a primary land use; rather, the City requires new garage facilities to function as public garages offering hourly, daily, weekly and monthly parking at market rates. The intent of this “unbundling” practice is to discourage new tenant employees from driving to work. The details of garage pricing and operations will be reviewed and conditioned in local zoning via the project’s Mobility Management Plan with the City.

The ENF notes that the Project will provide preferred parking for electric vehicles and fuel efficient vehicles. The Proponent should work with the City to plan and install the maximum number of electric vehicle charging stations in the project’s proposed garage to help catalyze regional electrification of the passenger vehicle fleet.

Transportation Demand Management

The Proponent has committed to implementing a comprehensive TDM program to reduce single occupancy vehicle (SOV) trip generation and increase mode share in the study area of the project. The ENF identifies a number of TDM programs to be implemented as part of the project. These programs are generally regrouped under five themes: • Alternative mode benefits; • Bicycle/Pedestrian trips; • Public Transportation; • Ride sharing; and, • Parking Strategies.

Specific elements of these programs to be implemented by the Proponent include: • Provision of covered/secured bicycle parking spaces; • Provision of short-term bicycle parking spaces; • Designate a transportation coordinator for the project to coordinate the elements of the TDM programs; • Post information regarding public transportation services, maps, schedules, and fare information in a central location and/or otherwise made available to residents; • Provide a “welcome packet” to residents detailing available public transportation services, bicycle and walking alternatives, and commuter options available; • On-site transit pass sales; • Guaranteed Ride Home; • Shuttle Bus Service; • Unbundle parking; and • Parking spaces reserved for carsharing services.

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Comments from MassDOT conclude that the proposed mitigation program will adequately address the impacts of the project.

Stormwater

The project will reduce impervious area from 1.15 acres under existing conditions to 1.02 acres by converting impervious area to landscaped open space. The project includes the construction of a separated drainage system that will eliminate illicit sanitary connections According to the ENF, the stormwater management system will meet the Massachusetts Department of Environmental Protection’s (MassDEP) Stormwater Management Standards (SMS). Runoff from the project site will be collected in a new stormwater management system with BMPs, including deep sump catch basins, that will improve water quality and lower peak flows prior to discharge into the City’s combined sewer in Columbia Street..

Water and Wastewater

The project will use 51,370 gpd (48,317gpd net new) of water and generate 46,700 gpd (43,925 gpd net new) of wastewater. The ENF describes the existing and proposed water and sewer collection systems. The project site and surrounding area is served by City of Somerville separate sanitary sewers and combined sewers primarily located in Webster Avenue and Columbia Street. Most sanitary flow generated in the area is conveyed to the municipal sanitary sewers. Stormwater generated in the area is collected by the municipal combined sewers, which also collect sanitary flows at remaining sanitary connections.

According to the MWRA, both the sanitary sewers and the combined sewers tie into a series of larger municipal combined sewers starting at the intersection of Webster Avenue and Columbia Street and eventually connecting to MWRA’s Cambridge Branch Sewer at Somerville Avenue and Poplar Street. The Cambridge Branch Sewer conveys combined sanitary and stormwater flows from parts of Cambridge and Somerville, as well as sanitary flows from parts of the City of Medford, to MWRA’s DeLauri Pumping Station in Charlestown. From there flows are pumped into MWRA’s North Metropolitan Sewer System for transport to the Deer Island Treatment Plant. In large storms, stormwater flows to MWRA’s Cambridge Branch Sewer can contribute to combined sewer overflows (CSO) at MWRA’s Prison Point CSO treatment facility, which discharges to the Upper Inner Harbor, and to untreated CSO discharges at outfalls on the Charles River Basin and the tidal waters of the Mystic River.

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 combined sewer overflows (CSOs), such as Somerville, 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 City to identify appropriate I/I mitigation for this project. As noted by the MWRA, groundwater discharges into the sanitary system are prohibited. Comments from the MWRA indicate that the MWRA will rely on the City of Somerville to provide information supporting full I/I mitigation for this project and other projects in the planned Boynton Yards and Union Square development areas.

A Sewer Use Discharge Permit is required prior to discharging process wastewater, laboratory wastewater or photo processing wastewater from office, high-tech, R&D, laboratory

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or commercial space associated with the project into the MWRA sanitary sewer system. Although not indicated in the ENF, due to the proximity of MWRA infrastructure to the project site, an 8(m) permit may be required from the MWRA. 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 its infrastructure.

Public Benefit Determination

The project site is comprised of tidelands subject to the provisions of An Act Relative to Licensing Requirements for Certain Tidelands (2007 Mass. Acts ch. 168) and the Public Benefit Determination regulations (301 CMR 13.00). According to the ENF, the project will provide the following public benefits:

• 2,500 sf of publicly accessible open space; • Bicycle and pedestrian facilities within and adjacent to the project site; • Stormwater management measures to improve water quality; • Upgrades to public drainage and sewer infrastructure; • Energy-efficient residential units and office/lab/R&D space; • Project design that is resilient to climate change; and, • Enhancement of an underutilized parcel.

Because the project is not subject to an EIR, I am declining to conduct a Public Benefits Review.

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 greenhouse gas emissions (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 GHG emissions, and effects, such as predicted sea level rise, when issuing permits, licenses and other administrative approvals and decisions. M.G.L. c. 30, § 61.

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 Charles River Basin is projected to rise by 3.5 to 10.7 degrees Fahrenheit (F),

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including an increase in the number of days with temperatures over 90 F from 15 to up to 76days compared to the 1971-2000 baseline period. During the same time span, the average annual precipitation is projected to increase by 0.7 to 8.2 inches, which may be associated with more frequent and more intense storms. The City’s Climate Change Vulnerability Assessment dated June 2017 identifies the site as being in an area potentially vulnerable to increased flooding from rainfall events and high outdoor heat exposure.

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.

According to the ENF, the project will be designed to be resilient to climate change and help the City achieve its goal of carbon neutrality by 2050. The ENF indicated that the project will mitigate heat island effects by converting impervious area to landscaped open space. Improvements to the drainage system will improve the quality of runoff leaving the site and be designed to accommodate future storm events. The buildings will be designed with energy efficient heating and cooling systems and building envelopes to minimize energy use and keep occupants comfortable under extreme heat conditions.

I advise the Proponent to include design elements that will be designed to minimize impacts associated with sea level rise, more frequent and intense storms and extreme heat waves including, but not limited to:

• 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; and, • Protection of emergency generator fuel supplies from effects of extreme weather and flood-proofing.

Greenhouse Gas (GHG) Emissions

The project is not subject to the MEPA GHG Policy because an EIR is not required. The MEPA GHG Policy requires projects to quantify carbon dioxide (CO2) emissions and identify measures to avoid, minimize or mitigate such emissions. However, the ENF does describe the project’s overall conceptual approach to building performance and sustainability. The project will trigger local City zoning requirement to be LEED Platinum certifiable. Local zoning requirements in the City’s Master Planned Development (MPD) Overlay District set higher sustainability standards for non-laboratory buildings. While this project is designed with some lab uses, the majority of the square footage is programmed for non-lab uses. Non-laboratory buildings in the MPD Overlay District must meet the following standards in zoning: • No on-site combustion for HVAC system operation;

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• No on-site combustion for cooking equipment, excluding Eating & Drinking Establishment principal uses; and, • Be certifiable as Zero Carbon or higher from the International Living Future Institute; or PHIUS+ from the Passive House Institute U.S.

For non-laboratory uses, the ENF states that the project design is expected to maximize electrification where possible to reduce emissions as much as possible. Comments from the City indicate that the City will be looking for partial electrification proposals and more details in the Development Review Applications.

In Master Planned Development Districts, all new principal building types must include a green roof, photovoltaic (PV) devices, or both for 100% of the roof area not occupied by building systems equipment or required outdoor amenity spaces. Comments from the Department of Energy Resources (DOER) provide a detailed scenario for strategies for the project to reduce GHG emissions, improve resiliency, and affordability. Specifically, I encourage the Proponent to consider the following design measures: • Building design and construction practices that result in low heating and cooling thermal energy demand intensity (heating and cooling “TEDI”) by: o Maintaining envelope integrity with framed, insulated walls with continuous insulation; o Thermally-broken windows and other components to eliminate thermal bridges; o Minimizing glass curtain wall assemblies and excessive windows; o Low air-infiltration, confirmed with in-building air-infiltration testing; o Energy recovery; and, o Management of solar heat gains. • Efficient electrification of space heating, including: o For highly ventilated lab office (including speculative core-and-shell developments): low temperature, hydronic space heating with heat-input provided by hybrid, in-building, central plant consisting of air-to-water heat pump (primary) and gas boilers (secondary); • Efficient electrification of water heating, where feasible; • Extensive rooftop solar-readiness; and, • Electric vehicle ready parking spaces.

Comments from DOER estimate that incorporating the above measures together will deliver 50 to 80% less emissions than projects built to Code while improving affordability and resilience. In addition, significant incentives may be available including MassSave® incentives, Alternative Energy Credits (AECs), and Solar Massachusetts Renewable Target (SMART) credits.

Mixed use lab/R&D/office buildings typically have high ventilation loads which may have made electrification of space heating a challenge in the past, particularly with a speculative core/shell project. However, DOER’s comments indicate recently there are designs for highly- ventilated, speculative core and shell lab/office projects that are pursuing pathways to partially electrify space heating for these types of projects. The approach uses an in-building, centrally located, hybrid heating plant consisting of air to water heat pumps and gas equipment in which the air source heat pump can provide 80-90% total annual space heating end use.

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I remind the Proponent that 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 including C402.1.5 (envelope), C405.3 and C405.4 (lighting), C405.10 (EV charging), and C406 (three additional efficiency measures).

Construction Period

The Proponent will require its construction contractors to use Ultra Low Sulfur Diesel fuel, and consider the use of after-engine emissions controls, such as oxidation catalysts or diesel particulate filters.

I encourage the Proponent to commit to C&D recycling activities as a sustainable measure for the project. Demolition of any structures must comply with the MassDEP Asbestos Regulations (310 CMR 7.15) that became effective on June 20, 2014. These regulations require a pre-demolition and post-abatement survey and inspection by a licensed asbestos monitor. The Proponent is reminded that any contaminated material encountered during construction must be managed in accordance with the MCP and with prior notification to MassDEP.

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.

Conclusion

The ENF has sufficiently defined the nature and general elements of the project for the purposes of MEPA review and demonstrated that the project’s environmental impacts will be avoided, minimized, and/or mitigated to the extent practicable. Based on information in the ENF and consultation with State Agencies, I find that no further MEPA review is required. However, I remind the Proponent that if the building program changes beyond what was presented to MEPA during the local permitting process, the Proponent will be required to submit a NPC.

April 23, 2021 ______Date Kathleen A. Theoharides

Comments received:

04/12/21 The Union Square Neighborhood Council Board 04/13/21 Board of Trustees and Residents of 80 Webster Ave 04/13/21 Massachusetts Department of Transportation (MassDOT) 04/13/21 City of Somerville 04/13/21 Massachusetts Water Resources Authority (MWRA) 04/15/21 Massachusetts Department of Transportation (MassDOT) 2nd Comment 04/21/21 Department of Energy Resources (DOER)

KAT/ACC/acc

12 April 12, 2021

Ref: EEA #16343

Secretary Kathleen A. Theoharides Executive Office of Energy & Environmental Affairs Attn. MEPA Office 100 Cambridge Street Suite 900 Boston, MA 02114

Re: Environmental Notification Form, Boynton Gateway, comment

Dear Secretary Theoharides;

The Union Square Neighborhood Council is a publicly elected representative body created in December 2017 dedicated to serving the Union Square community, addressing the neighborhood’s concerns, and advocating for the community members’ needs.

We, the Union Square Neighborhood Council (USNC) Board Members, appreciate the work the developer, CV Properties LLC, has done to complete the Environmental Notification Form (ENF) submitted to the EOEEA MEPA Division. Following thorough review of this document, we are submitting the following comments regarding the content and your anticipated Certificate.

Size of the Development

This proposal calls for a development that is simply too big for the piece of land squeezed between two heavily traveled roadways, Columbia Street and Webster Avenue. By trying to build to such volume and height the developer has left the adjacent community to ponder what life would be like dodging hundreds of new vehicles on their streets. Unfortunately, the developer barely mentions the residential abutters in its description of surrounding properties. One such abutter, 80 Webster Avenue (a 4-story condominium complex), will be less than 20 feet from the proposed 12-story high rise commercial building.

Accessibility to the New Union Square MBTA Green Line Station

Somerville planning documents dating from SomerVision 2030 through the Union Square Neighborhood Plan have stressed the importance of improved pedestrian access as the priority above all other modes of transit (with public transit immediately following in importance). Since walking and cycling are preferred in these documents, improvements for safe pedestrian access to and through intersections all around this project must be comprehensive and well thought out. Timing of walk signals must be adequate for all mobility-challenged pedestrians.

Traffic

The intersection of Prospect Street and Webster Avenue is one of the most congested and dangerous five-way intersections in the city of Somerville. Other intersections in the area also would be severely impacted by the additional vehicle trips generated by this new development. We feel that a study must be conducted to assess the traffic and safety implications of the proposed development with respect to each of these intersections. Windsor Place and Webster Avenue comes to mind. So do the following: Warren and Medford Streets, and Medford and South Streets. Many of these intersections fail during morning and afternoon rush hours. As this development proceeds, each phase must be studied to determine if the additional vehicular traffic causes already-failing- intersections to trigger a cascade of new failing intersections.

It is not clear what “planned or potential development” is included in the background condition that will form the basis of the traffic analysis. Other proposed developments in the immediate area must be considered in the background condition and factored in (e.g. Union Square, Boynton Yards, and the Gateway Innovation Center project). And, if the development does not proceed in the proposed timeframe and the background conditions change, the proponent’s plans should be re-evaluated. In that eventuality a lower density alternative should be seriously considered.

Somerville has established a Vision Zero goals/action plan. CV Properties LLC must do its part to insure that the city achieves this goal for safety on our streets. We strongly believe that CV Properties LLC should partner with other major commercial developers in the Boynton, Union Square and Union Square East area to subsidize a shuttle service to the Red Line station in Kendall Square. Convenient transportation to the Kendall Square destination is necessitated by the anticipated abundance of life science tenants in the proposed building. Transportation

Mode share projections need to be adjusted from those used by the developer, even though they may be the same as those used in the Union Square Neighborhood Plan (USNP) (“somewhat modified”). Since the USNP was completed, Somerville has adopted a climate control commitment to be carbon zero by 2050. Achieving that objective will require a significant decrease in vehicle emissions.

The developer’s plan for mode share measurements refers to “adjusted vehicle trips that takes into account shared intersection capacity, mode share, and pass-by-trips.” The developer needs to say how much each factor contributes to this determination. Absent this specification, how are we to assess the accuracy of the measurements?

To fulfill the Green Line Extension’s role in decreasing vehicle use through Union Square, transit must be a much larger proportion of mode share if the GLX is to have any significant environmental mitigation impact. As with the accessibility issues, achieving this goal will require improved cooperation between the City of Somerville, MassDOT, the MBTA, and residents. Ultimately, we should be aspiring to a transit alternative that contains up to 60% transit share and 15% auto share. It is the only option that will allow Somerville to have a sustainable future, which requires mitigating the impact of cars in the city.

We can do better than a modal split of 20% for transit use. Instead of waiting for this dismal number to become part of the future of Union Square, the developer must aim higher…to at least 30-40%. We do not need to wait for traffic counts to spell out what we already know, which is that gridlock will get worse and air pollution will dramatically increase.

Achieving 40% transit use would require the MBTA to significantly improve their transit service and provide necessary increased capacity to the Green Line Extension. Such improvements are necessary to absorb new trips generated by the planned development, whereas the roads cannot bear additional vehicular traffic and are already far beyond capacity. MEPA requires an appropriate definition for Transit Oriented Development that sets a high bar. This requirement implies that public transit trips must at a bare minimum exceed vehicle trips. We feel that your office should develop guidelines to properly assess the capacity of mass transit in urban areas, especially in areas like Union Square where there is quite literally no room for additional vehicles. In the past, Green Line trolley service was nine times more frequent than what is provided by current rush-hour schedules.

Parking Transportation around this project must depend much more on public transit via the new Union Square station than on additional vehicular travel which results in road congestion, pollution, and a need for new parking. CV Properties LLC intends to construct a parking garage that would accommodate over 200 off-street vehicles. They claim that the parking space to square footage ratio is “lower than that found in other comparable developments in the area.” We ask that the Certificate include a requirement to document this contention.

The developer should reduce the amount of parking to dis-incentivize car usage and take full advantage of the proximity of the site to the Union Square Green Line station now under construction. Furthermore, a high rate of shared vehicle uses should be considered. The most effective way to cut congestion and pollution is to make driving unappealing. Union Square already has some of the worst traffic congestion and pollution in the area. Taking extra cars off the road by limiting parking space would increase the well-being and the safety of all residents and visitors. We also recommend the addition of higher capacity charging stations for heavy duty vehicles in addition to those proposed for conventional electric vehicles.

Open Space Somerville is the densest city in New England. Neighborhoods with large concentrations of poor and working class families, like Union Square, face a deficit of publicly useable open space. SomerVision 2030 called for 30 acres of new open space in transformational zones like Union Square in order to make up for Somerville’s severe deficit in both passive and active open space. If large commercial developers in Union Square East, Boynton Yards, Union Square, Assembly Row, and the Inner Belt Industrial Area continue to do the minimum called for, Somerville will never reach SomerVision targets. The developer should be part of the solution for avoiding this dire projection. Increasing the size and configuration of the open space between the proposed development and the residential condominium complex adjacent to the property is absolutely essential if shadows, air circulation and other health-related issues are genuinely factored into the design of this project. Resiliency and Sustainability A commitment to green roofs and other design measures should be included to increase the project’s resiliency to the risk of adding to heat island effects. The developer states that it is increasing the amount of pervious area on the site. The Draft Environmental Impact Report must include an accurate accounting of this claim. The developers state that they “are contemplating a groundwater recharge system.” The Certificate should require that such a system be designed in conformity with the understanding that the proposed development lies within the area of the former site of the Millers River. Though water that once would have flowed through that riverbed now travels through an underground culvert, soil in the adjacent area remains seriously contaminated as a result of dumping of toxic materials into the river over a long period of time. Thus the recharge system being contemplated would have to isolate circulating water from such contaminated soil. Similarly, the proponent states that it will “store groundwater infiltrate to the extent feasible.” Instead, the Certificate should require that the proponent explain why they cannot recycle rainwater for irrigation throughout the development area. We in the USNC see our role being to motivate developers in our area to address the sorts of concerns indicated above. We hope and expect that your office will take these concerns into account in your consideration of the applicant’s ENF filing. Please do not hesitate to contact the Council Board with any questions.

Sincerely, The Union Square Neighborhood Council Board Ref: EEA #16343, the Boynton Gateway project

Secretary Kathleen A. Theoharides Execuve Oﬃce of Energy & Environmental Aﬀairs 100 Cambridge Street, Suite 900 Boston, MA 02114

Re: Public comment on the Boynton Gateway Environmental Noﬁcaon Form, case EEA #16343, of March 15, 2021 Dear Secretary Theoharides:

We are wring as residenal abuers to the Boynton Gateway project planned for 64 Webster Ave and 495 Columbia Street, on the block of Somerville south and west of Columbia Street and east of Webster Ave. We live in 80 Webster Ave, a 46-unit, 4-story condominium building immediately south of 64 Webster Ave and west of 495 Columbia Street. As a large group of Somerville residents adjacent to the Boynton Gateway project we risk considerable adverse impact from the project as conceived. The concerns described here are very widely shared among residents in our building and among neighbors as well. A general leer of concern regarding the Boynton Gateway project signed by a majority of the 80 Webster residents and owners can be found at hps://docs.google.com/document/d/1gO7ogbr_0oYbMbnuQy2-CrlQm_QZgtN7liLqGGacAvc/edit?usp= sharing.

Overall, we believe that the proposed Boynton Gateway project is far too large to be placed so close (within twenty feet, according to present plans) to a low-rise residenal building such as ours. As context, since our building’s compleon in 2009, new owners and residents have consistently understood that the properes around our building would be commercially redeveloped, but as mid-rise in keeping with the character of our block and the neighborhood immediately to the west, with our block serving as a mid-rise “transion” to the heart of Boynton Yards to the east, as indicated for example in drawings from the 2 016 Union Square Neighborhood Plan. Although many of our residents worked hard to follow the comprehensive Somerville rezoning process leading up to its 2019 passing, none of us were aware that one of the implicaons of the Boynton Yards overlay was to rezone the eastern half of our block for potenally unlimited height high-rise development (this feature of the rezoning is not at all apparent from the Somerville Zoning Atlas or its pre-adopon dras that were circulated during 2019 and before; one has to dig into the full Zoning Ordinance in order to discover this). We learned of this only in October 2019 when the Boynton Gateway project was ﬁrst publicly presented. Since then we have done extensive internal discussion among our building’s residents and owners, and with concerned neighbors. We believe that the concerns we describe here are already widely shared by Somerville residents in this neighborhood, and will be shared even more widely as awareness of the project grows.

Proposed scale beyond the largest buildings envisioned by the Union Square Neighborhood Plan. The new building proposed for 495 Columbia Street is proposed at 12 stories (190 feet) plus 40 feet of mechanicals on top. In contrast, the lab building parameters described in the Union Square Neighborhood Plan of 2016 (h ps://www.somervillebydesign.com/neighborhoods/union-square/) are described as “4–10 stories; 13–16 foot ﬂoor to ﬂoor avg.” Thus, the proposed Boynton Gateway project, which is a t the edge of Boynton Yards, w ould be larger than the largest proposed lab buildings for anywhere in the Union Square area, including Boynton Yards. Not only would a building of this scale itself create a burden on the neighborhood, it risks seng a precedent for even larger buildings closer to the heart of Boynton Yards. We are skepcal that this part of Somerville can handle development at this scale without fundamentally compromising the liveability of adjacent neighborhoods. As the residenal building abung Boynton Gateway, we are at ground zero of this potenal negave impact.

The impact of addional parking on the Boynton Gateway site. The project proposes 200 parking spaces underground (Secon 1.7.1), to be accessed via Beach Avenue oﬀ of Webster Ave (Figure 1.5, Secon 3.1.3.2, General Project Informaon page 3, and Secon 1.3). Webster Ave is already heavily congested on weekdays, especially at rush hours; its intersecons with Prospect Street and with Cambridge Street are already oen near gridlock. The underground parking would increase this congeson substanally, aﬀecng not only our building but also the enre neighborhood.

Risks from use of Beach Avenue access from Webster Avenue. From Webster Ave (between 80 Webster Ave and 64 Webster Ave), Beach Avenue is intended to provide vehicular access to the 200 spaces of underground parking, access to bicycle parking, and pedestrian access to the publicly accessible courtyard (Secon 1.4). At present, Beach Avenue has extremely lile vehicular traffic, so this plan would dramacally increase vehicular traffic at this intersecon. There are residenal units on the north side of our building with windows facing Beach Ave, which would suffer from air and noise polluon generated by vehicles entering and exing. Vehicular access for underground parking would also create risks to cyclists and pedestrians accessing bicycle parking, the courtyard, and the development itself. Furthermore, the sidewalk and bicycle lane crossing Beach Ave on the east side of Webster Ave are very heavily used (the bicycle lane is heavily used by commuters going between Union Square and Cambridge), and vehicular access would create risks to passing bicyclists and pedestrians, especially during rush hours. Entry and exit from Beach Ave would encourage aggressive, risky, and dangerous behavior by drivers. For example, it is extremely likely that drivers aempng to exit onto Webster Avenue during evening rush hour would come out into the bike lane in an aempt to get northbound traffic to stop so that they can turn onto Webster Ave, blocking the bike lane as they wait to get out onto the street and even potenally hing northbound cyclists.

The open space landscaped courtyard (secon 1.4). Although open space at the planned courtyard locaon will be welcome, its edge comes within several feet of windows to ﬁrst-ﬂoor units on the northern part of our building. Use by the general public will create privacy risks.

Safety for neighborhood residents. As proposed, the Boynton Gateway development will dramacally increase the amount of acvity around and aenon to our building and in the neighborhood. We are concerned that this acvity and aenon will present safety risks to neighborhood residents especially in non-daylight hours.

Hazards of laboratory materials so close to a residenal building. The large laboratory building proposed here presents potenal chemical and biohazard risks around it. These risks are magniﬁed by pung such a large laboratory building so close – within twenty feet! – of a residenal building.

Light and noise polluon. A ny large commercial building, and especially a lab building where there will be signiﬁcant nighme acvity, creates risks of noise and light polluon. Residents on the north and east sides of our building will be looking out their windows straight at a wall of commercial and lab usage, which is likely to be brightly lit at night, and will be subject to the noises of building acvity.

In summary, though we believe that appropriately scaled commercial development on the Boynton Gateway site can be salutary for the neighborhood and help Somerville achieve its broader goals of reduced residenal taxpayer burden, new jobs, non-vehicular commung (public transit, bicycles, walking), beer open space, and environmental sustainability, we do not believe that a project anywhere near the scale presently proposed for Boynton Gateway will help producvely achieve these goals. We would be glad to elaborate on these concerns in further communicaons; please do not hesitate to contact us.

Yours truly, Members of the Board of Trustees and Residents of 80 Webster Ave:

Roger Levy

Stephanie L. Smith Holger F. Siebrecht

Claudia Robaina Winston

Joyce Wu Jónas Oddur Jónasson

CITY OF SOMERVILLE, MASSACHUSETTS MAYOR’S OFFICE OF STRATEGIC PLANNING & COMMUNITY DEVELOPMENT JOSEPH A. CURTATONE MAYOR

GEORGE PROAKIS EXECUTIVE DIRECTOR

April 12, 2021

Secretary Kathleen Theoharides Executive Office of Energy and Environmental Affairs Attn: Anne Canaday 100 Cambridge Street, Suite 900 Boston, MA 02114

Dear Ms. Canaday,

Thank you for the opportunity to comment on the submitted Environmental Notification Form (ENF) for the proposed Boynton Gateway redevelopment project (EEA#16343), dated March 15, 2021 and published in the MEPA Environmental Monitor on March 24, 2021.

The Project as described in the ENF is broadly consistent with our community’s vision for equitable growth and low-carbon mobility in the Union Square district. The City’s adopted Comprehensive Plan, adopted Union Square Neighborhood Plan and local zoning all prioritize mixed-use transit-oriented development in the Boynton Yards district at a scale and intensity capable of supporting Somerville’s progressive agenda around affordable housing production, workforce development, open space creation, infrastructure modernization and tax base diversification.

This comment letter will focus on the specific elements of the ENF as follows:

Travel Mode Share

The ENF describes a Project planned for approximately 339,000 square feet of office / lab and accessory retail space. The ENF projects that approximately 900 workers would be associated with the new land uses.

The Project is described as aiming to leverage the robust mass transit ecosystem in Union Square, which is centered around high-frequency MBTA bus service using dedicated on-street transit infrastructure, combined with new MBTA Green Line light rail service. The ENF also references Somerville’s rapidly-expanding network of high-quality walking and biking

CITY HALL ● 93 HIGHLAND AVENUE ● SOMERVILLE, MASSACHUSETTS 02143 (617) 625-6600 EXT. 2500 ● TTY: (617) 666-0001 ● FAX: (617) 625-0722 www.somervillema.gov Page 2 of 6 infrastructure as a keystone of the Proponent’s planning to minimize the environmental impacts of new automobile traffic associated with the Project.

The Project is modelled at a non-automobile mode share of 60%, which reflects existing neighborhood journey-to-work data along with the strong and rapidly-improving multimodal transportation environment. The City applauds this mode share target, noting that the Somerville Comprehensive Plan establishes future non-automobile mode share targets for new development at 62.5% non-auto by 2030 and 75% non-auto by 2040. Monitoring of performance against these requirements will be handled through the Project’s Mobility Management Plan, which is an enforceable condition of local zoning entitlements.

Motor Vehicle Trip Generation

The ENF uses standard methodology to estimate likely motor vehicle trips generated by the Project. The Proponent projects 2,994 unadjusted daily weekday vehicle trips and 1,404 adjusted daily vehicle trips. Given the Project’s 339,000 square foot program, this rate translates to roughly 4.1 daily motor vehicle trips per 1,000 square feet of built space. The Project will be required to submit a City-standard multimodal Transportation Impact Assessment Study (TIAS) during the local entitlement process.

Motor Vehicle Parking

The ENF describes a proposed motor vehicle parking supply of 200 spaces. Given the Project’s 339,000 square foot program, a ratio of approximately 0.6 parking spaces per 1,000 square feet of built space is planned. Since motor vehicle parking has been identified as the most important factor in determining automobile mode share in new development, the City supports all efforts to minimize new parking supply.

The City prohibits new off-street parking from being designated as “accessory” to a primary land use; rather, the City requires new garage facilities to function as public garages offering hourly, daily, weekly and monthly parking at market rates. The intent of this “unbundling” practice is to discourage new tenant employees from driving to work. The details of garage pricing and operations will be reviewed and conditioned in local zoning via the Project’s Mobility Management Plan.

The ENF notes that the Project will provide preferred parking for electric vehicles and fuel- efficient vehicles. The City looks forward to working with the Proponent to plan and install the maximum number of electric vehicle charging stations in the Project’s proposed garage to help catalyze regional electrification of the passenger vehicle fleet.

Mass Transit

The ENF notes that the Project anticipates a 30% transit mode share for new trips, generating approximately 1,200 new daily weekday mass transit trips. MBTA research has demonstrated a Page 3 of 6 clear link between bus reliability and ridership; hence, on-street transit bus infrastructure like the City’s existing Prospect Street, Washington Street and Somerville Avenue bus priority treatments are crucial to the long-term success of bus transit in the Project area.

The Project identifies upgrades to MBTA bus stop facilities as an important measure to encourage transit usage by new employees and visitors. The Project will be required to upgrade bus stop facilities and provide real-time transit screen infrastructure to encourage maximum use of MBTA bus transit.

The City is currently working with the MBTA to improve service frequency on Route 85, Route 91 and Route CT2 bus service, including via the MBTA Bus Network Redesign Process. Similarly, the City is currently supporting the MBTA Silver Line Extension planning process (which is currently considering options for a one-seat transit connection from Boynton Yards to Logan Airport via Sullivan Square, Everett and Chelsea). We look forward to continued collaborations with the Proponent, the MBTA and all stakeholders to maximize bus transit mode share for new Project-generated trips.

Regarding light-rail transit, the Proponent has committed to providing the City with a Green Line contribution payment consistent with City policy. The ENF identifies provision of subsidized transit passes to new tenant employees as part of its mitigation framework. The City has successfully worked with other development proponents to ensure maximum transit subsidy for new employees under approved Mobility Management Plans (MMPs); we look forward to detailed review of the Project’s MMP commitments in the local zoning process.

Bicycle Parking

The ENF describes a bike parking program of 19 short-term spaces and 96 long-term covered/secured spaces. Local zoning has specific requirements for bike parking in new development; the City looks forward to reviewing the Project’s detailed proposals in the local entitlement process.

The ENF notes that the Proponent will provide a standard Blue Bikes public bike share station. The City looks forward to detailed siting discussions with the Proponent to determine the most accessible and useful station location on the Project site.

Pedestrian Environment

The ENF notes that the Project will upgrade pedestrian infrastructure, including reconstructing all adjacent sidewalks to provide 14’ – 18’ of sidewalk width. Creation of accessible, attractive sidewalk facilities is anticipated to encourage higher rates of mass transit utilization for Project- generated trips, since the new MBTA Green Line station is located approximately ¼ mile to the north of the Project site.

The Project proposes sidewalk amenities including street trees, seating, lighting and furnishings consistent with City standards. The City applauds the Proponent’s commitment to use soil cell Page 4 of 6 or suspended pavement treatments to provide uncompacted soils that support street tree vitality. In addition, new on-site public open space facilities are proposed, which will further enhance the pedestrian environment.

Bicycle Environment

The ENF’s modelling anticipates that roughly 14% of Project-generated trips will be made by bicycle, translating to roughly 580 new daily bicycle trips. In 2017 and 2018, the City implemented a series of low-cost protected bike lane facilities in Union Square, including along Webster Avenue at the Project site. Additional protected bike facilities will be completed in 2021, including sidewalk-level protected lanes along Somerville Avenue and street-level protected lanes along Medford Street.

The ENF identifies upgrades of the Webster Avenue bike facilities as an important opportunity to improve safety and comfort for people biking to the Project site. The City is currently working with multiple development proponents in the Boynton Yards and Union Square neighborhoods to reconstruct streets and sidewalks, and we look forward to more detailed review of the Project’s proposed streetscape upgrades along Webster Avenue in the local zoning process. The City’s vision is to convert Webster Avenue’s existing on-street flex-post protected bike lanes into sidewalk-level separated bike lanes.

The ENF identifies provision of subsidized Blue Bikes membership passes for new tenant employees as part of its mitigation framework. The City has successfully worked with other development proponents to ensure maximum Blue Bikes subsidy for new tenant employees under approved Mobility Management Plans (MMPs); we look forward to detailed review of the Project’s MMP commitments in the local zoning process.

Transportation Demand Management

The ENF notes the Proponent’s commitment to Transportation Demand Management strategies, and Section 3.1.3.1 provides a list of anticipated measures. The City notes that this list includes a firm commitment to unbundled, market-rate parking for any motor vehicle parking created by the Project. Parking supply and policy is increasingly recognized as the most important determinant in travel behavior of new workers and residents in new development. The City looks forward to continuing review of the Project’s motor vehicle parking supply and management strategies in local zoning review.

Other TDM strategies listed as commitments include on-site mobility coordinator, real-time transit screen, guaranteed ride home programming, and use of employee benefits including subsidized transit passes. These measures and others will be memorialized in the Project’s local Mobility Management Plan (MMP), which represents as an enforceable condition of local zoning permits.

The City notes that neighboring private development proponents in the Union Square and Boynton Yards districts are obligated under state and local permits to participate in formation Page 5 of 6 and operation of a new Transportation Management Association (TMA) serving this neighborhood. The ENF does not list TMA participation as a commitment, but the City expects the Proponent to commit to this activity as part of its local MMP.

Wastewater Generation

The ENF acknowledges that the Project exceeds sewer generation threshold thus triggering the City Inflow & Infiltration Policy. The Project will generate an increase of 43,925 GPD of sewer flows to the City system. The ENF also commits to developing an I/I mitigation plan in coordination of I&I Removal, but does not provide specific details for accomplishing required removal of I/I. The Proponent subject to the I/I Policy may elect to pay a fee based on the project’s I/I mitigation requirement that will be deposited into a dedicated account that funds those projects. The per-gallon fee is established annually based on the program costs to remove I/I. The CY2018 I/I mitigation fee is $14.35.

Stormwater

The Project proposes to reduce overall runoff by reducing total impervious area, and constructing a stormwater management and groundwater recharge system. A project of this size will require a direct connection to the municipal sewer system to maintain safe street conditions. Based on the City’s Site Construction Permit Rules & Regulations (August 2020), a direct stormwater connection will require reduction of the proposed 10-year storm peak runoff rate to be less than or equal to the existing 2-year storm peak runoff rate. The ENF does not provide sufficient hydrology modeling to determine whether the project scope can meet this requirement.

This project is part of the Boynton Yards district-wide infrastructure upgrade plan. This includes sewer separation, downstream stormwater pump system, water distribution system, street reconstruction and open space development. All projects in the Boynton Yards District, including this project, are required to contribute to a City fund, or in kind, to construct these infrastructure projects.

Groundwater

The Project proposes subsurface garage/basement that will be below seasonal high groundwater. Any permanent dewatering will need to be managed on-site by recharge and/or reuse. Groundwater may not be discharged to the municipal sewers.

Sustainability / Building Performance

The ENF describes the Project’s overall conceptual approach to building performance and sustainability. The Project will trigger local zoning requirement to be LEED Platinum certifiable. Local zoning requirements in the Master Planned Development (MPD) Overlay District set higher sustainability standards for non-laboratory buildings. While this project is Page 6 of 6 designed with some lab uses, the majority of the square footage is programmed for non-lab uses. Non-laboratory buildings in the MPD Overlay District must meet the following standards in zoning:

 No on-site combustion for HVAC system operation  No on-site combustion for cooking equipment, excluding Eating & Drinking Establishment principal uses  Be certifiable as Zero Carbon or higher from the International Living Future Institute; or PHIUS+ from the Passive House Institute U.S.

For non-laboratory uses, the Project design is expected to maximize electrification where possible to reduce emissions as much as possible. The City will be looking for partial- electrification proposals and more details on the planned ECMs in the Development Review Applications.

In Master Planned Development Districts, all new principal building types must include a green roof, photovoltaic (PV) devices, or both for 100% of the roof area not occupied by building systems equipment or required outdoor amenity spaces. We look forward to seeing more detail on how the proponent plans to utilize their roof space to provide the maximum environmental benefits.

The City looks forward to seeing more detail on the proposed electric vehicle charging plans in the DRA, including the number of spaces that will have chargers installed and those that will be EV ready or capable.

Thank you for the opportunity to comment on the Boynton Gateway ENF. The City looks forward to continuing its collaboration with the Proponent and with all stakeholders in the MEPA process. Please do not hesitate to contact me with any question or concerns.

Sincerely,

Brad Rawson Director, Mobility Division Mayor’s Office of Strategic Planning & Community Development City of Somerville, MA

April 13, 2021

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

RE: Somerville: Boynton Gateway – ENF (EEA #16343)

ATTN: MEPA Unit Anne Canaday

Dear Secretary Theoharides:

On behalf of the Massachusetts Department of Transportation, I am submitting comments regarding the Environmental Notification Form for the Boynton Gateway project in Somerville, 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

Boynton Gateway Page 2 4/13/2021 cc: Jonathan Gulliver, Administrator, Highway Division Patricia Leavenworth, P.E., Chief Engineer, Highway Division Paul Stedman, District 4 Highway Director John McInerney, P.E., District 6 Highway Director Neil Boudreau, Assistant Administrator of Traffic and Highway Safety Office of Strategic Planning and Community Development, City of Somerville Metropolitan Area Planning Council Massachusetts Bay Transportation Authority

MEMORANDUM

TO: David Mohler, Executive Director Office of Transportation Planning

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

DATE: April 13, 2021

RE: Boynton Gateway– ENF (EEA #16343)

The Public/Private Development Unit (PPDU) has reviewed the Environmental Notification Form (ENF) for the proposed Boynton Gateway project in the Boynton Yards neighborhood of Somerville. The project site consists of approximately 1.15 acres of land bounded by Columbia Street to the north and east, Beach Avenue and an existing parking garage to the south, and Webster Avenue and an existing residential building (80 Webster Avenue) to the west. The project is located at 495 Columbia Street. The site currently contains seven one-story buildings including 20,200 square feet (sf) of auto repair uses, a 10,700-sf moving/storage facility, and surface parking.

The project consists of removing the existing structures and constructing a 339,000-sf development, including 136,400 sf of lab uses, 201,600 sf of office/research and development (R&D) uses, and 1,000 sf of retail space (“Project”). The project will increase the parking supply on site by 150 spaces, resulting in 200 parking spaces provided beneath the project. Access to the structured parking will be provided from Beach Avenue, internal to the project site, which will connect with Webster Avenue to provide access and egress for passenger vehicles and with Columbia Street to provide egress for service and loading vehicles only.

According to information in the ENF, the Project is expected to generate 2,994 net new unadjusted vehicle trips per day and 886 net new adjusted vehicle trips per day. The project trip generation exceeds the Massachusetts Environmental Policy Act (MEPA) ENF transportation threshold, 11.03(6) (b) (13), “generation of 2,000 or more new average daily vehicle trips (ADT) on roadways providing access to a single location.” Due to the project’s location on former railroad land, the project requires Chapter 40 Section 54a consent and a license from the MBTA for construction on former railroad land. An ENF was previously submitted for this project in December 2020, but it was rescinded due to changes in the development program that caused the project to no longer exceed Environmental Impact Report (EIR) thresholds. MassDOT believes the revised proposal may still exceed MEPA threshold for the preparation of an Environmental Impact Report (EIR).

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

Boynton Gateway Page 2 4/13/2021

The ENF includes a limited a Transportation Impact Assessment (TIA) generally consistent with the MassDOT/EEA Transportation Impact Assessment Guidelines. The TIA adequately discusses the transportation impacts of the project and includes a comprehensive multimodal mitigation program to address the Project’s impacts. The following comments should be addressed in the EIR.

Trip Generation

The ENF determined that Institute of Transportation Engineers (ITE) Trip Generation Manual (10th Edition) Land Use Codes (LUCs) 710 – General Office, 760 – R&D Center, and 820 – Shopping Center would most accurately reflect the proposed development. MassDOT notes that the trip generation calculations in the ENF omit LUC 820, the retail portion of the development. Based on the addition of the retail component, the project is estimated to generate in excess of 3,000 unadjusted vehicle trips on an average weekday, and therefore requires the preparation of an EIR.

The site currently contains six auto repair facilities (20,200 sf) and a 10,700-sf moving/storage facility, all of which are still in operation. To estimate trips generated by the existing uses, the Proponent used ITE trip rates for LUCs 151 – Mini-Warehouse and 942 – Automobile Care Center. Given that the existing land uses are auto-oriented, no mode share reduction was applied. Subtracting the existing trip generation from the proposed project trip generation results in 874 net new vehicle trips on an average weekday, including 70 vehicle trips during the weekday morning peak hour and 54 vehicle trips during the weekday evening peak hour.

Transit

Boynton Gateway Page 3 4/13/2021 study area. Some of these proposed developments, more specifically the Boynton Yards and the US 2 Development are expected to provide comprehensive mitigation to address transit impacts in the study area. When considered without the background development projects, this project alone is expected to have minimal impacts to current transit operations. Notwithstanding, the Proponent has committed to provide the City of Somerville with transit funding to implement transit improvements in the vicinity of the Project.

Multi Modal Access and Improvements

The ENF describes improvements to sidewalks along the project frontages. Beach Avenue is currently a historic access easement owned almost entirely by the Proponent and will be improved as part of the project. Beach Avenue will run east-west through the project site and will be transformed into a curbless drive to accommodate all modes of transportation, including access to the parking garage, service, and loading. Along Beach Avenue, two-way travel will be allowed at the Webster Avenue side of the drive, which will be used as the passenger vehicle entrance and exit. Beyond the parking garage entrance on Beach Avenue and continuing to Columbia Street, the Beach Avenue circulation will change to one-way to allow service and loading vehicles to exit the project site.

Along Columbia Street the Proponent will construct 18-foot sidewalks with new curb zones, furnishing zones, and concrete pedestrian zones. At the north eastern corner of the project side, along Columbia Street there will be a building entrance with an expanded hardscape plaza. Where Columbia Street intersects Beach Avenue, the Proponent will construct a pedestrian prioritized flush driveway providing vehicular access to the loading dock.

Transportation Demand Management (TDM)

The Proponent has committed to implementing a comprehensive TDM program to reduce single occupancy vehicle (SOV) trip generation and increase mode share in the study area of the Project. The ENF identifies a number of TDM programs to be implemented as part of the project. These programs are generally regrouped under five themes: • Alternative mode benefits/Tactics • Bicycle/Pedestrian trips

Boynton Gateway Page 4 4/13/2021

• Public Transportation • Ride sharing • Parking Strategies

MassDOT believes that the proposed mitigation program would adequately address the impacts of the Project. The EIR should include an updated trip generation for the Project and address whether the proposed mitigation is sufficient to accommodate any increase in the Project’s trip generation. The Proponent should continue consultation with the City of Somerville and appropriate MassDOT units, including PPDU and the District 4 Office during the preparation of the EIR. If you have any questions regarding these comments, please contact me at [email protected].

April 13, 2021

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

Subject: EOEEA #16304 – Environmental Notification Form Boynton Gateway, Somerville, MA

Dear Secretary Theoharides,

The Massachusetts Water Resources Authority (MWRA) appreciates the opportunity to comment on the Environmental Notification Form (ENF) submitted by Boynton Gateway Owner LLC (the “Proponent”) for Boynton Gateway (the “Project”) in Somerville, Massachusetts. The Project site is bounded by Columbia Street to the north and east, an existing parking garage to the south, and an existing condominium building and Webster Avenue to the west. The site currently contains approximately 30,888 square feet of industrial and commercial uses across seven one-story buildings as well as supporting surface parking. The Project involves demolition of the existing structures and construction of a pedestrian- and transit-oriented commercial development to contain office, research and development, and laboratory space as well as accessory retail space and approximately 200 parking spaces.

MWRA’s comments on this ENF relate to wastewater issues and the need for Infiltration/Inflow (I/I) Removal, stormwater, Toxic Reduction and Control (TRAC) discharge permitting and MWRA Enabling Act Section 8(m) permitting.

Wastewater and Stormwater

The ENF describes the existing and proposed stormwater and sanitary collection systems. The Project site and surrounding area is served by City of Somerville separate sanitary sewers and combined sewers primarily located in Webster Avenue and Columbia Street. Most sanitary flow generated in the area drains to the municipal sanitary sewers. Stormwater generated in the area is collected by the municipal combined sewers, which also collect sanitary flows at remaining sanitary connections. Both the sanitary sewers and the combined sewers tie into a series of larger municipal combined sewers starting at the intersection of Webster Avenue and Columbia Street and eventually connecting to MWRA’s Cambridge Branch Sewer at Somerville Avenue and Poplar Street. The Cambridge Branch Sewer conveys combined sanitary and stormwater flows from parts of Cambridge and Somerville, as well as sanitary flows from parts of the City of Medford, to MWRA’s DeLauri Pumping Station in Charlestown. From there flows are pumped into MWRA’s North Metropolitan Sewer System for transport to the Deer island Treatment Plant. In large storms, stormwater flows to MWRA’s Cambridge Branch Sewer can contribute to combined sewer overflows (CSO) at MWRA’s Prison Point CSO treatment facility, which discharges to the Upper Inner Harbor, and to untreated CSO discharges at outfalls on the Charles River Basin and the tidal waters of the Mystic River.

The ENF reports that the Project will generate 46,700 gallons per day (gpd) of wastewater, an increase of 43,925 gpd over the estimated existing wastewater generation of 2,775 gpd. The ENF also reports that remaining stormwater generated on the Project site will continue to be directed to the municipal combined sewer system, until that system may be separated in the future by the City of Somerville. To ensure that the Project’s new wastewater flow does not increase surcharging and overflows in large storms and does not compromise the environmental benefits of MWRA’s $912 million region-wide CSO control program, including the program’s intended water quality benefits for the Charles and Mystic rivers, the Proponent should fully mitigate the Project’s potential wastewater flow impacts with infiltration/inflow (“I/I”) or stormwater removal in compliance with Massachusetts Department of Environmental Protection and City of Somerville regulations. Both regulations require four gallons of I/I removal for every gallon of new wastewater. To avoid impacts, effective mitigation should be implemented prior to the Project’s buildings being occupied. The ENF acknowledges the I/I mitigation requirement and states that the Proponent is committed to developing an I/I mitigation plan in coordination with the City.

The ENF reports that the Project proposes on-site stormwater management systems to capture both roof and site stormwater runoff and reduce stormwater runoff to the municipal combined sewer system. If the Project is required to submit an Environmental Impact Report (EIR), the Proponent should present in the EIR an estimate of the quantity of stormwater that will be removed from the sewer system, the remaining I/I mitigation necessary to accomplish the required 4:1 removal, and a full mitigation plan and implementation schedule. If the Project does not require submission of an EIR, MWRA will rely on the City of Somerville to provide information supporting full I/I mitigation for this Project and other projects in the planned Boynton Yards and Union Square development areas.

TRAC Discharge Permitting

Pursuant to 360 C.M.R. 10.091-10.094, a Temporary Construction Dewatering Permit is required prior to the discharge of groundwater from any construction sites associated with the Project into the sanitary sewer system. For assistance in in obtaining a permit, both the Proponent and the Contractor should contact Stephen Buczko, Industrial Coordinator in the TRAC Department at 1 (617) 305-5619.

A Sewer Use Discharge Permit is required prior to discharging process wastewater, laboratory wastewater or photoprocessing wastewater from office, high-tech, R&D, laboratory or commercial space associated with the Project into the MWRA sanitary sewer system. For assistance in obtaining this permit, a representative from the proposed laboratory and commercial space should contact Stephen Buczko, Industrial Coordinator, in the TRAC Department at 1 (617) 305-5619.

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 infrastructure to the Project site, an 8(m) permit may be required. The Proponent should contact Ralph Francesconi in the Water Operations Permitting Group at 1 (617) 305-5827 for assistance related to this matter.

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,

Beth Card Director Environmental and Regulatory Affairs

cc: John Viola, DEP Rich Raiche, City of Somerville Jessica Fosbrook, City of Somerville

From: Lucien, Lionel (DOT) To: Greaves, Kyle; Ian McKinnon Cc: Canaday, Anne (EEA); Alex Phillips; Saquib, Samhita; [email protected]; Czepiga, Page (EEA) Subject: Re: Boynton Gateway Trip Gen Date: Thursday, April 15, 2021 3:19:29 PM

Anne/Page

I have reviewed the email below by Kyle Greaves regarding the Boynton Gateway project. If the proposed retail space is designed as a tenant-space amenity as discussed below and is not generally accessible to the motoring public, we concur that it could be considered integral part of the office use and therefore would not result in additional trips to trigger the EIR threshold. Let me know if you have any questions. Thanks

Lionel

J. Lionel Lucien, P.E. Manager, Public/Private Development Unit Office of Transportation Planning 10 Park Plaza Room 4150 Boston, MA 02116

From: Greaves, Kyle Sent: Thursday, April 15, 2021 9:22 AM To: Ian McKinnon ; Lucien, Lionel (DOT) Cc: Canaday, Anne (EEA) ; Alex Phillips ; Saquib, Samhita ; [email protected] ; Czepiga, Page (EEA) Subject: Boynton Gateway Trip Gen

CAUTION: This email originated from a sender outside of the Commonwealth of Massachusetts mail system. Do not click on links or open attachments unless you recognize the sender and know the content is safe. Dear Lionel and Anne,

The team has spent time reflecting on our conversations yesterday, and I wanted to provide an update. As previously conveyed by Ian McKinnon, the ground level “retail” space that we had identified in the ENF has always been viewed as a tenant focused amenity that would be available and designed into the lobby. We are at an early conceptual stage of design, however after reviewing these thoughts with the design team, we wanted to confidently state that the Proponent is comfortable committing in the Certificate that this space is intended as an accessory use within the larger lobby. While not designed at this time, the Proponent envisions uses like a juice bar or a coffee kiosk that is integrated into the lobby, and would not be a driver of new trips to the site. This convenience amenity will not have its own dedicated storefront. It was my understanding that this was the commitment that Lionel was seeking yesterday, which is consistent with how we have calculated the trip generation for this space. I thank you for your patience and welcome any follow up questions. We appreciate your partnership in this process.

Kyle

Kyle Greaves Sr.Environmental Planner/Project Manager

P 617.607.2988 www.vhb.com From: Ian McKinnon Sent: Wednesday, April 14, 2021 1:23 PM To: Lucien, Lionel (DOT) Cc: Canaday, Anne (ENV) ; Greaves, Kyle ; Alex Phillips ; Saquib, Samhita ; [email protected] Subject: [External] Boynton Gateway Trip Gen

Hi Lionel,

Thanks for taking the time earlier to discuss the Project and your most recent review. We believe the Transportation Study and ongoing local Project TIS/mobility review are extremely robust and conservative. The Project team would like to offer an adjusted trip forecast (attached) reflecting your concerns over how the 1,000 SF of retail is characterized in the travel forecasting. As you know, these projects continue to be refined and detailed as they progress. One of the more recent items included in the 3/15 ENF was a slight increase in GFA on the MR-5 building to expand towards Webster Ave to align the street wall with the adjacent bldg. Understanding the importance of the Webster Ave corridor a pedestrian route to the imminent Union Square Green Line station and think the reduction of this area to provide additional width of sidewalk horizontally (2.2KSF under lab) would be a benefit to the public realm transportation. With this change, and acknowledging your request to categorize the ground floor retail under a retail (LUC 820 – Shopping) we have targeted as ancillary to building tenants we provide this updated trip forecast. With this revision as you will see puts the net-new trips below 3,000ADT.

We’ve included a summary table, a proposed site plan for reference, and a detail trip gen analysis by mode in the attached.

Please feel free to give me a call to discuss if you’d like.

Thanks, Ian

Ian McKinnon, P.E., PTOE, RSP Associate |Technical Leader, Institutional and Private Markets

direct: 617.348.3341 office: 617.482.7080 11 Beacon Street, Suite 1010, Boston, MA 02108 www.hshassoc.com Facebook LinkedIn

This communication and any attachments to this are confidential and intended only for the recipient(s). Any other use, dissemination, copying, or disclosure of this communication is strictly prohibited. If you have received this communication in error, please notify us and destroy it immediately. Vanasse Hangen Brustlin, Inc. is not responsible for any undetectable alteration, virus, transmission error, conversion, media degradation, software error, or interference with this transmission or attachments to this transmission. Vanasse Hangen Brustlin, Inc. | [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

21 April 2021

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

RE: Boynton Gateway, Somerville, MA, EEA #16304

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 a 339,000-sf office, lab and R&D building. The objective of this letter is to share strategies for the project to reduce greenhouse gas emissions (GHG), improve resiliency, and affordability.

Key Strategies

Deployed together, the following have been found to be effective strategies in advancing emission reduction, resilience, and affordability:

• Building design and construction practices that result in low heating and cooling thermal energy demand intensity (heating and cooling “TEDI”) by:

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

o Thermally-broken windows and other components to eliminate thermal bridges;

o Minimizing glass curtain wall assemblies and excessive windows;

Boynton Gateway, EEA #16304 Somerville, MA

o Low air-infiltration, confirmed with in-building air-infiltration testing;

o Energy recovery;

o Management of solar heat gains;

• Efficient electrification of space heating, including:

o For highly ventilated lab office (including speculative core-and-shell developments): low temperature, hydronic space heating with heat-input provided by hybrid, in-building, central plant consisting of air-to-water heat pump (primary) and gas boilers (secondary);

• Efficient electrification of water heating, where feasible;

• Extensive rooftop solar-readiness;

• Electric vehicle ready parking spaces.

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 including MassSave® incentives, Alternative Energy Credits (AECs), and Solar Massachusetts Renewable Target (SMART) credits.

Key Mitigation Strategies Explained

Envelope, Heat Recovery, and Solar Gains

The combination of quality envelope, heat recovery, and management of solar gains can result in significant reduction in heating (and cooling) thermal energy demand intensity (TEDI, units of kBtu/sf-yr). In addition to reduced utility costs and emissions, the value of a targeted focus on heating and cooling TEDI results in:

• Simplified space heating electrification; • Reduction, and possible elimination, of perimeter heating systems; • Improved resiliency; • Reduced peak demands; • Improved occupant comfort; • Reduced maintenance.

Specific TEDI reduction strategies are:

• High-performance window and walls; • Thermal-broken windows and components to eliminate thermal bridges; • Low air-infiltration; • Ventilation heat recovery;

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Boynton Gateway, EEA #16304 Somerville, MA

• Solar gain management via external shading and/or low solar heat gain coefficient (SHGC)

Buildings with curtain wall envelope require high performing windows and high performing opaque spandrels to achieve heating TEDI reductions. High performing windows and high performing opaque spandrels should be carefully evaluated if curtain-wall construction is considered.

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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Boynton Gateway, EEA #16304 Somerville, MA

Electrifying Space Heating for Lab/Office

Mixed use lab/R&D/office buildings typically have high ventilation loads which may have made electrification of space heating a challenge in the past, particularly with a speculative core/shell project. However, DOER is aware of recent highly-ventilated, speculative core and shell lab/office projects that are pursuing pathways to partially electrify space heating for these types of projects. The approach uses an in-building, centrally located, hybrid heating plant consisting of air to water heat pumps and gas equipment in which the air source heat pump can provide 80-90% total annual space heating end use.

Key strategies for this hybrid approach are as follows:

• Include a hot water distribution loop of 120℉;

• Include a centralized heating plant consisting of both an air to water heat pumps and a gas-fired condensing boiler;

• Size the gas boiler for 100% of the peak load; size the air source heat pump for 25% of the peak load;

• Prioritize air source operation first, utilizing gas boiler only when loads exceed 25% of peak.

A hybrid approach like this may provide a feasible means to partially electrify space heating of highly ventilated lab/office building, including for speculative core/shell projects.

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 this application could be challenging but encourages the proponent to analyze and review all opportunities for electrification, including heat pump water heaters for the building.

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 setting 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.

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Boynton Gateway, EEA #16304 Somerville, MA

Electric Vehicle (EV) Parking Spaces

EV charging stations are critical for the continual transition towards electric mobility. Even if EV charging stations are not installed during construction, it is critical to maximize EV ready parking spaces as it is significantly cheaper and easier to size electrical service and install wiring or wiring conduit during construction rather than retrofitting a project later.

Incentives

Buildings which incorporate the above strategies can qualify for significant incentives:

• MassSave® performance-based incentives1 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.

• Alternative Energy Credits (AECs)2 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 program3 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.

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 including C402.1.5 (envelope), C405.3 and C405.4 (lighting), C405.10 (EV charging), and C406 (three additional efficiency measures).

Recommendations

The strategies described above provide pathways to GHG mitigation, increased affordability, and improve resiliency. The following are questions that should be considered throughout the planning process:

1. Did the baseline building scenarios meet all requirements including relevant MA amendments? The project should clearly indicate how it is achieving all MA Amendments,

1 https://www.masssave.com/en/saving/business-rebates/new-buildings-and-major-renovations/ 2 https://www.mass.gov/guides/aps-renewable-thermal-statement-of-qualification-application 3 https://www.mass.gov/solar-massachusetts-renewable-target-smart Page 5 of 7

Boynton Gateway, EEA #16304 Somerville, MA

specifically which three C406 measures are being used in the Baseline. C406 measures should be regarded as project commitments. For example, if the project choses additional solar PV, the solar PV would be considered a project commitment. Emissions reduction due to C406 measures is considered “code required” and does not count as mitigation.

2. Did the project confirm adherence to envelope code requirements? The project should develop two UA analysis tables to confirm compliance, 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.

3. Did the project design the envelope with the aim of reducing heating TEDI using a combination of high-performing envelope, heat recovery, and solar gain management. Strategies to achieve this include:

a. Above code-threshold envelope (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.

b. Glass curtain wall/spandrel systems should be minimized as much as possible, and avoided where possible, as these are the lowest performing wall systems.

c. If curtain wall systems are used, evaluate systems having opaque “spandrel” portion of R-10 or better.

d. Reduce air infiltration to Passivehouse levels to 0.08 cfm at 74 Pa . In-building field tests are recommended to confirm air-infiltration.

e. Ventilation Energy Recovery. High performing energy recovery is essential to achieving low TEDI.

f. Solar gain management. Manage solar gains with external shading and/or low solar heat gain coefficient (SHGC).

4. Did the project look at opportunities to fully or partially electrify the buildings? The following represents an example that is being used on high performing lab office buildings across the commonwealth:

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Boynton Gateway, EEA #16304 Somerville, MA

a. Improved envelope as described above. Downsize the HVAC as much as possible. Best in class energy recovery ventilation. Hybrid electrification scenario described above (central plant consisting of air to water heat pump sized to 25% of peak with gas condensing boiler). Service water with electric air source heat pump hot water. External shading and improved solar heat gain coefficient windows to control space cooling loads. Energy reduction shall be attributable to reductions in heating, cooling, fan, ventilation, heat recovery and pumping.

5. Did the project consider all opportunities for incentives? Including:

a. Estimate of Alternative Energy Credits

b. Estimates of MassSave® incentives, based on meeting with utility.

• Did the project set-aside as much space as possible for rooftop PV? It is important to set- aside roof space for PV early to ensure that mechanical equipment spacing is designed to maximize rooftop space. A target of 80% roof set-aside is generally achievable.

6. Did the project maximize EV ready parking spaces? It is important to establish EV ready parking during construction as it is much easier to lay wire conduit and size transformers correctly during design and construction than to retrofit these in the future.

Sincerely,

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

Brendan Place Clean Energy Engineer Massachusetts Department of Energy Resources

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