harvard mepa comment letters

8/14/2019 Harvard MEPA comment letters

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Secretary Ian A. Bowles

EOEA, Attn: MEPA Office

Briony Angus, EOEA No. 14069

100 Cambridge Street, Suite 900

Boston MA 02114

Dear Secretary Bowles,

I do not believe the Harvard Science Complex meets the requirements for a Phase 1

waiver.

I ask you to listen to the voices of this community and our neighbors in Cambridge. No

one is opposed to building the science complex, however nearly every person who spoke

at the meeting on Thursday, August 23rd

opposed granting the phase 1 waiver.

I believe that there is no question that the Science Complex will have a significant impact

on our community. Harvard has spent months determining the impact the complex willhave on traffic, parking, the environment, and the rodent problem in the community. Our

roads are already congested, it is already difficult to find parking, and rodents have

become a growing problem in the community. Any impact on these issues would

constitute a significant one.

Sincerely,

Mark Ciommo Candidate, Allston-Brighton District City Council


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The Hon. Ian A. Bowles

SecretaryExecutive Office of Environmental Affairs

100 Cambridge Street

Suite 900

Boston, MA 02114

Attention: MEPA OfficeBriony Angus

EOEA No. 14069

September 10, 2007


I am writing to both express concerns about Harvards proposed 20-year Master Plan for

and also to express my strong opposition to the requested Phase One Wavier for theScience Complex.

I am a lifelong resident of Brighton and a community leader who has spent more than 15

years representing my neighbors concerns on a range of issues. Specifically, I wasappointed by Mayor Menino to serve on the Boston College Task Force. In this capacity,

for more than a decade I have worked closely with Boston College and, although it hasnt

always been easy, weve built important relationships in an effort to limit the negative

consequences of their development on residents and our infrastructure.

Again, although we have our differences, Boston Colleges understands its symbiotic

relationship with the community a community of which it is a member. Boston Collegeunderstands that has an interest and a stake in the community. Concerns about public

safety and city services (trash, rodent infestation, parking, traffic congestion, etc.), are not

just our concerns but their concerns. Their students quality of life is equally impacted.

To date, Harvard University has not worked with the community. Worse yet, Harvard

University has not shown any respect for the community in which it seeks to develop its

Science Complex. And Harvard University fails to understand that the health, safety andvibrancy of Allston-Brighton is fundamental to the successful implementation of their

plans.

To date, Harvard University has operated under a veiled cloak of secrecy. Its lack of

transparency and, at times, hostile engagement with the community is of grave concern.

Harvards complete disregard for the community is alarming. Issues of pollution andtraffic congestion are real concerns and they are issues that will impact current residents,

current students and future beneficiaries of the Science Complex alike.


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Let me be absolutely clear. I fully support the development of the Science Complex as do

the majority of residents I know. We do not question whether the Science Complexshould be developed, but rather how it should be developed.

No doubt Harvard is anxious to start its development as soon as possible. However, we

are anxious that this development be done thoughtfully and taking into account thelegitimate concerns of local residents and business owners.

Harvard University should not be afraid to work with us we are not their enemy. We

want to work with them but we want them to be responsible and accountable for the

impact this development will have on our community.

It is therefore of the utmost importance that Harvard University proactively addresses

these concerns before construction begins. They have failed to do so.

Furthermore, granting their application for a Phase One Waiver will only serve to teach

Harvard University that they can bull-doze and ignore the Allston-Brighton residents.Given the breadth and scope of the proposed development, this would be a devastatinglesson and further exacerbate the already strained relationships Harvard University has

with the community a community who want to work and negotiate with Harvard in a

mutually-respectful manner.

In conclusion, I reiterate my strong opposition to granting Harvard Universitys

application for a Phase One Waiver.

Thank you for your consideration and if you have any questions or I can provide any

additional information, please dont hesitate to contact me.

Sincerely,

Rosie Hanlon172 Chiswick Road

Brighton, MA 02135


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Richard A. Dimino, President Gordon Feltman, Vice President Grace S. Shepard, Treasurer Jay Ash, Secretary

Marc D. Draisen,Executive Director

September 7, 2007

Secretary Ian A. BowlesExecutive Office of Energy and Environmental Affairs

Attention: MEPA OfficeBriony Angus, EEA # 14069

100 Cambridge Street, Suite 900Boston, MA 02114

RE: Harvard University Master Plan, EENF, EEA # 14069

Dear Secretary Bowles:

The Metropolitan Area Planning Council (MAPC) regularly reviews proposals deemed to have

regional impacts. The Council reviews projects for consistency with MetroPlan, the regional policyplan for the Boston metropolitan area, and MAPCs Smart Growth Principles, as well as for their

impacts upon the environment. MAPC has reviewed the Expanded Environmental NotificationForm (EENF) for Harvard Universitys 20 Year Master Plan and the Science Complex and submits

the following comments. Please note that our review and comments are limited to thosematerials submitted as part of the MEPA process.

The Master Plan covers 215 acres of Harvard-owned land in Allston. When the 20 year plan is

fully implemented, Harvard estimates there will be:

4 to 5 million square feet of structures 1,343 new student beds (for a total of 2,500) An additional 4,360 parking spaces (for a total of 5,400) An additional 12,400 vehicle trips per day (for a total of 16,600) A reduction of 50 acres of impervious surfaces Open space, new streets and improvements to existing streets

In addition, sustainability guidelines are expected to reduce energy and water use and lowergreenhouse gas emissions for newly constructed buildings compared to conventional designs.

The site for the Science Complex is approximately 8.5 acres and is currently occupied by

industrial buildings and surface parking. The complex will include four buildings, totaling 537,000square feet, and underground parking for 350 cars. An additional 150 surface parking spaces will

be dedicated for use by the Science Complex. In addition to research and academic uses, the

complex will include 6,400 square feet of retail space, an atrium, day-care center, and aquadrangle-type park. New roadways are proposed. The building will aim for LEED Certification

at the Gold Level.

Special Review Procedure for the Master PlanThe EENF notes that the proponent is favorable to undergoing a Special Review Procedure, which

would entail the formation of a Citizens Advisory Committee. We feel that given the size of this

project and its regional importance, it is critical that Harvard does make this request and that aCAC is formed. We ask you to encourage Harvard to do so.

We feel it is important for MAPC, as the regional planning agency, to be represented on the CAC

since implementation of the Master Plan will incur impacts and provide benefits beyond Boston


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Ian A. Bowles, Secretary, Executive Office of Energy and Environmental Affairs September 7, 2007

Re: Harvard University 20-Year Master Plan, Boston, EOEA # 14069, EENF Page 2 of 2

city limits. We have played a role in other Special Review Procedures, such as the South

Weymouth Naval Air Station CAC, the MWRA Water Supply CAC and MWRA Wastewater Facilities

Planning CAC for Harbor Clean-up. We also are serving on the South Coast Rail InteragencyStudy Team, which is reviewing land use issues along the routes proposed for the commuter rail

to New Bedford and Fall River.

Since the Allston Campus will have transportation impacts on Cambridge, Brookline, andWatertown, we suggest that those municipalities also be invited to participate on the CAC.

Lastly, because Allston is home to significant environmental justice populations, we hope that the

CAC will reflect the communitys diversity. Consultation with the Allston Brighton CommunityDevelopment Corporation on CAC membership could help to achieve a diverse composition.

Phase 1 W aiver Request for Science Complex

Based on the information contained in the EENF, we cannot at this time support the proponentsrequest for a Phase 1 Waiver for the Science Complex. We base our decision on two specific

issues.

1. The EENF does not demonstrate that the traffic impacts of the Science Complex will not be

significant, nor does it demonstrate that current transportation infrastructure can support the

Science Complexs needs, as required by the MEPA regulations in order to grant a Phase 1Waiver. The planned shuttles to the Cambridge campus and the Longwood Medical area, alongwith the internal pathways and bicycle facilities to encourage walking and bike-riding will certainly

divert some of the trips to the Science Center away from automobiles. Limiting parkingavailability (500 spaces) will be even more important for reaching the goal of reducing auto trips.

The ratio of one parking space per 1,000 square feet should be maintained throughout all phases

of the project.

However, there is no demonstration that these measures will achieve either the citys target of59% single occupant vehicles or Harvards more ambitious goal of 50%. The EENF simply

assumes that these goals will be met.

The EENF acknowledges that there are congestion problems at the Charles River crossings andother locations nearby, but no roadway mitigation is proposed for Phase 1. Rather, there is anassertion, but no demonstration, that there will be a net decrease in auto trips and therefore no

need for roadway mitigation during Phase 1.

The trip generation information, which is the basis for the assertion that there is a net decrease inauto trips, is incomplete and appears to have been incorrectly calculated. The trip generation

figures quoted for Research and Development uses have been used as person trips, when in fact

all rates in the ITE Trip Generation manual are vehicle trips. Using the calculated figures asperson trips, and then reducing their numbers by the assumed 50% to estimate vehicle trips,

grossly underestimates the potential new trips to the Science Center. In addition, it does notappear that trips to the day care center and the retail components of the Science Center have

been included.

Net vehicle trips are the new trips to the Science Center minus those displaced from existing usesat the site. As best we can tell, the calculations used to estimate existing trips displaced are not

shown in the EENF. Ideally, the displaced trips for existing uses would have been measured

directly through driveway counts and employee surveys, rather than estimated,. This option wasnot used, dismissed because there were supposedly cut through trips in the parking lots that

would skew the numbers. Instead, trip generation rates from ITE were used, but the EENF doesnot make clear which rates were used on which properties. For example, WGBH is cited as being

displaced, but WGBH has not closed and those trips do not disappear; they are simply moved tothe new WGBH location.


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The EIR should include a complete accounting of which uses will no longer be in the area, which

will be moved, to where, and during which phase of the Harvard reconstruction. There should

also be a justification that the trip generation rates will produce the best estimates of how manyauto trips are being removed from the area. Until this information is provided there cannot be an

evaluation on whether or not there is a net reduction in auto trips in the area. And since the nonew net trips is the transportation justification for the Phase 1 waiver, the waiver should not be

granted until this information is provided and reviewed.

2. Based on the information contained in the EENF, we do not believe that Phase 1 is severable

from implementation of the full Master Plan. According to the MEPA regulations, among otherfindings, in order to grant a Phase 1 Waiver, the Secretary must find that the Project is

severable, such that phase one does not require the implementation of any other future phase ofthe Project or restrict the means by which potential environmental impacts from any other phase

of the Project may be avoided, minimized or mitigated. The EENF does not contain adequateinformation about the proposed storm water system to demonstrate that it meets this waiver

requirement.

As outlined in the EENF, important aspects of both the Master Plan and the Science Complex

include the reduction of impervious surfaces, use of Low Impact Development (LID) techniques,

and overall improvement to the current storm water situation. Yet, when constructing theScience Complex, Harvard proposes to replace an existing 36-inch storm drain pipe with a 72-inch pipe. This new 72-inch pipe will then feed back into a 36-inch drain pipe. Unless drainage

calculations are presented, we assume that this drainage scheme requires the smaller drain pipes

also to be upgraded or else flooding will occur due to constricted water flow from the larger pipeto the smaller pipe. Therefore, it appears that the Science Complex (Phase 1) does depend up on

the construction of the future phases i.e., the replacement of additional 36-inch drainage pipeswith 72-inch pipes. Without more detail on the proposed drainage, one has to assume that the

Science Complex is not severable from future phases of the Master Plan and is not eligible for awaiver.

Construction of a 72-inch drainage pipe also raises questions about the overall storm water

approach. Doubling the size of drainage pipes would seemingly would transport more water,faster to the Charles River contrary to their stated storm water goals.

Consistency with MAPC Smart Growth P rinciples and MetroFutureAs noted in the EENF, the conceptual Master Plan appears to be consistent with many aspects of

smart growth and MetroFuture (MAPCs soon to be released regional plan).

Important smart growth features of the Master Plan include:

Redevelopment that is replacing auto-dependent uses with denser, mixed usedevelopment.

Sustainable building design, reduction in green house gas emissions, and aggressive waterconservation.

Reduction of impervious surfaces. Possibly opening up housing opportunities for residents by providing more housing for

students on campus and through contributions to housing funds via the citys linkage

program. Though not yet finalized, many of the mitigation measures and items included in the yet-

to-be-created community benefits agreement will likely include job training programs andother amenities for the community.

As we mention below, we would like the proponent also to discuss consistency with MAPCs Smart

Growth Principles and the Commonwealth Sustainable Development Principles.

Items to be Included in EIR


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Regional Impacts

As mentioned above, the future of these 200 acres will provide regional benefits and haveimpacts beyond the citys boundary. The EIR should identify potential impacts that may occur

outside of Boston and outline appropriate mitigation. In determining the impacts and mitigation,it is important that the proponent consult with neighboring municipalities, particularly the city of

Cambridge and the towns of Brookline and Watertown.

Alternatives to Analyze in EIR

The Allston Brighton CDC and the city worked with the community a few years ago to create theNorth Allston Strategic Framework for Planning (NASFP). The NASFP embraces the presence of

Harvard and its campus expansion plans and lays out a physical framework for the development,among other things. Comparing this framework to the Master Plan indicates that Harvard has not

embraced the plan. We request that the NASFP be the basis for one alternative analyzed in theEIR, specifically including the NASFPs proposed street network and the river walk concept.

The Charles River Watershed Association proposes a sub-watershed approach to storm watermanagement in this area, including the daylighting of Allston Brook, and more aggressive LID

measures. We also would like to see this approach analyzed as an alternative in the EIR.

Other Items to Address in EIR

As noted, the proponent should discuss consistency with MAPCs Smart Growth Principlesas well as the Commonwealths Sustainable Development Principles. The MAPC principlescan be found on our web site at:

www.mapc.org/regional_planning/MAPC_Smart_Growth.html

EOEAs Environmental Justice maps indicate that the site is located in an area withEnvironmental Justice populations. The EIR should include demographic information andthe proponent should clarify whether the project meets the threshold for Enhanced Public

Participation.

The EIR should explain who will finance the various improvements and who will buildthem. This includes all non-building improvements such as utility upgrades andextensions, new roadways, transit improvements, improvements to existing roadways

(including Soldiers Field Road), storm water infrastructure and green space.

Traffic impacts are likely to be felt on intersections in Cambridge, Brookline, andWatertown. These communities should be consulted for locations that should be evaluated

as part of the comprehensive traffic analysis that should be part of the EIR. If necessary,

mitigation should include roadway improvements in these three communities as well asBoston.

Even with a goal of a 50% auto mode share for this campus, Harvard estimates they willadd more than 12,000 new vehicles to an already overburdened roadway network. In the

EIR there should be a demonstration that this 50% target is both feasible and adequate.The BRA apparently requires that all new development in Brighton begin with at most a

59% auto share in an area well served only by bus. However, Harvard notes that theyalready have a lower mode share for auto trips on the Cambridge campus. That figure,

which is not cited, should also be the goal on the Allston campus, especially consideringthe possibility of a commuter rail stop or Urban Ring spur in the Allston community. The

EIR should also spell out the consequences of not meeting the final agreed-upon targetand the additional mitigation steps that would be taken in that eventuality.

As part of this discussion there should be an analysis of the demand for bus rapid transitand rail service, provided by the Urban Ring and a commuter rail stop in Allston/Brighton,


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and a discussion of Harvards contributions to the capital or operations costs of these

services as part of its mitigation responsibilities.

Harvard has proposed covering and depressing Soldiers Field Road as part of a plan toreclaim the riverfront for campus and community use. As a member of the Boston RegionMPO, MAPC is aware of the severe shortage of transportation funds for projects throughout

the Commonwealth. We believe it is unrealistic to suggest that traditional federal andstate sources of transportation funds will be available for this project. In addition to

discussing how this work will be funded, in the EIR the proponent should also demonstrate

how, if at all, this change will benefit the regional transportation network.

The EIR should clarify ownership of streetscape and infrastructure improvements. Thisapplies to new streets, improvements made to existing streets, and all improvements

constructed within public rights-of-way. This is particularly important in those caseswhere operation and maintenance of infrastructure is critical to mitigating environmental

impacts (for example, street sweeping, maintaining sidewalks and street trees, etc.).

While the draft Master Plan does include elements of green space throughout the campus,it does not seem to be a comprehensive network, nor are connections from the

neighborhoods to the river evident. In some cases, it appears that pathways dead-end atbuildings. We would like to see more detailed maps showing connections to the river, andas noted earlier, we would like to see the concepts from the NASFP, such as the river walk,

included in the plan. Actual pedestrian routes from the neighborhoods through the

campus to the river should be provided on maps.

The Charles River Reservation is an important regional asset. In addition to our pointabove about ensuring access by the local community, the EIR should indicate how regional

access to the reservation and river will be maintained and improved.

The impacts to the historic character of the parkway system by placing a segment ofSoldiers Field Road underground need to be explored in the EIR. While burying the

roadway would create open space and provide a connection from the Harvard campus tothe Charles River, DCRs parkway system is a unique regional amenity that defines thecitys and regions roadway system. Placing the roadway underground seems contrary to

the purpose of the parkways, and could ironically restrict views of the Harvard campus andthe river to thousands of motorists daily. The proponent should consult with DCR and the

EIR should weigh the advantages to pedestrians against the impacts to the parkway

system and the motoring public if this segment were to be buried. The EIR should alsoclarify if the land above the buried parkway would be publicly owned and accessible to all.

The 20 Year Master Plan covers 215 acres and a number of buildings currently exist on thisland. The EIR should provide information on what will occur in this area in the interimperiod will buildings be demolished, sit vacant, or will businesses continue to operate?

The impacts of the interim state of this land should be discussed in the EIR.

We strongly support the use of LID techniques for minimizing storm water impacts and weare pleased that Harvard is committed to employing innovative methods. The EENF doesstate that this area has a high water table and testimony at the August 23 MEPA hearing

indicated that there are current drainage issues in this area. The EIR should elaborate onwhich LID techniques will be employed and how the high water table could affect

successful implementation of those measures. We also would like to see the EIR includethe CRWAs suggestion for green streets as further mitigation for storm water impacts.

In terms of water resources, the EIR should delineate sub-watershed boundaries anddrainage patterns. The EIR should discuss past and current flooding and drainage issues,


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include drainage calculations for existing and proposed conditions with particular attention

to potential impacts on nearby properties and streets. The EIR should demonstrate that

there will be no net loss of flood storage capacity.

There is a growing body of evidence that traffic-related pollution, especially for those livingwithin 100 to 500 feet of a major roadway, creates adverse health impacts. In 2006,

MAPC convened a workshop of experts to discuss this emerging issue. Public healthexperts from the Harvard School of Public Health participated and discussed their findings

on the health impacts (see www.mapc.org/transportation/Air_Quality/Air_Quality.html). It

appears that the Master Plan will place student housing next to Soldiers Field Road. Weurge Harvard to consult with its School of Public Health to develop mitigation measures to

reduce the potential health impacts to students. These measures should be included inthe EIR.

The City of Boston recently completed a Natural Hazard Mitigation Plan with assistancefrom MAPC and funding from FEMA. The plan delineates areas at risk of natural hazards,

and shows that a major portion of the Harvard Campus in Allston is located in an areasubject to liquefaction during an earthquake and is also susceptible to storm surges during

a hurricane. We urge the proponent to review the plan and to incorporate mitigation

measures for these natural hazards into the EIR. In addition to measures to protect thebuildings, the EIR should include measures to protect infrastructure roadways, drainagepipes, electrical systems which can be particularly vulnerable to damage.

While we understand that the timing and phasing of construction is uncertain, the EIRshould provide at least a rough timetable for implementing the benefits the green space,

the storm water management structures, the new streets, etc. to ensure that someportion of the campus-wide benefits are phased in along with building construction.

At the August 23 MEPA hearing, Harvard representatives noted that the use diagramscontained in the EENF indicate anchor uses. For example, Figure 2-2 indicates that landat Barrys Corner will be slated for athletic and cultural/performing arts uses. However,

the proponent has stated that this area may also include residences and retail. The EIRshould elaborate/clarify which types of uses will be included in each area.

The EIR should include more detail on how deliveries and service vehicles will beaccommodated.

The EIR should include the final community benefits agreement that is currently beingdeveloped as part of the BRAs Article 80 process.

Harvard should provide more detail on the campus / community interface (those buildingsalong the southern and western perimeters that are closest to existing neighborhoods).Though the diagrams and sketches in the EENF are only drafts, it appears that in some

cases the backs of buildings will abut neighborhoods. It is unclear how the design and

layout of the buildings will help to ease the transition from neighborhood to campus andprovide connections between both communities. Harvard states that it will create design

guidelines for each area of the campus. We urge Harvard to include a set of guidelinesspecific to these campus-community interface/transition areas and to include them in the

EIR. The EENF also refers to a Harvard Design Review Group. More information should beprovided on this group including whether community members will have seat(s) on the

Group. We feel that appropriate, neighborhood scale design along the perimeters canencourage pedestrian activity.

Providing more on-campus housing for students may reduce the number of students livingin nearby neighborhoods, if enrollment is the same as today. The EIR should provide


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information on likely enrollment figures at the campus when the new housing is

constructed compared to today to better gauge the magnitude of this benefit. In other

words, if the increase in enrollment equals the increase in the number of beds, then thereis no net housing benefit to the community.

The EIR should evaluate alternatives for construction-related traffic and outline impacts toresidential neighborhoods and commercial areas. It is our understanding that theproponent is exploring the feasibility of using the rail yards to access the site during

construction. The advantage of this approach is that it could minimize traffic on residential

roads. However, if this alternative is being considered, the EIR should also analyzewhether using the rail yards would result in delays or added costs to the regions freight

transport and the MTBA.

Thank you for the opportunity to provide our input on this important regional project. We hope tocontinue to play a role as Harvard continues work on its Master Plan.

Sincerely,

Marc Draisen

Executive Director

cc: Kairos Shen, BRA

Thomas Tinlin, BostonJeanne E. Richardson, BWSC

Susanne Rasmussen, Cambridge

Jeff Levine, BrooklineGregory P. Watson, Watertown


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Cambridge, MA 02139

September 6, 2007

Secretary Ian A. BowlesMEPA, Attn. Briony Angus EEA #14069


Boston MA 02114

By email: [email protected]


On behalf of the Cambridge Bike Committee, I am submitting comments with

regard to Harvards Expanded Environmental Notification Form for the proposed Allston

campus and Harvards related application for a Phase One waiver for the ScienceComplex. We on the committee would have concerns about any final approval from

MEPA, including a Phase One Waiver, which would fail to secure the highest feasible

standard of bike facilities. We are particularly interested in on-road and, where

appropriate, off-road bike lanes, off-road bike storage and related facilities, and strong

connectivity between the Allston campus and the Harvard campus in Cambridge. For

that reason, we urge that MEPA grant final approval to Harvard only when you are

satisfied that excellent bike facilities are well secured.

We think you would agree that bike transportation offers a range of benefits to

cyclists and non-cyclists alike. For cyclists, biking offers convenience, exercise, and

enjoyment. For non-cyclists, the fact that others bike reduces pollution, traffic

congestion, competition for parking, and the public health costs of more sedentarylifestyles.

High quality bike facilities encourage biking. Good facilities make biking safer

for cyclists and reduce conflicts between bikes and motor vehicles. Storage and related

facilities for bike commuters (e.g. showers, lockers for biking clothes and the like) make

bike commuting more common, and thereby reduce motor vehicle congestion.

We are truly pleased to see that Harvard is aiming for LEED certification. It

appears that much effort and thought has gone into the design of buildings to minimize

negative environmental impacts. Preliminary attention to bike lanes is, from our

perspective, very positive.

Despite these positive steps, however, we remain concerned that the plans for bike

facilities are preliminary. The only direct mention of bike facilities in the Phase One

portion of the MEPA application posted online is as follows:

The Science Complex also will include a wide landscaped area supporting a pedestrian/bicycle

pathway to the west of the Science Complex called Academic Way, further described in the

Supplemental narrative.


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We do not know specifically what bike facilities will be created outside Academic Way.

Now is the perfect opportunity to build the strongest feasible bike connectivity

between the Cambridge and Allston campuses, and between the Allston campus and

regional transportation systems. The Science Complex alone will increase traffic

between Cambridge and Allston by foot, by bike, by bus, and by motor vehicle. Good

bike connectivity will help reduce demand for travel by car. Opportunities may exist to

link Allston with other regional transportation initiatives.

We do not see the Science Complex as a small matter. At the presentation on the

evening of August 23 at Spangler Hall, Harvards representatives pointed out that the

Science Complex alone might not have triggered MEPA review. We do not see that as a

reason to grant a Phase One waiver lightly, as transportation is fundamental to the Allston

campus as a whole, and the facilities built as part of the Science Complex may tend to set

the tone for the campus as a whole. A Phase One Waiver will end review by MEPA of

the Science Complex.

In conclusion, we ask that you consider carefully whether the Science Complex

plans at this stage are sufficient to guarantee a level of bike facilities that is in the best

interests of bikers and non-cyclists alike.

Thank you for your consideration.

Yours sincerely

Catharine Hornby

Secretary, Cambridge Bicycle Advisory Committee


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September 7, 2007

Secretary Ian A. Bowles, MEPA,Attn. Briony Angus EEA #14069,100 Cambridge Street, Suite 900,Boston, MA 02114


I am writing to comment on Harvard Universitys Plan for Harvard in Allston (draft),Executive Summary, January 2007 and their Institutional Master Plan notification form,both posted to their project web page. In the interests of full disclosure, I was a designconsultant with Goody Clancy for the BRA and helped to shape the North AllstonNeighborhood Strategic Plan. Earlier, as a consultant to the MDC, I produced theCharles River Basin Master Plan with the park staff. As a Harvard student in the 70sand 80s and later as a consultant I have thought about this area for years. I was notaware of the deadline for MEPA comments until very recently and, therefore, will keepmy comments brief and focus on one aspect of the proposed plan: access to openspace for the existing neighborhood and future academic community. The central pointI would like to convey is this: it is in the interest of all Allston stakeholders toestablish direct and safe pedestrian links to Herter Park - the central park of theCharles River Basin. Such a move would unlock over a mile of riverfront and open upacres of open space to community use. This goal is explicitly laid out in the CharlesRiver Master plan and the North Allston Neighborhood Strategic Plan and is broadlysupported within the North Allston community. The institutional master plan makes agesture in this direction but falls short of achieving this important neighborhood goal.

The bird's eye view of the proposed institutional master plan - with the Charles Riverand green athletic fields in the foreground, downtown Boston in the distance, andHarvard Square off to the left - paints a lovely picture but also points out a currentweakness in the plan: it fails to fully engage the existing North Allston neighborhoodand knit together the neighborhood and the nearby open space. The campus planfocuses inward to a large extent even at the Charles River where Soldiers Field road isdepressed and covered. Extending future student housing along the river and puttingthe parkway underground is a compelling and even visionary idea but one that doeslittle to improve the lives of North Allston residents. I hope Harvard will pursue this bold


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September 7, 2007

Secretary Ian Bowles

Executive Office of Energy and Environmental Affairs


Boston, MA 02114

RE: Expanded Environmental Notification Form

Harvard Allston Campus 20-Year Master Plan

MEPA N. 14069

Dear Mr. Bowles:

We have reviewed the EENF for the Harvard University 20-Year

Master Plan, comprising an overview of the universitys proposed

developments in the Allston neighborhood of Boston. The EENF

requests a MEPA Phase One Waiver for the Science Complex Projectin Allston, which would allow the MEPA review for the complex to

move ahead of the MEPA review of the Master Plan.

Process Concerns

As expressed by many of the people who spoke at the MEPA meeting

held on August 23rd in Allston, WalkBoston feels that the speed

and timing of the EENF, including the proponents request for a

Phase I waiver is an unfortunate element of the review. While

there has been extensive interaction between Harvard and the

community about the Master Plan, this timing and speed of this

filing seemed to catch almost everyone off guard. In particular,

granting of a Phase I waiver request depends on compliance withseveral criteria including the availability of ample and

unconstrained infrastructure, a criterion that is difficult to

assess without more detailed information.

Initial Reactions

Our review of the Harvard Allston Campus 20-Year Master Plan and

the MEPA Phase One Waiver for the Science Complex raised several

overall questions concerning the pedestrian environment, open

spaces, parking and proposed changes in traffic patterns that

will affect pedestrians. We began with an examination of The Plan

for Harvard in Allston (Draft) Executive Summary, January, 2007-

a precursor to the EENF that is the subject of the currentanalysis. We used this document extensively as a guide to the

proposed evolution of the Allston campus and proposals that

affect the Science Complex. We also used the Science Complex DPIR

for details of that project. We wanted to see if we understood

the details of the Science Complex and their effects on


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pedestrian facility planning for the initial project. We also

wanted to see to what extent the Science Complex, if built

according to the current plans, will guide the Master Plans

subsequent developments, and whether the Master Plan might be

changed if the proposal for the Science Complex did not come

about.

We agree with the overall goals of the January 2007 Executive

Summary of the Plan for Harvard in Allston with respect to place

making. We agree with the goal of a shared urban campus/community

environment that offers more open green space and improvements to

streetscapes. We think it wise to make Western Avenue an active

urban boulevard. We agree with the notion that a network of

campus green space can help integrate academic development with

civic, neighborhood and public functions.

Furthermore, we agree with the transportation framework that

seeks a diverse, inter-connected system of memorable andaccessible places, each having a specific function and a distinct

identity. We think positively about the proposed open space

hierarchy of core open spaces as focal points for recreation and

relaxation, courtyards within building groupings (such as the

Science Complex), and generously landscaped paths that connect

all of these open spaces, so that one can walk internally from

any place on campus to any other and to Barrys Corner by

crossing only one or two streets.

General conclusions:

1.The Harvard Allston Science Complex and the Harvard AllstonCampus 20-year Master Plan are intertwined and highlyinterrelated. The Science Complex appears to set policy for

many aspects of the Master Plan as it affects pedestrians. Yet

the Master Plan does not include the pedestrian policies that

appear to be emerging from the plan for the Science Complex.

2.There is little documentation that existing transportationinfrastructure facilities and services are ample and

unconstrained in support of the Science Complex Project, as is

required for a waiver. There is also little documentation that

proposed improvements that are part of the Science Complex

will mitigate the impacts on several of the streets that serve

the area.

Questions to be Addressed:

The proposed Harvard Allston Science Complex marks thebeginning of development of 200 acres in the City of Boston.

Is this project intended to serve as the mechanism to detail

pedestrian paths and walkways for the whole district covered


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by the Master Plan?

Designs for the Science Complex suggest a hierarchy ofpedestrian facilities along two major streets, a collector

street, a greenway, a local street, a park and an interior

courtyard. Does the Master Plan envision a hierarchy of

pedestrian facilities (similar to its hierarchy of streets) to

reflect the differing functions and designs of walkways along

major and minor streets and off-street facilities such as

greenways and courtyards?

Does the Master Plan envision a hierarchy of bicycle routesthat is different from the hierarchy of pedestrian facilities?

How will bicycle facilities be separated from pedestrian

facilities?

Will the Master Plan include design standards for pedestrianfacilities along streets widths of sidewalks, space for

landscaping and street furniture, etc.? Will there be

different design standards for off-road paths in the

pedestrian facility hierarchy? Will there be design standards

for bicycle ways?

The Science Complex sets a precedent for pedestrian andbicycle routes at the edges of a Master Plan development area

where buildings surround an interior courtyard. Will the

courtyard be reserved for pedestrians, as in Harvard Yard?

Will this guiding principle be extended throughout the areas

covered by the Master Plan?

Will separate walking and bicycle paths be provided throughoutthe area covered by the Master Plan?

Will the Master Plan provide for off-road (as opposed tostreetside) pedestrian paths with connections to the Charles

River, into the residential community, and to the proposedBarrys Corner retail area?

Will the Master Plan include details for institutingpedestrian access from the Science Complex and other locations

within the 200 acres to the existing river crossings at the

Anderson Bridge, the Weeks Footbridge and the Western Avenue

Bridge? How can pedestrian access to each of these bridges be

improved?

Will the Master Plan include guidelines and examples forconnections between sidewalks and the riverside walkways at

each bridge? This is especially important at the difficult

pedestrian crossings of Soldiers Field Road/Storrow Drive on

Western Avenue and at North Harvard Street. Will the Master Plan include details for a connection between

the campus and Allston neighborhoods to the Charles River

parklands west of the stadium area? Can the proposed extension

of Stadium Way pass over Soldiers Field Road as a footpath to

the spacious riverfront parkland that is currently difficult


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to reach from either the Allston residential neighborhoods or

the Master Plan additions to the Allston campus?

What is the relation of the city-owned Smith Park to theMaster Plan? Are there methods of integrating this park more

completely with the Master Plan, perhaps with walking paths

and integration of the ball fields with the large riverfront

park on the opposite side of Soldiers Field Road?

Are the proposed coverings of Soldiers Field Road on the northside of the Master Plan area intended to provide additional

riverfront parkland and access to users of structures in the

development areas centered on Western Avenue? Cant users of

the Master Plan areas get to the Charles River parklands more

efficiently via Western Avenue or the proposed footpath

extension of Stadium Way? How would the Master Plan insure

that the riverfront adjacent to the north side of the Allston

campus feels like public open space and not like the front

yard for new undergraduate housing developments?

Will traffic calming features be part of the Master Plan? Willthere be guidance for design of street rights of way and

intersections, including curb extensions at major

intersections, street trees, curbside parking or mid-block

crossings?

Will the Master Plan include guidelines and examples for theanalysis of pedestrian activity, such as the level of service

at intersections for pedestrians, and prospective signal

timing to maximize pedestrian crossing times?

Will the Master Plan provide guidelines and examples forpaving materials in sidewalks to include flat surfaces for

mobility-impaired pedestrians and for wheelchairs?

How will the Master Plan include incremental changes intransit service, routings, stops and nodes that will need to

be modified to meet demand as the Master Plan is carried

forward?

Will the Allston Campus meet the level of non-auto access thatis achieved by the Cambridge campus? As reported in Harvards

2006 Parking and Transportation Demand Management report,

Approximately 85% of employees commute to campus using

alternative modes of transportation (public transit,

bicycling, walking) an increase of 2% over 2005. (Source:

http://www.upo.harvard.edu/Reports/ptdm.html).

Can public access to shuttle services be provided by Harvardand MASCO?

How will commercial activities located along Western Avenue,North Harvard Street and Stadium Way be related to the

proposals for retail areas in Barrys Corner? How will these

activities relate to the hierarchy of Harvard Allston major

and minor street sidewalks, bicycle ways, greenways and


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courtyard pedestrian walkways?

What are the ample and unconstrained transportation facilitiesand services that support the Project in the event a Phase I

waiver is granted? Will most of the burden of providing

vehicular access to the site fall on Western Avenue? What

about the need for improvements on North Harvard Street? If

so, to what extent will these two streets be reconstructed to

handle the demand for vehicular travel as well as pedestrian

movement in the initial phase of development?

Thank you for the opportunity to comment on this EENF. Please

feel free to contact us for clarification or additional comments.

Sincerely,

Wendy Landman Robert Sloane

Executive Director Senior Planner


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FW: MEPA comment letter from Allston Brighton CDC

Ava Chan

Below please find Allston Brighton CDC's MEPA comment letter.

From: Ava ChanSent: Friday, September 07, 2007 12:55 PMTo: '[email protected]'Subject: MEPA comment letter from Allston Brighton CDC

Briony Angus

Environmental Analyst, MEPA Office

Executive Office of Energy and Environmental Affairs


Boston, MA 02114

RE: EEA# 14069

Dear Ms. Angus:

The Allston Brighton Community Development Corporation is writing torequest that you deny or approve with conditions Harvard University'srequest for a partial waiver of a mandatory EIR review threshold that

would allow the proponent to proceed to Phase I of the project prior topreparing an EIR.

You are in receipt of an Expanded Environmental Notification Form (EENF)that has been submitted to the Massachusetts Environmental Policy Act(MEPA) office for Harvard University's Science Center Project EEA#14069. This form includes Harvard University's 20-year Master Plan ENFfor the development of its campus in Allston. This plan reflects minorupdates of the Allston Campus Institutional Master Plan NotificationForm issued by Harvard University to the Boston Redevelopment Authorityin January, 2007 as well as material from the Science Center DraftProject Impact Report which Harvard University submitted to the City inJune, 2007.

It is our contention that contrary to MEPA policy and regulations, theScience Center Project represents a segmented review process. Harvard'srequest for a waiver allows them to bypass the necessary review ofissues of State and regional importance. These issues come under thejurisdiction of the MBTA, Massachusetts Turnpike Authority, DEP, EOTC,amongst other agencies. If the waiver is approved strong conditionsshould be placed on Harvard, to ensure that the State government doesnot abdicate its responsibility to ensure that damage to the environmentwill not take place.

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Harvard University maintains that their Master Plan and the ScienceCenter DPIR are consistent with the City's plan for the area and havebroad support in the community. To the contrary, Harvard's Master Planand Science Center project are not in conformance with the North AllstonStrategic Framework Plan ("NASFP"), which was prepared by the City'sconsultant with the participation of the Mayor's Task Force and HarvardUniversity in 2005. As the Science Center is a key "Building Block" inHarvard's over-all master plan, its segmented development will prevent

key aspects of the NASFP from being implemented. As a key buildingblock, it will establish a precedent for future development, which willbring undue harm to the community.

We have enclosed various documents to demonstrate the following:

1. There are significant transportation, construction, urbandesign, open space, and infrastructure environmental impacts from PhaseI, which have not been addressed. Only by segmenting this project, doesHarvard University avoid exceeding numerous thresholds for MEPA reviewin this 4 to 5 million square foot development project.2. Ample and unconstrained infrastructure and services do NOT existto support Phase I without substantial off site improvements, which needCity and state approvals.3. The project is NOT severable. Its implementation will requiresubstantial additional changes in infrastructure, roads, transit, openspace, parking in future phases, which will further undermine theFramework Plan.4. By permitting a segmented process, MEPA will abdicate itsresponsibilities to properly manage the environmental review for a 4 to5 million square foot, 20 year development project. Instead, MEPA willrely on the segmented review process under Article 80B of the BostonZoning Code to assure State agencies, such as the MBTA, theMassachusetts Turnpike Authority, EOTC, and DEP, to have control overthe review of future phases.

MEPA approval without conditions of a waiver request at this time will

seriously undermine North Allston North Brighton's ability to shapeHarvard's growth in a manner which builds a stronger community as wellas educational and research institution. The proposed super block siteplan of institutional uses is totally at variance with current zoning,the street layout and mixed use vision for North Allston North Brightonas noted in extensive comments from the BRA, City Agencies and thecommunity.

The Boston Civic Design Commission (BCDC) and the BRA Planning andDesign Department have noted at a Allston Task Force Meeting as recentlyas August 6, 2007 that "the BRA planning staff and the BCDC are focusedon the broader context that surrounds the Science Complex and how itwill relate to Harvard's future development...the Commission shares the

concerns that the community has voiced."

If any delays in the review process are assumed to cause HarvardUniversity undue hardship, one has to acknowledge that theresponsibility rests with the University. The Allston Task Force andthe City have been working with Harvard since 1996. The North AllstonStrategic Framework Plan was approved by the BRA in May 2005. Harvardhas chosen to ignore this plan and develop its own plan, which hasconsistently been opposed by large segments of the community.

We request that you delay granting a waiver request until such time as




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Harvard's Science Center Plan can be modified in conformance with theFramework Plan and the input of the BCDC, BRA Planning and Design staff,and the proposed Citizen Advisory Committee which you would establish.

Documentation in support of ABCDC position opposing granting of a Waiver

Following are more detailed comments, which contradict the Findings byHarvard University in support of their request for a Phase I waiver as

noted in the Harvard University 20 Year Master Plan, pages 3-122 through3-125.

1. There are significant transportation, construction, urbandesign, open space, and infrastructure environmental impacts from PhaseI, which have not been addressed. Only by segmenting this project, doesHarvard University avoid exceeding numerous thresholds for MEPA reviewin this 4 to 5 million square foot development project.

As Kairos Shen, Director of Urban Design and Planning at the BRA statedat a Harvard Allston Task Force Meeting on August 7, 2007, "the planningstaff feels very strongly about building public streets and avoiding asuper block".

The Science Center impacts are precedent setting and extremelysubstantive. Harvard and their consultants have done their best tominimize the impacts by segmenting the project and making assertions,which cannot be supported:

* Traffic impacts have been minimized below threshold levels byexcluding the traffic from WGBH when these cars are still in the areaonly at a site, which is less than one mile away.

* Trip Generation estimates are based on the use of a singleland use code for a Research and Development Center, which does notadequately describe the population that will be located at the Science

Center. Furthermore, it is quite likely that Harvard has greatlyunderstated the population which will occupy this facility as labresearch personnel occupy less than one half the 400 sq feet peremployee assumed by this proposal.

* By segmenting this project Harvard is not acknowledging theadditional one million square feet of science center developmentincluded in the Institutional Master Plan and the additional parkingthat it will require.

* Assumptions about modal split and the parking needs ofemployees are based upon wishful thinking and have little relationshipto current parking demand by faculty in North Allston. Seventy-two

percent of the Business School Faculty in Allston currently drives towork.

It is clear from Harvard's response in the DPIR to the community'scomments that most of the pertinent issues raised by the community havenot been addressed adequately by Harvard and their consultants. Asummary which highlights the inadequacy of Harvard's response to ourconcerns as well as those of local residents and public agencies isattached in the review of the eight key topics of the DPIR which we haveprepared and handed out to Task Force members at recent public meetings:(1) Project Description and Environmental Protection (2) Transportation




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and Construction, (3) Sustainability/Urban Design, and (4) HistoricResources/Infrastructure.

2. Ample and unconstrained infrastructure and services do NOT existto support Phase I without substantial off site improvements, which needCity and state approvals.

The MBTA bus service and the private shuttles are inadequate to address

projected demand. Furthermore, the infrastructure improvements are notminor improvements. They must be sized to address future demand and beplanned in accordance with a street network, which has the approval ofthe BRA, the City Transportation Department, Public ImprovementCommission, and the BWSC. None of these agencies have given favorablecomments to Harvard's plans.

3. The project is NOT severable. Its implementation will requiresubstantial additional changes in infrastructure, roads, transit, openspace, parking in future phases, which will further undermine theFramework Plan.

The BRA noted at the August 6, 2007 Task Force meeting that it is not

clear "how much of the project is really considered on the site; thetrapezoid boundary of the Science Complex site. Harvard has a proposalfor 'off-site' improvements..."

Issues of street layout, public access, connections to open space,pedestrian, bike and stormwater systems have not been resolved. TheCity wants public streets and a site plan with connections to adjacentareas. Harvard has proposed an extension of their campus, a privatestreet system, and a super-block plan, which excludes the community.

4. By permitting a segmented process, MEPA will abdicate itsresponsibilities to properly manage the environmental review for a 4-5million square foot, 20-year development project. Instead, MEPA will

rely on the segmented review process under Article 80B of the BostonZoning Code to assure State agencies such as the MBTA, the MassachusettsTurnpike Authority, EOTC, DEP, that they will have control over thereview of future phases.

MEPA should take note that the State has failed to get HarvardUniversity to produce a schedule of future filings, which address, in acomprehensive fashion, regional impacts on transportation,infrastructure, and economic development. Why, for example, should thiswaiver be granted when EOTC, working with Harvard University since2004, has failed to produce a required study of the local and regionalimpacts of Harvard's purchase of Allston Landing South? Issues of railaccess, Urban Ring Service, a commuter rail station, continued freightservice, connections to the local street system were to be addressed.This study has yet to be produced and reviewed by the State, the City,or the Allston Brighton community.

Respectfully submitted,

David G. Evans

President, Board of Directors

Allston Brighton Community Development Corporation




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EEA file #14069

Robert Alexander

Dear Ms. Angus and Secretary Bowles:

We are homeowners who have resided in Allston for 60+ years and are writingto request an extension to the Harvard University waiver to beginconstruction on the proposed Western Avenue science center before a completeenvironmental impact review is compiled for the entire Allston campusproject. We understand the deadline for community comment is September 7and given the enormous amount of information to review, we feel that thisdeadline is completely inadequate. Please do not rush through this processand give in to various pressures from city, state, federal agencies andHarvard University to permit this construction without fully realizing howthe neighborhood will be affected in terms of air and noise quality, traffic

congestion, and river pollution. The affects of this construction will bedistributed over a wider area than just the actual science center site andthe whole picture should be taken into careful consideration.

We understand North Harvard Street will undergo construction for Nstar andother utilities to be connected to the new science site. We strongly urgethat the present tangle mass of leaning poles with cables and wires be movedunderground in conjunction with the new connections being made undergroundto the science center. These cables present a serious danger to the public.Just last fall, one of Harvards own students was struck down and

seriously injured by a cable that snapped when it was pulled down by atruck. This occurred right in front of our house and pictures were taken ofthe accident. At the time, we did not realize who the student was becausehe was unconscious and taken away by ambulance to the hospital. He later

contacted us for information about his accident, in which he was left withmemory loss, some physical problems had to have about 20+ stitches in hishead. Attached are photos of the cable and damage done to cars andproperty along North Harvard Street as a result of the cable being draggedby the truck. Also attached are photos of dirty air pollution that settleson our window sills from the buses, diesel trucks and the poor air qualitythat we breathe and live with on a daily basis. This is taken from newreplacement windows we installed in our home. This is the amount ofpollution that accumulates in just one week. It is similar to coal miningdust.

As part of a community benefit to the Allston neighbors for living with allthe disruption of Harvard construction for the next 20-50 years, placing the

overhead wires and cables underground while North Harvard Street is underconstruction would be a major improvement to our community.

With regard to other detriments that will occur at the science center site,the noise level is impossible and the foul odor is dreadful. An ordinaryhomeowner does not have the technical capacity to record these things. Werecall from the construction of One Western Avenue and the Spangler Centerat the Harvard Business School, how bad it was. The construction engineerfrom Harvard said that chemicals can be added to the soil to alleviate theterrible smell, but it did not work previously.

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There are many other concerned neighbors and agencies such as the CharlesRiver Conservancy that fear this project is being rushed through withoutcareful consideration. We ask that you please help us.

Sincerely,

Paula and Robert Alexander226 North Harvard Street

Allston, MA 02134email: [email protected]

_________________________________________________________________Now you can see troublebefore he arriveshttp://newlivehotmail.com/?ocid=TXT_TAGHM_migration_HM_viral_protecti...

DSCN1036.JPG524K ViewDownload







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MEPA comment letter.

[email protected]

Dear Secretary Bowles and Ms. Angus,

I am writing to you today to voice my opposition to granting the Phase1 Waiver requested by Harvard University for their planned sciencecomplex in North Allston.

The university claims that it qualifies for such a waiver, that thescience center project is severable, and that the presentinfrastructure can support it. It is incredible to me that Harvard canclaim that what is essentially the anchor of a largely undiscloseddevelopment plan for a new branch of a campus is somehow severable,and also insist that its impacts will not be a crippling burden on the

surrounding area's infrastructure.

Harvard's LEED Gold Certification propaganda is a wonderfuldistraction from the issues at hand that it hopes will be overlooked.LEED is bought and is far from perfect, the highest standard beingPlatinum.

But the hollow PR prestige of a LEED rating won't help such problemsas the traffic issues, the dust, noise and the rodents fromconstruction, our over-burdened roads, light pollution, noisepollution, or the influx of construction workers, Harvard employeesand students who are parking in North Allston in increasing numbers.

Harvard has full-time professionals and many many months dedicated toproducing the volumes of material that it has given to residents toreview who are giving their time and energy after long work-days whatseems an intentionally short period of time while rejecting requestsfor extensions.

A full review of the Allston plan and a full environmental review ofthe impacts of the science center must be allowed to take place beforethey can be allowed to proceed.

Again, please do not grant Harvard a Phase 1 Waiver!!

Respectfully Submitted,

Tamara Bonn

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6 September 2007

Secretary Ian A. Bowles

MEPA, Attn. Briony Angus EEA #14069


Boston MA 02114

Dear Secretary Bowles:

LivableStreets Alliance appreciates the opportunity to comment on Harvards Expanded

Environmental Notification Form for the proposed long-term development of the

North Allston Campus as well as Harvards application for a Phase One waiver for

the Science Complex. Though preliminary information regarding transportation and the

public realm has been provided to the public by Harvard University, details are lacking and

are too vague to make a reasonable determination at this stage. This project, involving

about 200 acres, is too important to allow important details to go un-reviewed prior to

approval. We therefore urge you not to grant final approval to either of these

requests until additional details are provided to MEPA and the public.

Changes to the streetscape and public realm as a result of Phase One will be permanent.

Therefore, without additional detail, it is not possible to make the determination that the

potential environmental impacts of phase one, taken alone, are insignificant, according to

301CMR11 11(4)(a). According to the ENF submitted by Harvard, vehicle trips per day

will ride from about 1,000 to over 4,000 a significant increase that warrants detailed

environmental analysis and adequate mitigation. In addition, it is clear that the roadway

infrastructure is severely constrained, and none of the transportation infrastructure is

ample to meet any of the transportation needs, as required by 301CMR11 11(4)(b)ample and unconstrained infrastructure facilities and services exist to support phase

one.

Various documents submitted to the Boston Redevelopment Authority (BRA) regarding

transportation and public spaces have supported improved access to the Harvard Allston

campus by various modes and to mitigate the impacts of the project by improving the


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Mr. Bowles, Re: EEA #14069 Harvard/Allston Science Center6 September 2007Page 2

public realm. LivableStreets Alliance agrees with the overall goals stated in the 2007 Executive Summary

of the Plan for Harvard in Allston. Harvard is touting this as a premier sustainable project while there is

enormous depth to the details of building design, the transportation planning is conventional at best. A

comprehensive sustainable transportation plan is needed to mitigate the negative environmental impactsof this development.

To evaluate Phase One of this project from a transportation perspective, a detailed understanding of how

this phase will fit into the Master Plan is need, but is lacking. The Master Plan does not provide adequate

details, in the following categories: (1) A transportation plan for the future of transit in the area (including

bus, rapid transit, commuter rail) with clear strategy for connecting to regional transit initiatives; (2) a

detailed bicycling master plan, pedestrian master plan, and discussion of the relationship between

bicyclists and pedestrians; (3) streetscape design standards (including bicycle and pedestrian

accommodation, paving materials, improved accessibility through Universal Design concepts, intersection

design, signal timing, landscaping, vehicle design speed, traffic calming measures); connectivity to

greenspace and openspace (e.g., Charles River paths). Phase One will significantly impact the remaining

development. Designs for the much of the above for Phase One will set the tone and direction of future

development. Academic Way is a critical piece of an off-road network, yet connectivity details are yet to

be developed.

It would be shortsighted to move forward with such a large development without having a broader

transportation and public space plan; otherwise the development will preclude options and better

decisions in the future. The future of environmental protection includes the reduction of single-occupancy

vehicle trips. This can only be accomplished by developing a comprehensive transportation plan andattending diligently to the public realm, including the development of quality public spaces as it pertains to

creating a dynamic urban environment, to maximize its use by pedestrians, bicyclists, and transit users

and minimize dependency on the motor vehicle.

Please feel free to contact us to discuss any of our comments in greater detail.

Sincerely,

Charles Denison Jeffrey L. Rosenblum, PE

Board of Directors Executive Director

LivableStreets Alliance LivableStreets Alliance


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September 6, 2007

Secretary Ian A. BowlesEOEA, Attn: MEPA OfficeBriony Angus, EOEA No. 14069

100 Cambridge Street, Suite 900Boston MA 02114

Re: MEPA Public Comment on Harvard Master Plan / Science ComplexEOEA No. 14069


I am writing to you in opposition to Harvard University's request for a waiver of full environmentalimpact review by MEPA.

I find the following relevant issues to be lacking in Harvard's proposal to build the science complex andtheir request for the MEPA waiver:

1. The science complex proposal is lacking in significant improvements to the public realm.Pedestrian and especially bicycle access throughout the bordering regions in North Allston isawful. I am a bicycle commuter who often must travel through the neighborhood, and I fear itevery time. Too many intersections are dangerous and too many street surfaces are in dangerouscondition for night-time commuting. Public access (bicycle and pedestrian) from North Allston tothe Charles River is sketchy at best (Larz Anderson Bridge), and outright hazardous at worst(Cambridge Street). The Charles River is a beautiful resource which should have improvedaccess as a result of their project, but Harvard has submitted no plan for it. Finally, the sciencecomplex has afundamental design flaw: the green space is in a private, enclosed space encircledby four buildings, rather than being an inviting space; maintaining this closed design can only bemitigated by guarantee through deed restriction of open space, comparable in size, in a nearby site(of which Harvard has many!).

2. The traffic/transportation infrastructure required by Harvard for their site is already over-taxed and cannot support added usage. Harvard's own analysis shows that 38% of theirmorning/evening commuting vehicles will pass through the Cambridge Street / Storrow Drive /River Street Bridge intersection, yet that intersection is currently rated a level-of-service F withapproximately 25,000 vehicles using it daily. Harvard's project (both construction and steady-state usage) will heavily over-burden this intersection, requiring additional study. Otherintersections offering access into North Allston also have poor levels-of-service (C through

F). These must be studied in detail, and a plan in place to improve them prior to approval ofHarvard's proposed project. Many of Harvard's employees will be using MBTA bus #66, which isalready one of the most over-used bus routes in the city; Harvard's argument that travel will onlybe counter-commute is incorrect, since most of their employees will be commuting from home,not from Harvard Square. An independent, peer review of traffic/transportation, paid for by thedeveloper, should be required to assess the project's impact.

3. Need for an alternate access to the route for construction vehicles. Harvard owns neighboringproperty that they could use for construction vehicle access which would not overburden StorrowDrive a parkway on a regional natural resource, the Charles River. Harvard can do it with their


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own property, so further study should be required.

4. Rodent control program is needed for the construction phase of the project. Allston-Brightonalready has a serious rodent problem that verges on a dangerous public health situation. Harvardshould be required to study their project thoroughly to put forward an intelligent rodent controlprogram.

5. Underground streams should be examined. North Allston has a number of natural streams thatwere historically put underground. Harvard should be required to examine the impact of theirdevelopment on these waterways, including studying the possibilities of daylighting one ormore of them.

6. Enforcement. Independent, dedicated enforcement officers are needed to ensure thatenvironmental damage is minimized and that Harvard implements all agreements. Suffice it to saythat Harvard has received bad press recently due to their failure to implement agreements made adecade ago.

7. Segmented, rather than comprehensive, planning. Contrary to MEPA policy and regulations,

Harvard's science complex proposal represents a segmented review process. Harvards requestfor a waiver allows them to bypass the necessary review of issues of State and regionalimportance. These issues come under the jurisdiction of the MBTA, MTA, DEP, EOTC, amongothers.

As a result of these weighty and unresolved issues, I request that you require a full environmental impactreview of Harvard's proposed science complex and their institutional master plan.

Sincerely,

Dr. Michael Pahre

76 Foster StreetBrighton, MA [email protected]
mailto:[email protected]:[email protected]


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Alex Selvig Harvard/MEPA Letter

Alex Selvig

Alessandro (Alex) SelvigCandidate, Boston City CouncilDistrict 9, Allston-BrightonPO Box 35755Brighton, MA 02135

Secretary Ian A. BowlesEOEA, Attn.: MEPA OfficeBriony Angus, EOEA No. 14069100 Cambridge St., Ste. 900Boston, MA 02114


I am writing to voice my opposition to granting a Phase 1 Waiver asrequested by Harvard University for their planned science complex inNorth Allston.

As presented, the university plan would not qualify for such a waiverunder the current, established guidelines. The environmental impactsdirectly or indirectly caused by the Science Complex are far frominsignificant, and the existing infrastructure is certainly not ampleand unconstrained.

Examples of this include, but are by no means limited to, the

following:

According to the DPIR compiled and provided by Harvard, windscreated by the proposed buildings will exceed BRA maximum levels.Several other issues exist in the DPIR.

Traffic in a large area will be severely disrupted. It shouldbenoted that the Boston Transportation department has disagreedpubliclywith Harvard's mode share numbers.

Quality of life for abutting residents will be severely

impacted dueto noise, air pollution, debris, rodents and other factors associatedwith construction of such enormous scale.

Groundwater, drainage and aquifers, some feeding into theCharlesRiver, may be adversely affected by release of materials andpollutants currently on site or commonly used in the constructionprocess, or by changes in their natural courses.

Existing infrastructure at the Massachusetts Turnpike exit for

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Allston-Brighton is grossly inadequate for normal traffic. Theaddition of several hundred large construction vehicle trips at theseseverely stressed points will have a devastating, negative effect ontransportation.

This project is highly complex, and Harvard has failed toconclusivelydemonstrate that it meets the criteria for granting the Phase 1

waiver. Detailed, deliberate, meticulous planning must be carried outin order to definitively protect the residents and the environment inthe vast area impacted.

A full review would be the only prudent, responsible, and reasonableway to work towards a positive end result.

Sincerely yours,

Alessandro (Alex) Selvig


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Fwd: Comments on Harvard Science Center, Allston

[email protected]

************************************** Get a sneak peek of the all-new AOL athttp://discover.aol.com/memed/aolcom30tour

[ Attached Message ]

Dear Ms. Angus,

I am writing to request that MEPA deny Harvard University's request for awaiver for the science building/complex they are proposing in Allston. Thisproject has been descried as a key element of the Allston campus, despite therequest to treat this as a severable project. Despite, the assertions intheir request, this project will have significant negative impact in thesurrounding neighborhood.

You have received comments from other neighbors that eloquently detail thecurrent situation we are managing in regards to traffic, pollution, rodentcontrol, and noise. The proposal will dramatically increase those problems.Any approval of this request should have such strict conditions that the needfor such a conditioned response indicates that this proposal is not ready forapproval by the various public agencies involved in the review process.

Harvard has submitted voluminous materials for review by a dedicated groupof local residents over the summer and has not allowed sufficient time toaddress the scope of the proposal and the many issues it raises. Requests fromthe task force they have worked with for years, residents and several localofficials have been dismissed. This response is quite concerning given the 50year plans and aspirations Harvard has for the Allston portion of theircampus.

Given Harvard's insistence on the current deadline, I would urge you to denythe request and allow an opportunity for a proper review of their entireplan for Allston.

Sincerely,

Karen Smith70 Athol St.Allston, MA 02134

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AllstonBrighton2006

From:[email protected]

To:[email protected]:Thu, 6 Sep 2007 22:28:36 EDT

Local:Thurs, Sep 6 2007 10:28 pmSubject:Comments on Harvard Science Center, Allston


harvard mepa comment letters

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