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
May 15, 2020
CERTIFICATE OF THE SECRETARY OF ENERGY AND ENVIRONMENTAL AFFAIRS ON THE DRAFT ENVIRONMENTAL IMPACT REPORT
PROJECT NAME : Riverside Station Redevelopment PROJECT MUNICIPALITY : Newton PROJECT WATERSHED : Charles River EEA NUMBER : 16024 PROJECT PROPONENT : Mark Development, LLC DATE NOTICED IN MONITOR : March 11, 2020
Pursuant to Section 11.08(8)(b) of the MEPA regulations, I hereby determine that the Draft Environmental Impact Report (DEIR) submitted on this project does not adequately and properly comply with the Massachusetts Environmental Policy Act (MEPA; M.G.L. c. 30, ss. 61-62I) and with its implementing regulations (301 CMR 11.00), and therefore require the filing of a Supplemental DEIR (SDEIR). Specifically, I find that the DEIR has not provided a comprehensive description of project components and analyses as required in the Scope for the DEIR. As such, I cannot find that the project has satisfied the regulatory requirements to ensure that the project’s environmental impacts have been clearly described and fully analyzed or that it has incorporated all feasible means to avoid Damage to the Environment.
Project Description
As described in the DEIR, the project includes the redevelopment of the surface parking lot at the Massachusetts Bay Transportation Authority (MBTA) Riverside Station and an adjacent site occupied by a hotel. The project includes the demolition of the hotel building and construction of an EEA# 16024 DEIR Certificate May 15, 2020
approximately 1.025-million square foot (sf) mixed-use development in 10 buildings. Seven buildings will be occupied by 653,571 sf (617 units) of residential space, 250,887 sf of office space, 77,300 sf (150 rooms) of hotel use and 43,242 sf of retail space. The tenth building will be a parking garage with 1,990 spaces, including 1,000 spaces to replace the parking lot used by commuters. The buildings will range in height from 63.9 feet to 170 feet. The project will provide 2.3 acres of public open space, including: Transit Square, with a paved area for active use and a lawn for passive use; Amphitheater Garden to host small performances; and Hotel Green, which includes space for recreational uses.
To minimize the volume of project-related traffic on Grove Street, primary vehicular access is proposed at the western end of the site adjacent to Interstate-95 (I-95). The Proponent will reconfigure the I-95 Northbound Off-Ramp adjacent to the site so that it terminates at a new intersection at the site entrance. A new signalized intersection on Grove Street at the western end of the site will direct vehicular traffic to the main entrance.
The project will be constructed in two phases. Phase 1 includes demolition of the hotel, relocation of a water main, regrading of the site and construction of Buildings 2, 3, 4, 7, 8 and the portions of Buildings 9 and 10 containing the parking garage. Phase 2 will include construction of Buildings 1, 5, 6, 7, the retail portion of Building 9 and the residential portion of Building 10.
Project Site
Riverside Station is located to the east of the intersection of I-95 and Grove Street. The project site encompasses an area of 13.05 acres, including 10.35 acres owned by the MBTA and the 2.7-acre Hotel Indigo property owned by the Proponent. The site is bordered to the north by the MBTA Green Line maintenance facility and associated structures, Riverside Station, the Green Line tracks and Riverside Office Park; to the east by Grove Street; to the south by Grove Street and I-95; and to the west by I-95 and associated ramps and roadways and undeveloped, forested land and wetland resource areas adjacent to the Charles River. In addition to surface parking, the portion of the site owned by the MBTA includes a bus stop and provides the primary access to its maintenance facility. The Hotel Indigo parcel includes the hotel and structured and surface parking lots.
The Newton Lower Falls neighborhood is located to the southwest on the opposite side of I-95. The Auburndale neighborhood is located to the northeast on the other side of Route 30. Residential uses and a golf course are located on the east side of Grove Street.
The Charles River and the Department of Conservation and Recreation’s (DCR) Charles River Reservation are located north of the site. According to the Massachusetts Department of Environmental Protection’s (MassDEP) Year 2016 List of Integrated Waters, impairments affecting the use of the segment of the Charles River near the site include the presence of non-native aquatic plants, fish bioassessments, DDT in fish tissue, PCB in fish tissue, pathogens, nutrients and phosphorous. The U.S. Environmental Protection Agency (EPA) and MassDEP have established Total Maximum Daily Loads (TMDL) for nutrients and pathogens in the Charles River.
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Environmental Impacts and Mitigation
Potential environmental impacts associated with the project include the generation of 11,368 weekday average daily trips (adt) and 9,972 adt on Saturday, construction of 2,041 parking spaces (an increase of 821 spaces compared to existing conditions), use of 96,900 gallons per day (gpd) of water and generation of 92,210 gpd of wastewater. Greenhouse Gas (GHG) emissions are associated with on- site energy use and transportation.
Measures proposed to avoid, minimize and mitigate impacts identified in the DEIR include local and regional roadway and signal improvements, implementation of a Transportation Demand Management (TDM) program to minimize single-occupant vehicle (SOV) trips to the site, a 0.6-acre decrease in impervious area, connections to pedestrian and bicycle networks and construction of a stormwater management system.
Jurisdiction and Permitting
The project is subject to the preparation of a Mandatory EIR pursuant to the 301 CMR 11.03(6)(a)(6) and 301 CMR 11.03(6)(a)(7) because it requires Agency Actions and will generate 3,000 or more new trips on roadways providing access to a single location and construct 1,000 or more new parking spaces at a single location, respectively. The project requires a Vehicular Access Permit from the Massachusetts Department of Transportation (MassDOT) and an 8(m) Permit from the Massachusetts Water Resources Authority (MWRA). It may require a Construction and Access Permit from DCR. The project is subject to review under the MEPA GHG Emissions Policy and Protocol (GHG Policy).
The project requires an Order of Conditions (OOC) from the Newton Conservation Commission (and a Superseding Order of Conditions (SOC) from MassDEP in the event the OOC is appealed). It requires Site Plan Review, a Special Permit and approval of re-zoning by the Newton City Council. The project requires review by the Federal Highway Administration (FHWA) and a National Pollutant Discharge Elimination System (NPDES) General Permit for Stormwater Discharge from Construction Activities and Stormwater Notice of Intent from the EPA.
The Proponent is seeking a Land Transfer in the form of a lease and a conveyance in fee from the MBTA affecting nearly the entire project site. Therefore, MEPA jurisdiction extends to all aspects of the project that are likely, directly or indirectly, to cause Damage to the Environment pursuant to 301 CMR 11.01(2)(a)(3).
Changes Since the Filing of the ENF
The DEIR identified changes to the project since the ENF was reviewed. The project site has decreased in area by 1.35 acres and the gross square footage of the proposed buildings has decreased from approximately 1.5 million sf to 1.025-million sf. The changes include the following:
• The number of residential units has decreased from 675 to 617; • The number of hotel rooms has from 194 to 150; 3
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• The area of office/lab space has been reduced from 562,267 sf to 250,887 sf; • The area of retail/commercial space from 64,655 sf to 43,242 sf; • The proposed mixed-use common area has been eliminated from the project design; • The maximum building height has decreased from 225 ft to 170 ft; and, • The amount of parking has been reduced from 2,922 to 2,041 spaces and all spaces will be located within a single structure.
The project design also includes a third entrance to the site from Recreation Road that will provide access to the MBTA maintenance facility and to the office building (Building 1) loading dock.
Review of the DEIR
The DEIR reviewed existing conditions and provided a description of the project, including the size and proposed use of each building and plans showing the location of the buildings and open and civic spaces. It identified the project’s impacts on transportation, air quality, infrastructure and water quality. The DEIR provided an analysis of the project’s GHG emissions and climate change resiliency. The DEIR included a Response to Comments received on the ENF, identified mitigation commitments and provided draft Section 61 Findings. It identified the statutory and regulatory standards and requirements applicable to the project and summarized the status of the project’s review by the City of Newton (City). As noted below, the DEIR did not respond to several issues raised in the Scope. These issues should be addressed in the SDEIR.
Alternatives Analysis
The DEIR included an updated Alternatives Analysis that compared the Preferred Alternative as presented in the DEIR to the alternatives reviewed in the ENF, including the 1.5-million sf project that was previously identified as the Preferred Alternative. The alternatives reviewed in the ENF included the following:
• No Build alternative: Maintain the site’s current use by the MBTA and hotel. • Residential Build: A 585,300-sf mixed-use development, including 550 residential units (541,400 sf), 30,400 sf of office space, 6,300 sf of retail uses, a 5,000-sf café and 825 parking spaces; the existing hotel would be maintained and a parking structure for transit users would be constructed. This alternative would generate 7,970 adt, use 143,641 gpd of water, generate143,370 gpd of wastewater and reduce impervious area by 0.1 acres. • Previously Proposed Build (reviewed by MEPA between 2010-2015): A 793,700-sf mixed- use development with 426,400 sf of office space, 295 residential units (348,400 sf), 14,300 sf of retail space, a 5,000-sf café and 2,380 parking spaces (including spaces for transit users). This alternative would generate 9,972 adt, use 110,325 gpd of water, generate 112,705 gpd of wastewater and reduce impervious area by 0.9 acres. • ENF Alternative: A 1.5-million sf mixed-use development with 675 residential units (702,202 sf ), 562,267 sf of office space, a 194-room hotel, 64,655 sf of retail/commercial space, 36,507 sf of common area and a parking garage with 2,866 spaces (including spaces for transit users). Impacts associated with this alternative include 14,550 adt, use of 138,193 4
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gpd of water and generation of 125,630 gpd of wastewater. It would reduce impervious area by 0.6 acres.
The DEIR reviewed the consistency of each alternative with planning goals for the site established by the City. These goals generally prioritized multi-modal transportation, improved conditions for vehicular traffic, affordable housing, open space and enhanced connections to the Charles River, improved water quality and benefits to the neighboring community. According to the DEIR, the No Build, Residential Build and Previously Proposed alternatives would not address the planning goals for the site as compared to the ENF alternative or the Preferred Alternative, since the former set of alternatives would not provide sufficient density to financially support the proposed roadway and Charles River parkland improvements.
According to the DEIR, the Preferred Alternative has greater environmental impacts than all but the ENF Alternative, but it includes a development density necessary to finance a project that meets the planning goals. The reduced scale of the Preferred Alternative compared to the ENF Alternative will reduce transportation impacts and use of water and wastewater infrastructure. Because the Preferred Alternative will provide the mitigation measures previously identified in the ENF in connection with the larger project, the mitigation measures are anticipated to have greater beneficial effect.
Land
The DEIR included a review of the Proponent’s lease agreement with the MBTA; existing easements across the site and potential changes to those easements; new easements; proposed on-site public open space; and existing and proposed site grades.
The Proponent described potential changes to the lease agreement under negotiation with the MBTA. The potential changes include a reduction of the lease area to 8.68 acres, conveyance in fee of a 1.44-acre parcel from the MBTA to the Proponent; and conveyance in fee of a 1.16-acre parcel from the Proponent to the MBTA or MassDOT. Buildings 1, 5, 6, 7, 8, 9 and 10 will be on leased land; Building 4 and small portions of Buildings 2 and 3 will be on land to be conveyed in fee from the MBTA to the Proponent and the majority of Buildings 2 and 3 will be on the Hotel Indigo site owned by the Proponent. The lease agreement will require the Proponent to maintain temporary commuter parking during the construction period, fund all roadway and infrastructure improvements, and provide the MBTA with 10,000 sf of office space, including 7,500 sf in Building 1 and 2,500 sf on the ground floor of Building 8 near the Green Line station. According to the DEIR, the Proponent and MBTA will enter into a reciprocal easement agreement that will allow each party to use all roadways at the site, install utilities and use specified common spaces; in addition, the Proponent seeks an easement from the MBTA to use a portion of its site adjacent to Building 1 and temporary easements for construction of the project. The DEIR did not include a plan showing the location of these easements, as requested by the MBTA; they should be included in the SDEIR.
The DEIR indicated that the Proponent will improve trails north of the site in DCR’s Riverside Park and that the Proponent will secure the necessary easements or approvals from DCR for this purpose. Comments from DCR indicate that the Proponent has committed to design and construct the following improvements: 5
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• Pony Truss Trail Link between the pedestrian bridge crossing the Charles River at Riverside Park and the Depot Tunnel Link; • Depot Tunnel Link between the terminus of Charles Street in Newton and the Pony Truss Trail Link through an existing tunnel below the MBTA/Commuter Rail/Amtrak rail line; • MWRA Path Link between the terminus of the proposed multiuse path along Recreation Road at Riverside Park in Weston to the existing paved recreational trail adjacent to the MWRA facility located near the Charles River crossing of the MassPike; and, • An access ramp from Recreation Road/Connector-Distributor Road to the east end of the proposed Two Bridges trail, and, if feasible, an at-grade shared use path from the east end of the proposed Two Bridges trail directly to the Riverside MBTA Station.
DCR’s comment letter also indicates that the Proponent will design improvements to the pedestrian tunnel under the MBTA Worcester Commuter Rail tracks and complete the design of the proposed Two Bridges trail, which will span Recreation Road/ Connector-Distributor Road and I-95 on two unused rail bridges to connect the Lower Falls neighborhood and the project site.
The Scope included in the ENF Certificate required the DEIR to describe and provide plans of existing and proposed conditions associated with all project components to be constructed off-site and/or on DCR property, including the Riverside Trail, and describe how the path and open space areas will be designed to accommodate bicycle and pedestrian use and enhance the recreational and environmental qualities of those areas. The DEIR did not include this information and it should be provided in the SDEIR.
The DEIR described proposed changes to site topography. The project site is relatively flat. Grove Street, which forms the eastern boundary of the site, rises approximately 30 feet from north to south, creating a steep incline between the site and street at the southern end of the site. The project includes a ramp system near the center of the site and stairs at the southern end of the site to provide access to the proposed multi-use path along the west side of Grove Street. Most of the site will be raised by five feet or less. The area of the existing hotel at the southern end of the site will be lowered by up to 30 ft. The western corner of the site behind the proposed Building 1 will be lowered by up to 10 ft; it is anticipated that blasting of bedrock will be required to achieve the desired elevation. Fill will be placed in the location of proposed Buildings 4 and 5 which are adjacent to Grove Street.
Traffic and Transportation
The DEIR included a transportation study generally consistent with the EEA/MassDOT Transportation Impact Assessment (TIA) Guidelines issued in March 2014. The DEIR described existing and proposed roadway, pedestrian, and bicycle conditions, public transit capacity and infrastructure, roadway and intersection volumes and roadway safety issues.
Analyses of vehicular operations were provided for the weekday morning and evening and Saturday mid-day peak hours for Existing 2019, No Build 2029 and Build 2029 scenarios. The analysis used a 10-year planning horizon rather than the seven-year horizon required under the TIA Guidelines; the DEIR did not provide a justification for the alternative study period. A revised analysis using the seven-year horizon should be included in the SDEIR. The TIA identified potential pedestrian and 6
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bicycle accommodations, roadway improvements, transit service and TDM measures, which will be implemented to minimize impacts to the transportation network. The TIA analyzed the transportation impacts of the project in a study area including the following 33 intersections:
• Grove Street at Riverside MBTA Station Driveway; • Grove Street at Condominium Driveway; • Grove Street at Recreation Road/Massachusetts Turnpike/Route 30/I-95 Northbound (NB) On-Ramp; • Grove Street at I-95 Southbound On-Ramp/Quinobequin Road/Asheville Road; • Grove Street at Riverside Office Building (south)/Apartment Driveway; • Grove Street at Riverside Office Building (center)/Apartment Driveway; • Grove Street at Riverside Office Building (north)/Seminary Avenue; • Grove Street at Hancock Street; • Grove Street at Woodland Road; • Grove Street at Central Street/Auburn Street; • Grove Street at Hagar Street; • Route 16 (Washington Street) at Concord Street; • Route 16 at Grove Street; • Route 16 at Quinobequin Road/Wales Road/1-95 Southbound (SB) Ramps; • Route 16 at 1-95 NB Ramps; • Route 16 at Beacon Street; • Route 16 at Woodland Street; • Route 16 at Auburn Street; • Route 16 at Commonwealth Avenue (Route 30); • Route 16 at Perkins Street/1-90 Eastbound On-Ramp; • Route 16 at I-90 Westbound Off-Ramp; • Route 30 (Commonwealth Avenue) at Melrose Street; • Route 30 at Auburn Street (east intersection); • Route 30 at Lexington Street; • Route 30 at Auburn Street (west intersection); • Concord Street at Hagar Street; • I-95 Exit 21B Collector-Distributor Road at I-95 SB On-Ramp; • Hancock Street at Woodland Street; • Woodland Road at Central Street; • Lexington Street at Auburn Street; • Lexington Street at Wolcott Street; • South Avenue at River Road/I-95 SB Ramps; • South Avenue/Route 30 at I-95 NB Ramps; • I-95 Exit 21 NB On-Ramp; and • I-95 Exit 22 NB Off-Ramp.
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Vehicular access to the site will be provided at three locations. The primary access to the site will be provided by a new signalized intersection at the west side of the site. The intersection will be comprised of a northerly spur from Grove Street, the terminus of the realigned I-95 NB Off-Ramp to Grove Street, and a southerly extension of Recreation Road which would provide travel in both directions. The intersection will also provide access to I-95 NB Exits 24 and 25 via the C-D Road. Another signalized intersection will be constructed at the intersection of Grove Street and the Grove Street spur. The unsignalized intersection of the I-95 SB Off-Ramp at Grove Street will be converted into a rotary. The secondary site access will be provided by a signalized intersection at the site entrance on Grove Street; left turns into the site from eastbound Grove Street will be prohibited. A driveway off of Recreation Road will be used for deliveries to Building 1 and will provide access to the MBTA maintenance yard. The third driveway was referred to in a memo included in an appendix and appears to be shown on site plans, but was omitted from discussions of site access in the DEIR. It should be fully described and analyzed in the SDEIR.
Trip Generation
The project’s trip generation was estimated using trip rates published by the Institute of Transportation Engineers (ITE) Trip Generation Handbook.1 Based on the ITE trip generation rates for land use codes (LUC) 221 (Mid-Rise Residential), 310 (Hotel), 710 (Office) and 820 (Shopping Center), the project will generate 11,368 unadjusted vehicle trips on an average weekday, including 746 vehicle trips during the AM peak hour and 981 vehicle trips during the PM peak hour. On an average Saturday, the project is estimated to generate 9,972 vehicle trips, including 889 vehicle trips during the Saturday midday peak hour.
These trip generation estimates were adjusted to account for mode share, internal capture (trips between uses within the site), existing trips to the hotel and MBTA station, and pass-by trips attributable to the proposed retail uses. The TIA assumed that 75 percent of the residential, 95 percent of the office and 100 percent of the retail trips would be taken by vehicles. As adjusted, the site is expected to generate 508 net new vehicle trips and 73 new transit trips during the weekday AM peak hour; 542 net new vehicle trips and 58 new transit trips during the weekday PM peak hour; and 501 net new vehicle trips and 55 new transit trips during the Saturday mid-day peak period. As noted by MassDOT, the analysis did not estimate the number of trips that will be taken by walking or bicycling, which is inconsistent with the TIA Guidelines. The SDEIR should include a revised estimate of bicycle and pedestrian trips to and from the site and identify appropriate mitigation measures.
Traffic volumes for the Existing 2019 condition were established using turning movement counts (TMC) and automatic traffic recorder (ATR) counts collected on weekdays in June and October, 2018 and on Saturdays in September 2019. The counts collected in 2018 were adjusted to reflect 2019
1 According to the DEIR, the trip generation was based on an earlier iteration of the development program that was slightly larger than currently proposed. It included approximately36,000 sf more office space, approximately 9,000 sf more retail space and 17 fewer residential units than currently proposed. An appendix to the DEIR included a memo that compared the results of the TIA included in the DEIR to impacts expected from the currently proposed development program. The memo concluded that there would be no significant differences in traffic operations. 8
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conditions. The No Build 2029 scenario incorporated a 0.5 percent annual growth rate in vehicle trips and additional trips generated by four planned development projects in the vicinity of the project site. The Build 2029 condition includes the addition of project-generated trips to the No Build 2029 scenario.
Traffic Operations
The TIA provided an evaluation of the impact of project-generated vehicular traffic on roadways in the study area, including an intersection capacity analysis of peak hour traffic operations at study area intersections. The analysis designated intersections with a Level-of-Service (LOS), which reflects the overall operations of an intersection, including traffic speed, delay, and capacity. For urban intersections, LOS D reflects an acceptable level of operations. In general, project-generated traffic will increase congestion and delay at study area intersections, but is not expected to cause significant deterioration of traffic operations. According to the analysis, four signalized intersections will operate at LOS E or LOS F under No Build 2029 conditions and will continue to do so under Build 2029 conditions; however, the analysis concluded that project-generated traffic will not cause any signalized intersections operating at LOS D or better in the No Build 2029 scenario to degrade to LOS E or LOS F. The analysis showed that project-generated vehicle trips will cause operations at seven unsignalized intersections that operate at LOS D or better under No Build 2029 conditions to operate at LOS E or LOS F under the Build 2029 scenario. The impacted unsignalized intersections are generally located along Grove Street in the immediate vicinity of the site. The proposed roadway improvements and resulting operations at mitigated intersections are discussed below.
The DEIR included a review of operations at four intersections on Grove Street on days when the Red Sox played a home game. Traffic volumes were estimated to increase by approximately 10 to 17 percent on game days at the intersections and cause significant impacts under the Build 2029 condition. As described below, proposed roadway improvements are anticipated to mitigate the project’s impacts on study area intersections, including unsignalized intersections on Grove Street that would be most impacted under Build 2029 conditions.
The DEIR included an evaluation of the impacts of project-generated vehicular traffic on sections of I-95 adjacent to the project site, including the I-95/Grove Street interchange (Exit 22 NB and SB) and the C-D Road providing access from I-95 NB to Exits 23, 24 and 25. Weave, merge, diverge, and freeway segment analyses were conducted for highway segments near the project site.2 Similar to the intersection capacity analysis described above, these analyses assign an LOS to reflect traffic operations and vehicular density. According to the DEIR, the project will not have a significant impact on traffic on I-95 and associated ramps. The weave analysis documented congested conditions on the C- D Road between the Grove Street Ramp and Recreation Road Ramp and between the Recreation Road Ramps and MassPike Ramps under Existing 2019 conditions. The addition of project-generated vehicular traffic modeled in the Build 2029 condition would increase congestion in these areas;
2 A weave analysis documents interactions of vehicles in two or more crossing traffic streams moving in the same direction, such as occurs when an on-ramp is closely followed by an off-ramp. A merge/diverge analysis considers the interaction between freeway through traffic and traffic merging or diverging to on- and off-ramps. A freeway segment analysis measures the flow of traffic on the freeway unaffected by weaving, merging or diverging and is based on density of vehicles. 9
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however, these weave segments will be eliminated as part of the project’s reconfiguration of the Grove Street Ramp and Recreation Road.
Roadway Mitigation
The project includes significant changes to roadways in the vicinity of the site, including the I- 95/Grove Street interchange, Grove Street, the C-D Road and Recreation Road. Roadway improvements include the following measures:
• Reconfiguration of the I-95 NB off-ramp to Grove Street to eliminate a direct connection to Grove Street and create a new intersection at the proposed west entrance of the site. The reconfigured ramp would also provide access from I-95 NB to Recreation Road via a southerly extension of Recreation Road to the new intersection. The new intersection would also provide access to Grove Street via the Grove Street extension; • A new signalized intersection between Grove Street and the proposed Grove Street extension. The intersection will provide access from the reconfigured I-95 NB off-ramp to Grove Street via the Grove Street extension and between Grove Street and Recreation Road at the west site entrance intersection. • The Recreation Road extension will provide two-way access between the west site entrance intersection and Recreation Park at the existing terminus of Recreation Road terminus; • Elimination of the existing Recreation Road on- and off-ramps to the C-D Road (Exit 23), which will require all Recreation Road traffic to use the west site entrance intersection and Recreation Road extension; • A signalized intersection on Grove Street will provide access to the site and Riverside MBTA Station near the existing site entrance. Eastbound left turn from the site to Grove Street will be prohibited; • The intersection of Grove Street at the 1-95 SB Ramps will be converted to a one-lane roundabout; and, • The three new signalized intersections will include Adaptive Traffic Signal Technology to accommodate fluctuations in traffic demand conditions and optimize traffic flow.
According to MassDOT, this set of improvements to the I-95/Grove Street interchange and associated roadways would not only improve vehicular access to the project site and the MBTA station, but also address existing deficiencies of some of the weave, merge, and diverge movements at the interchange, improve access to Recreation Road and parkland along the Charles River, and better manage access along the Grove Street corridor. The DEIR evaluated traffic operations at mitigated intersections under a Build with Mitigation scenario. The three new signalized intersections and proposed roundabout will operate at LOS C or better during all peak periods, which will address degraded operations at these currently unsignalized intersections under the Build 2029 condition. As noted above, the reconfigured interchange will also improve weave, merge and diverge movements. The proposed changes to the I-95/Grove Street interchange were described and analyzed in an Interchange Modification Report (IMR) submitted by MassDOT to the Federal Highway Administration (FHWA). The Scope included in the ENF Certificate required that the DEIR include a copy of the IMR. The IMR was not included in the DEIR; instead, a copy of a letter from FHWA to MassDOT
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preliminarily approving the changes was included in an appendix. The IMR should be included in the SDEIR.
According to the DEIR, four intersections within the study area have been identified as Highway Safety Improvement Program (HSIP) locations based on high crash rates compared to the region. The Proponent conducted Road Safety Audits (RSA) at the HSIP locations and three other intersections identified by MassDOT, and developed recommendations for potential safety improvements. As recommended by MassDOT, the SDEIR should include a commitment to implement some of the safety improvements.
Bicycle and Pedestrian Facilities
Sidewalks and crosswalks with pedestrian signals are generally present along roadways and at intersections, however, sidewalks are located only on the west side of Grove Street along a 1,200-ft long section that includes the project site frontage. Bicycle facilities are limited within the study area and no dedicated bicycle facilities are located adjacent to the site. A shared use path is located within DCR’s Riverside Park north of the site.
The project will provide sidewalks and crosswalks throughout the internal roadway system and a pedestrian plaza adjacent to the entrance of Riverside Station. Multi-use paths will be provided along the west side Grove Street adjacent to the site extending to the south to the proposed roundabout at the intersection of Grove Street at I-95 Southbound On-Ramp/Quinobequin Road/Asheville Road. A multi- use path to be constructed along the Grove Street Extension and Recreation Road will connect to the Riverside Park path system north of the site. The Proponent will construct a bicycle lane on the east side of Grove Street along the project site to DeForest Street to the west. At least one secured bicycle parking space will be provided for each residential unit and secured parking will be provided for transit users.
In the ENF and DEIR, the Proponent proposed to improve off-site trail systems along the Charles River and in Riverside Park. The DEIR indicated that the Proponent will enhance the trail system in Riverside Park and connect the proposed shared use path on Recreation Road to the pedestrian bridge across the Charles River. This commitment was included in the list of mitigation measures and Draft Section 61 findings provided in the DEIR. As noted above, plans of existing and proposed conditions associated with all project components to be constructed off-site and/or on DCR property, including the Riverside Trail, were to have been provided in the DEIR. The DEIR did not include this information and it should be provided in the SDEIR. The DEIR did not address conflicts between pedestrians and bicyclists using the Recreation Road shared use path and MBTA and delivery vehicles using the third entrance near Building 1. The SDEIR should evaluate potential conflicts at this location and identify design measures that will ensure the safety of users of the path.
Public Transportation
According to the DEIR, the project is a transit-oriented development planned benefitting from its location at Riverside Station, the western terminus of the MBTA’s D/Riverside Branch of the Green Line (the D Line). The site is also served by Bus Route 558, which provides service between Riverside Station and downtown Boston via the Massachusetts Turnpike/I-90. A private bus service between 11
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Cambridge and New York City stops at Riverside Station. In addition, shuttle buses operated by the Metrowest Regional Transit Authority (MWRTA) and private employers run shuttle buses to Riverside Station throughout the day.
The DEIR included an analysis of existing and future ridership on the D Line and Bus 558. Using ridership data provided by the MBTA, the analysis compared the number of subway riders to the capacity of subway vehicles for each half-hour period throughout the day and the number of bus passengers per bus for each trip.
Under Existing conditions (based on data from Fall 2018), the D Line experiences over-crowded conditions in the inbound direction from 9:00 AM to 9:30 AM. Future ridership under No Build 2029 conditions was established by applying a 1.29 percent annual growth rate to the D Line based on projections developed by the Central Transportation Planning Staff (CTPS) for the Boston Region Metropolitan Planning Organization (MPO) travel demand model. Project-generated trips were estimated based on the low transit use scenario developed for the traffic study (transit accounting for 5 percent of the office and 25 percent of the residential trips) and a more realistic scenario assuming that 15 percent of office trips and 35 percent of residential trips would be taken using subway or bus service. The analysis indicated that Bus Route 558 operates well below capacity under Existing conditions and is projected to continue to do so under all future scenarios modeled in the analysis. The Build 2029 scenario, which includes the addition of projected background growth and project-generated ridership to Existing trips, was modelled for two subway capacity conditions: one with no increase in capacity and another based on the with no increase in subway capacity and added capacity planned in connection with the MBTA’s Green Line Transformation Project. Without additional capacity, the project will contribute to overcrowded conditions in the inbound direction between 9:00 AM and 9:30 AM and in the outbound direction between 6:30 PM and 7:00 PM. No overcrowding is anticipated if the Green Line Transformation Project is implemented. The DEIR did not identify measures to mitigate impacts to the Green Line.
Coordination with MBTA Operations
The Certificate on the ENF highlighted the need for the Proponent to design and construct the project in a manner that will minimize conflicts with the MBTA’s maintenance yard operation of the Riverside Station. The Scope required a detailed review of potential impacts to existing and future use of the MBTA facility and Green Line, and design and construction measures that will minimize and mitigate these impacts. The MBTA’s comment letter indicated that there has been ongoing coordination with the Proponent on these matters that was not reflected in the DEIR. Much of the information requested in the MBTA’s comment letter on the ENF and required in the Scope for the DEIR was either not provided or was inadequate in form or content. Critical issues not adequately addressed in the DEIR include the following:
• Design and operation of a separate entrance to the site for buses; • Paths of travel by pedestrians through the site to the Riverside Station; • Capacity of the site to accommodate berths for busses paths of travel from these areas to other modes of travel;
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• Potential impacts to MBTA maintenance and transit operations from construction methods, staging and phasing and measures to minimize these impacts; • Consistency of the design and operation of proposed parking garage, bus stations and other facilities to be provided by the project with standards of the MBTA and Massachusetts Architectural Access Board; • Maintenance of delivery routes to the maintenance facility, including delivery of new Green Line cars, during and after construction; and, • Management of stormwater and snow associated with facilities that will be maintained by the MBTA in the future.
The analyses and information listed above, and as detailed in the MBTA’s comment letter on the DEIR, must be provided in the SDEIR.
Parking
The project will include a parking garage with 1,990 spaces, including 1,000 spaces dedicated for use by transit users, and 51 surface parking spaces. According to the DEIR, electric vehicle (EV) charging stations will be provided at 10 percent of the non-MBTA parking spaces. The Scope included in the ENF required the DEIR to provide an analysis of how the parking supply was developed for each use and evaluate opportunities for reducing parking demand through the implementation of TDM measures and shared parking. The DEIR included a minimal discussion of parking. It referred to a parking memorandum provided in the appendix and indicated that full documentation of a shared parking analysis prepared for the City was provided in an appendix. The appendix included a copy of a presentation with slides that summarized how the number of parking spaces was calculated, noted that measures to reduce vehicular access to and from the site and shared parking could minimize the peak parking demand and mentioned that digital, automated and smart parking systems could direct drivers to available spots. The SDEIR should provide a full analysis of parking demand and supply and include supporting documentation.
Transportation Demand Management (TDM)
According to the DEIR, the Proponent will implement a TDM plan to minimize single- occupancy vehicle trips. The TIA noted that the Proponent will designate a TDM Coordinator who will be responsible for implementing TDM measures and that residents and employees would be eligible for full or partial reimbursement of the cost of MBTA passes and/or bikeshare memberships. The TIA referred to a more detailed TDM plan provided in an appendix, which provided a comprehensive overview of potential TDM measures. The DEIR and documents in the appendix did not clearly indicate which measures would be adopted by the Proponent and suggested that some measures may be implemented if traffic exceeds the conditions predicted in the TIA. The Draft Section 61 Findings did not identify any TDM commitments. The SDEIR should clearly identify all measures to be included in the TDM plan and identify the measures as commitments in the Draft Section 61 Findings.
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Traffic Monitoring Plan
The DEIR included a commitment to conduct traffic monitoring, but did not identify the type or location of traffic counts that would be collected, as recommended in MassDOT’s comment letter on the ENF. The DEIR indicated that traffic monitoring would be commenced upon full occupancy of each phase and continue annually for two years after full build-out and that and that parameters of the monitoring plan that would be developed by the City. The SDEIR should include a detailed and comprehensive traffic monitoring plan consistent with MassDOT’s recommendations.
Climate Change
The DEIR provided an analysis of stationary- and mobile-source GHG emissions and identified measures to mitigate the project’s GHG impacts. It reviewed existing and future site conditions and described design features to improve resiliency to the effects of climate change.
Greenhouse Gas (GHG) Emissions
The DEIR included a GHG analysis based on the MEPA GHG Policy. The GHG Policy requires projects to quantify carbon dioxide (CO2) emissions and identify measures to avoid, minimize or mitigate such emissions. The analysis quantified the direct and indirect CO2 emissions associated with the project's energy use (stationary sources) and transportation-related emissions (mobile sources). The DEIR outlined and committed to mitigation measures to reduce GHG emissions.
The stationary source GHG analysis evaluated CO2 emissions for the Base Case and the Design Case. The Base Case was designed to meet the minimum energy requirements of the 9th Edition of the Massachusetts Building Code, which references the American Society of Heating, Refrigerating and Air-Conditioning Engineers (ASHRAE) 90.1-2013. The Design Case included additional energy- efficiency measures proposed in the Preferred Alternative.
The GHG analysis used eQuest modeling software to quantify emissions from the project’s stationary sources. The model estimated energy use of a prototype of each building use (medium-density residential, high-density residential, hotel, lab/office, retail and parking garage). The project’s overall stationary source CO2 emissions were estimated at 6,832 tons per year (tpy) under the Base Case scenario. The mitigation measures included in the Design Case will reduce GHG emissions to 5,449 tpy, a reduction of 2,042 tpy (20.2 percent). The estimates of GHG emissions were calculated using the CO2 emission factors of 682 pounds per megawatt-hour for grid electricity published by the Independent System Operator- New England (ISO-NE) in the 2016 ISO New England Electric Generator Air Emissions Report and 117 pounds per million British Thermal Units (MMBtu) estimated by the U.S. Energy Information Administration.
The project design includes significant measures that will minimize the proposed buildings’ GHG emissions. According to the DEIR, two of the residential buildings will be designed to Passivehouse Institute-U.S. (PHIUS) standards and the six other residential buildings will include high- performing envelopes that achieve PHIUS standards for air-infiltration and heating and cooling load reduction. As noted by the Department of Energy Resources (DOER), the design of the building 14
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envelope will exceed the requirements of the revised Building Code scheduled to take effect in August 2020. More specifically, building envelope design features include:
• Triple-pane windows with U-value 0.22; • Roof insulation that will exceed August 2020 Code requirements by 60 percent; • Vertical wall performance that will exceed August 2020 code requirements by 23 percent; • Except for the hotel, roof insulation will be well above code August 2020 requirements; and, • Inefficient glass curtain wall/spandrel assemblies are not proposed in any of the buildings.
The project also includes electric space heating in all the residential buildings and partial electrification of space heating in the hotel. As noted above, the six residential buildings that are not proposed to be designed to PHIUS standards have envelopes and heating/cooling systems that are similar to the two that will be PHIUS-certified. According to DOER, the six non-Passivehouse residential buildings will have an energy use intensity (EUI) between 32 and 34 thousand British thermal units per square foot per year (kBtu/sf-yr) while the two PHIUS-certified buildings will have an EUI of about 18 kBtu/sf-yr. The project’s reduction of stationary-source GHG emissions can be nearly tripled by designing all eight residential buildings to the PHIUS standard. The SDEIR should clarify why the EUI values are so different for the buildings, despite their similar building envelope design, and include an analysis of the feasibility of designing all buildings to PHIUS standard. Comments from the City indicate that the Proponent has committed to constructing three PHIUS-certified residential buildings. The SDEIR should provide an updated GHG analysis based on the construction of at least three PHIUS-certified buildings.
The Proponent evaluated the feasibility of constructing rooftop solar PV systems. According to the DEIR, the buildings could accommodate a PV system with a capacity of approximately 11,529 kilowatts (kW) that could generate that could generate 1,806,505 kilowatt-hours (kWh) annually. The DEIR included a commitment to construct building rooftops that could support a PV system of this size.
Mobile Source GHG Emissions
The DEIR analyzed the project’s mobile-source CO2 emissions using the EPA’s MOVES emissions model and data from the traffic study. The MOVES model calculates emissions factors for vehicles expressed in a volume per distance travelled. Total emissions of vehicles are estimated by applying Vehicle Miles Travelled (VMT) data to vehicles in the study area and emissions from idling vehicles. The analysis calculated GHG emissions under the Existing 2019, No Build 2029 and Build 2029 scenarios. Regional GHG emissions from mobile sources are expected to decrease from 30,595 tpy under Existing 2019 conditions to 26,937 tpy under No Build 2029 conditions due to anticipated improvements in vehicle engine and emissions technologies. Regional GHG emissions in the 2029 Build condition were estimated as 28,889 tpy, representing an increase of 1,952 tpy due to project-related vehicle trips. The proposed roadway improvements will reduce emissions by 588 tpy (30 percent) from 1,952 tpy to 1,364 tpy. The SDEIR should quantify additional reductions in GHG emissions due to implementation of TDM commitments.
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Adaptation and Resiliency
Consistent with M.G.L. c. 30, § 61, MEPA review of projects subject to an EIR must consider the reasonably foreseeable climate change impacts of projects, including GHG emissions and effects such as predicted sea level rise; and (2) ensure that projects subject to MEPA review take all feasible measures to avoid, minimize, or mitigate “Damage to the Environment” (as defined in the MEPA statute), including GHG emissions.
The DEIR included a review of projected changes in temperature and precipitation in the Charles River Basin based on data prepared by the Northeast Climate Science Center at the University of Massachusetts at Amherst3 and by the City of Boston in its 2016 Climate Ready Boston report. The site is expected to be impacted by increased temperatures, including more days with temperatures exceeding 95 degrees Fahrenheit (F), and higher annual precipitation and more frequent untense storm events. The City is a participant in the Commonwealth’s Municipal Vulnerability Preparedness (MVP) program and prepared a Climate Vulnerability Assessment and Adaptation and Resiliency Action Plan (CVA) in 2018. The CVA identifies the Riverside Station site as potentially vulnerable to increased flooding due to its proximity to wetlands, but it is not considered to be prone to flooding. Due to its large paved parking lot, the CVA recognizes the site as an area subject to high temperatures.
Resiliency measures have been incorporated into the project design to address higher temperatures and potential flooding in the future. The project will minimize the urban heat island effect by reducing impervious area at the site, adding densely vegetated landscaped areas and trees and using materials with less heat-absorbing capacity such as green roofs. The project includes buildings designed to Passivehouse standards that will minimize cooling needs while providing comfortable conditions.
The DEIR reviewed data developed by the cities of Boston and Cambridge that predict that precipitation levels for the 10-year 24-hour storm event will range from 6.08 to 6.65 inches by the year 2100. It notes that the Boston Water and Sewer Commission recommends that that drainage systems be designed to accommodate a 6-inch storm event representing the 10-year storm in 2100 and an 8.8-inch storm event based on predicted 100-year storm conditions in 2100. It is not clear from the DEIR whether the proposed stormwater management system has been designed to accommodate these events; this issue should be addressed in more detail in the SDEIR. Flooding will be minimized by the use of stormwater BMPs that will encourage infiltration Low Impact Design (LID) measures such as green roofs, tree pits, planters and permeable pavement. Emergency generators will be located on rooftops to avoid damage from flooding events. According to the DEIR, the Proponent will evaluate the use of rooftop solar PV systems with battery storage that could provide electricity during power outages.
Wetlands and Stormwater
The project will reduce impervious area by converting some paved areas to landscaped open space. I note that the Alternative Analysis section of the DEIR indicated that the project will reduce impervious area from 11.8 acres under existing conditions to 11.2 acres but the discussion of the
3 This data is available through the Climate Change Clearinghouse for the Commonwealth at www.resilientMA.org 16 EEA# 16024 DEIR Certificate May 15, 2020
proposed stormwater management system indicated that paved surfaces will be reduced to 37 percent of the site. The SDEIR should clarify pre- and post-development impervious areas and rooftop areas used to design and evaluate the proposed stormwater management system. The site includes stormwater infrastructure consisting of catch basins that are connected to drain pipes that discharge to the Charles River with little treatment. Runoff from most of the site is conveyed to the City’s 60-inch culvert that discharges into the Charles River. Stormwater from the southern end of the site is conveyed to a drainage system in Recreation Road and discharged to the Charles River.
According to the DEIR, the project includes construction of a stormwater management system that will meet MassDEP’s Stormwater Management Standards (SMS). Surface runoff will be collected and treated using Best Management Practices (BMPS) including deep-sump catch basins, proprietary water quality units and three subsurface infiltration systems. The project will reduce post-development peak discharge rates and volumes by reducing impervious area. The stormwater management system will be designed to meet requirements for land uses with higher potential pollutant loadings (LUHPPL) by infiltrating the first 1.0 inches of rainfall over the site and removing at least 44 percent of Total Suspended Solids (TSS) prior to discharge into an infiltration system. It will include BMPs to remove 80 percent of the TSS in runoff prior to discharge to the City’s drainage system. The BMPs will reduce phosphorous concentrations from stormwater by at least 65 percent, as required by the TMDL calculated for the Charles River. The project may also include green infrastructure and Low Impact Design (LID) measures such as green roofs on Buildings 3 and 4, landscaped strips and planters adjacent to sidewalks, capture roof runoff for use in irrigation, permeable pavement and bioretention areas.
Subsurface conditions documented in the DEIR include the presence of ash and cinders within the existing urban fill soil, documented releases of hazardous material on a portion of the site and underground storage tanks (UST), some of which have been removed from the site. As noted by MassDEP and other commenters, the DEIR did not include a demonstration that soils and groundwater conditions are suitable for infiltration, as required in the Scope. This information is necessary in order to address impacts from infiltration of stormwater through potentially contaminated soils or recharge to groundwater that is close to the surface. The DEIR included a commitment to construct a stormwater management system that will conform to the SMS and address the Charles River TMDL for nutrients and pathogens, but did not include a detailed analysis or calculations in support of the proposed design of the system. It did not address the discharge of stormwater from the City’s outfall, provide an analysis of erosion caused by stormwater discharges or evaluate opportunities for mitigating this condition, as required by the Scope. These analyses, based on the proposed post-construction impervious area, should be provided in the SDEIR.
The project includes pathway improvements in or near wetlands adjacent to the Charles River in Riverside Park. The Scope included in the ENF Certificate required the DEIR to identify any impacts to wetland resource areas associated with off-site drainage infrastructure and improvements to paths and open space. The DEIR did not include this information and it should be provided in the SDEIR.
Water and Wastewater
The project will require the use of 96,900 gpd of water and will generate 92,210 gpd of wastewater. The City is supplied with drinking water through its connection to the MWRA’s water 17
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system. Water service to the site is provided by eight-inch and 12-inch diameter water mains in Grove Street that are maintained by the City. The project will include a l2-inch diameter water loop through the site to which every building will be connected. The proposed water loop will be connected to the 12- inch water main in Grove Street at two locations. Water service to the MBTA maintenance facility will provided by two connections to the proposed water loop. According to the DEIR, the City’s water system has adequate capacity to serve the project site. The DEIR indicated that an integrated water conservation plan will be developed that will be tailored to each building and will include sub-meters for each unit. The DEIR did not identify potential water conservation measures that could be implemented or a project-wide water goal for reduced water use; the SDEIR identify specific water conservation measures that will be incorporated into the project.
A 48-inch water main within a 30-ft wide easement maintained by the MWRA crosses the western part of the site. The project includes the removal of an 875-ft long section of the water main and its replacement with a 1,050-ft long 48-inch main within a 30-ft MWRA easement. The water main relocation is necessary to permit the construction of Buildings 1 and 10. The proposed route for the section to be replaced would follow Groove Street Extension, turn into the site at the proposed site entrance and turn north along the eastern side of Building 1 to rejoin the existing water main.
Wastewater from the proposed buildings will be conveyed to a new sewer to be constructed within the site that will connect to the MWRA’s Albemarle sewer main via a 10-inch City-owned sewer main. According to the DEIR, sufficient capacity exists within the City and MWRA sewer infrastructure to accept wastewater flows from the site. The DEIR included an appendix that calculated the Proponent’s contribution to inflow/infiltration (I/I) removal will be between $5.0 million and $5.9 million.
Solid and Hazardous Waste
According to the DEIR, three releases of hazardous material regulated under the Massachusetts Contingency Plan (MCP) or located on MBTA-owned land. Two of the releases are entirely confined within the maintenance facility. The third release, designated as Release Tracking Number 3-10565 (RTN 3-10565), extends onto the northern part of the project site. Remediation of RTN 3-10565 included the removal of 2,000 tons of oil-impacted soil and rail ballast and its disposal at an off-site location. In addition, two underground storage tanks (UST) associated with the maintenance facility were removed and one UST has been removed from the existing hotel site. No Activity and Use Limitations (AUL) that restrict uses on the site are anticipated to be necessary. A construction Release Abatement Measure (RAM) Plan will be prepared to address potential disturbance of contaminated soil at the site. The RAM Plan will include a health and safety plan that will identify construction practices to protect workers, dust control measures and air and dust monitoring. Asbestos is suspected to be present in the existing hotel. Once the hotel building is no longer occupied, an asbestos survey will be completed and all asbestos containing materials (ACM) will be removed prior to its demolition. Any ACM removed from the building will be managed as a “special waste” in accordance with MassDEP’s Solid Waste Management Regulations and transported to an off-site disposal facility. Construction and demolition (C&D) debris will be reused or recycled on site where feasible. Concrete demolition material, blasted bedrock material and large boulders will be crushed and reused as fill on site.
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Construction Period Impacts
The DEIR provided an overview of impacts associated with each phase of construction. For Phase 1, it provided a conceptual-level plan showing construction zones, staging areas and areas available for parking and access to Riverside Station by transit users, but did not include a detailed Construction Management Plan (CMP) specific to the MBTA uses, as required by the Scope for the DEIR; this should be provided in the SDEIR.
An appendix to the DEIR included a Draft CMP (DCMP) prepared for the City. The DCMP provided a comprehensive review of potential air, noise, traffic and water quality impacts during the construction period and identified the following mitigation measures:
• Implementation of construction traffic management measures to minimize impacts to the community, including designated truck routes using I-95 and minimizing construction traffic to the site during peak hours; • Compliance with MassDEP’s Solid Waste regulations and implementation of measures to reuse and recycle construction and demolition (C&D) debris and appropriately handle and dispose of asbestos; • Minimizing air quality impacts by using wetting agents on exposed soil, roadway sweeping, compliance with anti-idling regulations and participation in MassDEP’s Diesel Retrofit Program; • Monitoring of soil and groundwater disturbance by a Licensed Site Professional (LSP); • Using sedimentation and erosion controls in compliance with the requirements of the SMS and the NPDES General Permit for Construction Activities; • Minimizing noise impacts by complying with the City’s noise requirements, using mufflers on construction equipment, working within hours designated by the City and turning off idling equipment; and. • Conducting blasting activities during daytime hours and in accordance with applicable safety regulations with prior notification to abutters.
The DMCP included additional construction phasing plans, but they were not described in any accompanying text.
Conclusion
As noted above, the DEIR did not adequately address the requirements of the DEIR Scope included in the ENF Certificate. Comments from MBTA, DCR and MassDEP indicated that the DEIR did not adequately address their comments on the ENF; these agencies request additional information and analysis necessary to identify permitting requirements, environmental impacts, and measures to avoid, minimize, and mitigate impacts. As such, I cannot find that the DEIR and supplemental information have satisfied the regulatory requirements to ensure that the project’s environmental impacts have been clearly described and fully analyzed and that the project takes all feasible means to avoid Damage to the Environment. In addition to inadequately and incompletely responding to the Scope, the DEIR provided key information in appendices rather than the main chapters of the DEIR and did not
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provide direct responses to many of the comments received on the ENF. Accordingly, I am requiring the Proponent to file an SDEIR pursuant to Section 11.08(8)(b)(3) of the MEPA regulations.
SCOPE
General
The SDEIR should follow Section 11.07 of the MEPA regulations for outline and content, as modified by this Scope. The SDEIR should clearly demonstrate that the Proponent has sought to avoid, minimize and mitigate Damage to the Environment to the maximum extent feasible. I expect the SDEIR will provide a comprehensive response to comments on the DEIR that specifically address each issue raised in the comment letter; references to a chapter or sections of the SDEIR alone are not adequate and should only be used, with reference to specific page numbers, to support a direct response. The SDEIR should identify measures the Proponent will adopt to further reduce the impacts of the project since the filing of the DEIR, or, if certain measures are infeasible, the SDEIR should discuss why these measures will not be adopted.
The information and analyses identified in this Scope should be addressed within the main body of the SDEIR and not in appendices. In general, appendices should be used only to provide raw data, such as drainage calculations, traffic counts, capacity analyses and energy modelling, that is otherwise adequately summarized with text, tables and figures within the main body of the SDEIR. Information provided in appendices should be indexed with page numbers and separated by tabs, or, if provided in electronic format, include links to individual sections. Any references in the SDEIR to materials provided in an appendix should include specific page numbers to facilitate review.
The SDEIR should address, in a detailed and comprehensive manner, issues raised in comment letters submitted by MBTA, MassDOT, MassDEP and DCR, which are incorporated by reference herein. In general, information and analyses provided in response to these comment letters should be incorporated into the main body of the SDEIR rather than provided solely in the Response to Comments section of the SDEIR.
Project Description and Permitting
The SDEIR should include a clear and consistent description of the project, including updated plans that clearly identify existing and post-development conditions, including, at a minimum, site grading, buildings, public areas, impervious areas, pedestrian and bicycle accommodations, MBTA buildings and facilities, bus berths, and stormwater and utility infrastructure, at a legible scale. The SDEIR should identify any phasing of the project and include a detailed description of all project components and activities associated with each phase. It should identify and describe State, federal and local permitting and review requirements associated with the project and provide an update on the status of each of these pending actions. It should include a description and analysis of applicable statutory and regulatory standards and requirements, and a discussion of the project’s consistency with those standards. The SDEIR should indicate whether the Proponent will seek State Financial Assistance in connection with the project. 20
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Land
The SDEIR should clearly and in detail identify and describe any temporary or permanent interests in real property the Proponent is seeking from the MBTA and provide an update on the proposed terms of the MBTA lease, if necessary. It should identify any areas of the site that will be subject to easements by the MBTA, MWRA or DCR under post-construction conditions.
The DEIR indicated that the Proponent may construct a multi-use paths and other open space improvements on DCR parkland adjacent to the Charles River. The SDEIR should identify all project components, including roadways, paths and open space improvements, to be constructed off-site and/or on DCR property. It should provide plans and detailed descriptions of the trail and open space improvement summarized above and detailed in DCR’s comment letter. In consultation with DCR, the SDEIR should describe the Proponent’s commitments for these improvements and include a copy of a draft Memorandum of Understanding (MOU) or any other agreements reached with DCR.
Traffic and Transportation
The SDEIR should describe and provide plans of the third driveway proposed near Building 1. It should clarify whether it is intended as a temporary or permanent feature and any measures necessary to restrict its use. The SDEIR should review potential conflicts between pedestrians and bicyclists using the proposed shared use path and vehicles using this driveway, and identify any necessary mitigation measures. The SDEIR should include a detailed description of all on-site and off-site bicycle and pedestrian facilities to be designed and/or constructed by the Proponent.
Some commenters noted that major transportation infrastructure projects, such as MassDOT’s I- 90 Allston Interchange project, will strain the regional public transportation and roadway system and question whether the project will affect the ability of the MBTA and MassDOT to accommodate the resulting change in travel patterns. The Proponent should consult with MassDOT and MBTA regarding the status of planned infrastructure projects and anticipated measures that may be implemented to maintain transportation capacity.
Coordination with MBTA Operations
The SDEIR should include the analyses requested in the MBTA’s letter, including a detailed analysis of potential bus-only access lanes. I note that an appendix to the DEIR included bus turning movement diagrams and analyses of LOS at intersections used by buses; however these analyses were provided without any accompanying description or analysis, which should be provide din the SDEIR. The SDEIR should provide a detailed analysis, accompanied by plans, describing construction-period and final build conditions with respect existing and future MBTA maintenance operations. All information and analyses should be provided in the body of the SDEIR in the format requested by the MBTA.
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Traffic Operations
The TIA included in the DEIR provided was based on low transit ridership by residents and visitors to the site. As a transit-oriented development adjacent to the Riverside Station, the project should set high goals for transit and other alternate modes of travel. Comments from MassDOT recommend that the traffic analysis and mitigation program be revised to reflect more realistic mode shares for transit, bicycle and pedestrian use. The revised analysis should use a seven-year study period, consistent with the TIA Guidelines. MassDOT notes that the Proponent could conduct a sensitivity analysis to determine whether or not a revised capacity analysis is necessary. If a sensitivity analysis is performed, it should also evaluate any potential differences due to the use of a 10-year rather than seven- year study period. The Proponent should consult with the MEPA Office prior to providing either of these analyses in the SDEIR. The SDEIR should provide a copy of the IMR, as required by the Scope for the DEIR. As recommended by MassDOT, the SDEIR should identify safety measures identified in the RSAs that the Proponent will implement.
Transportation Demand Management and Transportation Monitoring
The Scope required that the DEIR include a comprehensive TDM plan with a thorough evaluation of feasible TDM measures to reduce the SOV trips to the site by both employees and visitors, evaluate the expected trip reduction of each and include commitments by the Proponent to adopt all feasible measures. As noted above, the SDEIR should include a comprehensive analysis of potential TDM measures and identify measures the Proponent will implement. At a minimum, TDM measures should include those identified in the ENF Certificate and recommended by MassDOT. The SDEIR should provide a proposed traffic monitoring plan, including data to be collected, and describe how it will be used to monitor performance of TDM measures.
Parking
The SDEIR should include a comprehensive analysis of shared parking at the site, supported by text and graphics. It should provide the information regarding the parking garage requested by the MBTA, including details of its design and operation.
Climate Change
All residential buildings have been designed with high performing envelopes that appear to meet Passivehouse building standards; however the DEIR indicated that only two of them would be certified by PHIUS. The SDEIR should clarify differences between the residential buildings designed to PHIUS standards and those that are not, and account for differences in the modelled EUI for the buildings. As noted earlier, the Proponent has committed to the City to construct three residential buildings to PHIUS standards. The SDEIR should include an updated analysis of the project’s anticipated GHG reductions based on construction of at least three PHIUS-certified residential buildings, and, if committing to less than three PHIUS-certified buildings, provide a clear justification for this reduced level of mitigation. As requested by DOER, the GHG analysis in the SDEIR should update the Base Case to reflect August 2020 building codes with Massachusetts amendments, confirm that the four-story residential buildings will conform to section R406 of the Stretch Code and incorporate retail portions of residential buildings 22 EEA# 16024 DEIR Certificate May 15, 2020
in modelling calculations. The DEIR should evaluate DOER’s recommendations for analyzing external shading and solar heat gain and the use of air source heat pumps for domestic hot water production,
An updated mobile-source GHG analysis should be provided in the SDEIR to reflect TDM measures to be adopted by the project, and describe what measures the project will take to make equivalent reductions in mobile source GHG emission in the event that TDM monitoring indicates less than anticipated effectiveness of TDM measures in reducing SOV trips or vehicle use generally. The SDEIR should provide an update on any additional resiliency measures evaluated by the Proponent and incorporated into the project design. The SDEIR should provide more information about potential flooding identified in the City’s CVA, whether there are conditions under which the site may be subject to flooding from off-site sources and identify anticipated base flood elevation levels. It should clarify what future precipitation conditions can be accommodated by the proposed stormwater management system and analyze potential flooding at the site the MBTA facility that could be affected by intense rainfall events. The SDEIR should identify measures the project will take to locate critical infrastructure and/or ground-floor residences or otherwise provide protection from flooding.
Wetlands and Stormwater
The DEIR did not provide a description of wetland resource areas potentially affected by the project, including areas subject to stormwater improvements or increased discharge, and areas proposed for open space or trail improvements, as required in the Scope included in the ENF. The SDEIR should include this information and identify any impacts to wetland resource areas and mitigation measures.
As noted above, the DEIR did not contain sufficient information about post-construction site drainage characteristics and the design of the proposed stormwater management system to evaluate the project’s compliance with the SMS and Charles River TMDLs. In addition, the DEIR did not address potential impacts associated with the siting of infiltration systems in areas with contaminated soils. The SDEIR should provide a more detailed analysis of existing and proposed drainage conditions, including impervious area and rooftop runoff, and document that the proposed stormwater management system will meet SMS and TMDL requirements. It should confirm that infiltration systems will be designed and sited to minimize impacts from contaminated soils.
Construction Period Impacts
The SDEIR should provide a detailed CMP that describes how construction activities will be undertaken to minimize interference with MBTA service and maintenance activities. It should include the DCMP and plans, updated if applicable, within the SDEIR and list construction period mitigation measures in the draft Section 61 Findings.
Mitigation and Section 61 Findings
The SDEIR should include a separate chapter that summarizes measures to avoid, minimize and mitigate environmental impacts. It should include draft Section 61 Findings for the MBTA and for State Agency from which permits are required. The proposed Section 61 Findings should specify in detail all feasible measures the Proponent will take to avoid, minimize and mitigate potential environmental 23 EEA# 16024 DEIR Certificate May 15, 2020
impacts to the maximum extent practicable. The draft Section 61 Findings should clearly identify parties responsible for funding and implementation, and the anticipated implementation schedule that will ensure mitigation is implemented when appropriate in relation to environmental impacts.
The SDEIR should include a commitment to provide a GHG self-certification to the MEPA Office at the completion of the project. It should be signed by an appropriate professional (e.g. engineer, architect, transportation planner, general contractor) indicating that all of the GHG mitigation measures, or equivalent measures that are designed to collectively achieve identified reductions in stationary source GHG emission and transportation-related measures, have been incorporated into the project. To the extent the project will take equivalent measures to achieve the identified reductions, I encourage the Proponent to commit to achieving the same level of GHG emissions identified in the mitigated (design) case expressed in volumetric terms (e.g., tpy).
Responses to Comments
The SDEIR should contain a copy of this Certificate and a copy of each comment letter received. In order to ensure that the issues raised by commenters are addressed, the SDEIR should include direct responses to comments to the extent that they are within MEPA jurisdiction. This directive is not intended, and shall not be construed, to enlarge the scope of the DEIR beyond what has been expressly identified in this certificate.
Circulation
The Proponent should circulate the SDEIR to those parties who commented on the ENF or DEIR, to any State Agencies from which the Proponent will seek permits or approvals, and to any parties specified in section 11.16 of the MEPA regulations. Per 301 CMR 11.16(5), the Proponent may circulate copies of the DEIR to commenters in CD-ROM format or by directing commenters to a project website address. However, the Proponent must make a reasonable number of hard copies available to accommodate those without convenient access to a computer and distribute these upon request on a first- come, first-served basis. The Proponent should send correspondence accompanying the CD-ROM or website address indicating that hard copies are available upon request, noting relevant comment deadlines, and appropriate addresses for submission of comments. The SDEIR submitted to the MEPA office should include a digital copy of the complete document. A copy of the SDEIR should be made available for review at the Newton Public Library.4
May 15, 2020 Date Kathleen A. Theoharides
4 Requirements for hard copy distribution or mailings will be suspended during the Commonwealth’s COVID-19 response. Please consult the MEPA website for further details on interim procedures during this emergency period: https://www.mass.gov/orgs/massachusetts-environmental-policy-act-office. 24 EEA# 16024 DEIR Certificate May 15, 2020
Comments received:
04/15/2020 Newton Lower Falls Improvements Association 04/17/2020 Metropolitan Area Planning Commission (MAPC) 04/20/2020 Charles River Watershed Association (CRWA) 04/20/2020 Frederick P. Salvucci 04/24/2020 Lisa L. Mead on behalf of Woodland Golf Club 04/24/2020 Massachusetts Water Resources Authority (MWRA) 04/28/2020 Department of Energy Resources (DOER) 05/01/2020 City of Newton 05/01/2020 John H. McElduff 05/01/2020 Department of Conservation and Recreation (DCR) 05/01/2020 Massachusetts Department of Environmental Protection (MassDEP)/Northeast Regional Office (NERO) 05/01/2020 Massachusetts Department of Transportation (MassDOT) 05/01/2020 Amy Mah Sangiolo 05/01/2020 Frederick P. Salvucci 05/08/2020 Massachusetts Bay Transportation Authority (MBTA)
KAT/AJS/ajs
25 Telephone (617) 796-1120
Telefax (617) 796-1142 City of Newton, Massachusetts TDD/TTY Department of Planning and Development (617) 796-1089 www.newtonma.gov 1000 Commonwealth Avenue Newton, Massachusetts 02459 Ruthanne Fuller Barney S. Heath Mayor Director
May 1, 2020
Kathleen Theoharides Secretary of Energy and Environmental Affairs Executive Office of Energy and Environmental Affairs (EEA)
Attn: MEPA Office, Alex Strysky 100 Cambridge Street, Suite 900 Boston MA 02114
Subject: Riverside Station Development-EEA #16024 City of Newton Comments on the Draft Environmental Impact Report
Dear Secretary Theoharides,
The City of Newton is pleased to submit comments on the draft Environmental Impact Report (the “EIR”) for the Riverside Station Development. Members of several City Departments have read the EIR and offer the following comments regarding transportation, sustainability, stormwater management, and solid/hazardous waste.
Transportation:
• The City appreciates the proponent’s strong Transportation Demand Management Plan in conjunction with the infrastructure improvements; however, the proponent should consider increasing options for alternative methods of transportation should traffic exceed projections. Such options could include a shuttle to other transit hubs or regional points of interest or working with the Massachusetts Bay Transportation Authority (the “MBTA”) to pilot bus routes as part of the MBTA’s Better Bus Project.
• Car-share program- We note that the Bike-Share Program is mentioned. We think that there is also a good opportunity to include the car-share program that the City is piloting in three City-owned parking lots. Under this program, residents, patrons, and employees will have the use of EVs provided by car-share companies, with charging stations also provided on-site. This will promote the use of EVs and may also enable residents to avoid owning cars.
Preserving the Past Planning for the Future Page 2 of 4
• We also suggest that preferential parking for EVs be considered.
Green House Gas Emissions and Air Quality Assessment: • Stationary sources- The analysis for medium- and high-density residential was done for all units based on the Passive House Certified design levels. Since only the residential portions of three buildings are being designed to this standard, it would be more accurate to either model them all on the Passive House Principles standard or to model three buildings on the PH Certified standard and five buildings on the Passive House Principles standard.
• We wonder if the proponent has evaluated Passive House design for the office and hotel buildings and, if not, why that decision was made.
Solar: • There are some areas that the developer may want to investigate more closely to improve the economics and practicality of solar projects that are built in tenant/landlord situations. The proponent may want to consider whether community solar may be appropriate for this project, since the renters will be paying the utility bills and there is an opportunity under SMART for this approach that can benefit both the owner of the solar systems and the renters.
• Use of battery systems will also increase the SMART incentives and enable the owner to get payments under the utility and ISO-NE demand response programs by lowering their peak electricity use. We note that batteries are mentioned only as a resiliency issue, but because batteries can lower peak demand, they also provide financial benefits.
• Modified accelerated depreciation (MACRS) may be available for the solar projects, which would also improve the project economics. We are not sure if this program still exists and, if so, exactly what form it takes, but in the past, it has provided significant tax advantages for entities with taxable income.
Climate Change Adaptation and Resiliency: • Green roofs and roof-mounted solar- It is not clear to us how the proponent thought about photovoltaic vs. green roofs. Also, we assume that making white any areas of the roofs that are not green is beneficial because of the albedo effect, even if also used for PV.
• EVs- It is not clear whether EVs were included in the climate change portion of the analysis.
Preserving the Past Planning for the Future Page 3 of 4
Wetlands and Stormwater: • The City appreciates the thoughtful approach to employ multiple stormwater management best management practices. The temporary storage and re-use of rainwater is commendable. As the project progresses, it would be helpful to know how much rainwater harvesting will be employed (in the long-term) given the lack of lawn space and limited landscaping proposed.
• Given the number of best management practices and the site’s proximity to wetland resources, the proponent should develop a strong operations and maintenance plan(s) to ensure the long-term functionality of the stormwater management system and to protect adjacent resources.
• Insufficient information is provided in the EIR to determine if residual contamination from past releases could be mobilized by the proposed infiltration practices. Of concern is Infiltration System 101 (beneath building 9) because it coincides with the disposable site boundary for Release Tracking Number (RTN) 3-10565. The horizontal and vertical extents of oil and/or hazardous materials (OHM) in soils should be provided in cross- sections, noting seasonal high groundwater elevations. The bottom elevations of the proposed infiltration systems need to be reviewed with this information in mind. A groundwater contour map would be useful, too.
Solid and Hazardous Waste:
• The proponent should conduct an analysis estimating the expected solid waste generation by weight and volume for each of the uses proposed for the site with consideration to peak volumes. • Several reportable OHM releases to the environment have occurred over the years at the project site. Based on the Mass DEP database these releases have been addressed in accordance with the Massachusetts Contingency Plan (MCP) for the current land uses. The impacts of these releases for the proposed future uses were reviewed by Sanborn, Head, & Associates. Given the scale and high-profile nature of this project, it would be prudent to have an independent third-party review the past releases and subsequent field investigations. Would the DEP Bureau of Waste Site Clean-up be able to review the past release tracking numbers (RTNs) and recent studies considering the proposed residential use? • The EIR notes “It is possible that a National Pollutant Discharge Elimination System (NPDES) Remediation General Permit (RPG) will be required depending on the proposed development plans and groundwater quality”. We urge the proponent to determine the likelihood of encountering groundwater and whether dewatering (after on-site treatment) into the City’s drainage system may be necessary. The proponent should
Preserving the Past Planning for the Future Page 4 of 4
provide groundwater data collected from site monitoring wells across all seasons of the year. • The EIR notes that the project site is close to an Interim Wellhead Protection Area (the “IWPA”). Please note these two drinking water wells are no longer in use and have not been since the 1960’s. Please see Attachment A for the location of the IWPA and email correspondence between a City staffer and Steve Fogg, Weston Town Engineer.
Thank you for the opportunity to comment on the EIR for the Riverside Station Development. We look forward to continuing to work closely with the proponent on this very important project.
For the City,
Barney S. Heath Director of Planning and Development
ATTACHMENTS Attachment A: Graphic and Correspondence Regarding Interim Wellhead Protection Area
CC: Newton’s Executive Office DPW/Engineering DPW/Utilities DPW/Transportation Co-Directors of Sustainability Health and Human Services
Preserving the Past Planning for the Future Attachment A
Graphic I: IWPA Location
Graphic II: Correspondence
April 20th 2020
Kathleen Theoharides Executive Office of Energy and Environmental Affairs Attn: Alex Strysky, MEPA Office 100 Cambridge St, Suite 900 Boston, MA 02114
RE: Riverside Station Redevelopment, EEA #16024
Dear Secretary Theoharides,
The Charles River Watershed Association (CRWA) has reviewed the above referenced Draft Environmental Impact Report (DEIR) and offers the comments below for your consideration.
CRWA is encouraged to learn that the amount of proposed public open space has been increased to 4.2 acres, from as previously proposed in the ENF. The proposed site design includes a significant reduction in paved surfaces across the Project Site (from approximately 68% impervious coverage to 37%), including a ½-acre of proposed permeable pavers. Since the ENF, the site design has evolved to include Green Infrastructure and Low Impact Design (LID) features that will exceed stormwater management regulatory requirements while creating public amenities, reducing heat island effect, enhancing natural habitat and reconnecting Newton residents to the Charles River Basin.1
Also as per the DEIR, under proposed conditions, new pervious spaces will infiltrate rainwater where it falls, thereby, increasing groundwater recharge and reducing peak discharge rates compared to existing conditions.2 In addition, the project will use a combination of stormwater Best Management Practices (BMPs), which are integrated into the site design with a focus on groundwater recharge, water quality improvement, and phosphorous removal. Three subsurface infiltration systems are proposed to infiltration more than the 1-inch water quality storm from the Project Site’s impervious areas, including proposed roofs, roadway, sidewalks, and plazas. The proposed drainage infrastructure collects, treats, and recharges stormwater runoff prior to discharging to the existing 60-inch drain culvert tributary to the Charles River. The combination of BMP techniques provides a minimum 65-percent reduction in total phosphorous from stormwater runoff, as required by the Total Maximum Daily Load (TMDL) criteria established by the EPA for the Upper/Middle Charles River.3
1 Pg. 0-1, DEIR 2 Pg. 7-3, DEIR 3 Ibid
Charles River Watershed Association 190 Park Road Weston, MA 02493 t 781 788 0007 f 781 788 0057 e [email protected] www.charlesriver.org
The DEIR includes a variety of stormwater management practices such as bioretention basins, planters and curb bump outs, permeable pavement, street trees with sand-based structural soil and rainwater harvesting and Infiltration chambers.4 However there are no sizing calculations or estimates for phosphorus reductions estimates included in the DEIR. In fact there is no mention of any of the above BMP’s except for the infiltration chambers in the Stormwater Management Plan dated December 2019. Having reviewed the Stormwater Management Plan CRWA would like the proponent to address the following issues identified in the FEIR:
- The stormwater report is missing key site data and analysis and although it purports to show improvements in stormwater quality will occur as a result of the project they are not demonstrated or quantified.
-Some new access roadway supports appear to be within 200 feet of a wetland and the project will involve new connections to the existing Runaway Brook underdrain discharging to wetlands and subject to Conservation Commission jurisdiction and oversight. The plan should identify all the aspects of the work that trigger Conservation Commission notifications and oversight.
-The proponent has not evaluated what happens when the stormwater discharge to Runaway Brook is severely cut back by rerouting existing stormwater to the infiltration system. This may be a very important impact as Runaway Brook (which currently receives nearly all the stormwater flow) drains the Woodland Gold Course and is probably laden with eutrophication chemicals such as ammonia and nitrogen and chemicals that cause low dissolved oxygen contents. By removing the Riverside contribution under low flow conditions these discharges will be at much higher concentrations and poorly flushed and may lead to algal blooms with low dissolved oxygen in the exposed wetlands along the Charles River.
- The project proponent needs to model the proposed groundwater table and gradients prior to and following the proposed subsurface infiltration systems to understand how groundwater will be impacted at the site and downgradient rail maintenance facility.
- The report provides no description of the current regulatory environment of the affected existing discharge. The proponents did not describe that outfalls as a MS4 stormwater sewer regulated by Newton Public Works. The report does not indicate that the outfalls are within the MS4 program as outfalls NEW-44B, NEW-47 and NEW-48. It does not discuss meeting any of the MS4 requirements for BMPs or the city ordinances (Newton Ordinance No Z-45 30-5(c) and required treatment requirements. The facility stormwater system should be compliant with Newton’s Stormwater Management plan for MS4 discharges because the Riverside discharge is to these outfalls.
CRWA expects that the above concerns will be addressed by the proponent in the FEIR. In addition to that we expect to see appropriate documentation of the design of all the green infrastructure BMPs that will be used with corresponding drainage calculations and demonstrated compliance with the TMDL. Please feel free to contact me at (781) 788-0007 ext-232 or via email if you have any questions or additional information to share.
4 Pg. 7-6 DEIR
Charles River Watershed Association 190 Park Road Weston, MA 02493 t 781 788 0007 f 781 788 0057 e [email protected] www.charlesriver.org
Sincerely,
Pallavi Kalia Mande Director of Watershed Resilience, CRWA [email protected]
Charles River Watershed Association 190 Park Road Weston, MA 02493 t 781 788 0007 f 781 788 0057 e [email protected] www.charlesriver.org
Charles D. Baker Kathleen A. Theoharides Governor Secretary
Karyn E. Polito Martin Suuberg Lieutenant Governor Commissioner
May 1, 2020
Kathleen A. Theoharides, Secretary RE: Newton Executive Office of Riverside Station Redevelopment Energy & Environmental Affairs EEA # 16024 100 Cambridge Street Boston MA, 02114
Attn: MEPA Unit
Dear Secretary Theoharides:
The Massachusetts Department of Environmental Protection Northeast Regional Office (MassDEP-NERO) has reviewed the Draft Environmental Impact Report (DEIR) for the Riverside Station Redevelopment in Newton. MassDEP provides the following comments.
Wetlands
The proposed project is for the redevelopment of a 13.5-acre parcel associated with the MBTA's Riverside Station and the existing Hotel Indigo into a mixed-use development which will include approximately 1.025 million square feet of office/lab, residential, retail, and hotel uses.
Though there are no jurisdictional wetland resources located on the project site, there are wetlands off-site to the east and west. Off-site resource area buffers extend on to the project site. In addition, the site is bisected by an existing 60-inch culvert which conveys Runaway Brook from south to north under the site.
The project site has been historically mined for gravel and subsequently occupied by expansive paved parking areas supporting the MBTA bus and rail operations. Under existing
This information is available in alternate format. Contact Michelle Waters-Ekanem, Director of Diversity/Civil Rights at 617-292-5751. TTY# MassRelay Service 1-800-439-2370 MassDEP Website: www.mass.gov/dep Printed on Recycled Paper
conditions, the project site is developed and predominantly impervious. The proposed project will reduce paved surfaces at the site from approximately 68% to 37%.
Under existing conditions, stormwater from within the hotel and MBTA parking areas is collected by a series of catch basins and is conveyed to the existing 60-inch culvert which also conveys flows from Runaway Brook. A portion of the parking lot runoff is treated by an oil- water separator located in the western part of the MBTA parking lot. Section 7.3.1 notes that the 60-inch culvert discharges to the Charles River. Review of aerial photos indicate that the discharge is to wetlands associated with the Charles River and a channel is visible which carries the flows from Runaway Brook and the stormwater runoff to the Charles River. The Final EIR should include more information on the condition of this outfall and evaluate any opportunity for mitigation of possible erosion and scour from this outfall's discharge.
The proposed drainage infrastructure will collect, treat and recharge stormwater runoff prior to discharging to the existing 60-inch culvert tributary to the Charles River. According to the DEIR, Stormwater Best Management Practices (BMPs) include deep sump catch basins with hoods, subsurface infiltration systems equipped with isolator rows, and proprietary media infiltration structures.
The MEPA certificate of June 7, 2019, indicates that there should be a demonstration that soil and groundwater conditions are suitable for infiltration. The DEIR chapter on Response to Comments refers to Section 7.3.2.1. of the of DEIR which states that previously conducted subsurface investigations were used to establish infiltration rates. As this documentation has not been included in the DEIR, MassDEP cannot verify suitability of subsurface conditions for infiltration in accordance with MA Stormwater Standards.
Section 7.3.2.3 of the DEIR states that there will be 44% TSS removal prior to infiltration BMPs; this cannot be verified as TSS worksheets have not been provided. Common pretreatment for infiltration basins includes aggressive street sweeping, deep sump catch basins, oil/grit separators, vegetated filter strips, water quality swales, or sediment forebays. Though a proprietary particle separator device is proposed on the west side of Infiltration System #1, only catch basin with hoods and sumps are proposed for Infiltration Systems 101, 102, and the east side of Infiltration System 103. Pollution prevention and pretreatment are particularly important at sites where infiltration basins are proposed; this is especially relevant at this site as the Charles River is designated as impaired and the Final TMDL for Nutrients in the Upper/Middle Charles River establishes targeted reductions in phosphorus loading to the Charles River. The DEIR notes that the project commits to meeting this phosphorus reduction target.
P. 9-2 of the DEIR notes that, based on previous environmental site assessment reports, the presence of ash and cinders encountered within the existing urban fill soil and the possible presence of former USTs on the MBTA portion of the project site are two potential remaining concerns that have been identified for the project site. The DEIR states that, "These potential environmental conditions, common to historically industrialized properties in eastern MA such as this project site will be evaluated further during the pending project design phase". In light of these potential conditions, MassDEP is concerned about the suitability of the project site for subsurface infiltration.
2
The MassDEP appreciates the opportunity to comment on this proposed project. Please contact Rachel [email protected] or at (78) 694-3258 for more information on wetland issues. If you have any general questions regarding these comments, please contact me at [email protected] or at (978) 694-3304.
Sincerely,
John D. Viola Deputy Regional Director
cc: Brona Simon, Massachusetts Historical Commission Eric Worrall, Rachel Freed, Heidi Davis, MassDEP-NERO
3
COMMONWEALTH OF MASSACHUSETTS EXECUTIVE OFFICE OF ENERGY AND ENVIRONMENTAL AFFAIRS DEPARTMENT OF ENERGY RESOURCES 100 CAMBRIDGE ST., SUITE 1020 BOSTON, MA 02114 Telephone: 617-626-7300 Facsimile: 617-727-0030
Charles D. Baker Kathleen A. Theoharides Governor Secretary
Karyn E. Polito Patrick C. Woodcock Lt. Governor Commissioner
28 April 2020
Kathleen Theoharides, Secretary Executive Office of Energy & Environmental Affairs 100 Cambridge Street Boston, Massachusetts 02114 Attn: MEPA Unit
RE: Riverside Station Redevelopment, Newton, Massachusetts, EEA #16024
Cc: Maggie McCarey, Director of Efficiency Programs, Department of Energy Resources Patrick Woodcock, Commissioner, Department of Energy Resources
Dear Secretary Theoharides:
We’ve reviewed the Draft Environmental Impact Report (DEIR) for the above project. The proposed project consists of about 1.07 million square feet of new residential (eight buildings), retail, office/lab, and hotel.
Executive Summary
• The project is taking significant measures to avoid emissions, including committing to Passivehouse (for 2 of the residential buildings) and very high-performing envelope (for the 6 remaining buildings). In fact, the six remaining residential buildings are achieving Passivehouse (PHIUS) standards for air-infiltration and heating and cooling load reduction.
• The project is also committing to efficient electrification of space heating for all the residential buildings and partial electrification of the hotel.
• Above-grade envelope performance for the Hotel and Lab/Office are 7% and 15% above cod performance, respectively.
• In addition, the project is committed to be PV ready for 1.5 MW of rooftop PV.
Our detailed comments are provided herein. Riverside Station Redevelopment, EEA #16024 Newton, Massachusetts
Pathway to 38% Mitigation Level
The project (all buildings) is currently-proposed to have a Mitigation Level1 of 15%. This can be improved by about x2.5 to 38%. In summary:
• The currently-committed efficiency strategies deliver a Mitigation Level (ML) of 15%. This is accomplished with improved envelope for all buildings, Passivehouse for two of the residential buildings, very high performing envelope for the other six residential buildings, and efficient electrification of space heating for the residential buildings.
• Mitigation Level can be improved to 38% as follows:
o Increasing the number of residential building that meet Passivehouse total energy limits from 2 residential buildings to all 8 residential buildings improves ML to 25% o Additional electrification of heating (office portion of office/lab) improves ML to 30% o Installing solar PV on committed PV-ready areas improves ML to 38%.
1 Mitigation Level is the percent GHG reduction beyond the reduction that would occur as a result of following state and local building codes. A Mitigation Level of 0% means that no mitigation is proposed.
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Riverside Station Redevelopment, EEA #16024 Newton, Massachusetts
Codes and Baseline
Massachusetts Stretch Code applies to this project. Stretch Code requires a 10% energy performance improvement over ASHRAE 90.1-2013-Appendix G plus Massachusetts amendments. Accordingly, the baseline for this project should be based on ASHRAE 90.1-2013 plus Massachusetts amendments. The project is using this baseline.
In addition, Massachusetts Stretch Code also requires that all dwelling units in buildings 4 stories or less comply with R-406 of the residential stretch code. This dwelling unit requirement will apply to Buildings 5 and 6, as these are both 4 stories. Section R-406 requires that all dwelling units comply with Energy Star v3.1, or Passivehouse, or have a HERS rating of 55 or less. This section also requires that each dwelling unit complies with various mandatory requirements, including air leakage, duct testing, 100% LED lighting, and other requirements. The proponent should confirm that the baseline for these two buildings comply with this code minimum.
In August 2020, an update to the Massachusetts Stretch Code will take effect. The underlying code provisions will not change. The Stretch Code to take effect in August also uses ASHRAE 90.1-2013-Appendix G. However, there will be several new, or changed, Massachusetts amendments including: C402.1.5 (envelope), C405.3 and C405.4 (lighting), C405.10 (EV charging), and C406 (additional efficiency measures). In addition, the additional C406 measures are increased from 2 to 3 while the list of additional measures to choose from are expanded.
To accurately estimate Mitigation Level for this project, we recommend that the baseline for this project be set at the Stretch Code provisions which will be required in August 2020 as this will likely be the code that will be used for building construction. Accordingly, updates to lighting, envelope, and additional efficiency measures will be required in the baseline. In accordance with the GHG Policy, the project is welcome to continue to compare to the baseline that existed at the time of the ENF, as well.
Building Envelope Performance
High-performing envelope is essential to successful GHG mitigation. Key strategies for maintaining integrity of envelope are:
• Continuous insulation; • Reducing air infiltration; • Reducing thermal bridges; • Limiting or eliminating use of glass “curtain wall” and spandrel assemblies; • Maximizing framed, insulated walls sections; • Maintaining window at code levels.
Beginning in August 2020, Massachusetts energy code amendments require conformance with 2018 IECC Section C402.1.5 which mandates that the aggregate performance of all above-grade surfaces perform at least as well as the envelope performance factors in IECC Table C402.1.4 and C402.4 and the fenestration values in C402.4.1 and C402.4.3. It is likely that the buildings conform to this requirement though this should be verified.
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Riverside Station Redevelopment, EEA #16024 Newton, Massachusetts
Also beginning in August 2020, Massachusetts amendments require that baseline residential buildings set maximum fenestration to 24% from current 40%.
In general, the project is taking exemplary efforts with respect to quality of envelope. These include:
• For all residential buildings, including the residential buildings which are not planning to pursue Passivehouse certification:
o air infiltration limit will be at Passivehouse limits (estimated at 0.014 cfm/sf) and verified with in-field testing;
o Windows will be triple pane windows (U value 0.22);
o Roof insulation will be 60% higher-performing than August 2020 code requirement;
o Vertical wall performance (walls and windows) will be 23% higher-performing than August 2020 code requirements;
o Envelope performance will result in heating and cooling load end uses which meet Passivehouse (PHIUS) limits, based on the WUFI analysis provided.
• All buildings, including the lab/office and retail, are completely avoiding glass curtain wall/spandrel assemblies.
• Excepting the hotel, the project is also committing to roof insulation well above code requirements (particularly for the residential buildings). Roof insulation in some cases makes an appreciable contribution toward overall above-grade performance.
Above grade envelope performance (vertical, roof, and exposed lowest level floors) for the buildings are as follows:
Building August 2020 Code Committed Improvement in U- minimum (U value) (U value) value performance Residential 0.100 0.076 24% Hotel 0.119 0.111 7% Lab/office 0.132 0.112 15% Aggregate Above-grade U value (All exposed horizontal and vertical assemblies)
The retail portion of the project will be part of the residential buildings. In the FEIR, the window and wall assembly values of the retail should be incorporated into the residential building values.
Page 4 of 7
Riverside Station Redevelopment, EEA #16024 Newton, Massachusetts
Passivehouse
The project is committing to Passivehouse for two of the eight residential buildings. At a minimum, this would represent about 120,000 sf of Passivehouse if the two smallest residential buildings are used.
Notably, the other six residential buildings appear to have the same envelope performance as the two proposed Passivehosue residential buildings, including committing to the same air infiltration limit. As noted above, the heating and cooling end uses for these six buildings also appear to meet Passivehouse standards. HVAC and other systems are also near-identical as the two Passivehouse committed buildings.
We noted that the six residential (non-Passivehouse) buildings will have an EUI between about 32 and 34 kBtu/sf-yr while the two residential which will be Passivehouse will have an EUI of about 18 kBtu/sf-yr. For the next submission, we request additional elaboration on what is specifically different about the Passivehouse and Nonpassivehouse buildings to account for these the different EUIs.
Passivehouse Incentive
Note that the MassSave Passivehouse incentive used in the submission is only a portion of the total incentive. The MassSave incentive has several components, including:
- A $500 per dwelling unit preconstruction component - A $2,500 per dwelling unit postconstruction component
It appears that the submission is only including the postconstruction component and not the preconstruction component. Therefore, the incentive should be $3,000 per unit and not the $2,500 used in the submission.
Also note that the incentive, in addition to above, includes funding for feasibility, modeling, and an additional “net performance bonus”. Feasibility and modeling has a value of up to $25,000 and the net performance bonus can add several hundred more dollars per unit.
Total Passivehouse incentive (at $3,000 per unit) for this project could reach $2.7M if applied to all planned residential units.
Building Envelope and Perimeter Heating
The hotel, office/lab, and retail have vertical wall performance at-code (0.055) albeit all with improved windows. We recommend the proponent to also examine whether further wall and/or window improvements could potentially eliminate or reduce the need for perimeter heating for these buildings.
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Riverside Station Redevelopment, EEA #16024 Newton, Massachusetts
Elimination/reduction of perimeter heating could potentially result in significant construction cost savings, improved comfort, and reduced maintenance. Also, elimination/reduction of perimeter heating may also make full electrification more feasible and thus improve GHG reduction.
External Shading and Solar Heat Gain Coefficient (SHGC)
External shading and solar heat gain coefficient (SHGC) have not been analyzed yet, consistent with the level of design of the project at this time. As the project moves forward, we encourage examination of building self-shading, external shading, and varying SHGC as a function of exposure. (For example, targeting lower SHGC-rated glass for building sides and areas more exposed to sun and/or less shaded.)
Fossil-Fuel Reduction and Efficient Electrification
Efficient electrification of space and service water heating is an effective strategy for GHG mitigation. Electrification entails swapping from gas-fueled equipment to air source electric heat pumps and VRF systems.
The project is making significant strides towards electrification including:
• fully electrifying space heating of all residential buildings; • fully electrifying space heating of the retail portions; • partial electrification of hotel space heating;
We recommend expanding electrification of space heating as shown below. (An estimate of the GHG reduction is provided at the beginning of this letter.)
• the office portion of the office/lab
For water heating, the residential and retail buildings are committing to electric resistance water heating for the residential. All other buildings are planning natural gas water heating.
Consider committing to having one (1) building with central air source heat pump for domestic hot water production, potentially in tandem with planned natural gas system.
Rooftop Solar PV
Rooftop PV can provide significant GHG benefits as well as significant financial benefits. The proponent completed a detailed analysis for rooftop PV space, concluding there is space for 1.5 MW of PV when applied across all buildings (approximately 150,000-sf of roof space, total). Further, the project is committing to this amount of rooftop PV solar readiness.
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Riverside Station Redevelopment, EEA #16024 Newton, Massachusetts
Recommendations for Subsequent Submissions
Recommendations are as follows:
1. Update project baseline to reflect August 2020 building codes with Massachusetts amendments.
2. Confirm that the 4 story residential dwelling units will conform to section R406 of the Stretch Code.
3. Update the UA calculations to incorporate retail portion of residential buildings. 4. Elaborate on what is specifically different about the Passivehouse and Nonpassivehouse buildings to account for significant differences in anticipated EUI.
5. Examine effect of targeted SHGC and external shading considering variability of exposure to sun, building self-shading, and shadows from other buildings.
6. Consider committing to having one (1) building with central air source heat pump for domestic hot water production, potentially in tandem with planned natural gas system.
Sincerely,
Paul F. Ormond, P.E. Energy Efficiency Engineer Massachusetts Department of Energy Resources
Brendan Place Clean Energy Engineer Massachusetts Department of Energy Resources
Page 7 of 7
April 15, 2020
By Email: [email protected]; [email protected]
Secretary Kathleen Theoharides Executive Office of Energy and Environmental Affairs 100 Cambridge Street, Suite 900 Boston, MA 02114
Attn: MEPA Office, Alexander Strysky, EEA #16024
Re: Riverside Station Development; EEA # 16024
Dear Secretary Theoharides,
Below are comments on the Draft Environmental Impact Report, Riverside Station Development, March 2020 submitted on behalf of the Riverside Committee of the Newton Lower Falls Improvement Association, a 501(c)(3) corporation. The comments are divided into General Comments; Subject Area Comments, which include Site Contamination and Remediation, Stormwater/Wastewater/Underground Injection, Air Pollution Control, Solid and Hazardous Waste Spill Control; and Miscellaneous Comments regarding inconsistencies. Additional comments on other topics may be submitted by the Lower Falls Improvement Association Riverside Committee under separate cover.
General Comments
1) In the “Summary of Environmental Due Diligence and Pre-characterization Activities Riverside Station Redevelopment” report dated 1/28/20 prepared by Sanborn Head for Mark Development LLC., the study results were apparently not properly addressed in accordance with the MassDEP regulations. The study was not sent to the MassDEP, soils exceeding RCS-1 levels were not reported, and a plan to file a site closure determination was not submitted. The proponent also is not planning on addressing the contamination exceeding S-1 criteria and protecting the residential and utility workers, using such tools as a gardening BMP for surface soils on the residential development site. The proponent also did not employ the MassDEP guidance document to determine whether the contamination identified is consistent with historic fill (the proponent just assumed it is). The proponent should be reporting the “release” and then quickly filing a PSS with Conditions so that the presence of historic fill is documented.
2) The project developer is planning on injecting/infiltrating stormwater into the aquifer at 3 injection/infiltration sites. This will likely mobilize contamination from the MBTA maintenance Secretary Kathleen Theoharides April 15, 2020 Page 2
facility towards the Charles River. The stormwater that will be injected/infiltrated into the aquifer will have runoff from all the new building materials and there is no oil/water separator. The quality of that groundwater injection/infiltration and the discharge via the stormwater outfall to the Charles River should be assessed prior to, during, and after construction, bearing in mind that the project site is close to the river and it is on the edge of an Interim Wellhead Protection Area for two Weston public water supply wells. Ideally, sentry groundwater wells would be monitored along the downgradient extent of the MBTA maintenance facility and the existing stormwater outfalls monitored prior to, during, and after construction to assess contaminant mobilization to the wetlands, the Charles River, and the IWPA. Constituents in groundwater at the MBTA site between the Development site and the Charles River exceed the GW-1 standards (e.g., arsenic) and/or are very close to GW-1 standards (Tetrachloroethylene at 4.7 ug/L vs the standard of 5).
3) The three-groundwater injection/infiltration systems are regulated as underground injection wells at 40 CFR 144.12 (within the Underground Injection Control (UIC) provisions within the Federal Safe Drinking Water Act) but this has not been identified in the DEIR. The proponent will need to file a registration and/or permit with the USEPA. The injection/infiltration systems are also regulated under the MassDEP 314 CMR 5.04 and will need a permit. That permit will require the proponent to sample and monitor discharge on a frequent basis. If the water should jeopardize a drinking water standard, then the proponent might not even be allowed to discharge. The discharge is near the IWPA and the rule specifically discusses any discharges which could cause contaminants to migrate to an IWPA. Further, the groundwater at the site is designated for water quality purposes as a Class 1 aquifer which is a different terminology than used in the MassDEP cleanup program. The proponent should explain this in the DEIR. There is a long list of water discharge limits at 314 CMR 6.06 and monitoring requirements at CMR 6.08. If the stormwater currently being discharged is not meeting the groundwater injection/infiltration discharge water quality criteria the proponent would not be allowed to inject/infiltrate the stormwater. Moreover, the site should be considered a P1 stormwater sector discharge facility because the MBTA is a P1 (rail) stormwater sector facility and part of the site receives run-on from the MBTA facility; in addition, MBTA owns the development site – the development is leasing the property from the MBTA. There is nothing in the DEIR about any of these regulations or requirements or how the proponent plans to meet the requirements/standards. The proponent should indicate that stormwater must be sampled to determine if it is even possible to discharge stormwater to groundwater because of the groundwater water quality requirements. Because the data from such sampling might show that the stormwater cannot be infiltrated, it is inappropriate and premature for the proponent to claim that the project will definitely produce the benefit of lessening stormwater discharge to the wetlands and the Charles River and associated lowering of water quality impacts.
4) The proponent does not clarify who is doing the offsite work and what rules apply to that work. For example, there is significant development along Recreation Road for new roadways, bike paths, and pedestrian walkways, and there is major work proposed on the MBTA facility for contractor parking and possible soil storage. The DEIR should include information about how these areas will be addressed from an environmental standpoint. Also, these proposed work activities are within the conservation setback for the Charles River and/or the IWPA. This was not clearly identified in the DEIR. Secretary Kathleen Theoharides April 15, 2020 Page 3
5) The proponent does not provide design information for the base elevation of the project excavations. A contour map should be provided which shows the base of excavation, so that it can be determined which contaminated soils will be excavated and whether groundwater dewatering will be needed. The contour map should consider the three infiltration units that will be installed, the utility trenches, the building excavation depths, and any other excavations needed.
6) The DEIR does not indicate the sequence of activities that will occur during construction regarding soil stockpiling and soils to be brought onsite as fill. The amounts of soils brought in and out should be provided in a timeline and the amounts in storage should be identified. It is also not clear whether the truck traffic associated with these soil movements have been included in the DEIR. There is no description of how incoming soils will be tested to ensure they are safe nor how excavated soils will be tested to classify them for storage, treatment, and disposal.
7) The Memorandum of Understanding to develop trails along the Charles River is commendable and a very positive aspect of this project.
8) The existing facility has oil/water separators, but the proposed project does not include them. Because it is highly likely that a spill will occur given the size and scope of the development, oil/water separators should be included to avoid injection/infiltration of spills into the aquifer and/or discharge to the Charles River.
9) The proposed development includes demolition of the Indigo hotel, MBTA Bus Depot, all the current asphalt paving throughout the site, and 875 feet of MWRA drinking water welded steel piping, and perhaps other existing facilities/areas. The demolition has been repeatedly mischaracterized as “minimal” in the DEIR. The Indigo Hotel alone is a 191 room, 74,553 square foot building with 21,630 square feet of deck. This would therefore be one of the larger demolition projects in Newton and certainly the largest one for the local neighborhoods in recent memory. The proponent says that a hazardous material survey will be conducted prior to demolition, but the proponent should share the results of previous hazardous material surveys that had been done prior to the hotel’s purchase. The proponent should also be clear about whether asbestos is present. Additionally, the proponent should identify those materials that are probably present given the buildings’ ages, including the presence of such materials as lead in paint and PCBs in building materials and caulk. There should be some discussion of how these hazardous materials will be dealt with.
10) The project proponent is unclear whether crushing will be conducted onsite. In some passages, the proponent mentions crushing will occur but then in subsequent passages not. The proponent also indicates that demolished materials will be reused onsite as fill, but the proponent has also said that these materials will only be taken offsite. The proponent should be clear on what activities are going to occur in this regard. If the proponent does plan to conduct crushing and filling on site with construction debris, additional questions should be raised; however, it is assumed that this will not occur because the proponent has indicated this to be the latest plan. Secretary Kathleen Theoharides April 15, 2020 Page 4
11) What will be the drinking water pressure change as a result of this project? If it will vary from neighborhood to neighborhood, the proponent should show how it is projected to change by neighborhood. The results of water distribution system modeling should be provided showing the changes expected.
12) What assurances will be provided indicating that there will not be overflows from the sewer system as a result of this project? Sewer system back-ups have occurred in Auburndale at Lyons Field, in Lower Falls on Concord Street and St. Mary’s Street, and along a section of Quinobequin Road in Waban. Sewer system modeling, calibrated to existing conditions, should be conducted to demonstrate the impact of the proposed development. Although the proponent is proposing to conduct infiltration/inflow reduction efforts at a ratio of 4:1 or 8:1, such reductions can be conducted on a City-wide basis and not solely within the portion of the sewer system most impacted by the development.
13) How will the proponent be required to address any shortcomings in outcomes compared to what the proponent states will be achieved? For example, if stormwater quality or the amount of infiltration is not as promised, what are the plans for mitigation?
14) There needs to be a program to monitor emissions (air dust / wastewater / stormwater / groundwater / noise) prior to construction (to define baseline conditions), during construction, and then after construction, to show that the environmental impacts are consistent with what the proponent indicates will happen.
Subject Area Comments
A. Site Contamination and Remediation
1) Are the planned elevators mechanical or hydraulic? Hydraulic elevators will require a piston that is usually extended below ground in the elevator shaft and will house hydraulic oils. How will subsurface elevator oil filled pistons be protected from leakage. [Table 5.6]
2) The proponent has indicated that dewatering will not be necessary, but this should be demonstrated by providing a map of the groundwater elevations overlaid on a map of the base of excavations. This concern is based on review of supporting documentation that shows that many or most of the water table elevation data were collected during low water table seasons. In addition, the excavation plans show that the proposed depths may be close to (i.e. near the seasonal high-water table) or below the existing water table. For example, the latter is shown by the proposed excavation in the area of the Indigo hotel, with depths up to 30 feet although the groundwater at that area is relatively shallow. [Section 10.3]
3) Figure 4.28: It would be helpful for the trail map to show underground passageways versus overland, given crossing of roadways and rail tracks. [Figure 4.28]
4) the proposed project includes offsite activities such as the creation of contractor parking spaces and extensive off-site roadwork, including along Recreation Road. A portion of that work is within the wetlands setback and it is also within the Interim Wellhead Protection Area (IWPA) Secretary Kathleen Theoharides April 15, 2020 Page 5
for the two nearby Weston Wells. The proponent should modify the figure to show the wetland set back lines and IWPA radiuses. [Figure 1.6]
5) The project proponent is agreeing to construct passive buildings and is being asked to consider designing more. While this may be a worthy goal for green buildings it also can be a problem from indoor air exchanges. Is the proponent planning on doing any indoor air sampling of these units? It is recommended that Summa canister sampling be conducted, and also that the proponent should get firm commitments from suppliers regarding VOC/SVOC emissions of their building materials. [Section 10.3.4]
6) What is the proponent planning for air monitoring equipment? Will the proponent provide PM dust level monitoring at the site and have that simultaneously uploaded to the Internet? Such equipment is readily available, as well as the means and methods for Internet-based reporting. Similarly, VOC monitoring and reporting should also be conducted. [Section 9.4.1]
7) There is a mention of Sanborn Head doing additional pre-characterization sampling (page 9-4). This needs to be described in sufficient detail. [Section 10.3.2]
8) What type of explosives is the proponent planning to use? The proponent mentions that it will not contain perchlorate without specifying which explosive. [Section 10.3.2]
9) Regarding noise during construction, the proponent is comparing it to existing traffic noise. However, noise is additive. Therefore, the proponent must describe the projected total noise levels. That is what the local neighborhoods will experience. This is the standard Approach. [Section 10.3.2]
10) Does the traffic analysis include construction vehicles traversing the road with the extra 36,000 cubic yards of soil that will be sent offsite? How much demolition debris will be generated from the 2 buildings and the asphalt paving? Depending on the size of truck, just disposing of the soil could require 2,000 heavy truck trips. Plus, soil will be brought onsite. How much will this be? How many truck trips in total will be required for all of the demolition and soils work? [Section 4.5.2]
11) The DEIR does not provide enough clarity about how contractors will set up at the site. Will they have dedicated project trailers and support facilities? What site security will be provided at night? What lighting will be added to conduct work in the evening? [Section 10.2]
12) Section 9.4.1 of the DEIR indicates that soil data shows that the site meets the most stringent RCS-1 standards. This needs to be checked because the most recent January 28, 2020 Environmental Due Diligence report plainly reported that soil testing showed soils exceeded RCS-1 standards for 2-methylnapthalene, benzo (a) pyrene, phenanthrene, and arsenic. These soil tests were composite sampling over many feet of soil indicating a significant zone of contamination. [Section 9.4.1]
13) The description of groundwater and soils categories regarding allowable contaminant concentrations needs to be changed, because RCS-1 is not a soil standard nor is RCGW-2 a groundwater standard, but instead they are reportable concentration standards. The soil Secretary Kathleen Theoharides April 15, 2020 Page 6
standards are S-1, S-2, and S-3, and the groundwater standards are GW-1, GW-2, and GW-3; in addition, there can be combinations. This report should have described the soil and groundwater standards, not the RC ones. [Sections 9.4.1 and 9.4.2]
14) Although the proponent’s LSP asserts that the soils are exempted as historical fill, he has not provided his rationale including the requisite research and testing required to support his conclusion. The LSP should document his determination using the MassDEP checklist and provide it as part of the DEIR. The checklist can be found at https://www.mass.gov/files/documents/2016/08/qj/draft-historic-fill-technical-update-2016- 05-20.pdf [Section 9.2]
15) Even if the LSP concludes that site soils are historical fill, it must still be managed as remediation waste and could require an AUL or Conditions. This depends on what is found when excavation occurs. See the boring logs for RIZ-5 and HA-09-15 for example, which show many feet of solid buried wood. [Section 9.2]
16) The proponent should show the Weston and Sampson and ATC groundwater wells and borings at the MBTA site in their report. It is unclear why only selective borings were presented. For example, ATC-3 had levels of the contaminant tetrachloroethylene (PCE) at 4.7 ug/l versus the drinking water limit of 5 ug/L and MBTA facility soils exceeded PCE reporting limits. It should be specially noted that groundwater well ATC-3 is within the Interim Wellhead Protection Area for the Weston drinking water wells and along the downgradient border of the MBTA site with the Charles River and surrounding wetlands. Increasing the groundwater gradient at the site (through groundwater infiltration) and blasting and excavation activities are likely to further mobilize this contamination towards the Charles River, the wetlands, and the two Weston supply wells.
B. Stormwater/Wastewater/Underground Injection
1) Is the proponent planning on installing electrical transformers? This is likely but there is no mention of it in the DEIR. If this is the case, will the proponent commit to secondary containment for the transformers and will FR3 environmentally friendly and non-toxic dielectric fluids be used? [Section 10.2]
2) Where are the oil/water separators being installed? The only reference to such was an oil/water separator for the garage parking, which drains to the sewer line that goes to the MWRA. Is the parking building draining to the MWRA sewer? What is the source of rainwater in the parking structure? [Section 8.4.2]
3) What if an oil or hydraulic spill occurs along the road that goes into the storm drain? What would keep that from being injected/infiltrated into the aquifer or discharged to the Charles River? [Section 7.3.2.3]
4) There are frequent statements that paved surfaces will be decreased from 68% to 37%, implying that there is more opportunity for infiltration. If a drop of rain lands on the roof it will be discharged to the storm drain nearly as fast as paved surfaces. In fact, due to the height of the buildings, blowing rain will be stopped by the buildings and will result in more precipitation Secretary Kathleen Theoharides April 15, 2020 Page 7
landing on the site. Therefore, roofs should be included as paved surfaces for a valid comparison [Section 7.3.2]
5) How will the infiltration units be unclogged once they begin to receive stormwater and have been running for a while? A certain amount of fine sediment and micro plastic for example will be discharged and pass through the filtration system. Over time this will clog the pores of the units and the aquifer, and slowly the units will lose the ability to discharge at design rates. Since the main infiltration unit is under a building and the two others are under paving, it is not clear how these systems will be maintained over time. Also, the units are likely to have issues with biofouling. What are the plans for maintenance? Will dosing the aquifer with biocides or acid washing be conducted, as is usually done for injection wells/galleries to control biofouling? [Section 7.3.2]
6) Is the proponent planning for wheel washes for vehicles leaving the site during construction? These are common, but there are only references to truck watering. Note that there is also the possibility for street sweepers that don’t use water. [Section 7.3.2.3]
7) The proponent should describe the roof cisterns. Are they tanks on the roof or elsewhere, or are they piping? How many buildings will have them and what is their capacity? [Section 7.3.2.2]
8) The proponent is proposing a single bioretention basin. Is this a garden or tree area? In the winter the ground will freeze and not allow infiltration to occur. Is there piping to this area? [Section 7.3.2.2]
9) Is the proponent planning on heat tracing wastewater/stormwater lines to keep them from freezing? [Section 7.3.2.2]
10) Does the proponent know where the MWRA sewer will be lined to get the 4:1 reduction in infiltration/inflow (I/I)? What if the proponent is unable to achieve this with the funding set- aside (i.e., less groundwater was infiltrating than estimated)? How will the reduction in I/I be demonstrated? [Section 8.4.3]
11) The plan to place construction soils on top of polyethylene and then covering with polyethylene sheeting may be problematic. The heavy equipment will rip the polyethylene base and the polyethylene cover will blow away in a wind unless it is heavily weighted, and polyethylene will not survive either use for long. It would be better to construct a paved base and to use a different cover material that is heavily weighted. Landfill operators often use tires as weights, and they pull thick tarps using heavy equipment with ring connections to cover the daily fill area. [Section 9.3]
12) It is not a given that stormwater will be improved. For example, the runoff from the new building materials will leach contaminants into stormwater that have not been emitted from the existing parking lot. To address this concern, pre-construction, construction, and post construction stormwater sampling should be conducted to define the baseline conditions and to observe the changes, to help demonstrate that the objectives have been met. Also, it will be helpful to evaluate ecological risks. [Section 7.3.2] Secretary Kathleen Theoharides April 15, 2020 Page 8
13) The proponent should consider that the MBTA is a P1 (rail) stormwater sector facility because the development site will be assigned that sector rating. This triggers sampling requirements and limits for contaminants. Part of the site receives run-on from the MBTA facility and the MBTA owns the site. This will be encountered when the proponent is asked about SIC codes applicable to the site during the NOI process. [Section 7.3.2.3]
14) Also, sampling at the outfall will very likely continue. The City has sewer discharge limits for that outfall. Therefore, the proponent can obtain data from the City on the contaminants that appear in the outfall’s discharge under existing conditions. [Section 7.3.2.3]
15) The stormwater controls provided in the DEIR should be specific. The proponent should meet the Department of Conservation and Recreation (DCR) Best Management Practices, see Appendix J. The DCR and/or Newton Conservation Commission may require this because the MBTA operations area discharges to the Riverside Development property. [Section 7.3.2.3] https://www.americantrails.org/files/pdf/MA-Trails-Guidelines-Best-Practices.pdf
16) See the General comment above regarding applicability of permitting under the UIC provisions of the SDWA, in reference to the proposed injection/infiltration facilities. [Section 7.3.2.3]
17) What is the water use profile/timing for the MWRA water supply line that will be relocated? Can the line be out-of-service for as long a period as planned? The proponent should coordinate with the Towns of Wellesley and Needham as part of overall coordination with the MWRA. Included in this should be consideration of an alternative method that would allow construction of the new section before demolishing the section to be replaced, so that downtime would be negligible. [Section 8.3.3.1]
18) The proponent indicates that each stormwater infiltration unit was designed using soil characterizations from a boring placed in the proposed unit’s location. However, based on the boring map there are no borings within the footprint of infiltration system 103. Nearby borings and bedrock outcrops indicate that bedrock is very shallow at that site and thus P-103 will probably not be able to achieve an adequate infiltration rate. [Section 7.3.2.3]
19) The existing stormwater is of generally good quality for the parameters measured regularly by the Newton MS4 group within the DPW. This means that whatever changes occur due to the proposed development, improvements in phosphorous and TSS will not be significant, or there could be increases. Therefore, the proponent should acknowledge the current data, and consider whether improvement will actually be realized. [Section 7.3.2.3]
20) Based on the proponent’s estimates of stormwater that will be collected, treated, and discharged through the outfall to the Charles River, only about 16% of the 2 year design storm event and 2% of the 10 year event will be treated. This provides further demonstration of the need for baseline (pre-construction), construction, and post-construction monitoring, for providing data showing whether the proposed project actually leads to an improvement in discharged stormwater quality. [Section 7.3.2.3] Secretary Kathleen Theoharides April 15, 2020 Page 9
C. Air Pollution Control
1) There are multiple, differing statements in the DEIR about whether emergency generators would be used. Due to the height of the buildings, it is likely that the building code will require emergency generators. If so, what are their likely Kilowatt ratings? Section 6.3 of the report states that diesel-powered generators will be used. [Section 5.1 and 5.3]
2) Is the proponent planning on installing any diesel or fossil fueled fire pumps? Again, if so, the proponent should identify the tank size and number of pumps. Note that these may also be air emission sources that require permitting. [Section 5.1 and 5.3]
3) The Plan calls for leasing lab space, therefore, what kinds of labs are being considered? For example, would biological labs be included and what level of protective measures are planned? [Section 1.2.1]
4) For the greenhouse gas emissions summary, did the proponent include the combustion engines? There will likely be backup emergency generators, fire pump emissions, and boiler emissions. Are all of these included? What size boilers are likely? Also, if the proponent is planning on using boilers, will they be water boilers, and will the proponent need to neutralize the boiler water discharge and add oxygen scavengers, biocides, and other water treatment chemicals? By the way, the backup emergency generator will likely be required to meet 40 CFR 63 subpart ZZZZ. That should be listed as a requirement in the DEIR. [Section 5.1, 5.3 and 8.4.2]
D. Solid and Hazardous Waste
1) See the General comment regarding the large size of the demolition aspects of the proposed project, versus the proponent indicating the demolition work will be “minimal”. [Sections 8.3.3.1, 9.5, 10.3.3 and 7.3.2.2]
2) Did the proponent conduct a due-diligence investigation of the hotel prior to acquisition, as is good practice? If so, a hazardous material survey (HMS) would have been prepared at that time. That data should be included in the DEIR. Further, the comment about asbestos possibly being present is confusing. Is it there now? Obviously, rules would require labeling of the piping, repairing and maintaining it in a certain manner, and preparing an asbestos management plan so that workers are notified. Therefore, is there asbestos present now? Note the online filings in which the proponent has applied for asbestos abatement with the agency, under Project ID 100126318. [Section 10.3.3] https://eeaonline.eea.state.ma.us/portal#!/asbestos/141933/ANF- 001
3) Under the Solid and Hazardous waste section it would be helpful to describe what the proponent plans to do with project-generated hazardous wastes and TSCA wastes, such as used oil, painting solvents, demolition debris (lead paint waste, PCB caulk and sealants), etc. It is not clear whether each contractor will be responsible for its own wastes or whether Mark Development will take on this responsibility. The proponent will need to obtain a hazardous and universal waste generator Identification number, unless to the proponent can use the one held by the MBTA. [Section 9.0] Secretary Kathleen Theoharides April 15, 2020 Page 10
4) Describe the specifics of the crusher units that may be deployed and how noise will be controlled. Also, under what regulatory basis will any crushing and filling with demolition debris be managed? [Section 10.3.3]
E. Spill Control
1) The proponent should list the approximate size of the emergency generator diesel tanks and the number of generators. Also, the DEIR should indicate if the proponent is willing to commit to double-walled tanks. The emergency generators will be placed on the roof; therefore, how does the proponent plan to pump diesel to the roof? If there is a spill on the roof, what would prevent it from going into the roof drainage and stormwater injection/infiltration system and then potentially to discharge via the river outfall? [Section 6.6.3]
2) Is the proponent planning on preparing a Spill Prevention and Control Plan (SPCC) prior to the construction phase, or later? There are threshold triggers that would require one, but the full scope of proposed fuel/oil storage is not described. Also, does the proponent plan to have fuel and oil storage tanks onsite to refuel heavy equipment during construction, or will the proponent rely on fueling trucks that will be brought onsite for refueling? Further, is the proponent planning on maintaining construction equipment onsite, or will that be done offsite? [Sections 6.6.3 and 10.3]
3) If diesel fired fire pumps are installed, what size are the tanks and how many? [Section 8.3.1]
Miscellaneous Comments (regarding inconsistencies)
- Section 1.3 – project phasing: It should include items regarding environmental concerns, the associated monitoring needed, water/stormwater/wastewater aspects, and ecological issues.
- Figure 1-4: The site boundary is smaller than the total Phase 1 and Phase 2 extents, thus the text should explain the differences.
- Section 8 – Wastewater flow rates: There are different estimates in different text passages, including 72,500 gallons per day (gpd) and 67,048 gpd, and maybe other values. These estimates should be consistent.
- Section 11.1:
o Mentions “Blue Line Stations.” This “boilerplate” should be made site-specific.
o Indicates that the 60-inch MWRA water supply pipeline (serving the Towns of Wellesley and Needham) will be relocated during Phase 1, thus earlier Sections should mention this as well.
- Groundwater modeling: This effort should be documented in the DEIR, noting that a memorandum has been submitted by the proponent, which will be commented on separately by this Committee. Secretary Kathleen Theoharides April 15, 2020 Page 11
Thank you for your attention to the above.
Sincerely,
______Andrew Smyth, LSP
______Robert P. Schreiber, PE, BCEE, D.WRE
On behalf of the Lower Falls Improvement Association Riverside Committee
April 17, 2020
Kathleen Theoharides, Secretary Executive Office of Energy & Environmental Affairs Attention: MEPA Office – Alex Strysky, MEPA #16024 100 Cambridge Street, Suite 900 Boston, MA 02114
RE: Riverside Station Redevelopment, MEPA #16024
Dear Secretary Theoharides:
The Metropolitan Area Planning Council (MAPC) regularly reviews proposals deemed to have regional impacts. The Council reviews proposed projects for consistency with MetroFuture, the regional policy plan for the Boston metropolitan area, the Commonwealth’s Sustainable Development Principles, consistency with Complete Streets policies and design approaches, as well as impacts on the environment.
MAPC has a long-term interest in alleviating regional traffic and environmental impacts, consistent with the goals of MetroFuture. Furthermore, the Commonwealth encourages an increased role for bicycling, transit and walking to meet our transportation needs while reducing traffic congestion and vehicle emissions. Additionally, the Commonwealth has a statutory obligation to reduce greenhouse gas emissions (GHG) by 25% from 1990 levels by 2020 and by 80% from 1990 levels by 2050.
A Draft Environmental Impact Report (DEIR) has been filed with the EOEEA by MD 399 Grove Owner LLC, Ramirez Concord LLC, BH Normandy Riverside LLC, c/o Mark Development LLC (together, the Proponent) propose to redevelop land comprising the surface parking lot associated with the MBTA’s Riverside Green Line Station and the site of the existing Hotel Indigo in Newton. Since the filing of the Environmental Notification Form (ENF), the overall project size has decreased by approximately 30 percent from approximately 1.5 million square feet (sf) to 1.03 million sf. The amount of parking has also been reduced by approximately 30 percent from 2,922 to 2,041 spaces.
The Proponent proposes to redevelop the 13.5 acre Project site with a mixed-use, transit-oriented development (TOD) comprising approximately:
➢ 653,571 sf of residential space (579 units); ➢ 250,887 sf of office space; ➢ 77,300 sf of hotel space (150 rooms); ➢ 43,242 sf of retail space; and ➢ Open space comprising over 4 acres.
The Project will generally be built in two phases and will include ten buildings. The proposed buildings can be developed together, independently of each other, and in differing sequences. The mix of uses constructed will be in response to evolving market conditions, which is probable particularly appropriate given current market uncertainties.
The Riverside Station Redevelopment (the Project) is at the end of the MBTA Green Line Riverside Branch (D), Newton’s busiest transit stop. The Project site is expected to generate an estimated 11,368 new weekday daily vehicle trips1 and 2,041parking spaces are proposed.
Adjacent to Riverside Station, the Project site is bordered by the MBTA maintenance facility and Charles River Greenway to the northwest; the existing Riverside Office Park to the northeast; Grove Street, a golf course, and a small condominium complex to the southeast; and the I-95 Exit 23 interchange to the west. The Project site includes a portion of the existing MBTA facility at 355 Grove Street and the Hotel Indigo site (399 Grove Street).
MAPC has reviewed the Draft Environmental Impact Report (DEIR) and has concerns that address advancing a robust Transportation Demand Management (TDM) program, developing mode share goals, project monitoring and reporting, mitigation, parking, and bicycle/pedestrian connections. Proposed recommendations and questions regarding these topic areas are detailed as an attachment to this letter.
In order to minimize adverse impacts and to keep the Commonwealth on track in meeting its regulatory and statutory goals, MAPC respectfully requests that the Secretary incorporate our comments as part of the Certificate issuance.
Thank you for the opportunity to comment on this project.
Sincerely,
Marc D. Draisen Executive Director
cc: Jenifer Caira, City of Newton David Mohler, MassDOT
1 New Unadjusted Vehicle Trips (Note: This number does not include the current 4,700 vehicle trips per day generated at the site by the MBTA Station. Table 4-5 – Project Trip Generation).
Metropolitan Area Planning Council (MAPC) comments on The Riverside Station Redevelopment, DEIR, MEPA # 16024
MAPC is pleased the Proponent has advanced a mixed-used transit-oriented development (TOD) at a major MBTA transit station. Below are our comments and questions that, if implemented and addressed, will ensure the Project reaches is maximum potential as a successful TOD site.
Transportation Demand Management (TDM) Program
Clearly Identify TDM Program Commitments The Transportation Appendix2 contains two documents, both of which identify components to consider for implementing a Transportation Demand Management (TDM) program: Draft 128 Business Council TDM Plan (dated December 9, 2019) and VHB Traffic and TDM Monitoring Summary (dated January 14, 2020). While both documents identify considerations to implement a TDM program, the language is unclear as to whether these TDM components are clear commitments or are simply mentioned for consideration. Additionally, the TDM commitments need to be clearly identified in the draft Section 61 Findings for the MassDOT Access Permit, not as an Appendix. We respectfully request that the TDM program commitments be consolidated and included in the draft Section 61 Findings for the MassDOT Access Permit. Doing so will ensure future monitoring of the Proponent’s TDM program.
Proposed Reimbursements for Use of Sustainable Modes of Transportation Both the Draft 128 Business Council TDM Plan the VHB Traffic and TDM Monitoring Summary contain sections on Incentives for Sustainable Transportation, which propose reimbursements for reliance upon sustainable modes of transportation. While we applaud the proposal that residents who entirely forgo the use of a residential parking space would be eligible for reimbursement of up to $200/month, we strongly disagree with the proposal to reimburse residents who lease a single parking space to be eligible for reimbursements of up to $75/month. To ensure the Project is a successful TOD and has a strong TDM program, residents should not receive a monetary reimbursement if they lease a single parking space. We also note that both documents mention a similar program will be instituted for office users, the specific details of which will be determined by ongoing traffic monitoring. MAPC respectfully requests that a similar program be instituted for office users as soon as the Project is ready for occupancy, and not after the fact when it likely would be more difficult to implement.
Importantly, the TDM program also needs to specify the proposed reimbursements for resident and employee MBTA passes and/or bikeshare memberships.
Specific TDM Strategies MAPC recommends the TDM Program include:
➢ A commitment to join and participate in the 128 Business Council Transportation Management Association (TMA) in addition to hiring an on-site Transportation Coordinator, and:
➢ A discussion of how tenancy lease agreements or a tenant manual will be used as a mechanism to ensure implementation, maintenance, and success of TDM measures.
Mode Share Goals, Monitoring and Reporting
One of the primary goals of the Project is to create a TOD at Riverside Station that will encourage residents, employees, and visitors to access the Project site via public transportation and other modes of transportation and not place pressure on the existing roadways by creating significantly more vehicle trips. To ensure this is accomplished, it is essential that the Project identify mode share goals and have a monitoring and reporting program in place.
2 Appendix C ______Kathleen Theoharides, Secretary, Executive Office of Energy and Environmental Affairs April 17, 2020 RE: Riverside Station Redevelopment, DEIR, MEPA #16024 Page 2 of 5 Metropolitan Area Planning Council (MAPC) comments on The Riverside Station Redevelopment, DEIR, MEPA # 16024
Mode Share Goals The DEIR contains no mention of mode share goals and this is even acknowledged by the Proponent. It is important to underscore that the ENF Certificate3 required the Proponent to develop a traffic monitoring program that includes mode share goals. The Proponent needs to delineate a program that ensures clearly defined mode share goals are accomplished over a specified time frame related to the two phases of the Project’s development. Along with specific steps to achieve these goals, the Proponent should provide annual updates, and publicly share the results.
Developing and monitoring mode share goals is a central component as outlined in the EOEEA/MassDOT Guidelines for Traffic Impact Assessments (TIAs). Specifically, the TIA Guidelines state: “The TIA should include an assessment of the mode split assumptions, as well as the Proponent’s plan to maximize travel choice, promote non-SOV modes, and achieve the assumed mode shares.” (p. 17) The Proponent needs to define mode share goals specifically, with numerical targets for automobiles (SOV and shared), bicycle, pedestrian, Green Line, and bus, as part of their commitment to conduct monitoring and reporting, and to adjust the project’s TDM program as necessary. An essential component of a successful TOD project is the identification and monitoring of mode share goals.
Monitoring and Reporting The Proponent should specifically outline their monitoring and reporting program and commit to it in the Section 61 findings. The ENF Certificate required the Proponent to include in the DEIR “a draft traffic monitoring program to evaluate the assumptions made in the traffic study, including mode share goals, and the adequacy of the transportation mitigation measures, including the TDM and shared parking programs. The program should include annual traffic monitoring for a period of five years. The monitoring program should include:
• Automatic traffic recorder (ATR) counts at each site driveway for a continuous 24-hour period on a typical weekday and Saturday; • Travel survey of employees and patrons of the site; • Weekday AM and PM and Saturday peak hour turning movement counts (TMC) and operations analysis at mitigated intersections; and, • Vehicular and bicycle parking counts.” (p. 10)
The Proponent must also commit to conducting regular monitoring and reporting of transportation mode shares and adjust the Project’s alternative transportation services and TDM programs as necessary. MAPC recognizes that the Proponent has committed to requiring additional mitigation action and adjustments to the TDM plan should the Project traffic exceed ten percent of the projection for new traffic. However, the monitoring program needs to include details of how mode share goals will be attained, as well as steps that will be taken if goals are not met.
MAPC also recognizes that the Proponent has committed to monitor vehicle trips within 12 months of full occupancy of each phase and will continue to do so annually for two years following final build-out. However, as required by ENF Certificate, monitoring needs to take place on an annual basis for at least five years after full occupancy.
In order to ensure the success of this Project as a TOD, it is imperative that the Proponent commit to an extensive and thorough transportation monitoring and reporting program with mode share goals that includes annual data collection of traffic counts, parking usage, public transportation (rail and bus), bicycling, and walking, as well as specific steps to be taken if mode share goals are not attained.
3 Dated June 7, 2019. ______Kathleen Theoharides, Secretary, Executive Office of Energy and Environmental Affairs April 17, 2020 RE: Riverside Station Redevelopment, DEIR, MEPA #16024 Page 3 of 5 Metropolitan Area Planning Council (MAPC) comments on The Riverside Station Redevelopment, DEIR, MEPA # 16024
Mitigation
In order to fully realize this site as a successful TOD, it is critical that the Proponent commit to a strong TDM program. An aggressive TDM program is necessary to optimize the advantages of a development in close proximity to transit as well as minimize vehicular usage and project-related traffic impacts.
Summary of Mitigation Measures Table 11-1 Summary of Mitigation Measures, needs to be included as part of the draft Section 61 Findings for the MassDOT Access Permit. Table 11-1 should be expanded to include estimates of the costs for each proposed mitigation measure, identify the parties responsible for implementation, and a schedule for implementation.
Public Transportation Mitigation The Proponent recognizes that the Green Line may be overcapacity during the “shoulder peak” just after and before the weekday morning and weekday evening peak periods, respectively. Accordingly, the Proponent has indicated that they will work with the MBTA to mitigate the effects of the Project on the MBTA system. What the Proponent has identified to mitigate the effects needs to be included in the mitigation section of the draft Section 61 Findings for the MassDOT Access Permit.
Shuttle to Commuter Rail MAPC is pleased the Proponent mentioned that providing a shuttle service to offer access between Auburndale Station (Worcester commuter rail line) and Riverside Station is being considered and will be part of the future plan if there is demand. In addition to including a commitment to consider a shuttle in the Summary of Mitigation Measures, we respectfully ask that the Proponent evaluate a demand for this shuttle service as part of annual project monitoring.
MAPC considers that providing this service is paramount and has the potential to significantly reduce SOV trips to and from the Project site. Given the mixed-use nature of the Project site, the shuttle should be functional in both directions. During the morning peak hours, residents of the site would be dropped off at Auburndale Station and office employees would be picked up, and vice-versa during the evening peak hours. This shuttle would provide direct transit access between Riverside and destinations to the west (Worcester, Framingham, Natick, Wellesley) and to the east (downtown Boston, including the Longwood Medical Area, the Back Bay, and South Station).
Parking
The Proponent proposes 2,041 parking spaces for this Project. Specifically, 990 spaces will be allocated between the proposed residential, office, retail, and hotel uses. One thousand spaces will be dedicated for MBTA commuter parking. The remaining 51 spaces will be surface/on-street spaces located throughout the Project site. Riverside Station is a premiere TOD site located in close proximity to public transportation (bus and rail), enabling people to live and work car-free, or with limited auto ownership and use. The biggest determinant of whether people will use an automobile is the amount of parking provided at both the origin and destination at the site. Therefore, continuing to explore ways to further reduce the amount of parking is the most effective strategy to reduce auto trips.
Allocation of Parking Spaces The Proponent should disclose the allocation of proposed parking spaces for each land use type (residential, office, retail, and hotel).
Shared Parking As required in the ENF Certificate, the Proponent needs to identify clearly the opportunities for shared parking. Shared parking strategies should be used to decrease the number of parking spaces on-site. We respectfully ask the Secretary to require the Proponent to quantify how shared parking will be developed for this Project. For example, designating parking for residents in the evening while using the same parking spaces for office use during the day could be an effective shared parking strategy.
______Kathleen Theoharides, Secretary, Executive Office of Energy and Environmental Affairs April 17, 2020 RE: Riverside Station Redevelopment, DEIR, MEPA #16024 Page 4 of 5 Metropolitan Area Planning Council (MAPC) comments on The Riverside Station Redevelopment, DEIR, MEPA # 16024
We also note that the while the current observed peak demand of MBTA parking is 636 spaces, there will be dedicated MBTA parking for 1,000 spaces. The Proponent should explore ways to utilize the MBTA parking spaces should they not be fully utilized by commuters. We urge the Proponent to take full advantage of the benefits of this mixed-use development, including the fact that the various users at the site will have different parking needs throughout the day, thus enabling the Proponent to reduce the number of spaces on site.
MBTA Parking MAPC notes the Proponent stated in the DEIR that “How the 1,000 dedicated MBTA spaces are designated and used is entirely at the discretion of the MBTA and not the Proponent.” (p. 12-57) MAPC requests that the Proponent work with the MBTA to ensure that spaces are made available for carsharing (e.g., ZipCar), carpooling and/or vanpooling, as well as bicycle parking and bicycle sharing programs. The MBTA should also commit to the provision that 10 percent of the parking spaces have electric vehicle charging, the same percentage to which the Proponent has committed.
Unbundled Parking MAPC urges the Proponent to “unbundle” parking and housing costs at the site by uncoupling the parking from the housing unit lease or sale and charging the tenant a monthly or annual fee to park a vehicle at the site. Unbundling parking is an effective strategy that encourages households to own fewer cars and to rely more on walking, bicycling, and transit. In addition, unbundling parking allows allocation of space for other components of a building’s design which would have otherwise been allocated for parking.
Structured Parking Plans for future adaptability of structured parking should be explored for potential productive reuse of the space, should parking demand decrease in the future due to changes in automotive technology or other causes. Additionally, construction of phased construction of the parking facility should be explored with additional parking added depending on demand.
Bicycle and Pedestrian Connections
MAPC is pleased to see the paths, trails, and other bicycle and pedestrian infrastructure as proposed in the DEIR. They clearly line up with what the community as requested in terms of connections. However, the proponent falls short in what we believe should be constructed as part of this project to provide the vital connections. The below comments can be referenced on Fig 4.28.
Railroad Bridge over 95 The abandoned railroad bridge over I-95 is part of a planned rail trail between Route 16 in Wellesley and Riverside Station, passing through the edge of Leo Martin Park. Completion of this trail is critical to providing seamless access for cyclists and pedestrians coming from points west in Wellesley and beyond. We request that the proponent construct this trail from Riverside Station across I-95 to DeForest Street (as well as the path the Proponent proposed along Recreation Road). Currently, we see only the funding of design.
Path under Recreation Road We are pleased that the Proponent proposed this connection between the existing MWRA Trail and across the Charles River to Pigeon Hill. We request that the Proponent complete this connection by building the entire trail along Recreation Road and under it to meet the MWRA trail. One additional comment is that the trail along Recreation Road should be separated from the road by an ample tree planted landscaped buffer. Recreation Road should be moved westward as needed to accomplish this separation between the highway uses and the trail.
Grove Street Bike Lane The proposed bike lane on Grove Street should be extended all the way to the proposed roundabout at Quinobequin Road.
______Kathleen Theoharides, Secretary, Executive Office of Energy and Environmental Affairs April 17, 2020 RE: Riverside Station Redevelopment, DEIR, MEPA #16024 Page 5 of 5
May 1, 2020
Kathleen Theoharides, Secretary Executive Office of Energy and Environmental Affairs 100 Cambridge Street, Suite 900 Boston, MA 02114-2150
RE: Newton: Riverside Station Redevelopment – DEIR (EEA #16024)
ATTN: MEPA Unit Alex Strysky
Dear Secretary Theoharides:
On behalf of the Massachusetts Department of Transportation, I am submitting comments regarding the Draft Environmental Impact Report for the Riverside Station Redevelopment project in Newton, 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
Newton – Riverside Station Redevelopment Page 2 5/01/2020 cc: Jonathan Gulliver, Administrator, Highway Division Patricia Leavenworth, P.E., Chief Engineer, Highway Division John McInerney, P.E., District 6 Highway Director Andrew Brennan, Director, Energy and Environmental, MBTA Neil Boudreau, Assistant Administrator of Traffic and Highway Safety Planning Department, City of Newton Boston Region Metropolitan Planning Organization
TO: David J. Mohler, Executive Director Office of Transportation Planning
FROM: J. Lionel Lucien, P.E, Manager Public/Private Development Unit
DATE: May 1, 2020
RE: Newton – Riverside Station Redevelopment: DEIR (EEA #16024)
The Public/Private Development Unit (PPDU) has reviewed the Draft Environmental Impact Report (DEIR) for the proposed Riverside Station Redevelopment (“Project”) in Newton. The14.4-acre site, located at 355 and 399 Grove Street, is currently occupied by the Massachusetts Bay Transportation Authority’s (MBTA) Riverside Green Line Station, an associated 960 space parking lot for the station, and a 194-room hotel. BH Normandy Riverside LLC (“Proponent”) was the selected developer from an invitation to bid for the leasing of a portion of the certain land and air rights at the premises, and entered into a lease agreement with the MBTA in 2009. The Proponent has since been working with the MBTA on a number of issues associated with the leasing of the site, including site access, site design, shared parking, easements, on-site vehicle storage, and transit analysis. Given the length of involvement with the Proponent on this project, the MBTA will submit in this particular instance a separate comment letter that will address these issues in more detail.
The DEIR includes a revised development program that has decreased by approximately 30% from the 1.5 million square feet development program identified in the Environmental Notification Form in 2019. The Proponent seeks now to redevelop the site into approximately 1.025 million square feet of mixed-use development comprised of 250,887 square feet of office space; 653,571 square feet (617 units) of residential space; 48,242 square feet of retail space, and 77,300 square feet (150 keys) of hotel space. All existing MBTA uses will be retained, but two of the proposed buildings would provide new shared parking facilities for Green Line commuters with residents, visitors, and employees of the project site. The project would be developed in two phases anticipated to be built over a four-year period.
Primary access to the site would be provided by a reconfigured I-95/Route 128 Exit 22 interchange with Grove Street. A new intersection would allow the western edge of the project site to process the majority of vehicles entering the site, with the Route 128 off-ramp serving as the eastern approach, the site driveway serving as the western approach, a newly- constructed Grove Street Extension serving as the southern approach and allowing access from Grove Street to the west, and a newly-constructed Recreation Road serving as the northern approach allowing access to the I-95/Route 128 Exit 24-25 interchange towards the
Ten Park Plaza, Suite 4150, Boston, MA 02116 Tel: 857-368-4636, TTY: 857-368-0655 www.mass.gov/massdot Newton-Riverside Station 2 5/01/20
Massachusetts Turnpike (I-90) and Route 30. An additional access point on Grove Street is proposed via a signalized intersection, with eastbound Grove Street left-turns prohibited from entering the site.
The project will require a Vehicular Access Permit from MassDOT as the project site would be accessed from the I-95/Route 128 off-ramp, a state-owned roadway. Several licenses/approvals will also be required from the MBTA given the impacts to the Riverside Green Line station.
The DEIR includes a Transportation Impact Assessment (TIA) prepared in conformance with the current MassDOT/EOEEA Transportation Impact Assessment Guidelines. The study includes a comprehensive assessment of the transportation impacts of the project and provides capacity analyses for existing, future No-Build, and future Build conditions, particularly at state highway locations. The future Build conditions include an analysis of operations with and without any improvements. To mitigate traffic impacts, a comprehensive access management plan that includes modifications to the I-95/Route 128/Grove Street interchange along with traffic and geometric improvements at the Grove Street corridor is proposed to be implemented. An Interchange Modification Report (IMR) was separately conducted for the interchange to address existing deficiencies while providing a new access to the site. The IMR was reviewed and approved by MassDOT and FHWA.
The TIA also includes a comprehensive transit analysis for the Green Line, the MBTA Express Bus Route 558, and regional buses that serve the site. Overall, the DEIR proposes an integrated multimodal mitigation package intended to improve vehicular traffic operations while supporting increased use of walking, bicycling, and transit by commuters, employees and residents of the development. The following comments should be addressed in the FEIR.
Trip Generation
Based on the revised development program identified in the DEIR, the Full-Build project would generate 11,368 unadjusted vehicle trips on an average weekday, including 746 vehicle trips during the AM peak hour and 981 vehicle trips during the PM peak hour. On an average Saturday, the project is estimated to generate 9,972 vehicle trips, including 889 vehicle trips during the Saturday midday peak hour. These estimates are based on the Institute of Transportation Engineers (ITE)’s Trip Generation Manual (10th Edition) using trip generation equations for the appropriate land use codes. When adjusted for internal capture, existing hotel trips, and MBTA trips, the site is expected to generate 598 net new vehicle trips and 73 new transit trips during the weekday AM peak hour; 627 net new vehicle trips and 58 new transit trips during the weekday PM peak hour; and 556 net new vehicle trips and 55 new transit trips.
The TIA did not apply mode share credit for walking or bicycling to the trip generation in order to provide a conservative traffic analysis for the project. MassDOT notes that this approach is not fully consistent with our policy to create an appropriate balance between the different modes, which should be reflected in the transportation analysis and the Newton-Riverside Station 3 5/01/20
resulting mitigation program. The Proponent should consult with MassDOT and then update the TIA with appropriate project mode share credits for bicyclists and pedestrians. These mode shares will be used to measure the effectiveness of the project’s transportation demand management measures. Alternatively, the Proponent should discuss providing MassDOT with a sensitivity analysis to determine whether or not a revised capacity analysis is required for the project.
Trip Distribution
The TIA has used a combination of population densities, employment opportunity, travel patterns and the efficiency of the roadway system to determine trip characteristics for commuters, visitors, employees and residents of the project. The resulting trip distribution indicates that the majority of the traffic will travel to the site via the Interstate Highway System using Interstates 90 and 95. This information was used to justify the need to modify the ramp system to provide a more efficient and regional access to the MBTA Station and the Project.
Safety
The TIA includes a comprehensive safety analysis of the intersections and roadway segments in the study area. In consultation with MassDOT, seven locations were identified as Highway Safety Improvement Program (HSIP) locations that require Road Safety Audits (RSAs). The RSAs were conducted at all seven locations and a list of recommendations to improve safety was provided to the City of Newton, the Town of Weston and MassDOT. The FEIR should include a clear commitment to implement some of the safety improvements. Typically, MassDOT recommends that all low-cost improvements be implemented as part of mitigation for development projects.
Traffic Operations
Capacity analyses were conducted for the weekday AM, weekday PM, and Saturday midday peak hours for both existing and future conditions for all locations in the study area. In addition, capacity analyses for Build with mitigation conditions were also provided for all intersections.
According to the TIA, most intersections are expected to operate at levels of service (LOS) D or better, except for a few instances where an individual intersection movement would operate at less than acceptable conditions but with no major impacts to overall operations. The other exception is operating conditions along the Grove Street corridor where several unsignalized intersections currently operate at less than acceptable conditions or are expected to continue to experience worsening LOS and delay during the future No-Build and Build conditions. This corridor is also expecting to experience significant queuing and delay during event conditions when there is heavy usage of the parking facility by patrons heading to Red Sox games in Boston.
Newton-Riverside Station 4 5/01/20
Weave, merge, diverge, and roadway segment analyses were also conducted for the Interstate segment abutting the project site, including the I-95/Grove Street interchange. According to the TIA, several locations are expected to experience unacceptable LOS with or without the project due to the substandard design of the existing interchange.
To address these existing operational conditions and accommodate the additional traffic associated with the Project, the Proponent has worked with the MassDOT Highway Division over the past few years to develop conceptual alternative improvements for the interchange. These concepts were fully vetted and reviewed by the Federal Highway Administration (FHWA) and an Interchange Justification Report was submitted by MassDOT for review and approval. The selected alternative resulting from the IMR process is a comprehensive access management plan that includes a direct connection from the Interstate Highway System to the MBTA Riverside Station, reduces congestion in the vicinity of the site, upgrades existing pedestrian and bicycle accommodations, and includes traffic signalization with Adaptive Traffic Signal Technology to optimize traffic operations. These improvements would not only improve site access for commuters, employees, and residents to the Riverside Station Development but also address existing deficiencies of some of the weave, merge, and diverge movements at the I-95/Route 128/Grove Street interchange; improve access to Recreation Road and DCR properties along the Charles River; improve access and egress for MBTA and regional buses serving the site; and better manage access along the Grove Street corridor. With the interchange improvements in place, most of the intersections and the interchange weave, merge, and diverge movements are expected to operate at LOS D or better during normal and event conditions. The Proponent has committed to implement these improvements as part of mitigation for the project.
Parking
According to the TIA, the site will be served by a total of 2,041 parking spaces provided on surface and parking garage. A total of 1,000 spaces are reserved at all times for MBTA users; this amount is greater than the current number of parking spaces provided on site. The remaining spaces will be shared between the proposed residential, office, retail, and hotel uses. The DEIR includes in Appendix C a comprehensive parking analysis, which indicates that the proposed number of parking spaces and the new shared parking arrangement would not impact the MBTA parking needs or MBTA parking operations, more specifically during the high peak periods.
Public Transportation
The project site is currently served by the Riverside Station on the Green Line, a bus terminal serving local shuttle buses, a regional bus carrier (GoBus) and MBTA bus services. The DEIR includes a comprehensive transit analysis of the different transit services that surround the site. The TIA includes a detailed presentation of the impact to the transit system with summary tables for the anticipated demand in terms of MBTA Service Standards for transit and bus services. According to the analysis, both the transit lines and the bus routes surrounding the site are expected to have sufficient capacity in the future to accommodate the Newton-Riverside Station 5 5/01/20
additional transit trips generated by the project during the peak hours. The analysis indicates that the Green Line may be over capacity during the “shoulder peak” meaning after and before the weekday morning and evening peak hours, respectively.
As previously stated, the MBTA will be providing a comment letter discussing in more detail a number of issues that may need to be addressed in the FEIR. The letter will expand on the transit analysis and needed improvements to address the project’s impacts. We defer to the MBTA comments regarding the transit mitigation for the project.
Multimodal Access and Facilities
The Proponent has adequately addressed how the site would be made accessible and friendly to bicycles and pedestrians. The DEIR includes a complete inventory of pedestrian and bicycle accommodations throughout the study area as well as those planned by the Proponent. The site design includes a continuous network of sidewalks connecting the various uses on site. The proposed pedestrian infrastructure will facilitate pedestrian travel for residents and employees between the proposed buildings and the MBTA Riverside Station while minimizing the number of single-occupant vehicle trips. As part of the interchange improvements, the Grove Street corridor will be reconstructed and the improvements will also include bicycle and pedestrian accommodations that will connect to the infrastructure onsite.
Transportation Demand Management Program
The Proponent has outlined and committed to a comprehensive TDM plan in the DEIR, which at a minimum will include the following measures:
• Join a Transportation Management Association (TMA) established for the area: the Route 128 Business Council; • Designate a Transportation Coordinator to oversee all transportation related operational matters at each Project component, including vehicular operations, servicing and loading, parking and implementation of the TDM Plan. The Transportation Coordinator will act as the contact and liaison for the City of Newton, MBTA, MassDOT, the Route 128 Business Council and tenants/residents of the Project; • Post and make available transit maps, schedules and other information relevant to commuting residential and office building lobbies; • Assign Car Sharing spaces in garages, subject to demand; • Install electric vehicle charging stations and EV-ready parking in the parking garage; • Provide long-term covered secure and short-term public realm bicycle spaces
Newton-Riverside Station 6 5/01/20
Transportation Monitoring Program
The Proponent has committed to conduct an annual traffic monitoring program for a period of five years, beginning twelve months after occupancy of the full-build project. If the project is phased, the Proponent should work with MassDOT to devise an appropriate schedule. The monitoring program should include:
• Simultaneous automatic traffic recorder (ATR) counts at each site driveway for a continuous 24-hour period on a typical weekday and Saturday; • Travel survey of employees and patrons at the site (to be administered by the Transportation Coordinator); • Weekday AM and PM and Saturday peak hour turning movement counts (TMCs) and operations analysis at “mitigated” intersections, including those involving site driveways; • Parking counts to ensure the shared parking arrangement is working as anticipated and sufficient parking spaces are provided to accommodate commuters.
The goals of the monitoring program would be to evaluate the assumptions made in the Environmental Impact Report (EIR) and the adequacy of the mitigation measures, as well as to determine the effectiveness of the TDM program.
Section 61 Finding
The DEIR includes a Draft Section 61 Finding, outlining the mitigation measures the Proponent has committed to implementing in conjunction with this project. The FEIR should include a revised draft Section 61 Finding prepared in consultation with MassDOT and the MBTA to incorporate appropriate elements of the Lease Agreement that should be part of the permitting documentation for the project. The revised Draft Section 61 Finding will be the basis for MassDOT to issue a final Section 61 Finding for the project.
The Proponent should continue consultation with appropriate MassDOT units, including PPDU, the MBTA and the District 6 Office during the preparation of the FEIR. If you have any questions regarding these comments, please contact me at (857) 368-8862.
DocuSign Envelope ID: B2C9764A-9E12-47D6-9F83-F9800D38DA7F MBTA Logo, Charles D. Baker, , Lieutenant Governor, Stephanie Pollack, MassDOT Secretary & CEO, Luis, General Manager & CEO, MassDOT logo
May 8, 2020
Kathleen A. Theoharides, Secretary Executive Office of Energy and Environmental Affairs 100 Cambridge Street, Suite 900 Boston, MA 02114
Attention: Alex Strysky
RE: Riverside Station Redevelopment Draft Environmental Impact Report EEA #16024
Dear Mr. Strysky:
The MBTA appreciates the opportunity to comment on the above-referenced project. The MBTA has been working with the Developer of the site since the took over the project from the previous proponent. The Riverside Station Redevelopment represents a significant opportunity for the MBTA. Transit Oriented Development (TOD) projects are highly sought after by the MBTA because they provide better access for our customers by creating a land use that is far more environmentally sustainable than typical suburban areas. At the commencement of the lease, the Proponent will give the MBTA a significant payment in exchange for the use of the site. Non-fare revenues such as this allow the MBTA to fund the operations of the transit system and to do so without seeking fare increases or increased taxpayer funds.
The Station at Riverside Project proposes in total approximately 617 residential units, over 250,000 square feet of office/lab space, nearly 43,000 square feet of retail space, and a 150 room hotel as well as a new garage of over 2,000 parking spaces, inclusive of the spaces which will be reserved for MBTA customers. These spaces will replace the MBTA commuter spaces currently on site. As part of the project, the Proponent will build the MBTA anew parking garage for the MBTA’s customers to replace the spaces otherwise lost by the development. The MBTA and the Proponent have been coordinating on this project for a long period of time We have established a strong and cooperative relationship and appreciate the developer’s willingness to work with the MBTA and its ability to respond to our needs and concerns. We anticipate that this relationship will continue as the project develops. We believe that it is important for us to highlight these project development issues in the MEPA process by laying them out in this comment letter so as to codify these issues to keep the public informed as we advance this project. We are providing these comments on the DEIR so that the MEPA filings can provide a consistent and transparent overview of the steps that the Proponent is taking to avoid, minimize or mitigate impacts to the MBTA and its operations.
On May 28, 2019, the MBTA submitted comments on the ENF. The DEIR and its Response to Comments addresses many of these comments, but we believe that the Final EIR should provide a more specific and detailed response to these issues. Specifically, the FEIR should provide graphics and illustrations to show how these issues will be resolved. The Response to Comments section provides answers to these questions, but the answers lack specificity or transparent information. We realize that the work may be contained within the transportation Appendix (Appendix C) but this Appendix is a dense document of over 2700 pages and this document is attached to a very large DEIR. This format makes it very difficult to determine what questions are answered and what are not. The information presented in the FEIR should be provided in a manner that makes the information as accessible as possible, utilizing good graphics (with dimensions) and information summarized in tabular formats. Without a Massachusetts Bay Transportation Authority Ten Park Plaza, Boston, MA 02116 www.mbta.com DocuSign Envelope ID: B2C9764A-9E12-47D6-9F83-F9800D38DA7F Kathleen A. Theoharides, Secretary EEA RE: Riverside Station Redevelopment DEIR -- EEA #16024 Page 2 of 8 May 1, 2020
reader friendly presentation, it is difficult for the MBTA (and the public) to see how these important issues are answered.
The Proponent has advanced many of these issues in its further discussions and coordination with the MBTA. The MBTA appreciates the work the Proponent has done and understands that due to the timing of the DEIR, this information was no available to be presented in the document. Therefore, the public is not able to fully understand these developments. We believe it is important to not only advance these concepts with the MBTA, but to do so in a way that allows the public to review and comment on these developments. Because of this, the MBTA is basing it comments on the DEIR itself, and not the additional information. We assume that this information, and any additional advances in the design that occur going forward, will be made available in the upcoming FEIR.
In light of that, the MBTA makes the following comments as to how we believe the scope of the Final EIR should be developed.
MBTA Agency Actions:
In the ENF Comment Letter, the MBTA requested that the EIR include a detailed explanation of any interests in real property that it would need to acquire from the MBTA. The MBTA requested that the DEIR provide this information in the in the form of a narrative as well as graphics and presented in an appropriate scale. The DEIR provides a summary broad summary of MBTA properties in the project area, but does not have a detailed discussion of the parcels and easements (either permanent or temporary) that this project required. The DEIR should provide a table that articulates these real estate needs as well as a graphic that lays them out. The graphics and the narrative in the FEIR should provide specificity, including dimensions of these easements and the timing of the acquisition. This information is critical for the MBTA since the interest in real estate is the State Action pursuant to MEPA and forms the basis for the MBTA’s MEPA responsibilities. This State Action will trigger the need for the MBTA to issue its Section 61 Findings that will be required.
Transportation Impacts:
As described above, the MBTA currently operates extensive rapid transit near the site and bus service directly to the site. In its ENF Comment Letter, the MBTA requested that the EIR should contain an analysis of what additional Green Line demand will result from the project. In the Transportation Impact Access (TIA), the MBTA asked that the EIR indicate what the anticipated mode share will be and specifically what the transit mode share for the full build of this project. The MBTA requested that the TIA include impacts to the existing transit service in the form of an assessment of how riders, particularly in the MBTA peak period, will access the facility via transit. It is important for the MBTA to understand how the additional new ridership on the Green Line and what time of day those impacts will occur.
Overall, the DEIR does a good job of responding to the MBTA’s request for the analysis. The Proponent worked extensively to utilize best available information from the MBTA and apply the results to the MBTA’s Service Standards and Service Delivery Policy. The MBTA appreciates the extent to which the Proponent responded to the MBTA’s needs.
The result of the analysis is that there will be some impacts on the Green Line in the “shoulder” of the peak period: that is, as morning peak service begins to ramp down to the off peak period. (typically 8:30 AM to 9:30 AM). This is partly the result of the MBTA running fewer trains as it transitions from rush hour to non-rush hour service. The MBTA is undergoing a long term program to significantly enhance the Green Line capacity through the implementation of larger vehicles and increasing the frequency of trains. This requires a series of major capital investments to the signal systems, power systems, track alignments, bridge ratings and other upgrades. This DocuSign Envelope ID: B2C9764A-9E12-47D6-9F83-F9800D38DA7F Kathleen A. Theoharides, Secretary EEA RE: Riverside Station Redevelopment DEIR -- EEA #16024 Page 3 of 8 May 1, 2020
program (referred to as “Green Line Transformation”) is one of the MBTA’s most important priorities. This is a multi-decade program where the improvements come on line over time, with each improvement making incremental capacity improvements.
The Riverside Station Project will also be developed over a period of time, some or most of it occurring before many of the GLT improvements are completed. The result of this will that there will be some level of overcrowding on the Green Line as a direct result of riders who come from the Riverside Station Development and board the Green Line. That overcrowding level is defined by existing MBTA service standards assuming current levels of service.
To resolve this, the MBTA would need to look to adding some level of additional Green Line service, most likely one or two trains in this one-hour period. The MBTA has been discussing the best way to mitigate this impact on service and have held on-going conversations with the Proponent on this and other service related issues. The MBTA’s goal is to develop appropriate service levels to support this project. We request that the Proponent continue to work with the MBTA on this and that the results of this coordination be presented in the FEIR. Along with that, the ridership analysis should be updated to demonstrate any ridership or service level changes implemented by the MBTA before the FEIR is issued. The FEIR must demonstrate what the impacts to service level would be with this additional service in place. Additionally, given that the MBTA service levels and ridership are in a state of flux due to COVID-19 and that recovery service levels have not yet been established, it is important that the Proponent work with the MBTA so that ridership and service levels presented in the FEIR represent the MBTA’s current thinking on Green Line operations.
Bus Access, Circulation, and Traffic Improvements:
In its ENF Comment Letter, the MBTA requested an assessment of the impacts to MBTA bus service due to traffic generated by the project. The DEIR seems to indicate that all of the intersections will operate (with mitigation) at a Level of Service of C or better. The FEIR should confirm that the intersections utilized by MBTA vehicles will be able to meet this LOS.
The Response to Comments section of the EIR should provide a Turning Movement analysis and a Level of Service analysis for all affected intersections. The MBTA requests that the FEIR present, in a tabular format, an assessment of which of these intersections MBTA buses utilize and how their timing or turning movements will be affected by the increased traffic and/or proposed roadway changes that results from the project.
The DEIR states that they will include Adaptive Traffic Signal Technology which should assist in MBTA buses accessing the site without delay. The DEIR, however, does not explain what type of signalization is being proposed or how it will work. The FEIR should contain a more detailed description of what type of signal prioritization is being proposed. We realize that these signals are subject to approval by the City of Newton and MassDOT, but the FEIR should describe what is being proposed.
The MBTA continues to believe that a design for the driveway should segregate MBTA buses from automobiles and that this intersection utilizes signal systems that prioritize MBTA buses entering and exiting the site. The DEIR indicates the entrance has the capacity to accommodate emergency vehicles and additional MBTA buses when there is a service interruption via a gated driveway. It is unclear that how this entrance would operate given that there is no graphic demonstrating its operations. The MBTA feels that a segregated bus entrance for diversions and emergencies is not only needed but is also possible. The FEIR should contain a further assessment of this entrance and graphics to demonstrate it. If it is determined that this type of bus segregation is not warranted or not feasible, that assessment should be presented in the FEIR.
The FEIR should also present a design that considers segregating automobiles from the MBTA buses rather than both be utilizing the same curb areas for dropoff and pickup. The FEIR should present the efficacy of transit DocuSign Envelope ID: B2C9764A-9E12-47D6-9F83-F9800D38DA7F Kathleen A. Theoharides, Secretary EEA RE: Riverside Station Redevelopment DEIR -- EEA #16024 Page 4 of 8 May 1, 2020
priority such as the use of exclusive bus facilities on and off station property, as well as channelization and signal design at the intersection to minimize the conflict between buses and automobiles. The DEIR presents a layout of the bus layover area at the station for existing bus service that provide direct station access. The MBTA’s comment letter on the ENF also requested that the graphics identify additional bus layover to accommodate up to eight to ten buses. This additional layover area would not be used for long-term storage, but instead would be used when the MBTA plans a Green Line shut down for maintenance and/or construction and shuttle bus service must be provided. In those occasions, the MBTA needs to have additional bus area to accommodate the shuttle buses. The DEIR does not appear to include any such bus layover area. The MBTA requests that the FEIR demonstrate how this service, which is provided regularly at the existing Green Line station, is accommodated in this design.
The MBTA requested that the EIR identify the paths of travel that customers will take from the garage to the station. The DEIR states that customers can access via Main Street and Road C. The MBTA requests that the FEIR contain a graphic showing all of the major pedestrian paths of travel and explicit statements and graphics showing how the pedestrian path and accessible paths are aligned. The MBTA needs to make sure that the accessible paths need to be the same path of travel that all pedestrians utilize.
The MBTA needs to see a design that shows that all buses that utilize the station can be accommodated with sufficient berths and appropriate paths of travel for passengers to transfer from one mode to another. The Proponents graphics do not show specific information to determine whether there is capacity. The FEIR must demonstrate what the impacts to service level would be with this additional service in place. There are a large number of transportation modes that utilize this station such as MBTA express bus routes from Newton to downtown Boston. These modes originate at Riverside Station given that many of our bus customers arrive at Riverside by car and board the express buses. The MetroWest Regional Transit Authority (MWRTA) provides bus access to Riverside Station. Additionally, intercity buses (Academy Bus) provide service from this station. A simple graphic that merely indicated bus berthing does not provide the MBTA with sufficient information to conclude that all of these services will be accommodated and that our customers can safely access these service. Graphics, with meaningful and specific information, are critical. Additionally, turning movements and radii for these buses are different from MBTA buses, so the design presented in the FEIR should be sure to accommodate all types of vehicles.
The DEIR contains a detailed description of a TDM program that should ensure that employees and residents use transit to the greatest degree possible. The TDM program is detailed and covers a number of matters that are not usually proposed in a typical DEIR. The Proponent should be acknowledged for proposing such an extensive TDM. The Draft Section 61 Agreement should specifically incorporate this TDM Plan (or any updated plan made as part of the FEIR).
Coordination with Other MBTA Projects and Facilities:
The MBTA is focused on making major changes to the Green Line with a program objective of doubling the capacity of the Green Line through a series of projects that will be rolled out in four phases over the course of the next 15 years. The Green Line Transformation (GLT) Office directs a range of projects that will modernize stations, update tracks, signals, and power systems, and adopt new state-of-the-art technology to meet the demands of a modern city. Overall, GLT will ensure that twice as many passengers have access to a safer, more comfortable, more reliable Green Line.
The MBTA’s Riverside Maintenance Facility plays a key role in this program and as such, the Riverside Station Redevelopment project must be designed, built and operated in such a way as to not impede the MBTA’s ability to do this critical work at its maintenance facility.
DocuSign Envelope ID: B2C9764A-9E12-47D6-9F83-F9800D38DA7F Kathleen A. Theoharides, Secretary EEA RE: Riverside Station Redevelopment DEIR -- EEA #16024 Page 5 of 8 May 1, 2020
The MBTA’s ENF Comment Letter identified a number of projects that it is pursuing with questions as to how the Riverside Station Development will be constructed and operated in a way that does not interfere with these projects. The DEIR simply stated that the facility has been designed to accommodate and that the Developer will work with the MBTA on these. While we appreciate this cooperation, we feel that these issues need to be described, in both the narrative and graphically, so that all of the MBTA Departments can be assured that these projects are not impacted. Additionally, these projects are of great interest to the community at large and so the public should be informed as to how these projects are working together so as to be confident that the Riverside Station Development does not adversely impact these important MBTA projects.
Given that specific information and graphics are not provided in the DEIR, the MBTA wants to reiterate these questions so that they can be properly presented in the FEIR.
a. MBTA Buildings: The MBTA is working with the Proponent on how best to house some of the MBTA buildings that will be displaced by the project, specifically the the Trackmen’s Lobby at the station and as well as administrative/ management building. These buildings would replace the buildings currently on site and used by the MBTA. The MBTA and the Proponent are currently working to determine if these buildings will be built by the Proponent or by the MBTA. Regardless of who builds these buildings, the impacts need to be assessed in the environmental documents so as to not segment the review.
In the event that the MBTA and the Proponent agree that the Proponent will build these spaces as part of the project, the Proponent must develop these buildings to the MBTA’s standards associated with functionality, maintenance and building control systems, energy and water efficiency, accessibility and circulation, full access for all employees, and a host of other requirements. These buildings must be built in full conformance with all state and local codes, including the requirements of the Office of Public Safety and Inspection and other state building codes. There are codes and requirements that are unique to public entities like the MBTA and the Proponent must be sure that all of those requirements are met. The Proponent must work with MBTA Capital Delivery, Green Line operations and other departments to ensure full compliance. These design and operation issues will be a significant component of the MBTA/Proponent design review coordination discussed below.
The Proponent should identify not only the design of these MBTA buildings, but also the sequencing of them to ensure that the MBTA maintains the ability to support these functions with minimal impact to operations and employee activities.
The Response to Comments indicates that “proposed garage will be designed according to MBTA standards.” While we appreciate this statement, we believe that specific information, both in the narrative and in the graphics, is needed in the FEIR.
b. Green Line Vehicle Delivery: The MBTA is procuring new Green Line vehicles (so called “Number 9 Cars”) and they are beginning to arrive now. When vehicles arrive, they are delivered on large trucks to the Riverside Maintenance Facility. This is a major undertaking given the size and complexity of the trucking and off-loading of the new cars. The path that is currently used to deliver vehicles is in the area that will be taken over by the Proponent for the Project. The MBTA is also developing a design and standard for its next generation of Green Line cars (the so called “Number 10 Car”). To address capacity constraints, this car is likely to be significantly larger and more complex that the existing cars; delivery of these cars is likely to be more complex as well. These cars may arrive during the five-year construction window for the project and continue after the project is in operation. DocuSign Envelope ID: B2C9764A-9E12-47D6-9F83-F9800D38DA7F Kathleen A. Theoharides, Secretary EEA RE: Riverside Station Redevelopment DEIR -- EEA #16024 Page 6 of 8 May 1, 2020
The Response to Comments indicates that temporary curb cut during construction will be provided and that a dedicated curb cut will be built for the permanent condition. The FEIR should show with specificity how these access points, and how access for these large deliveries, will work. Graphics and turning information is critical and must be shown in the FEIR. The MBTA requests that the FEIR show graphics demonstrating how the deliveries will take place. Tables or figures identifying how turning radii were assumed and calculated.
Customer Access:
As stated in our comment letter on the FEIR, that while Riverside Station is nominally accessible to persons with disabilities, 20 years of deterioration as well as changes to federal and state codes means that the station itself will require updates, most notably for a second accessible means of egress. The developer will be required to ensure that all new components associated with and connected to the station, the parking structure, the bus stations, the paths of travel to the station and any other element associated with MBTA service, must meet the MBTA’s standards for accessibility, in terms of access, materials, signage, etc. The MBTA has developed progressive accessibility standards that were developed in conjunction with the Boston Center for Independent Living (BCIL) and are referred to as the BCIL standards. The comment letter on the ENF requested architectural plans in the DEIR to show how the developer will ensure that all of the plans are in compliance not only with the ADA and with the Massachusetts Architectural Access Board, as well as the BCIL Settlement Agreement and the MBTA’s Design Guide for Access. The DEIR states in the Response to Comments that the project has been designed to meet these requirements, but provides no specific information or graphics or plans demonstrating such compliance. The work the developer has been doing with the MBTA since the preparation of the DEIR does include more information, but due to the timing of the DEIR, they were unable to provide the information in the document. The Proponent should show all of this information in the FEIR in both the narrative of the documents and in graphics.
These standards for access for all of our customers and employees are critical not only in the design of the facilities, but also in the temporary/construction phases. These standards should be clearly met and identified in the Construction Management Plan discussed below.
An important component of the MBTA’s ENF Comment Letter was asking how MBTA customers who utilize the paratransit system (“The Ride”) would access and depart from the station. The MetroWest paratransit vehicles also utilize this station. The Proponent states in the Response to Comments that there will be a designated drop off spot at the Green Line Station and at the ground level of the garage. The graphics or the document itself does not show dimensions or paths of travel. This specific information is critical for the MBTA to see to determine that the access points provided are sufficient. This information should be provided in the FEIR.
Parking Supply and Management:
The developer will be building a new parking garage for the MBTA. The developer must ensure that the garage meets the MBTA Design Standards for parking garages. These design standards cover a host of issues including accessibility requirements, safety and security requirements, fare collection, lighting, and many other issues. Some of these design standards may change the size of certain elements or the layout or customer access points, so it is important that the design in the EIR comport with the standards. The Developer has been working with the MBTA on these issues but that information is not fully described in the DEIR.
As the MEPA review advances, however, the MBTA asks that more specific information on the design and layout of the garage be provided to ensure that customers exiting the garage, are planning the garage in such a way as to minimize queuing times. The DEIR Response to Comments does indicate that it is considering using LPR and DocuSign Envelope ID: B2C9764A-9E12-47D6-9F83-F9800D38DA7F Kathleen A. Theoharides, Secretary EEA RE: Riverside Station Redevelopment DEIR -- EEA #16024 Page 7 of 8 May 1, 2020
two separate ramping regimes to address queuing. These mitigation proposals (and potentially others) should be explored further for the FEIR and if feasible, should be articulated in the Section 61 Agreement.
The DEIR does describe how the garage will be designed and operated in ways that encourage non-single automobile access through the implementation of innovative methods. Much of this information is presented in the TDM in the Appendix. The MBTA requests that this information be summarized in the Response to Comments and in the narrative of the FEIR (as opposed to being part of a large Appendix), so that the MBTA and the public can clearly see what type of plans are being proposed. Additionally, within the graphics and figures, the Proponent should identify bicycle storage areas, providing space for bike and car share systems, electric vehicle charging stations, implementing technology to allow for preferred parking for high occupant vehicles, implementation of TDM methods, or any other type of improvement that reduces the need for traditional single occupant vehicles utilizing the garage.
The use of customer electric vehicle charging spots is an important issue for the MBTA. The MBTA is currently developing standards for the types of charging technology that is appropriate for these types of customers. The Proponent should work with MBTA to implement the preferred technology. At this point, the MBTA feels that a minimum of ten (10) EV parking spots, at least two of which are ADA compliant, are necessary at the facility,with the garage being constructed to facilitate easy ability to expand this size to as many as 20% of total spaces as the demand for EV charging increases. The FEIR should indicate where those spaces will be and make an explicit commitment to implement the charging technology that the MBTA concludes is the appropriate one.
The FEIR needs to describe in more detailed how the garage will be designed in order to address the stormwater management and snow removal requirements, which will ultimately be the responsibility of the MBTA or its parking management contractor to carry out. The DEIR simply states that storm water will be managed by “traditional means.” The FEIR should detail what type of stormwater management would be required to maintain the proposed design.
The DEIR does indicate that the structured garage will be designed to accommodate a photovoltaic (PV) array to power the garage or other MBTA elements. We believe the PV on the roof of the garage could be an excellent opportunity for mitigation to meet MEPA’s GHG requirements. As it has at other parking facilities (such as the Woodland Garage in Newton), the MBTA will engage a third party solar contractor to design, build, operate and maintain the solar system since this is the approach that is most financially successful for the MBTA. Given that the roof needs to be substantially complete before a 3rd party developer could come in and build the solar, the MBTA will put an RFP for solar on this roof during the construction period so that the solar can come on line as early as possible.
Construction Period Impacts:
The project will require significant new construction and construction equipment, as well as utility work adjacent to the MBTA Riverside Station, the MBTA’s Maintenance Facility and other associated facilities on the Riverside Campus as well as to the Green Line itself. To do this work, safe operations of the transit lines as well as a safe environment for patrons and workers must be maintained at all times.
The MBT requested a Construction Management Plan (CMP) designed to minimize impacts to MBTA service and its passengers. The CMP appears to cover the MBTA’s major issues at a level that is appropriate for a DEIR. The MBTA will be working with the Developer as the project advances to better flesh out these issues. The MBTA recognizes that the developer is at an early stage of planning and design and as such, a CMP at this phase will be less detailed than it would be at a later stage. The MBTA requests that this CMP be updated for the FEIR and at all other stages as the project develops.
DocuSign Envelope ID: B2C9764A-9E12-47D6-9F83-F9800D38DA7F Kathleen A. Theoharides, Secretary EEA RE: Riverside Station Redevelopment DEIR -- EEA #16024 Page 8 of 8 May 1, 2020
As described in its ENF letter, the MBTA is particularly concerned with how the project may potentially affect existing Green Line operations in the Riverside Carhouse campus. The project line directly abuts the MBTA’s storage tracks. These tracks are critical to MBTA operations. It is on these tracks that vehicles are stored and platooned prior to going into service each morning and throughout the day. Initial plans from the developer indicated that it might be necessary to take the track closest to the northern edge of the development site out of service for some extended period. (This track is referred to as “Track Zero” by the MBTA.) This storage track is one of 13 tracks used by the MBTA, and helps facilitate yard operations in the most efficient manner. The Riverside Maintenance Facility is at capacity for storage and maintenance of Green Line trains. Additionally, the MBTA is looking to increase Green Line service to address demand via the use of existing and new Green Line cars currently in production. Due to this scenario, all available track space and storage area is critical. The CMP in Chapter 10 does not address this issue. We believe that the CMP must describe how, to the greatest extent feasible, it will avoid utilizing any of this storage area. If that is not possible, the CMP should provide mitigation so the MBTA can continue to manage existing and proposed service levels during construction. This issue needs to be explicitly discussed in the FEIR.
Proposed Section 61 Finding:
The MBTA requests that the Secretary require that the FEIR contain a Proposed Section 61 Agreement for the MBTA. The DEIR has a Section 61 for MassDOT, but that document does not adequately cover the array of MBTA issues. The need for an MBTA specific Section 61 Agreement is triggered by the land agreement between the MBTA and the developer. The proposed Section 61 Finding should identify all proposed mitigation and improvements to the MBTA system to address impacts. The Section 61 Finding should also include specific dates and/or triggers as to when the mitigation will be in place.
Again, we appreciate the opportunity to comment and are available to answer any questions or provide any follow up information that you or the Proponent may require. If you have any questions regarding these issues, please feel free to contact me at 617-222-3126 or by email at [email protected].
Sincerely,
Andrew D. Brennan Sr. Director of Energy & Environment
May 1, 2020
By email: [email protected]; [email protected]
Secretary Kathleen A. Theoharides
Executive Office of Energy and Environmental Affairs 100 Cambridge Street, Suite 900 Boston, MA 02114
Attn: MEPA Office, Alexander Strysky, EEA # 16024
Re: Riverside Station Redevelopment; EEA # 16024
Dear Secretary Theoharides,
The following are formal comments on the Draft Environmental Impact Report, dated March 2020:
For many years the MBTA 500 Express Bus served Newton and surrounding communities. It ran from the Riverside Station Bus Stop, non-stop to Boston making two stops, both near South .Station. It ran many times during the morning and evening commuting hours. Ridership was robust. Over time, the MBTA led the route to its ultimate demise. This did not happen for lack of riders, but rather a collapse in customer service. On time performance suffered greatly and many scheduled trips never materialized. The ridership became frustrated, and chose alternate commutes. Eventually, the MBTA cancelled the route because of lack of ridership. During the robust years approximately 100 cars would park near the bus stop and take the bus. Today’s commuters have an even greater thirst for not owning cars and using 500 Express Bus type modes to get to Boston. Although the Proponent has stated support of accommodating such a route, there is no approved plan to reinstitute this route as part of the Transit Oriented Development (TOD). Please require the Proponent, and their public partner MASSDOT/MBTA to work together to reinstitute the 500 Express Bus. The prior riderhsip will return, as well as additional users associated with the TOD, the Green Line Transformation Capacity increase, and those that are affected by the Mass Pike Allston Interchange project. A five foot wide bike lane is proposed to transverse the east edge of Grove Street from the Route 128 Exit 22 South Bound Ramp to the Green Line Trestle. On the opposite side of the street, a safe ten foot wide two direction protected cycle track will also exist. I believe the five foot wide path is redundant, and introduces great danger to neighbors, bikers and commuters. The redundant bike lane eliminates an existing slip ramp which safely and efficiently moves cars towards the MBTA Station (since constructed over 50 years ago). The slip ramp has extremely clear sight lines. Because of the redundant bike lane, vehicles exiting the highway heading to the MBTA will be forced to queue at the proposed round-a-bout, to a point on the radial ramp that has a poor sight line, introducing a new potential for high speed rear end collisions. MASSDOT and the designer acknowledge that a lengthy back up will occur about 3 minutes each morning. Please note that the surrounding communities are thrilled to have the 10’ wide cycle track far across the round-about, protecting bike traffic from interchange congestion and speed. At a point approximately 150 feet from the Green Line Trestle, a signalized pedestrian/bike crossing has been proposed to accommodate the redundant bike lane. This pedestrian/bike crossing is exposed to another poor sight line condition, recognized by the designer, the City of Newton Transportation Department, and the traffic study peer reviewer. Its use will cause vehicles to stop and queue in another poor sight line zone, creating a second new potential location for rear end collisions. Pedestrians and bikers will also be subjected to the poor sight line conditions. Lastly, the 10 year post construction build out conditions, estimate that there will be 8 bikes in the network in both the am and pm peak hours. Please consider stipulating the removal of the redundant bike lane, and letting the slip ramp remain in service. Surely the ten foot wide cycle track can handle 8 bikes per peak hour.
Thank you for taking the time to consider my comments.
Sincerely, John H. McElduff 46 Lafayette Rd. Newton MA 02462
April 24, 2020
Kathleen A. Theoharides, Secretary Executive Office of Energy and Environmental Affairs 100 Cambridge St, Suite 900 Attn: MEPA Office, Alex Strysky Boston, MA 02114
Subject: EOEEA #16024 – Draft Environmental Impact Report Riverside Station Redevelopment, Newton, MA
Dear Secretary Theoharides,
The Massachusetts Water Resources Authority (MWRA) appreciates the opportunity to comment on the Draft Environmental Impact Report (DEIR) submitted by MD 399 Grove Owner, LLC, Ramirez Concord, LLC and BH Normandy Riverside, LLC c/o Mark Development, LLC (the “Proponent”) for Riverside Station Redevelopment (the “Project”) in Newton, Massachusetts. The approximately 14.4 acre Project site currently consists of the Massachusetts Bay Transportation Authority (MBTA) Riverside Green Line Station and a 194- key hotel. The Project includes the redevelopment of the Project site into a mixed-use, transit oriented development including approximately 1.025 million square feet of office/lab, residential, retail and hotel as well as open space. Existing MBTA uses will be retained, with certain elements, such as replacement of the surface parking areas with new structured parking and temporary training facilities, being integrated in to the Project.
MWRA previously comment on the Project ENF on May 28, 2019. MWRA’s comments continue to address MWRA Enabling Statute Section 8(m) Permitting concerns, wastewater flows and the need for Infiltration/Inflow (I/I) Removal, and Toxic Reduction and Control (TRAC) discharge permitting.
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 and the proposal outlined in the ENF to relocate portions of MWRA pipeline within the Project site, an 8(m) permit will be required. This permit would include limitations on both the duration and timeframe that the pipeline can be out of service. The Proponent is encouraged to contact Ralph Francesconi in the MWRA Water and Wastewater Permitting Group at 1 (617) 305-5827 as soon as possible for assistance related to this matter.
Wastewater
MWRA’s comments on the ENF stated that to ensure that the Project’s new wastewater flow does not increase surcharging and overflows in large storms and compromise the environmental benefits of MWRA’s CSO control plan, the Proponent should fully offset the Project’s wastewater flows with infiltration and inflow (I/I) removal in accordance with MassDEP regulations and the City of Newton policy. The ENF stated that the Proponent plans to contribute to the City of Newton I/I mitigation fund based on the City’s policy of 8:1 I/I mitigation. The DEIR states that the Project will result in an improvement to the regional wastewater system by providing wastewater I/I removal (mitigation) in accordance with MassDEP policy and the City of Newton requirement. The municipal requirement exceeds the MassDEP regulation by requiring the Proponent to remove, or cause the removal of, a minimum of 8 gallons of I/I flow for each gallon of new wastewater generated by Project. The DEIR reiterates that the Proponent intends to meet this requirement by contributing to the City’s I/I mitigation fund.
TRAC Discharge Permitting
MWRA prohibits the discharge of groundwater and stormwater into the sanitary sewer system, pursuant to 360 C.M.R. 10.023(1) except in a combined sewer area when permitted by the Authority and the local community. The Project site has access to separate sewer and storm drain systems. Therefore, as noted in the DEIR, the discharge of groundwater or stormwater to the sanitary sewer system associated with this Project is prohibited.
A Sewer Use Discharge Permit is required prior to discharging laundry effluent for any hotel associated with the Project into the MWRA sanitary sewer system. A Sewer Use Discharge Permit is also required prior to discharging laboratory wastewater, and/or photoprocessing wastewater from any laboratory and commercial space associated with the Project into the MWRA sanitary sewer system. For assistance in obtaining these permits, representatives from the proposed hotel, laboratory or 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.
On behalf of the MWRA, thank you for the opportunity to provide comments on this Project. Please do not hesitate to contact me at 1 (617) 788-4958 with any questions or concerns. Sincerely,
Bethany Card Director Environmental and Regulatory Affairs
cc: John Viola, DEP
From: Frederick P Salvucci To: Strysky, Alexander (EEA) Subject: Fwd: Riverside Station Development; EEA # 16024 Date: Friday, April 24, 2020 6:30:40 AM
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. Sent from my iPad
Begin forwarded message:
From: Frederick P Salvucci
Secretary Theoharides Executive Officer of Energy and Environmental Affairs 100 Cambridge Street, Suite 900 Boston,Ma 02114
Atten MEPA Office, Alexander Strysky, EEA #16024
APRIL 24, 2020
I am writing to urge that you find the Environmental Impact Report on the proposed development at Riverside Station inadequate, and require that a much more thorough analysis is prepared of the adverse impact on public transportation service in the Newton and Wellesley and western suburban area that would be caused by the development as it is currently proposed, and that this further analysis be made available for consideration by the public, the city of Newton, and the MBTA prior to making any decisions on leasing land to the developer, and / or allowing any development to proceed on this land other than alterations to MBTA public transportation facilities.
The EIR is inadequate in the following ways:
1) There is no consideration of the new environment caused by the pandemic which has so dramatically changed daily life and economic activity, and requires a fundamental reconsideration of the quality and convenience of public transportation service that will be required to attract riders to use the T, and avoid the return of the worst in the nation automobile congestion that has characterized the Boston metropolitan area. As the economy recovers , the current avoidance of the use of Public Transportation because of health concerns will need to be overcome by providing the most customer friendly and safe accommodations possible, or a very rapid growth of even more severe automobile congestion is likely to occur as western suburban residents seek to access the growing dense concentration of jobs in the downtown Boston, Longwood Medical Area, South Boston Seaport innovation District, and Kendall Square. This topic requires thoughtful consideration and presentation to the public and city of Newton and MBTA Fiscal Control Board in preparing to deal with this unanticipated challenge.
2)There is no consideration given in the EIR to the change in commuting patterns that will be caused when the Allston Interchange of the turnpike is reconfigured and reconstructed. According to the latest schedule presented to the MBTA Fiscal Control Board and MASSDOT board on April 13, construction is expected to begin in three years, and will require the reduction of the current 8 lane configuration of the turnpike in the Boston section to 6 temporary lanes through Allston, in order to provide room for the reconstruction of the structurally deficient viaduct in Allston. The current plan of MASSDOT also proposes to reduce the 2 track configuration of the Worcester Branch of the commuter rail to a single track operating under « slow orders » to provide a safe environment for the construction work during the ten year expected construction period. Since the expansion of the Worcester Branch from a single track to 2 track operation in Allston about six years ago, ridership on the Worcester Branch has grown by a dramatic 45%! This growth is presumably because of the improved reliability and capacity provided by the 2 track operation, the congested state of the turnpike, and the rapid growth of job destinations in downtown Boston and Cambridge. All of these dense job clusters continue to grow, with active construction underway that will add still more new job destinations during the next five to ten years., just when accessibility from Newton, Weston ,Wellesley , Natick, Framingham and Worcester will dramatically decrease, according to MASSDOT current plans. The turnpike will become significantly more congested. Spillover traffic will cause congestion to worsen on Route 9. Commonwealth Avenue, Route 16, and Washington Street will experience more congestion and air pollution. There has been significant concern raised about these outcomes, with substantial comment calling for a different Turnpike reconstruction plan that would leave intact the 2 track Worcester Branch , with investment in additional rail equipment to improve frequency and capacity, along with installation of high platforms to improve boarding times. There have been proposals for a maintenance of mobility plan for the western suburbs, with funding and priority for additional express bus service, and the addition of a route 128 regional rail station with significant parking capacity on the MASSDOT land formerly used for turnpike toll plazas, and calls for the replacement of the structurally deficient turnpike bridges over route 128. There have been proposals for additional ADA compliant platforms at the Newton stations to support two way service, and frequent mid day service, but as yet there is no official response to these proposals. This significantly problematic context needs to be described, along with any modifications to the current plan, in order to make reasonable judgements about the proposed development plan .
3)In the entire western corridor, the only current hope for improved capacity is on the Green Line, where state -of—good -repair upgrades to power and track, and delivery of some new vehicles offer the prospect of more frequent and reliable service in the immediate short term. Additionally the MBTA has started the process to procure an entirely new fleet of larger vehicles to transform the Green Line and double the ridership on the Line. But this presumes the ability of riders who do not live within walking distance of a station to park at a station. The only station where there is currently almost 1000 parking spaces available in a surface lot , with the potential for expansion ,is at Riverside, strategically located next to ramps to route 128. Yet the responses by the developer to questions about the decrease of available parking for public transportation compare the proposed availability of parking to the current parking availability, with no consideration of the substantially increased level of ridership being contemplated by the T , nor the even greater amount of parking required if the larger context including the turnpike construction is considered.This is really planning by looking in the rear view mirror.
4) With the recent upgrades to the Green Line track and power, and additional vehicles, and the prospect of the planned construction disruption of the turnpike and commuter rail service, a proactive plan for the Riverside station should involve construction of a major garage immediately adjacent to the Station platforms , providing significant ADDITIONAL parking to support both short term and long term passenger growth. In addition, there has been an ongoing study by MBTA to develop a plan to transform the entire commuter rail service into a Regional Rail service, with more frequent service all day and throughout the week to double or triple the peak period capacity of the system, and the MBTA has committed to start this transformation with several pilot projects. One pilot project should be to transform the Worcester Branch, using the proposals that have emerged in reaction to the current unacceptible turnpike reconstruction plan.
5)One short term opportunity at Riverside would be to activate the commuter rail spur from the Worcester Branch that reaches Riverside Station, which was previously activated when the Green Line Station at Kenmore was flooded, to provide temporary substitute service.Such a short term strategy could take advantage of the access to route 128, and the expanded parking supply at Riverside. In the longer range, a regional rail station at route 128 in the right of way of the Worcester Branch is the optimum location for a 128 Worcester Branch Station, but that Station and the necessary parking need to be constructed. In the short term, a route 128 presence of the Worcester Branch service could be established at Riverside. When the permanent new 128 station is constructed in the Worcester Branch right of way, the parking at Riverside will be required to support the transformed Green Line. So an expanded parking garage exclusively for the use of the T at Riverside can do double duty: in the short term it could support the current modestly improved Green Line, plus the Commuter rail spur, and in the longer range when the new 128 station is added in the Worcester Branch Right of way, the Riverside parking garage will be available to support the transformed Green Line. It is important to recognize that given the parking constraints elsewhere on the Green Line, if the total ridership,of the transformed Green Line is to double, parking availability at Riverside needs to increase by much more than double.
But to play this strategic role in the near term to relieve the accessibility crisis caused by the turnpike reconstruction, the entire current parking lot at Riverside will be needed for the immediate future to accommodate the staging necessary to build a large garage adjacent to the station platform exclusively for transit patrons.
6)It is also likely that some of the Riverside space will be needed to expand the maintenance facility to accommodate the new larger vehicles, when they are delivered, at the same time that current trainsets continue to be used to serve the line. There is no publicly available plan to accommodate the acceptance and storage of two to three times the current fleet anywhere else on land that the MBTA owns adjacent to the Green Line.
7)The planning for how to deal with the replacement of the structurally deficient turnpike bridges over route 128 has not been initiated. There seems to be urgency to replace the bridges before they fail. At the same time, the current configuration of the bridges is very convoluted, involving multiple crossings of the Charles River, with short and dangerous weaving sections. Ideally, there should be a new plan for how the replacement bridges will be configured, so that the new bridges are optimized, and the old ones can be removed when they are replaced. Alternatively, there could be cheap temporary replacements built adjacent to the current bridges, while the planning is done for the permanent configuration. But there is no public plan of how this is to be done. This begs the question of how the ramp modifications being contemplated at Grove Street to access Riverside will relate to this as yet not available plan. This section of route 128 and it’s access pattern is complex and includes dangerous weaving sections. It would be far preferable to have a clear game plan for the future of this section of route 128, and not make ad hoc adjustments at Grove Street now.
8) Finally, if there is to be some private development considered to be built on scarce MBTA owned land at Riverside, there should be alternative locations considered for the non MBTA uses. The land closest to the station platform is most desirable for a large MBTA garage, and bus and Dropoff locations . That land also seems to be the worst location for housing, nearest to the noise of the station, and in conflict with the traffic of transit riders seeking to park, and buses and Dropoff activity. The proposed location of the office tower seems to be much less conflictual with public transportation needs, although a plan is needed to ascertain that this is the case.
In conclusion, there should be a much more thoughtful plan prepared for the review of the public, the city of Newton, and the MBTA fiscal control board to make responsible decisions. MEPA should ensure that this more thoughtful process is conducted, by rejecting this EIR as inadequate, and requiring substantial new scoping to analyse these questions.
Sincerely,
Frederick P. Salvucci Secretary Theoharides Executive Office of Energy and Environmental Affairs 100 Cambridge Street, Suite 900 Boston,Ma 02114
Attn: MEPA Office, Alexander Strysky, EEA #16024
April 28, 2020
Dear Secretary Theoharides:
I am writing to urge that you find the Environmental Impact Report on the proposed development at Riverside Station inadequate, and require a much more thorough analysis of the adverse impact on public transporta- tion service in the Newton and Wellesley and western suburban area that would be caused by the Riverside development as currently proposed. This further analysis should be made available for consideration by the public, the city of Newton, and the MBTA prior to any decisions on leasing land to the developer, and / or allowing any development to proceed on this land ( other than alterations to MBTA public transportation facilities).
The EIR is inadequate in the following ways:
1) There is no consideration of the new environment caused by the pan- demic which has so dramatically changed daily life and economic activ- ity, and requires a fundamental reconsideration of the quality and con- venience of public transportation service that will be required to attract riders to use the T, and avoid the return of the worst-in-the-nation auto- mobile congestion that has characterized the Boston metropolitan area. As the economy recovers , the current avoidance of the use of Public Transportation because of health concerns will need to be over- come by providing the most customer friendly and safe accommodations possible. Initially, high frequency of service will be required, even for re- duced numbers of passengers, in order to provide safe spacing. Even- tually, as a hoped for vaccine and other medical mitigation becomes available, the number of commuters is likely to return at least to previous levels . If rail services fail to increase capacity, a very rapid growth of even more severe automobile congestion is likely to occur as western suburban residents seek to access the dense concentration of jobs in the downtown Boston, Longwood Medical Area, South Boston Seaport Innovation District, and Kendall Square.While the hoped for economic re- covery is very difficult to predict, the existing built environment, and the additional construction underway will almost certainly resume generating high levels of commuter activity, and present a serious likelihood of rene- wed congestion . This topic requires thoughtful consideration and presentation to the public and city of Newton and MBTA Fiscal Control Board in preparing to deal with this unanticipated challenge.
2) There is no consideration given in the EIR to the change in commuting patterns that will be caused when the Allston Interchange of the turnpike is reconfigured and reconstructed. According to the latest schedule presented to the MBTA Fiscal Control Board and MASSDOT board on April 13, con- struction is expected to begin in three years, and will require the reduction of the current 8 lane configuration of the Turnpike in the Boston section to 6 temporary lanes through Allston, to provide room for the reconstruction of the structurally deficient viaduct in Allston. The current plan of MASSDOT also proposes to reduce the 2 track configuration of the Worcester Branch of the commuter rail to a single track operating under slow orders to pro- vide a safe environment for the construction work during the ten year ex- pected construction period. Since the expansion of the Worcester Branch from a single track to 2 track operation in Allston about six years ago, rid- ership on the Worcester Branch has grown by a dramatic 45%! This growth is presumably because of the improved reliability and capacity provided by the 2 track operation, the congested state of the turnpike, and the rapid growth of job destinations in downtown Boston and Cambridge. All of these dense job clusters continue to grow, with active construction underway that will add still more new job destinations during the next five to ten years, just when accessibility from Newton, Weston ,Wellesley , Natick, Framingham and Worcester will dramatically decrease, according to MASSDOT current plans. The turnpike will become significantly more congested. Spillover traf- fic seeking to avoid the turnpike will cause congestion to worsen on Route 9. Commonwealth Avenue, Route 16, and Washington Street will experi- ence more traffic, congestion , and air pollution. There has been significant concern raised about these outcomes, with substantial comment calling for a different Turnpike reconstruction plan that would leave intact the 2 track Worcester Branch , with investment in additional rail equipment to support improved frequency and capacity, along with installation of high platforms at stations to improve boarding times. There have been proposals for a maintenance of mobility plan for the western suburbs, with funding and pri- ority for additional express bus service, and the addition of a Route 128 re- gional rail station with significant parking capacity on the MASSDOT land formerly used for turnpike toll plazas, and calls for the replacement of the structurally deficient turnpike bridges over Route 128. There have been proposals for level boarding ADA-compliant platforms at the Newton sta- tions to support faster two way service, and frequent mid-day service, but as yet there is no MASSDOT response to these proposals. This problem- atic context needs to be described, along with any modifications to the cur- rent plan by MASSDOT, in order to make reasonable judgements about the proposed development plan .
3) In the entire western corridor, the only current hope for improved capac- ity is on the Green Line, where state-of-good -repair upgrades to power and track, plus delivery of some new vehicles, offer the prospect of more fre- quent and reliable service in the immediate short term. The MBTA has also started the process to procure an entirely new fleet of larger vehicles to transform the Green Line and double the ridership on the Line. But these plans presume the ability of riders who do not live within walking distance of a station to park. The only station where there is currently almost 1000 parking spaces available in a surface lot , with the potential for expansion, is at Riverside, strategically located next to ramps to route 128. Yet the re- sponses by the developer to questions about the constrained available parking for public transportation in their development plan is to reduce the available parking to 450 spaces for transit users during a 28 month con- struction period followed by provision of 1000 spaces, essentially replacing the current amount of parking .
This is really planning by looking in the rear view mirror. There is no con- sideration of the more than doubling of parking required to support the in- crease in Green Line ridership being planned by the T, nor the even greater amount of parking required at Riverside if the larger context includ- ing the decade of reduced turnpike and Commuter rail capacity caused by the proposed turnpike reconstruction is considered.
With the recent upgrades to the Green Line track and power, and additional vehicles, and the prospect of the planned construction disruption of the turnpike and commuter rail service, a proactive plan for the Riverside sta- tion should involve construction of a major garage immediately adjacent to the Station platforms , providing significant ADDITIONAL parking to support both short term and long term passenger growth.
4) In addition, there has been an ongoing study by MBTA to develop a plan to transform the entire commuter rail service into a Regional Rail service, with more frequent service all day and throughout the week to double or tri- ple the peak period capacity of the system, and the MBTA has committed to start this transformation with several pilot projects. One pilot project should be to transform the Worcester Branch, using the proposals that have emerged in reaction to the current unacceptable turnpike reconstruc- tion plan.
A short term opportunity at Riverside to “ jump start” the transformation to Regional Rail might be to activate the commuter rail spur from the Worces- ter Branch that reaches Riverside Station (which was previously activated a few years ago when the Green Line Station at Kenmore was flooded) to provide temporary substitute service. Such a short term strategy could take advantage of the existing access to route 128, with an expanded parking supply at Riverside.
In the longer range, the addition of a new regional rail station at route 128 in the right of way of the Worcester Branch is the optimum location for a 128 Worcester Branch Station, but that Station and the necessary parking may take time to be engineered and constructed. In the short term, a route 128 presence of the Worcester Branch service could be established at Riv- erside, using the existing spur track if engineering analysis shows that it could be operational significantly sooner than the preferable permanent so- lution.
5) When the permanent new 128 station is constructed in the Worcester Branch right of way, the parking at Riverside will be required to support the ridership growth of the transformed Green Line. So an expanded parking garage exclusively for the use of the T at Riverside can do double duty: in the short term it could support the current modestly improved Green Line, plus the possible interim Commuter rail spur, and in the longer range when the new 128 station is added in the Worcester Branch Right of way, the Riverside parking garage will be available to support the expanded capacity of the transformed Green Line. It is important to recognize that given the parking constraints elsewhere on the Green Line, if the total ridership of the transformed Green Line is to double, as proposed by MBTA, parking availability at Riverside needs to increase by much more than double the currently available 1000 spaces.
But to play this strategic role in the near term to relieve the accessibility cri- sis caused by the turnpike reconstruction, and support the doubling of rid- ership of the Green Line proposed by MBTA, the entire current parking lot at Riverside will be needed for the immediate future to accommodate the staging necessary to build a large garage adjacent to the station platform exclusively for transit patrons.
6) It is also likely that some of the Riverside space will be needed to ex- pand the existing maintenance facility to accommodate the new larger ve- hicles, when they are delivered, at the same time that current train sets continue to be used to serve the line. There is no publicly available plan to accommodate the acceptance and storage of two to three times the current Green Line fleet anywhere else on land that the MBTA owns adjacent to the Green Line. A revised EIR must answer the question of accommodation of increased storage capacity in the Maintenance yard.
7) The planning for how to deal with the replacement of the structurally defi- cient turnpike bridges over Route 128 has not been initiated. It is urgent to replace the bridges before they fail. At the same time, the cur- rent configuration of the bridges is very convoluted, involving multiple crossings of the Charles River, with short and dangerous weaving sections. Ideally, there should be a new plan for how the replacement bridges will be configured, so that the new bridges are optimized, and the old ones can be removed when they are replaced. Alternatively, there could be cheap tem- porary replacements built adjacent to the current bridges, while the plan- ning is done for the permanent configuration. But there is no public plan yet. This begs the question of how the ramp modifications at route 128 be- ing contemplated at Grove Street to access Riverside will relate to this as yet unavailable plan. It would be far preferable to have a clear game plan for the future of this section of route 128, and avoid ad hoc adjustments at Grove Street now.
8) Finally, if there is to be some private development considered to be built on scarce MBTA owned land at Riverside, there should be alternative loca- tions considered for the non - MBTA office and housing uses. The land closest to the Green Line station platform is most desirable for a large MBTA garage, and bus and drop-off locations. That land also seems to be the worst location for housing, nearest to the noise of the station, and in conflict with the traffic of transit riders seeking to park, and buses and drop-off activity. The proposed location of the office tower seems to be much less conflictual with public transportation needs, although a plan is needed to ascertain that this is the case. A different configuration for hous- ing that would not be compromised by the adequate parking and bus ac- cess to the transit station should be developed.
In conclusion, there should be a much more thoughtful plan prepared for the review of the public, the city of Newton, and the MBTA fiscal control board to make responsible decisions. MEPA should ensure that this more thoughtful process is conducted by rejecting this EIR as inadequate, and requiring substantial new scoping to analyze these questions.
Sincerely,
Frederick P. Salvucci May 1, 2020
Executive Office of Energy and Environmental Affairs 100 Cambridge Street - Suite 900 Boston, MA 02114 Attn: MEPA Office - Alex Strysky
Re: Comments to the Draft Environmental Impact Report - EEA No. 16024
Dear Mr. Strysky:
Thank you for the opportunity to submit comments on the Draft Environmental Impact Statement submitted on behalf of Mark Development and the Riverside Station Redevelopment Proposal. I am a former Newton City Councilor and residential abutter. I ask that you forward these comments on to the petitioner and that these be addressed prior to the issuance of any final certification or permit.
Lease details
The Proponent has not adequately responded to the request regarding the new lease agreement with the MBTA particularly the terms of the amended and restated lease. As I mentioned in my previous request, such information is critical for the City and for the residents to understand the relationship and any commitments, limitations, conditions that could adversely impact 1) the project; 2) any future use of the site and any land surrounding the site - particularly as it relates to transportation in its current and potential future forms; and 3) the surrounding community, neighborhoods - Lower Falls and Auburndale and the environment - particularly the Charles River watershed.
The Proponent’s response that the negotiations are still ongoing appears suspect and not a prudent or fiscally responsible way that a state agency would manage their assets. I again, reiterate the importance of having transparency of the negotiations and any commitments, limitations and/or conditions with regard to the lease.
Internal Roadways
The Proponent has not adequately responded to the request regarding information on control of the internal roadways and snow removal and snow storage. If the roadways and sidewalks are to be maintained by the Proponent and they remain private, who will be responsible to enforce parking and traffic/safety violations?. Currently, at least regarding parking, the City does not enforce on private ways. Please provide details. Further, where will snow storage be located? Given the fact that the site is limited, will the MBTA allow snow storage in sensitive watershed areas or has an agreement been reached to store snow off-site and where is that location.
Interference with MBTA operations
The Proponent has not adequately responded to the request regarding impact of the proposed new development on continued operations of the MBTA. The response suggests that the Proponent has worked the MBTA to ensure the operations of the existing facilities are maintained during and post-construction but has failed to provide details on how that would work without burdening the surrounding neighborhood and traffic and access to the site.
In addition, there is the Allston- I-90 project which is anticipated to create lane closures on the Mass Pike and also interfere with operations of the Commuter Rail. Commuters may seek use of the MBTA - particularly, the Riverside Station - as a place to access public transport into Boston. Please request the Proponent and the MBTA to provide details on how they plan to address this.
Available, Affordable and Accessible Parking
The Proponent has failed to provide information on how they will ensure that public access to parking will continue throughout the life of this development and will remain available, affordable, and accessible - particularly if the state upholds its commitment to increase use of its public transit system. Given that this station is already a major public transportation hub and has the great potential of becoming a regional hub, a commitment by the Proponent to transit users is essential. Noting the importance of this without providing a commitment or details on how this will be achieved is inadequate.
Management and Control of the Parking Garage
The Proponent’s response suggests that a third party operator will maintain and operate the MBTA spaces at the garage. However, the garage will be used not just by MBTA users but also visitors to the site. Who will manage those spaces? Who will choose the third party operator and who will contract with the third party operator. Who will have responsibility and liability of any incidents that may occur within the garage?
Coordination with the Riverside Center Office Building
The Proponent has responded that the roadway connection as required by the Board Order granting a Special Permit for the redevelopment of the former Jordan Marsh Warehouse, has not been proposed by the MBTA. PLEASE require the MBTA - as a co-petitioner for this development, to investigate, review and address this connection. This connection would alleviate traffic on Grove Street and create a safer environment for pedestrians and cyclists.
Preferred Alternatives
The Proponent continues to state the previously proposed project was not financially feasible as approved but offers no evidence as to why. The current proposal requires the construction of a new ramp system - which the City was told at the time - was neither safe nor financially possible. The Proponent has failed to provide adequate evidence as to what made the original project not financially feasible.
Cost breakout for structure parking and roadway improvements
The Proponent has failed to provide a cost breakout/breakdown for the structured parking and roadway improvements. The Proponent’s response that “Separating these specific portions of the project cost has not be completed at this time,” is suspect. How can this project be considered financially feasible if the Proponent has not completed its project cost estimates? The City had been convinced by the previous Proponents that the project was financially feasible. The City and residents need to have a clear understanding and confidence that this project will work. Information regarding specific project costs and the Proponent’s ability to meet those costs are vital to establishing that confidence and financial feasibility of this project.
Ramp Improvements
The Proponent suggests that the ramp improvements are a result of a “fresh look” and “create a more sustainable ramp configuration for future conditions” - almost recognizing the importance of this site as a regional transportation hub. However, the Proponent (which includes the MBTA) has not provided any information on how they will transform the T system and the site to becoming a regional transportation hub that will enable more people to utilize public transportation. Without commitments from the MBTA on creating greater access to both points east (Boston and Cambridge) and points west (Natick and Framingham), the current site design and traffic layout create a car-centric development.
Coordination with other major State Projects
As mentioned above, it is so vitally important that the Proponent coordinates with other State agencies - particularly those working on the Allston -I-90 project as that will have a tremendous and potentially negative impact on the surrounding communities as it relates to traffic and public transportation. Disruption of the highway system with lane closures, and commuter rail operations will create major traffic congestion as well as commuters, desperately seeking alternative modes to commute. Simultaneous disruption to the Riverside Station due to this development project would create havoc. PLEASE require the Proponent to submit evidence of coordination with state agencies and officials with regard to the Allston - I-90 project and any other major development projects in this particular region.
Thank you for the opportunity to provide comments on this Draft Environmental Impact Report. If you have any questions, please contact me by email at a [email protected] or by phone at 617-969-0677.
Sincerely,
Amy Mah Sangiolo Former Ward 4 Newton City Councilor-at-Large and Abutter 389 Central Street Auburndale, MA 02466