The Commonwealth of Massachusetts Executive Office of Energy and Environmental Affairs 100 Cambridge Street, Suite 900 Boston, MA 02114 Charles D

Home , Soldiers Field Road

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

July 23, 2021

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

PROJECT NAME : Fenway Project PROJECT MUNICIPALITY : Boston PROJECT WATERSHED : Charles River EEA NUMBER : 16397 PROJECT PROPONENT : WS-Fenway-Twins Realty Venture LLC DATE NOTICED IN MONITOR : June 23, 2021

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

Project Description

As described in the Environmental Notification Form (ENF), the project consists of the redevelopment of 5.32 acres of land outside of Fenway Park, in the City of Boston (City). The redevelopment will include approximately 1.665 million square feet (sf) of office/research space, 213,500 of residential space (216 units), approximately 212,330 sf of retails pace, and associated stormwater management systems, utilities, landscaping, and other site development features. Approximately 3.43 acres of public roadways, sidewalks, and public spaces will be reconstructed or otherwise improved. The project proposes to reconstruct Jersey Street, between Van Ness Street and Brookline Avenue, to transform the vehicular right-of-way (as it exists currently) into a permanent pedestrian-only open space area. Privately-held land will be used to extend Richard B. Ross Way from Van Ness Street to Brookline Avenue, cutting through the middle of the project site. The project will construct 1,838 parking spaces located in four below-ground parking garages.

EEA# 16397 ENF Certificate July 23, 2021

The project is broken up into four development parcels: the Brookline Block, 1.0 acre located at 73-89 Brookline Ave; the Van Ness Block, 0.80 acres located at 70 Van Ness Street; the Lansdowne Block, two parcels (1.0 acre) located at 45-47 and 49-67 Lansdowne Street, and the Jersey Block, 9 parcels (2.52 acres) bounded by Jersey Street to the east, Van Ness Street to the south, other private property to the west, and Arthur’s Way to the north. The Jersey Block is proposed to be redeveloped into residential, commercial, retail/restaurant, and other uses in the form of up to 5 buildings totaling approximately 865,000 gross square feet (gsf). The Brookline Block, Van Ness Block, and Lansdowne Block parcels are proposed to be redeveloped into commercial and retail/restaurant uses totaling approximately 697,000 gsf in the Brookline Block, 327,300 gsf in the Van Ness Block, and 202,300 gsf in the Lansdowne Block. As described in the ENF, the project will be constructed in phases, however a specific phasing plan has not yet been established.

Project Site

The 8.75-acre project site consists of the four development parcels (described above), totaling 5.32 acres, and the surrounding roadways, public areas, and bicycle and pedestrian facilities that will be reconstructed or otherwise improved as part of the project (referred to in the ENF as “Offsite Public Realm Improvements”), totaling 3.43 acres. Fenway Park abuts the Lansdowne Block to the south and the Jersey Block to the east. As described in the ENF, the area immediately surrounding the project site is characterized by a mix of historically ballpark-oriented and entertainment-oriented uses such as food and beverage establishments, entertainment venues, parking facilities, and other more recent mixed-use development, including residential, office, retail, and health-care uses. The ENF states many of the venues in the immediate vicinity of the Project Site are destinations primarily focused on serving event- days at Fenway Park. The site is almost entirely impervious (8.5 acres of impervious surface on-site out of 8.75 total acres).

The project site does not contain Estimated and Priority Habitat of Rare Species as delineated by the Natural Heritage and Endangered Species Program (NHESP) in the 14th Edition of the Massachusetts Natural Heritage Atlas or an Area of Critical Environmental Concern (ACEC). The site contains several structures listed in the Massachusetts Historical Commission’s (MHC) Inventory of Historic and Archaeological Assets of the Commonwealth, including 78-88 Brookline Avenue (BOS.7502) and 45-47 Lansdowne Street; thelatter is proposed to be demolished as part of the project. Structural additions are proposed to 78-88 Brookline Avenue, further discussed below. The project site is within a half mile of two water bodies classified as impaired, the Charles River and Muddy River. The project site contains several areas previously regulated under the Massachusetts Contingency Plan (MCP; 310 CMR 40.0000) and assigned Release Tracking Numbers (RTN). Within a portion of the Brookline Block, a historic release from a former Underground Storage Tank (UST) was assigned RTN 3-4305; the UST was removed, and soil remediated, to achieve regulatory closure. Within the Lansdowne Block, two historic releases from UST were assigned RTN 3-31595 and 3-28084. The USTs were removed, and impacted soil remediated to achieve regulatory closure, which included an Activity and Use Limitation (AUL) on a portion of the 49-67 Lansdowne Street property. The ENF states the proposed uses will comply with this AUL.

Environmental Impacts and Mitigation

Potential environmental impacts of include generation of 8,644 new average daily trips (adt)

EEA# 16397 ENF Certificate July 23, 2021

(total of 8,957 adt when including existing uses on site); construction of 1,063 new parking spaces (total of 1,838 spaces); new water use of 309,893 gallons per day (gpd) (total of 319,953 gpd); new wastewater generation of 281,721 gpd (total of 290,866 gpd); and construction of 0.11 acres of new impervious surface (8.61 acres total on site).

Measures to avoid, minimize, and mitigate environmental impacts include reuse of an existing developed site; construction of bicycle hubs and wider sidewalks to support alternative modes of transportation other than vehicular travel; incorporating energy efficient and sustainable design principles into newly constructed buildings; construction of a stormwater management system that will reduce peak storm runoff into the Charles River Basin; and implementation of construction period best management practices (BMPs).

Jurisdiction and Permitting

This project is undergoing MEPA review and requires an ENF pursuant to 301 CMR 11.03(5)(b)(4)(a), 11.03(6)(b)(13), and 11.03(6)(b)(15) because it requires Agency Action and will involve: New discharge or Expansion in discharge to a sewer system of 100,000 or more gpd of sewage, industrial wastewater or untreated stormwater; generation of 2,000 or more New adt on roadways providing access to a single location; and construction of 300 or more New parking spaces at a single location, respectively. If a lab tenant is identified, the project will require a Sewer Use Discharge Permit from the Massachusetts Water Resources Authority (MWRA) in order to discharge laboratory wastewater, research and development (R&D) wastewater, and/or industrial process wastewater into the MWRA sanitary sewer system.

I note that the project also exceeds Mandatory EIR review thresholds for transportation at 301 CMR 11.03(6)(a)(6) and 11.03(6)(a)(7) because it will generate 3,000 or more New adt on roadways providing access to a single location, and construct 1,000 or more New parking spaces at a single location, respectively. Under 301 CMR 11.01(2)(a)(3), MEPA jurisdiction is limited when a project is undertaken by a Person and requires one or more Permits or involves a Land Transfer but does not involve Financial Assistance. Limited, or subject matter, jurisdiction means that the Scope, if an EIR is required, shall be limited to those aspects of the Project within the subject matter of any required Permit that are likely, directly or indirectly, to cause Damage to the Environment. Based on review of the ENF - and as asserted by the Proponent - the traffic impacts from this project are not related to the subject matter of the required Permit for this project, namely, a Sewer Use Discharge Permit from MWRA. Accordingly, I cannot issue a Scope for the project based on the mandatory EIR threshold related to transportation.1

As discussed below, comments from the Massachusetts Department of Conservation and Recreation (DCR) have identified concerns regarding potential impacts to DCR roadways from the project, and request additional traffic counts and other analysis to address such concerns. While the ENF and appended traffic study do not presently identify impacts sufficient to warrant mitigation on DCR roadways, it appears possible that additional analysis could change this conclusion. During the course of

1 I note, however, that this project is located in close proximity to Environmental Justice (EJ) communities in the Fenway- Kenmore area. Under new requirements imposed by Sections 56-58 of Chapter 8 of the Acts of 2021: An Act Creating a Next-Generation Roadmap for Massachusetts Climate Policy, similar future projects will be required to undergo an EIR review process once regulations are in place to implement such requirements. 3

EEA# 16397 ENF Certificate July 23, 2021

this review, the Proponent committed to conducting the additional traffic counts and analysis requested by DCR through further consultation after the conclusion of this review.2 Should this additional analysis result in material changes to anticipated impacts or required mitigation for the project, the Proponent should consult with the MEPA Office to determine if a Notice of Project Change (NPC) may be required.3

The project requires a National Pollutant Discharge Elimination System (NPDES) Construction General Permit (CGP) from EPA; and review from the Federal Aviation Administration (FAA). It requires numerous permits and approvals from the City of Boston (City) including Article 80B Large Project Review by the Boston Planning Development Agency (BPDA) and a Transportation Access Plan Agreement (TAPA) and Construction Management Plan (CMP) approval from the Boston Transportation Department (BTD).

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

Review of the ENF

The ENF provided a description of existing and proposed conditions, preliminary project plans, a summary of agency coordination and community outreach, and an analysis of alternatives. It identified measures to avoid, minimize and mitigate project impacts. Comments from the Charles River Watershed Association (CRWA) note concern regarding stormwater impacts and the project’s resilience to climate change. Comments from State Agencies also identify concerns regarding traffic impacts, construction impacts, and impacts to historic resources. State Agencies do not request additional analysis in the form of an EIR but identify additional information that should be provided regarding historic resources and traffic impacts during the permitting process. This information is detailed below.

Alternatives Analysis

The ENF includes analysis of the following alternatives: No Build; As-of-Right Build, and the Preferred Alternative. It includes a tabular comparison of impacts for the two build alternatives and describes the consistency of alternatives with the eight identified project goals. The No Build alternative would leave the site in its current condition. This alternative was dismissed because it would not provide public open space, multimodal infrastructure, or create new housing, including affordable housing. The ENF states that project aims to further the goals of Imagine Boston 2030, which set new goals for housing production and affordable housing, and detailed plans for strategic growth that preserves and enhances existing neighborhoods. These goals would not be met under the No-Build Alternative. According to the ENF, the project site currently contains zero (0) housing units.

2 Proponent’s commitment to conduct additional traffic analysis and potential mitigation, as necessary, described in an email from Lauren DeVoe (VHB) to Eva Murray (MEPA Office) sent on July 22, 2021. 3 The Proponent has asserted that, in the event a DCR Access Permit is later required to implement mitigation (such as signalization) on DCR roadways, this would not constitute a Permit required for the project, and, therefore, would not require the Secretary to issue a Scope for a mandatory EIR based on traffic thresholds. I do not deem it necessary to decide this issue at this juncture, as the analysis provided to date has not shown the need for mitigation. As noted, the Proponent should consult with the MEPA Office in the event there are material changes to impacts or required mitigation for the project. 4

EEA# 16397 ENF Certificate July 23, 2021

The As-of-Right Build Alternative would consist of an approximately 1.5 million-sf commercial redevelopment program (office/lab buildings with one level of ground floor retail), reflective of what is currently allowed under existing zoning regulations (Article 66 of the Boston Zoning Code). Compared to the Preferred Alternative, this alternative would include less unadjusted adt (7,646 new adt), parking spaces (760 new spaces), water use (217,844 additional gpd), and wastewater generation (198,040 gpd of an additional generation); it would also not result in any increase in impervious area on-site (as compared to the 0.11 acres for the Preferred Alternative). According to the ENF, the As-of-Right Build Alternative would not meet project goals (including creating a mixed-use neighborhood and creating new housing) and specifically would involve fewer public transit access improvements and bicycle accommodations due to the greater building footprint required to support the commercial developments; would involve fewer opportunities to incorporate sustainable site practices and GHG reduction measures; would not provide community-oriented uses/spaces; and would not create new housing, including affordable housing, within the project site. As noted above, the project site currently does not contain any housing units. For these reasons, the As-of-Right Build Alternative was dismissed.

According to the ENF, the Preferred Alternative, as described herein, would meet all eight of the project goals which include creating a year-round mixed-use neighborhood, improving the public realm, integrating new uses into existing urban fabric, incorporating anchor uses, defining the character of the area, create a model for sustainability, improve access, and create new housing (including 30 new affordable housing units, with zero housing displacement. According to the ENF, while the impacts of the Preferred Alternative are moderately higher than those of the As-of-Right Alternative, the two projects are comparable in terms of impacts, and the Preferred Alternative better meets project purposes and the critical need for affordable housing.

Water and Wastewater

According to the ENF, the project may require a Sewer Use Discharge Permit from MWRA pursuant to 360 CMR 10.007 prior to discharging laboratory wastewater, R&D wastewater, and/or industrial process wastewater from laboratory or commercial space associated with the project into the MWRA sanitary sewer system. The ENF states the project may also require a Temporary Construction Dewatering Permit from MWRA. The discharge of groundwater and stormwater into the sanitary sewer system is prohibited pursuant to 360 C.M.R. 10.023(1), except in a combined sewer area when permitted by the MWRA and the local community. Comments from MWRA state that the project site is not located in a combined sewer area and therefore, pursuant to 360 C.M.R. 10.023(1), the proposed discharge of groundwater or stormwater to the sanitary sewer system associated with project construction is prohibited, and a Temporary Construction Dewatering permit from MWRA cannot be issued.

The project will result in a total of 309,894 gpd of water demand (an increase of 281,721 gpd over existing demand). As described in the ENF, existing water service for domestic use and fire protection for the Project Site is supplied from water systems owned and operated by the Boston Water and Sewer Commission (BWSC). Water is delivered to the properties through an interconnected network of water distribution systems, designated by BWSC as the Southern Low Service (SLS) Systems. The project is expected to connect to existing water mains in Jersey Street, Brookline Avenue, Van Ness Street, and Lansdowne Street. As described in the ENF, the project will target at least a 50

EEA# 16397 ENF Certificate July 23, 2021

percent reduction in outdoor water use for landscape requirements through the selection of drought- tolerant, native, and adapted plantings, and water-efficient irrigation systems. The Project will target an approximately 25 to 35 percent reduction in indoor water use, depending on building typology, by using WaterSense-labelled, low and ultra-low flow water fixtures. The buildings will incorporate Energy Star- certified or equivalent appliances and will install whole building water meters. Cooling towers for the office/research typology will additionally be designed in a water-efficient manner.

The project will generate 290,866 gpd of wastewater (increase of 281,721 gpd over existing flows), which takes into account the potential for a lab/research space, as noted above. As described in the ENF, the project is expected to make new sewer connections to adjacent BWSC sanitary sewers in Jersey Street, Brookline Avenue, and Lansdowne Street. MWRA comments indicate that some wastewater flows are ultimately conveyed to MWRA’s Deer Island Wastewater Treatment Plant. In large storms when combined stormwater and sanitary flow exceeds the capacities of MWRA or BWSC systems or of municipal sewer connections, these flows can contribute to combined sewer overflow (CSO) discharges to the Charles River Basin.

The project is subject to MassDEP regulation and BWSC policies that require mitigation for Infiltration/Inflow (I/I) at a ratio of 4:1 relative to net new wastewater generation. MWRA comments indicate that increasing wastewater flow to the BWSC combined sewer system and the MWRA system without the required 4:1 offset may compromise the water quality benefits of MWRA’s recently completed $912 million CSO control plan. The ENF states the Proponent will work with BWSC to develop a plan to reduce I/I into the sanitary sewer system, and will offset sewer flows associated with the Project by removing I/I on a 4:1 basis of four gallons removed for every gallon generated per MassDEP guidelines. I refer the Proponent to MWRA comments regarding wastewater, requirements for removal of Infiltration/Inflow (I/I), and permitting associated with discharges.

Stormwater

The project will create an additional 0.11 acres of impervious surface, for a total of 8.61 acres on-site. As state above, the project site is almost entirely paved in its existing condition. The Project proposes new stormwater management infrastructure that will collect, treat, recharge, and filter stormwater runoff prior to discharging to the Boston Water and Sewer Commission (BWSC) storm system and ultimately, the Charles River Basin. The project will comply with the 2008 MassDEP Stormwater Management Policy and Standards for redevelopments to the maximum extent practicable and incorporate on-site stormwater management and treatment systems which will collectively improve water quality, reduce runoff volume, and attenuate peak rates of runoff in comparison to existing conditions. I note that MassDEP is currently in the process of updating the Massachusetts Stormwater Handbook and the Massachusetts Wetlands Protection Act (WPA) stormwater regulations (310 CMR 10.05(6)), including, at a minimum, adopting the U.S. National Oceanic and Atmospheric Administration (NOAA) Atlas 14 precipitation projections for stormwater management. I encourage the Proponent to proactively incorporate the best available precipitation data to design stormwater systems as the project proceeds to permitting.4 According to the ENF, the Proponent will work with the BWSC to evaluate green infrastructure elements, including subsurface infiltration systems and sidewalk infiltration through permeable pavement strips, plantings beds, and/or tree pits for incorporation into the

4 More information on the Massachusetts Stormwater Management updates can be found at: https://www.mass.gov/info- details/massachusetts-stormwater-management-updates-advisory-committee 6

EEA# 16397 ENF Certificate July 23, 2021

stormwater management system. As noted above, the Charles River is classified as an impaired water body and has associated Total Maximum Daily Loads (TMDLs) for phosphorous. Comments from the CWRA note concern with impacts from stormwater generated by the project on the Charles River, and state that the phosphorous TMDL for the Charles River requires that all redevelopment projects decrease the amount of phosphorous leaving the property. According to the Proponent, the project is expected to reduce phosphorus leaving the site through proposed stormwater control measures. Potential stormwater control measures will be reviewed with BWSC.5

Climate, Adaptation, and Resiliency

Governor Baker’s Executive Order 569: Establishing an Integrated Climate Change Strategy for the Commonwealth (EO 569; the Order) was issued on September 16, 2016. The Order recognizes the serious threat presented by climate change and direct Executive Branch agencies to develop and implement an integrated strategy that leverages state resources to combat climate change and prepare for its impacts. The Order seeks to ensure that Massachusetts will meet GHG emissions reduction limits established under the Global Warming Solution Act of 2008 (GWSA) and will work to prepare state government and cities and towns for the impacts of climate change. I note that the MEPA statute directs all State Agencies to consider reasonably foreseeable climate change impacts, including additional greenhouse gas emissions, and effects, such as predicted sea level rise, when issuing permits, licenses and other administrative approvals and decisions. M.G.L. c. 30, § 61.

The Climate Ready Boston report (December 2016) identifies the City’s vulnerabilities to climate change and potential measures to increase its resilience. As noted in Climate Ready Boston, the City is on track to experience both increasing average temperatures and increasing frequency, duration, and intensity of heat waves. Comments from CWRA note the project area currently experience “high” to “very high” heat in terms of daytime land surface temperature. The ENF states the project will address climate change resiliency related to more extreme weather by integrating greenery, trees, green infrastructure, shading structures, and materials with high solar reflectance/albedo into the proposed site design, to the extent feasible, to reduce urban heat island impacts.

Greenhouse Gas (GHG) Emissions and Sustainable Design

While the project is not undergoing EIR review and therefore is not subject to application of MEPA’s GHG Policy and Protocol, it involves the development of new residential and commercial uses that will add to GHG emissions from the building sector. The project is subject to the Massachusetts Stretch Code which requires a 10 percent energy performance improvement over ASHRAE 90.1-2013- Appendix G plus Massachusetts amendments. I refer the Proponent to the detailed comment letter from the Massachusetts Department of Energy Resources (DOER) which provides guidance on key mitigation strategies, energy efficiency pathways, and available incentives to reduce GHG emissions and improve resiliency. In particular, comments recommend key strategies for lab spaces. Effective strategies include:

• Passivehouse building standards (Residential Building) • Building design and construction practices that result in low heating and cooling thermal

5 Details regarding phosphorous removal provided in email from Lisa Chow (VHB) to Eva Murray (MEPA Office) on July 23, 2021. 7

EEA# 16397 ENF Certificate July 23, 2021

energy demand intensity • Efficient electrification of space and water heating • Rooftop solar PV and readiness • Electric Vehicle (EV)-ready parking

Significant incentives may be available including MassSave® incentives, Alternative Energy Credits (AECs), and Solar Massachusetts Renewable Target (SMART) incentives. Given the high energy use associated with lab uses in particular, I urge the Proponent to consider strong commitments to mitigation measures, such as electrification strategies, to maximize energy efficiency and reduce GHG emissions. This is consistent with recommendations made through the Massachusetts 2050 Decarbonization Roadmap6 as well as the 2050 Net Zero emissions goal now mandated by Chapter 8 of the Acts of 2021: An Act Creating a Next-Generation Roadmap for Massachusetts Climate Policy.

The ENF indicates that the project will target certifiability at the Gold level under the Leadership in Energy and Environmental Design (LEED) v4 for all office and laboratory building types, and a minimum Silver LEED certification for the residential and retail building types for new construction and major renovation. Each building will undergo its own full Article 37 review prior to construction. In addition to complying with Article 37, the Proponent will address other City sustainability initiatives, including Imagine Boston 2030’s initiative to improve the public realm, increase resilience, and provide greater job and public transit accessibility. The Proponent will explore available strategies for the project and buildings that align with these goals and leverage Article 37 compliance standards. The ENF states the project (based on conceptual design) is expected to achieve a 39 percent reduction in natural gas energy and associated emissions. The project proposes the electrification of heating for residential and retail buildings. Additionally, 25 percent of parking spaces in new developments will be “EVSE (electric vehicle supply equipment) installed”, and the remaining parking spaces will be EV-ready to the maximum extent possible. As noted above, I strongly urge the Proponent to consider additional electrification strategies, including hybrid-electrification strategies in lab spaces, to reduce GHG emissions consistent with the Massachusetts 2050 Decarbonization Roadmap and 2050 net zero emissions goal.

Traffic

The Project involves the proposed reconstruction and improvement of multiple segments of publicly-owned roadways and sidewalks, as well as the extension of Richard B. Ross Way, from Van Ness Street to Brookline Avenue. The ENF states this extension will complete an improvement planned by the City for the Fenway neighborhood by creating a direct vehicular connection from Boylston Street to Brookline Avenue to Beacon Street, helping to alleviate traffic patterns at Kenmore Square and the Sears Rotary by opening up a new circumferential local route allowing a mid-block connections for all modes. Additionally (as described above), the section of Jersey Street between Van Ness Street and Brookline Avenue, currently a vehicular right-of-way, will be reconstructed as a permanent, pedestrian- focused public space. A total of approximately 1,838 total parking spaces will be provided in four new garages underneath each of the development blocks with 745 spaces within the Jersey Block, 669 spaces in the Brookline Block, 129 spaces in the Lansdowne Block, and 295 spaces in the Van Ness Block.

6 https://www.mass.gov/info-details/ma-decarbonization-roadmap 8

EEA# 16397 ENF Certificate July 23, 2021

Several MBTA transit services are available within a ten-minute walk from the project site or within it, including the subway system, commuter rail line, and various bus routes.

The ENF presents a summary of the project’s transportation impacts including pedestrian and bicycle operations, public transportation services, vehicle traffic on study area roadway and intersections, vehicular level of service (LOS), parking conditions, and loading and service activities. The ENF states the study was conducted in conformance with MassDOT guidelines and uses standard methodologies, including the Institute of Transportation Engineers’ (ITE) Trip Generation Manual, 10th Edition, and local travel characteristics as defined in Access Boston 2000-2010 and the Go Boston 2030 Action Plan. Existing traffic conditions are based on data collected prior to the ongoing COVID-19 pandemic, adjusted to reflect 2021 conditions, per Boston Transportation Department (BTD) directives and MassDOT’s Guidance on Traffic Count data, published in April 2020.

Based on ITE’s Trip Generation Manual (10th Edition) Land Use Codes (LUCs) 222 (Multifamily Housing High-Rise), 710 (General Office Building), 760 (Research and Development Center), and 820 (Shopping Center), the project is estimated to generate 8,700 adt. According to the ENF, during the weekday morning peak hour, the project will generate approximately 180 new vehicle trips (135 entering and 45 exiting), 690 new transit trips (555 entering and 135 exiting), and 185 new walk/bicycle trips (130 entering and 55 exiting). During the weekday evening peak hour, the project will generate approximately 320 new vehicle trips (70 entering and 250 exiting), 1,310 new transit trips (395 entering and 915 exiting), and 450 new walk/bicycle trips (180 entering and 270 exiting). When adjusted based on mode share, net new vehicular trips are projected to be 400 adt. During the morning peak hour, the intersection of Commonwealth Avenue at Beacon Street/Brookline Avenue (Kenmore Square) operates at LOS D in the 2028 No-Build Condition, and, with the addition of Project trips, will operate at LOS E in the 2028 Build Condition. The ENF notes that this intersection is expected to be reconfigured in the future as part of a separate project (Kenmore Hotel project), and that signal optimization at this intersection is proposed to mitigate impacts. The Proponent will continue to consult with the City to monitor project impacts at this location. While existing public parking spaces historically used for remote commuter parking will be repurposed for pedestrian-focused spaces and buildings, the project will construct new underground parking garages to maintain the level of public parking required in the Fenway area, as identified by the City and BTD.

DCR has care, custody, and control over several parkways that provide indirect vehicular access to the site. Comments from DCR state the project will result in traffic impacts on the DCR roadway system that may require additional mitigation strategies, noting that traffic volumes are currently approaching 2019 levels and are expected to continue to increase in the coming months. DCR requests that BTD standard 11-hour Turning Movement Counts (“TMC”) and 7-day volume-only Automatic Traffic Recorder (“ATR”) counts be conducted at several nearby DCR roadways and intersections, some of which were not included in the traffic study conducted by the Proponent. DCR indicates that these counts could affect the baseline conditions on which project impacts were modeled in the traffic study. As stated above, the Proponent has agreed to conduct additional traffic counts at certain DCR intersections and roadways (as may be modified through coordination with DCR to best meet their needs) in the coming months. A copy of these counts and analysis will be submitted to DCR as well as the MEPA Office. The Proponent will also consider this additional traffic data as the planning and design of the project proceeds and will work with DCR to evaluate and implement potential mitigation measures. As stated above, should this additional analysis result in material changes to anticipated

EEA# 16397 ENF Certificate July 23, 2021

impacts or required mitigation for the project, the Proponent should consult with the MEPA Office to determine if additional review is required in the form of an NPC.

As described in the ENF, the project will create approximately 0.76 miles of new protected cycling infrastructure, approximately 4,000 linear feet (lf) of improved and/or expanded pedestrian sidewalk, and over 0.73 miles of reconstructed and/or modernized roadways designed to work better for all modes of transportation. The project will involve area-wide active transportation improvements focused on multi-modal travel, totaling over $10 million of investment in new transportation infrastructure serving multiple modes of transportation. Transportation access and accessibility to the Fenway neighborhood will be improved by reconstructing and improving a major bus hub on Brookline Avenue, including improvements to the “front door” of the Lansdowne MBTA station along Ortiz Drive, and creating new and better connections to existing MBTA stations to promote transit access to the area. The Proponent has also committed to implementing a transportation demand management (TDM) program and to joining the Transportation Management Association (TMA) established for the Fenway Area, A Better City (ABC). A Transportation Coordinator will be designated to oversee all transportation related operations and to act as the contact/liaison for the City, the ABC TMA, and residents/tenants of the Project. Comments from WalkBoston commend the proposed improvements in multi-modal infrastructure and in particular pedestrian access, but request the Proponent continue to work with WalkBoston, the City, and other stakeholders regarding accessibility of public infrastructure. I refer the Proponent to WalkBoston’s comments for further details on these design elements.

The Proponent is responsible for preparation of the Transportation Access Plan Agreement (TAPA), a formal legal agreement between the Proponent and the BTD. The TAPA formalizes the findings of the transportation study, mitigation commitments, elements of access and physical design, TDM measures, and any other responsibilities that are agreed to by both parties.

Historic Resources

The site contains several structures listed in MHC’s Inventory of Historic and Archaeological Assets of the Commonwealth (Inventory), including 78-88 Brookline Avenue (BOS.7502) and 45-47 Lansdowne Street. As described in the ENF, the building located at 45-47 Lansdowne Street was constructed in storage and light manufacturing uses in 1924/1925, and is proposed to be demolished as part of the project. The building at 78-88 Brookline Avenue was constructed as a commercial property in 1916/1917. The project proposes to add a vertical addition to this building. The ENF states the Boston Landmarks Commission will review the proposed demolition of 45-47 Lansdowne Street, as well as the other existing properties proposed for demolition (which are not listed in MHC’s Inventory) through Article 85 (Demolition Delay review) of the Boston Zoning Code. The Project is also subject to review by the MHC in accordance with M.G. L. Chapter 9, sections 26-27C, as amended by Chapter 254 of the Acts of 1988 (950 CMR 71.00). Comments from MHC state the ENF is incomplete for the purposes of MHC review, and requests that additional information be submitted in order to evaluate the potential effects of the proposed project on historic properties. I refer the Proponent to MHC’s comment letter for more details regarding the information that should be provided as the project proceeds to permitting.

Construction

EEA# 16397 ENF Certificate July 23, 2021

All construction and demolition activities should be managed in accordance with applicable MassDEP’s regulations regarding Air Pollution Control (310 CMR 7.01, 7.09-7.10), and Solid Waste Facilities (310 CMR 16.00 and 310 CMR 19.00, including the waste ban provision at 310 CMR 19.017). The project should include measures to reduce construction period impacts (e.g., noise, dust, odor, solid waste management) and emissions of air pollutants from equipment, including anti-idling measures in accordance with the Air Quality regulations (310 CMR 7.11). I encourage the Proponent to require that its contractors use construction equipment with engines manufactured to Tier 4 federal emission standards, or select project contractors that have installed retrofit emissions control devices or vehicles that use alternative fuels to reduce emissions of volatile organic compounds (VOCs), carbon monoxide (CO) and particulate matter (PM) from diesel-powered equipment. Off-road vehicles are required to use ultra-low sulfur diesel fuel (ULSD). If oil and/or hazardous materials are found during construction, the Proponent should notify MassDEP in accordance with the Massachusetts Contingency Plan (310 CMR 40.00). All construction activities should be undertaken in compliance with the conditions of all State and local permits. I encourage the Proponent to reuse or recycle construction and demolition (C&D) debris to the maximum extent.

Conclusion

The ENF has adequately described and analyzed the project and its alternatives, and assessed its potential environmental impacts and mitigation measures. Based on review of the ENF and comments received on it, and in consultation with State Agencies, I have determined that an EIR is not required. As stated above, should additional traffic analysis concerning DCR roadways result in material changes to anticipated impacts or required mitigation for the project, the Proponent should consult with the MEPA Office to determine if additional review is required.

July 23, 2021 ______Date Kathleen A. Theoharides

Comments received:

07/13/2021 Charles River Watershed Association (CRWA) 07/13/2021 Massachusetts Water Resources Association (MWRA) 07/13/2021 WalkBoston 07/14/2021 Massachusetts Department of Conservation and Recreation (DCR) 07/15/2021 Massachusetts Historical Commission (MHC) 07/16/2021 Massachusetts Department of Energy Resources (DOER)

KAT/ELM/elm

July 13, 2021

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

Subject: EOEEA #16397 – Environmental Notification Form Fenway Project, Boston, MA

Dear Secretary Theoharides,

The Massachusetts Water Resources Authority (MWRA) appreciates the opportunity to comment on the Environmental Notification Form (ENF) WS-Fenway-Twins Realty Venture LLC (the “Proponent”) for Fenway Project (the “Project”) in the Fenway neighborhood of Boston, Massachusetts. The Project involves a series of discrete development components to be constructed on approximately 5.32 acres of privately-owned land across multiple parcels as well as reconstruction and improvements to approximately 4 acre of publicly owned roadways and sidewalks. Development parcels will include a variety of residential, commercial, retail, restaurant, and public space.

Comments on the ENF relate to wastewater issues and the need for Infiltration/Inflow (I/I) Removal as well as Toxic Reduction and Control (TRAC) discharge permitting.

Wastewater

The ENF reports that the Project will increase wastewater flow by 281,721 gallons per day (gpd), from an existing wastewater flow of 9,145 gpd to 290,066 gpd. According to the Boston Water and Sewer Commission’s (BWSC) storm drain and sewer maps, the Project site is served by BWSC separate storm drains and sanitary sewers. There are existing sanitary sewer mains in Lansdowne Street and Brookline Avenue which convey flows to MWRA’s Ward Street Headworks in Roxbury, which in turn directs flows into MWRA’s Boston Main Drainage Tunnel for transport to the Deer Island Treatment Plant. Due to infiltration and inflow (“I/I”) that can enter tributary community sewers, along with stormwater that enters tributary BWSC combined sewers, combined flows in large storms can exceed the capacity of the conveyance system and contribute to combined sewer overflows (“CSO”) to the Charles River Basin.

To ensure that the Project’s wastewater flow does not increase system surcharging or overflows in large storms, the Proponent and BWSC should effect a 4:1 offset of the Project’s new wastewater flow by removing stormwater and/or I/I from a hydraulically related sewer system(s). Four gallons of extraneous flow should be removed for every gallon of new wastewater flow, in compliance with Massachusetts Department of Environmental Protection regulation and BWSC I/I policy. Increasing wastewater flow to the BWSC and MWRA sewer systems without targeted offset can compromise the sewer system benefits and Charles River water quality benefits of MWRA’s recently completed $912 million region-wide CSO control plan. The ENF states that the Proponent will work with BWSC and MassDEP to develop a plan to meet these requirements by removing I/I on a 4:1 basis.

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, a Temporary Construction Dewatering Permit cannot be issued and the discharge of groundwater or stormwater to the sanitary sewer system associated with this Project, during or after construction, is prohibited.

A Sewer Use Discharge Permit is required prior to discharging process wastewater, laboratory wastewater or photoprocessing wastewater from office, high-tech, R&D, laboratory or commercial space associated with the Project into the MWRA sanitary sewer system. For assistance in obtaining this permit, a representative from the proposed laboratory/R&D space should contact Lisa Chapman, Industrial Coordinator, in the TRAC Department at (617) 305- 5622.

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 (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 (617) 788-4958 with any questions or concerns.

Sincerely,

Rebecca Weidman Director Environmental and Regulatory Affairs cc: John Viola, DEP Adam Horst, BWSC

July 13, 2021

Secretary Kathleen A. Theoharides Executive Office of Energy and Environmental Affairs Attn via email: Eva Murray ([email protected])

Dear Secretary Theoharides:

WalkBoston has reviewed the PNF for the Fenway Project with respect to its impacts and benefits for people walking and using transit. We are very pleased that the proponent is proposing significant improvements to the walking environment in the Fenway neighborhood and giving detailed attention to the needs of people walking, taking transit and bicycling. The proposed transformation of Jersey Street into a pedestrian-only space will provide an exciting new way to experience Fenway Park (on non- game days) and add amenities for residents and visitors to the Fenway neighborhood. Overall, we believe the project will benefit pedestrians on the streets and sidewalks of the Fenway. We urge the proponent to continue working with WalkBoston, other advocates and the City of Boston to refine several elements of the design as the project proceeds. • Sidewalk/Bus stop/Bike interactions – The project includes re-designed streets (in particular Brookline Ave.) with new protected bike lanes. We urge the proponent to continue working with WalkBoston, the Boston Disabilities Commission and the MBTA’s Office of Systemwide Accessibility to ensure that the designs meet the needs of all sidewalk, transit and street users. • Paving surfaces – Some of the sketches shown suggest paving stones or other materials. We ask that all paving materials be fully accessible and comfortable for all people walking and that they be designed for good snow clearance. • Sense of welcome for all – The redesign and re-purposing of Jersey Street and all of the city blocks included in the project presents exciting opportunities for walkability. It also presents some challenges to ensuring that the spaces and places are not managed or curated in ways that could feel exclusive or less than fully welcoming to people of all races, incomes and ages. We urge the proponent to work with diverse community groups and individuals from a variety of Boston neighborhoods to ensure that the sense of welcome includes everyone. Thank you for the opportunity to provide comments. Sincerely,

Wendy Landman Stacey Beuttell Senior Policy Advisor Executive Director

July 13, 2021

Secretary Kathleen A. Theoharides Executive Office of Energy and Environmental Affairs Attn: Eva Murray, MEPA Office 100 Cambridge Street, Suite 900 Boston, Massachusetts 02114 Re: EOEEA #16397 Fenway Project ENF

Dear Secretary Theoharides: The Department of Conservation and Recreation (“DCR” or “Department”) is pleased to submit the following comments in response to the Environmental Notification Form (“ENF”) submitted by WS- Fenway-Twins Realty Venture LLC (the “Proponent”) for the Fenway Project (the “Project”). As described in the ENF the Project will redevelop thirteen privately-owned parcels in four primary blocks within the Fenway neighborhood. The Proponent plans to redevelop the parcels for residential, commercial, and retail / restaurant use. The Project also proposes to reconstruct and improve approximately four acres of publicly owned roadways and sidewalks. The ENF estimates the new development will generate 8,664 vehicle trips per day. DCR has care, custody, and control over several parkways that provide indirect vehicular access to the site. Considering the projected increase in vehicle trips, the Project will have significant impacts on the DCR roadway system that require long-term mitigation strategies. The ENF contends that, due to the COVID-19 pandemic, the timing is not ideal for gathering traffic data. DCR notes that traffic volumes currently are approaching 2019 levels and will continue to increase in the coming months. In order to assess impacts to DCR roadways, DCR requests that Boston Transportation Department standard 11-hour Turning Movement Counts (“TMC”) and 7-day volume-only Automatic Traffic Recorder (“ATR”) counts be conducted at the following DCR locations:

• TMCs o Boylston at Fenway o Boylston at Charlesgate o Boylston at Park Drive o Brookline/Boylston at Park Drive o Brookline at Fenway o Riverway at Park Drive o Riverway at Longwood o Riverway at Brookline • ATRs: o Soldiers Field Road W of Charlesgate o Storrow Drive E of Charlesgate o Boylston Street E of Park Drive o Boylston Street E of Charlesgate

COMMONWEALTH OF MASSACHUSETTS · EXECUTIVE OFFICE OF ENERGY & ENVIRONMENTAL AFFAIRS Department of Conservation and Recreation Charles D. Baker Kathleen A. Theoharides, Secretary, Executive 251 Causeway Street, Suite 600 Governor Office of Energy & Environmental Affairs Boston MA 02114-2119 617-626-1250 617-626-1351 Fax Karyn E. Polito Jim Montgomery, Commissioner www.mass.gov/orgs/department-of-conservation-recreation Lt. Governor Department of Conservation & Recreation EEA #16397 ENF Page 2 of 2

o Riverway W of Park Drive o Park Drive S of Brookline o Fenway S of Brookline o Park Drive N of Riverway

The listed sites, with total trips generated, should be shown on the trip distribution diagrams provided in ENF Figures 5.19 and 5.20.

It is important that DCR be able to fully assess the impact of the Project on its roadway infrastructure, and that begins with the existing traffic demand as measured with counts of existing traffic. The requested Traffic Impact Study will report the Project-specific trips that will be loaded onto DCR parkways segments and intersections as compared to No Build conditions. DCR will use this information to determine what measures may be required of the Proponent to mitigate the impact of its project on DCR roadways and roadway infrastructure.

Thank you for the opportunity to comment on the ENF. Please contact Jeff Parenti, DCR’s Deputy Chief Engineer at [email protected] with any questions. Sincerely,

______Jim Montgomery Commissioner cc: Jeff Parenti, Patrice Kish, Priscilla Geigis, Tom LaRosa

COMMONWEALTH OF MASSACHUSETTS EXECUTIVE OFFICE OF ENERGY AND ENVIRONMENTAL AFFAIRS DEPARTMENT OF ENERGY RESOURCES 100 CAMBRIDGE ST., SUITE 1020 BOSTON, MA 02114 Telephone: 617-626-7300 Facsimile: 617-727-0030

Charles D. Baker Kathleen A. Theoharides Governor Secretary

Karyn E. Polito Patrick Woodcock Lt. Governor Commissioner

12 July 2021

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

RE: Fenway Project, Boston, MA, EEA #16379

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

Dear Secretary Theoharides:

We’ve reviewed the Environmental Notification Form (ENF) for the proposed project. The project site includes approximately 1.67M-sf of office/research, 213,500 of residential space (216 units) and approximately 212,330-sf of retail space. The objective of this letter is to share strategies for the project to reduce greenhouse gas emissions (GHG), improve resiliency, and affordability.

Key Strategies

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

• Passivehouse (Residential);

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

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

Fenway Project, EEA #16379 Boston, MA

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

o Minimizing glass curtain wall assemblies and excessive windows;

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

o Energy recovery;

o Management of solar heat gains;

• Efficient electrification of space heating, including:

o For highly ventilated buildings (such as a life-science building, for example): low temperature, hydronic space heating with heat-input provided by hybrid, in- building, central plant consisting of air-to-water heat pump (primary) and gas boilers (secondary). Size the air to water heat pump to 20-40% of the heating peak load with the objective of providing 80-90% of the total annual space heating with air source. This approach can also work for speculative life-science buildings, as well.

o For all other buildings (residential (any number of units), office, and retail): hydronic space heating with 100% air to water heat pump input, or air source VRF, or air to air heat pumps.

• Efficient electrification of water heating, where feasible; (All Buildings)

• Extensive rooftop solar-readiness; (All Buildings)

• Electric vehicle ready parking spaces. (All Buildings)

Experience has shown that the above deliver 50 to 80% less emissions than projects built to Code while improving affordability and resilience. In addition, significant incentives may be available, including MassSave® incentives, Alternative Energy Credits (AECs), and Solar Massachusetts Renewable Target (SMART) credits. For this project, just the MassSave® Passivehouse incentive for the residential portion of the project is worth up to $648,000.

Key Mitigation Strategies Explained

Passivehouse

Passivehouse is an energy efficiency building standard that results in an ultra-low energy building requiring little energy use for space heating and cooling. This is achieved by focusing on envelope performance, airtightness, solar heat gain management, and energy recovery. Passivehouse projects also typically have efficient electrified heating, as described above, and much smaller- sized HVAC systems. Published studies show that in low-rise and mid-rise residential construction, Passivehouse doesn’t necessarily cost more to build because improvements to

Page 2 of 10

Fenway Project, EEA #16379 Boston, MA envelope are offset by reductions in HVAC1 costs. In high-rise residential construction, Passivehouse costs nominally more2.

Passivehouse is an energy code standard which is unlike other energy efficient building approaches in that its truly performance based by requiring mandatory, rigorous in-field tests to confirm that strict standards are being met. Passivehouse methods are recognized by both Massachusetts building Code, MassSave3, and incentives under Massachusetts’ Alternative Portfolio Standard (APS). For qualifying multifamily buildings, MassSave incentive for Passivehouse is approximately $3,000 per dwelling unit, or $648,000 when applied across the project.

Passivehouse also delivers:

• Significant reduction in utility costs: thus is much more affordable to residents;

• Improved resiliency: Passivehouse buildings can stay warm (or cool, in the summer) for extended periods of time even with loss of power.

The Passivehouse pathway accesses the most incentives, while also being the most affordable and efficient.

At this time there are over 5,000 Passivehouse units being designed or under construction in eastern Massachusetts. Additionally, upon completion of Winthrop Square Tower, Boston will be home to a 750,000-sf office space certified as Passivehouse.

1 Pennsylvania Housing and Finance Association. Passivehouse Cost Comparison Data set 2015, 2016, 2018 [Data Set] 2 Feasibility Study to Implement the Passivehaus Standard on Tall Residential Buildings, FXcollaborative, 30 March 2017, Prepared for NYSERDA 3 MassSave® is a consortium of Massachusetts utility companies designed to deliver energy efficiency throughout the Commonwealth of Massachusetts. Page 3 of 10

Fenway Project, EEA #16379 Boston, MA

Passivehouse Examples

Bunker Hill Housing Development Newton Riverside Charlestown, MA Newton, MA

Thermal Energy Demand Intensity (TEDI) Reduction: Envelope, Heat Recovery, and Solar Gains

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

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

Specific TEDI reduction strategies are:

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

Page 4 of 10

Fenway Project, EEA #16379 Boston, MA

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

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

Efficient Electrification

Efficient electrification and renewable thermal space and water heating entails the swapping of fossil fuels (natural gas, oil, and propane) or electric resistance systems with one or more of the following:

• Cold-climate air source heat pumps and variable refrigerant flow (VRF) for space heating; • Air source heat pumps for water heating; • Ground source heat pumps; • Solar thermal.

Electrification of space and water heating is a key mitigation strategy with significant short- and long-term implications on GHG emissions. Massachusetts grid emissions rates continue to decline with the implementation of clean energy policies that increase renewable electricity sources. The implication is that efficient electric space and water heating with cold climate air source heat pump and VRF equipment have lower emissions than other fossil-fuel based heating options, including best-in-class (95% efficient) condensing natural gas equipment.

Currently, efficient electric heating has approximately 50% lower emissions in Massachusetts than condensing natural gas heating. By 2050, efficient electric heating is expected to have approximately 85% lower emissions in Massachusetts than condensing natural gas heating. See illustration below.

Electrifying Space Heating for residential, mixed use and commercial spaces

Page 5 of 10

Fenway Project, EEA #16379 Boston, MA

Office, residential, retail, commercial, and most industrial spaces can readily achieve 100% efficient electrification of space heating using either air to water heat pumps, VRF, or air to air heat pumps.

Electrifying Space Heating for highly ventilated buildings (research space):

For highly ventilated buildings use low temperature, hydronic space heating with heat-input provided by hybrid, in-building, central plant consisting of air-to-water heat pump (primary) and gas boilers (secondary). Size the air to water heat pump to 20-40% of the heating peak load with the objective of providing 80-90% of the total annual space heating with air source. This approach can also work for speculative life-science buildings, as well.

Heat Pump Water Heating

Water heating can be accomplished in many ways, common technologies include fossil fuel boilers and electric resistance systems. There are approaches that utilize air-source heat pumps, as well. These applications include centrally located systems that distribute hot water to the units or distributed, unit-based heat pump water heaters.

Distributed heat pump water heating is feasible for office and retail spaces and is recommended for these applications. Distributed heat pump water heating may be feasible for the research building, as well, and is recommended if feasible.

Distributed heat pump water heating is much more challenging to implement in dense residential, however due to limited space in the individual units. For this application, we recommended evaluating a centrally located heat pump water heating system.

Solar PV

Rooftop PV can provide significant GHG benefits as well as significant financial benefits. The project should review opportunities to maximize on-site PV by set-aside as much roof space as possible for future rooftop PV.

Even if PV is not installed during building construction, it’s important to plan the project to ensure that roof space is set aside for PV and that roof space doesn’t become unnecessarily encroached with HVAC appurtenances, diminishing the opportunities for future PV. Electrification of heating and Passivehouse can both contribute to enabling more PV as these approaches can reduce rooftop equipment associated with conventional code HVAC.

Electric Vehicle (EV) Ready Parking Spaces

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

We encourage the project to maximize EV ready parking spaces for the project. Page 6 of 10

Fenway Project, EEA #16379 Boston, MA

Incentives

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

• MassSave performance-based incentives4 offer incentives for every kWh or therm saved compared to a program-provided energy model. The above energy efficiency strategies offer opportunities for large kWh and therm savings.

• MassSave Passivehouse incentives5 are available to multifamily buildings which meet either PHI or PHIUS Passivehouse certification. In addition to a $3,000/unit incentive, MassSave also funds pre-construction feasibility and modeling. The incentive structure is as follows:

• Alternative Energy Credits (AECs)6 offer incentives to electrify building space heating using heat pumps and/or VRF. This program also includes multipliers which increase value if the building meets Passivehouse standards or buildings built to HERs 50 or less. These credits may be distributed on a quarterly basis over time; or, may be distributed in a lump sum to the developer if certain conditions are met.

• Massachusetts SMART program7 provides significant incentives for solar development on top of federal and state tax incentives. SMART includes pathways which allow solar production to be sold without off-takers. This may be of potential interest to building developers as this allows them to develop rooftop solar without necessarily engaging with building tenants. For this reason, setting aside rooftop solar PV areas helps ensure that building owners’ ability to monetize the roof is not impacted.

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

4 https://www.masssave.com/en/saving/business-rebates/new-buildings-and-major-renovations/ 5 https://www.masssave.com/saving/residential-rebates/passive-house-incentives 6 https://www.mass.gov/guides/aps-renewable-thermal-statement-of-qualification-application 7 https://www.mass.gov/solar-massachusetts-renewable-target-smart Page 7 of 10

Fenway Project, EEA #16379 Boston, MA amendments including C402.1.5 (envelope), C405.3 and C405.4 (lighting), C405.10 (EV charging), and C406 (three additional efficiency measures).

Recommendations

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

1. Was each building and space use type modeled separately? Models should be separated by building or building area use type as follows: a. Office b. Research c. Residential d. Retail

2. Did the project ensure baseline building scenarios meet all requirements including relevant MA amendments. Each building should clearly indicate which three C406 measures are being used in the baseline. C406 measures are required for Code. For example, if the project choses additional solar PV, the solar PV must be installed to meet Code.

3. Did the project demonstrate compliance with envelope requirements? To demonstrate compliance each building could develop two UA analysis tables, as follows:

a. One table that shows how the baseline complies with Table 5.5-5 of ASHRAE 90.1 2013 Appendix G plus Massachusetts Amendment C401.2.4. Fenestration limits will vary depending upon building type.

b. A second table that shows how the proposed complies with 2018 IECC Tables C- 402.1.3, C402.1.4, and C-402.4. Fenestration limit should be 30% when calculating minimum performance requirements for all building types.

4. Was above-code envelope used throughout? The following measures should be reviewed:

a. Above code-threshold envelope should be used throughout (vertical walls, windows, roofs and exposed lower level floors). Priority should be given to increasing continuous insulation and framed insulated wall sections. Distinguish between R value of batt and R value of continuous insulation. Continuous insulation necessarily means insulation that is uninterrupted by hangers, studs, etc. Indicate planned wall assembly U value and wall construction type (mass, wood, metal stud, etc). Confirm that the relationship between R-value and assembly U-factor conform to Appendix A of the Code.

b. Glass curtain wall/spandrel systems should be avoided as these are the lowest performing wall systems.

Page 8 of 10

Fenway Project, EEA #16379 Boston, MA

c. Opaque curtain wall sections shall not have envelope performance larger than R- 10.

d. Reduce air infiltration, along with field tests to confirm integrity.

e. Recommended envelope for all building types, in summary, is an envelope with a 15% improved UA over IECC C402.1.5 minimum plus Passivehouse level air infiltration limit of 0.08 cfm at 75 Pa.

f. Low heating thermal energy demand intensity (TEDI). A combination of the above listed high-performing envelope measures paired with and heat recovery can deliver heating TEDI that is significantly smaller than code heating TEDI.

5. Did the project consider additional opportunities for high performing buildings? The project should consider approaches as follows:

a. Residential: Passivehouse with efficient electric space heating (electric air source heat pump/VRF or central air to water heat pump to 120F thermal distribution loop) and gas water heating. A study could be performed by a qualified Passivehouse consultant at little to no cost by leveraging the MassSave® funded Passivehouse feasibility study and modeling incentives.

▪ Investigate centrally located heat pump water heating

b. Commercial and Industrial: Improved envelope as described above. Downsize the HVAC as much as possible. In-building centrally-located efficient electric space heating (air to water heat pump sized at 100% peak heating capacity with no gas boiler back-up). External shading and improved solar heat gain coefficient windows to control space cooling loads. Heat pump hot service hot water. Energy reduction shall be attributable to reductions in heating, cooling, fan, ventilation, and pumping. We expect GHG mitigation to come primarily from reductions in heating, cooling, pumping, and fan energy.

▪ Investigate VRF alternative for space heating

c. Highly ventilated research buildings: Improved envelope as described above. Downsize the HVAC as much as possible. Low temperature, hydronic space heating with heat-input provided by hybrid, in-building, central plant consisting of air-to-water heat pump (primary) and gas boilers (secondary). Size the air to water heat pump to 20-40% of the heating peak load with the objective of providing 80- 90% of the total annual space heating with air source. External shading and improved solar heat gain coefficient windows to control space cooling loads. Gas hot service hot water. Energy reduction shall be attributable to reductions in heating, cooling, fan, ventilation, and pumping. We expect GHG mitigation to come primarily from reductions in heating, cooling, pumping, and fan energy.

▪ Investigate heat pump water heating

Page 9 of 10

Fenway Project, EEA #16379 Boston, MA

d. Retail portion: Improved envelope as described above. Downsize the HVAC as much as possible. Efficient electric (electric air source heat pump/VRF) space heating. External shading and improved solar heat gain coefficient windows to control space cooling loads. Electric air source heat pump service hot water. Energy reduction shall be attributable to reductions in heating, cooling, fan, ventilation, and pumping. We expect GHG mitigation to come primarily from reductions in heating, cooling, pumping, and fan energy over reductions in lighting and miscellaneous energy reduction.

6. Did the project evaluate incentives? Including:

a. Estimate of Alternative Energy Credits

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

7. Did the project evaluate rooftop solar PV? This should include building roof plans showing location of planned solar and location of roof HVAC equipment and other appurtenances.

8. Did the project maximize EV-ready parking spaces. Confirm commitment to installed EV charging station and EV ready spaces.

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 10 of 10