Harvard Mepa Comment Letters

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 will have 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

The Hon. Ian A. Bowles Secretary Executive Office of Environmental Affairs 100 Cambridge Street Suite 900 Boston, MA 02114 Attention: MEPA Office Briony Angus EOEA No. 14069 September 10, 2007 Dear Secretary Bowles, I am writing to both express concerns about Harvard’s proposed 20-year Master Plan for and also to express my strong opposition to the requested Phase One Wavier for the Science Complex. I am a lifelong resident of Brighton and a community leader who has spent more than 15 years representing my neighbor’s concerns on a range of issues. Specifically, I was appointed 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 hasn’t always been easy, we’ve 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 College understands 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 and vibrancy 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. Harvard’s complete disregard for the community is alarming. Issues of pollution and traffic congestion are real concerns and they are issues that will impact current residents, current students and future beneficiaries of the Science Complex alike.

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 Complex should 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 the legitimate 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 devastating lesson 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 University’s 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 don’t hesitate to contact me. Sincerely, Rosie Hanlon 172 Chiswick Road Brighton, MA 02135

September 7, 2007 Secretary Ian A. Bowles Executive Office of Energy and Environmental Affairs Attention: MEPA Office Briony Angus, EEA # 14069 100 Cambridge Street, Suite 900 Boston, 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 policy plan for the Boston metropolitan area, and MAPC’s Smart Growth Principles, as well as for their impacts upon the environment. MAPC has reviewed the Expanded Environmental Notification Form (EENF) for Harvard University’s 20 Year Master Plan and the Science Complex and submits the following comments. Please note that our review and comments are limited to those materials 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 lower greenhouse 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 537,000 square 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 a quadrangle-type park. New roadways are proposed. The building will aim for LEED Certification at the Gold Level. Special Review Procedure for the Master Plan The EENF notes that the proponent is favorable to undergoing a Special Review Procedure, which would entail the formation of a Citizen’s 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 a CAC 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 Richard A. Dimino, President

Gordon Feltman, Vice President

Grace S. Shepard, Treasurer

Marc D. Draisen, Executive Director

Jay Ash, Secretary

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 Interagency Study 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, and Watertown, 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 community’s diversity. Consultation with the Allston Brighton Community Development Corporation on CAC membership could help to achieve a diverse composition. Phase 1 Waiver Request for Science Complex Based on the information contained in the EENF, we cannot at this time support the proponent’s request 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 Complex’s needs, as required by the MEPA regulations in order to grant a Phase 1 Waiver. The planned shuttles to the Cambridge campus and the Longwood Medical area, along with 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 parking availability (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 city’s target of 59% single occupant vehicles or Harvard’s 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 and other locations nearby, but no roadway mitigation is proposed for Phase 1. Rather, there is an assertion, 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 in auto 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 as person 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 not appear 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 uses at 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 was not 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 does not 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 to the new WGBH location. Ian A. Bowles, Secretary, Executive Office of Energy and Environmental Affairs Re: Harvard University 20-Year Master Plan, Boston, EOEA # 14069, EENF

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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 many auto 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 “no new 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 other findings, 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 of the 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 adequate information 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 the Science Complex, Harvard proposes to replace an existing 36-inch storm drain pipe with a 72inch 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 pipe to 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 pipes with 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 a waiver. 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 Principles and MetroFuture As noted in the EENF, the conceptual Master Plan appears to be consistent with many aspects of smart growth and MetroFuture (MAPC’s 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 use development. • Sustainable building design, reduction in green house gas emissions, and aggressive water conservation. • 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 city’s linkage program. • Though not yet finalized, many of the mitigation measures and items included in the yetto-be-created community benefits agreement will likely include job training programs and other amenities for the community. As we mention below, we would like the proponent also to discuss consistency with MAPC’s Smart Growth Principles and the Commonwealth Sustainable Development Principles. Items to be Included in EIR Ian A. Bowles, Secretary, Executive Office of Energy and Environmental Affairs Re: Harvard University 20-Year Master Plan, Boston, EOEA # 14069, EENF

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Regional Impacts As mentioned above, the future of these 200 acres will provide regional benefits and have impacts beyond the city’s 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 the North 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 the EIR, specifically including the NASFP’s proposed street network and the river walk concept. The Charles River Watershed Association proposes a sub-watershed approach to storm water management 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 MAPC’s Smart Growth Principles as well as the Commonwealth’s Sustainable Development Principles. The MAPC principles can be found on our web site at: www.mapc.org/regional_planning/MAPC_Smart_Growth.html •

EOEA’s Environmental Justice maps indicate that the site is located in an area with Environmental Justice populations. The EIR should include demographic information and the proponent should clarify whether the project meets the threshold for Enhanced Public Participation.

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The EIR should explain who will finance the various improvements and who will build them. This includes all non-building improvements such as utility upgrades and extensions, new roadways, transit improvements, improvements to existing roadways (including Soldiers Field Road), storm water infrastructure and green space.

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Traffic impacts are likely to be felt on intersections in Cambridge, Brookline, and Watertown. 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 as Boston.

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Even with a goal of a 50% auto mode share for this campus, Harvard estimates they will add 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 they already 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 considering the 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 target and the additional mitigation steps that would be taken in that eventuality.

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

Ian A. Bowles, Secretary, Executive Office of Energy and Environmental Affairs Re: Harvard University 20-Year Master Plan, Boston, EOEA # 14069, EENF

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and a discussion of Harvard’s contributions to the capital or operations costs of these services as part of its mitigation responsibilities. •

Harvard has proposed covering and depressing Soldier’s Field Road as part of a plan to reclaim the riverfront for campus and community use. As a member of the Boston Region MPO, 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 and state 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.

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The EIR should clarify ownership of streetscape and infrastructure improvements. This applies to new streets, improvements made to existing streets, and all improvements constructed within public rights-of-way. This is particularly important in those cases where operation and maintenance of infrastructure is critical to mitigating environmental impacts (for example, street sweeping, maintaining sidewalks and street trees, etc.).

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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 at buildings. We would like to see more detailed maps showing connections to the river, and as 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.

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The Charles River Reservation is an important regional asset. In addition to our point above about ensuring access by the local community, the EIR should indicate how regional access to the reservation and river will be maintained and improved.

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The impacts to the historic character of the parkway system by placing a segment of Soldiers 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 to the Charles River, DCR’s parkway system is a unique regional amenity that defines the city’s and region’s roadway system. Placing the roadway underground seems contrary to the purpose of the parkways, and could ironically restrict views of the Harvard campus and the 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 also clarify if the land above the buried parkway would be publicly owned and accessible to all.

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The 20 Year Master Plan covers 215 acres and a number of buildings currently exist on this land. The EIR should provide information on what will occur in this area in the interim period – 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.

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We strongly support the use of LID techniques for minimizing storm water impacts and we are pleased that Harvard is committed to employing innovative methods. The EENF does state 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 on which 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 include the CRWA’s suggestion for “green streets” as further mitigation for storm water impacts.

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

Ian A. Bowles, Secretary, Executive Office of Energy and Environmental Affairs Re: Harvard University 20-Year Master Plan, Boston, EOEA # 14069, EENF

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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 living within 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 health experts 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. We urge 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 in the EIR.

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The City of Boston recently completed a Natural Hazard Mitigation Plan with assistance from 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 area subject 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 the buildings, the EIR should include measures to protect infrastructure – roadways, drainage pipes, electrical systems – which can be particularly vulnerable to damage.

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While we understand that the timing and phasing of construction is uncertain, the EIR should 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 some portion of the campus-wide benefits are phased in along with building construction.

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At the August 23 MEPA hearing, Harvard representatives noted that the use diagrams contained in the EENF indicate “anchor” uses. For example, Figure 2-2 indicates that land at Barry’s 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 EIR should elaborate/clarify which types of uses will be included in each area.

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

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The EIR should include the final community benefits agreement that is currently being developed as part of the BRA’s Article 80 process.

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Harvard should provide more detail on the campus / community interface (those buildings along 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 and provide 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 guidelines specific 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 be provided on this group including whether community members will have seat(s) on the Group. We feel that appropriate, neighborhood scale design along the perimeters can encourage pedestrian activity.

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

Ian A. Bowles, Secretary, Executive Office of Energy and Environmental Affairs Re: Harvard University 20-Year Master Plan, Boston, EOEA # 14069, EENF

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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 there is no net housing benefit to the community. •

The EIR should evaluate alternatives for construction-related traffic and outline impacts to residential neighborhoods and commercial areas. It is our understanding that the proponent 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 analyze whether using the rail yards would result in delays or added costs to the region’s freight transport and the MTBA.

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

Marc Draisen Executive Director cc:

Kairos Shen, BRA Thomas Tinlin, Boston Jeanne E. Richardson, BWSC Susanne Rasmussen, Cambridge Jeff Levine, Brookline Gregory P. Watson, Watertown

Ian A. Bowles, Secretary, Executive Office of Energy and Environmental Affairs Re: Harvard University 20-Year Master Plan, Boston, EOEA # 14069, EENF

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Cambridge, MA 02139 September 6, 2007 Secretary Ian A. Bowles MEPA, Attn. Briony Angus EEA #14069 100 Cambridge Street, Suite 900 Boston MA 02114 By email: [email protected] Dear Secretary Bowles, On behalf of the Cambridge Bike Committee, I am submitting comments with regard to Harvard’s Expanded Environmental Notification Form for the proposed Allston campus and Harvard’s related application for a Phase One waiver for the Science Complex. 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 sedentary lifestyles. 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.”

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, Harvard’s 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

September 7, 2007 Secretary Ian A. Bowles, MEPA, Attn. Briony Angus EEA #14069, 100 Cambridge Street, Suite 900, Boston, MA 02114

Dear Secretary Bowles, I am writing to comment on Harvard University’s “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 design consultant with Goody Clancy for the BRA and helped to shape the North Allston Neighborhood Strategic Plan. Earlier, as a consultant to the MDC, I produced the Charles River Basin Master Plan with the park staff. As a Harvard student in the 70s and 80s and later as a consultant I have thought about this area for years. I was not aware of the deadline for MEPA comments until very recently and, therefore, will keep my comments brief and focus on one aspect of the proposed plan: access to open space for the existing neighborhood and future academic community. The central point I would like to convey is this: it is in the interest of all Allston stakeholders to establish direct and safe pedestrian links to Herter Park - the central park of the Charles River Basin. Such a move would unlock over a mile of riverfront and open up acres of open space to community use. This goal is explicitly laid out in the Charles River Master plan and the North Allston Neighborhood Strategic Plan and is broadly supported within the North Allston community. The institutional master plan makes a gesture 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 River and green athletic fields in the foreground, downtown Boston in the distance, and Harvard Square off to the left - paints a lovely picture but also points out a current weakness in the plan: it fails to fully engage the existing North Allston neighborhood and knit together the neighborhood and the nearby open space. The campus plan focuses inward to a large extent even at the Charles River where Soldier’s Field road is depressed and covered. Extending future student housing along the river and putting the parkway underground is a compelling and even visionary idea but one that does little to improve the lives of North Allston residents. I hope Harvard will pursue this bold

initiative but more also needs to be done to create what Frederick Law Olmsted would term a “democratic landscape” shared by all. Fortunately such a democratic landscape is close at hand. In the foreground of the bird's eye view is Herter Park - the largest park within the Charles River Basin. Though isolated from North Allston by Soldiers Field Road, Herter Park still manages to attract a diverse group of visitors who drive in from Boston neighborhoods on warm summer days to picnic, rent canoes, and go to plays at the Publick Theatre. Sadly, Allston families living near by are cut off from this amazing resource by a high speed parkway. Future Harvard students will be as well. Only one poorly marked pedestrian bridge crosses this neighborhood barrier. It doesn’t have to be this way. There are two potential pedestrian paths serving the future campus and the neighborhood that, if built, would converge to cross Soldier’s Field Road at a critical location. The Harvard IMP picked up on an idea that I first developed in the North Allston Neighborhood Strategic Plan a few years ago with Goody Clancy: “Longfellow Walk.” This cross campus walk would connect the emerging campus right to the edge of Herter Park following the edge of the athletic fields. It would meet with another long neglected walk that runs along the edge of Smith field - the largest community park in Alston. It would be a simple thing to provide an at-grade cross walk at this point or, possible, a pedestrian bridge, to reach the broad fields of Herter Park. Longfellow Walk and Smith field hold the keys to unlocking access to Herter Park for the families and future students of North Alston. I urge the stakeholders to make this a priority and to explore a public/private partnership to help make it a reality. I along with many others believe that long time residents and academic newcomers can come together to make North Allston a more livable and vibrant place for all. Herter Park can provide common ground for these groups. Thank you for this opportunity to comment on the institutional master plan.

Herbert Nolan

September 7, 2007

Secretary Ian Bowles Executive Office of Energy and Environmental Affairs 100 Cambridge Street, Suite 900 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 university’s proposed developments in the Allston neighborhood of Boston. The EENF requests a MEPA Phase One Waiver for the Science Complex Project in 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 proponent’s 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 with several 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, 2007a precursor to the EENF that is the subject of the current analysis. 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

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 Plan’s 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 and accessible 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 Barry’s Corner by crossing only one or two streets.“ General conclusions: 1. The Harvard Allston Science Complex and the Harvard Allston Campus 20-year Master Plan are intertwined and highly interrelated. 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 transportation infrastructure 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 the beginning 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


























by the Master Plan? Designs for the Science Complex suggest a hierarchy of pedestrian 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 routes that 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 pedestrian facilities 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 and bicycle 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 throughout the area covered by the Master Plan? Will the Master Plan provide for off-road (as opposed to streetside) pedestrian paths with connections to the Charles River, into the residential community, and to the proposed Barry’s Corner retail area? Will the Master Plan include details for instituting pedestrian 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 for connections 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
























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 the Master 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 north side 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? Can’t 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? Will there 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 the analysis 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 for paving materials in sidewalks to include flat surfaces for mobility-impaired pedestrians and for wheelchairs? How will the Master Plan include incremental changes in transit 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 that is achieved by the Cambridge campus? As reported in Harvard’s 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 Harvard and MASCO? How will commercial activities located along Western Avenue, North Harvard Street and Stadium Way be related to the proposals for retail areas in Barry’s Corner? How will these activities relate to the hierarchy of Harvard Allston major and minor street sidewalks, bicycle ways, greenways and




courtyard pedestrian walkways? What are the ample and unconstrained transportation facilities and 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 Executive Director

Robert Sloane Senior Planner

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AllstonBrighton2006 FW: MEPA comment letter from Allston Brighton CDC Ava Chan Below please find Allston Brighton CDC's MEPA comment letter. From: Ava Chan Sent: Friday, September 07, 2007 12:55 PM To: '[email protected]' Subject: MEPA comment letter from Allston Brighton CDC Briony Angus Environmental Analyst, MEPA Office Executive Office of Energy and Environmental Affairs 100 Cambridge Street, Suite 900 Boston, MA 02114 RE: EEA# 14069 Dear Ms. Angus: The Allston Brighton Community Development Corporation is writing to request that you deny or approve with conditions Harvard University's request for a partial waiver of a mandatory EIR review threshold that would allow the proponent to proceed to Phase I of the project prior to preparing 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 ENF for the development of its campus in Allston. This plan reflects minor updates of the Allston Campus Institutional Master Plan Notification Form issued by Harvard University to the Boston Redevelopment Authority in January, 2007 as well as material from the Science Center Draft Project Impact Report which Harvard University submitted to the City in June, 2007. It is our contention that contrary to MEPA policy and regulations, the Science Center Project represents a segmented review process. Harvard's request for a waiver allows them to bypass the necessary review of issues of State and regional importance. These issues come under the jurisdiction of the MBTA, Massachusetts Turnpike Authority, DEP, EOTC, amongst other agencies. If the waiver is approved strong conditions should be placed on Harvard, to ensure that the State government does not abdicate its responsibility to ensure that damage to the environment will not take place.

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Harvard University maintains that their Master Plan and the Science Center DPIR are consistent with the City's plan for the area and have broad support in the community. To the contrary, Harvard's Master Plan and Science Center project are not in conformance with the North Allston Strategic Framework Plan ("NASFP"), which was prepared by the City's consultant with the participation of the Mayor's Task Force and Harvard University in 2005. As the Science Center is a key "Building Block" in Harvard's over-all master plan, its segmented development will prevent key aspects of the NASFP from being implemented. As a key building block, it will establish a precedent for future development, which will bring undue harm to the community. We have enclosed various documents to demonstrate the following: 1. There are significant transportation, construction, urban design, open space, and infrastructure environmental impacts from Phase I, which have not been addressed. Only by segmenting this project, does Harvard University avoid exceeding numerous thresholds for MEPA review in this 4 to 5 million square foot development project. 2. Ample and unconstrained infrastructure and services do NOT exist to support Phase I without substantial off site improvements, which need City and state approvals. 3. The project is NOT severable. Its implementation will require substantial additional changes in infrastructure, roads, transit, open space, parking in future phases, which will further undermine the Framework Plan. 4. By permitting a segmented process, MEPA will abdicate its responsibilities to properly manage the environmental review for a 4 to 5 million square foot, 20 year development project. Instead, MEPA will rely on the segmented review process under Article 80B of the Boston Zoning Code to assure State agencies, such as the MBTA, the Massachusetts Turnpike Authority, EOTC, and DEP, to have control over the 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 shape Harvard's growth in a manner which builds a stronger community as well as educational and research institution. The proposed super block site plan of institutional uses is totally at variance with current zoning, the street layout and mixed use vision for North Allston North Brighton as noted in extensive comments from the BRA, City Agencies and the community. The Boston Civic Design Commission (BCDC) and the BRA Planning and Design Department have noted at a Allston Task Force Meeting as recently as August 6, 2007 that "the BRA planning staff and the BCDC are focused on the broader context that surrounds the Science Complex and how it will 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 Harvard University undue hardship, one has to acknowledge that the responsibility rests with the University. The Allston Task Force and the City have been working with Harvard since 1996. The North Allston Strategic Framework Plan was approved by the BRA in May 2005. Harvard has chosen to ignore this plan and develop its own plan, which has consistently 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 the Framework 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 by Harvard University in support of their request for a Phase I waiver as noted in the Harvard University 20 Year Master Plan, pages 3-122 through 3-125. 1. There are significant transportation, construction, urban design, open space, and infrastructure environmental impacts from Phase I, which have not been addressed. Only by segmenting this project, does Harvard University avoid exceeding numerous thresholds for MEPA review in this 4 to 5 million square foot development project. As Kairos Shen, Director of Urban Design and Planning at the BRA stated at a Harvard Allston Task Force Meeting on August 7, 2007, "the planning staff feels very strongly about building public streets and avoiding a super block". The Science Center impacts are precedent setting and extremely substantive. Harvard and their consultants have done their best to minimize the impacts by segmenting the project and making assertions, which cannot be supported: * Traffic impacts have been minimized below threshold levels by excluding the traffic from WGBH when these cars are still in the area only at a site, which is less than one mile away. * Trip Generation estimates are based on the use of a single land use code for a Research and Development Center, which does not adequately describe the population that will be located at the Science Center. Furthermore, it is quite likely that Harvard has greatly understated the population which will occupy this facility as lab research personnel occupy less than one half the 400 sq feet per employee assumed by this proposal. * By segmenting this project Harvard is not acknowledging the additional one million square feet of science center development included in the Institutional Master Plan and the additional parking that it will require. * Assumptions about modal split and the parking needs of employees are based upon wishful thinking and have little relationship to current parking demand by faculty in North Allston. Seventy-two percent of the Business School Faculty in Allston currently drives to work. It is clear from Harvard's response in the DPIR to the community's comments that most of the pertinent issues raised by the community have not been addressed adequately by Harvard and their consultants. A summary which highlights the inadequacy of Harvard's response to our concerns as well as those of local residents and public agencies is attached in the review of the eight key topics of the DPIR which we have prepared 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) Historic Resources/Infrastructure. 2. Ample and unconstrained infrastructure and services do NOT exist to support Phase I without substantial off site improvements, which need City and state approvals. The MBTA bus service and the private shuttles are inadequate to address projected demand. Furthermore, the infrastructure improvements are not minor improvements. They must be sized to address future demand and be planned in accordance with a street network, which has the approval of the BRA, the City Transportation Department, Public Improvement Commission, and the BWSC. None of these agencies have given favorable comments to Harvard's plans. 3. The project is NOT severable. Its implementation will require substantial additional changes in infrastructure, roads, transit, open space, parking in future phases, which will further undermine the Framework 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; the trapezoid boundary of the Science Complex site. Harvard has a proposal for 'off-site' improvements..." Issues of street layout, public access, connections to open space, pedestrian, bike and stormwater systems have not been resolved. The City wants public streets and a site plan with connections to adjacent areas. Harvard has proposed an extension of their campus, a private street system, and a super-block plan, which excludes the community. 4. By permitting a segmented process, MEPA will abdicate its responsibilities to properly manage the environmental review for a 4-5 million square foot, 20-year development project. Instead, MEPA will rely on the segmented review process under Article 80B of the Boston Zoning Code to assure State agencies such as the MBTA, the Massachusetts Turnpike Authority, EOTC, DEP, that they will have control over the review of future phases. MEPA should take note that the State has failed to get Harvard University to produce a schedule of future filings, which address, in a comprehensive fashion, regional impacts on transportation, infrastructure, and economic development. Why, for example, should this waiver be granted when EOTC, working with Harvard University since 2004, has failed to produce a required study of the local and regional impacts of Harvard's purchase of Allston Landing South? Issues of rail access, Urban Ring Service, a commuter rail station, continued freight service, 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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AllstonBrighton2006 EEA file #14069 Robert Alexander Dear Ms. Angus and Secretary Bowles: We are homeowners who have resided in Allston for 60+ years and are writing to request an extension to the Harvard University waiver to begin construction on the proposed Western Avenue science center before a complete environmental impact review is compiled for the entire Allston campus project. We understand the deadline for community comment is September 7 and given the enormous amount of information to review, we feel that this deadline is completely inadequate. Please do not rush through this process and give in to various pressures from city, state, federal agencies and Harvard University to permit this construction without fully realizing how the neighborhood will be affected in terms of air and noise quality, traffic congestion, and river pollution. The affects of this construction will be distributed over a wider area than just the actual science center site and the whole picture should be taken into careful consideration. We understand North Harvard Street will undergo construction for Nstar and other utilities to be connected to the new science site. We strongly urge that the present tangle mass of leaning poles with cables and wires be moved underground in conjunction with the new connections being made underground to the science center. These cables present a serious danger to the public. Just last fall, one of Harvard’s own students was struck down and seriously injured by a cable that snapped when it was pulled down by a truck. This occurred right in front of our house and pictures were taken of the accident. At the time, we did not realize who the student was because he was unconscious and taken away by ambulance to the hospital. He later contacted us for information about his accident, in which he was left with memory loss, some physical problems had to have about 20+ stitches in his head. Attached are photos of the cable and damage done to cars and property along North Harvard Street as a result of the cable being dragged by the truck. Also attached are photos of dirty air pollution that settles on our window sills from the buses, diesel trucks and the poor air quality that we breathe and live with on a daily basis. This is taken from new replacement windows we installed in our home. This is the amount of pollution that accumulates in just one week. It is similar to coal mining dust. As part of a community benefit to the Allston neighbors for living with all the disruption of Harvard construction for the next 20-50 years, placing the overhead wires and cables underground while North Harvard Street is under construction 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 ordinary homeowner does not have the technical capacity to record these things. We recall from the construction of One Western Avenue and the Spangler Center at the Harvard Business School, how bad it was. The construction engineer from Harvard said that chemicals can be added to the soil to alleviate the terrible smell, but it did not work previously.

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There are many other concerned neighbors and agencies such as the Charles River Conservancy that fear this project is being rushed through without careful consideration. We ask that you please help us. Sincerely, Paula and Robert Alexander 226 North Harvard Street Allston, MA 02134 email: [email protected] _________________________________________________________________ Now you can see trouble…before he arrives http://newlivehotmail.com/?ocid=TXT_TAGHM_migration_HM_viral_protecti...

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AllstonBrighton2006 MEPA comment letter. [email protected] Dear Secretary Bowles and Ms. Angus, I am writing to you today to voice my opposition to granting the Phase 1 Waiver requested by Harvard University for their planned science complex in North Allston. The university claims that it qualifies for such a waiver, that the science center project is severable, and that the present infrastructure can support it. It is incredible to me that Harvard can claim that what is essentially the anchor of a largely undisclosed development 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 wonderful distraction from the issues at hand that it hopes will be overlooked. LEED is bought and is far from perfect, the highest standard being Platinum. But the hollow PR prestige of a LEED rating won't help such problems as the traffic issues, the dust, noise and the rodents from construction, our over-burdened roads, light pollution, noise pollution, or the influx of construction workers, Harvard employees and students who are parking in North Allston in increasing numbers. Harvard has full-time professionals and many many months dedicated to producing the volumes of material that it has given to residents to review who are giving their time and energy after long work-days what seems an intentionally short period of time while rejecting requests for extensions. A full review of the Allston plan and a full environmental review of the impacts of the science center must be allowed to take place before they 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 100 Cambridge Street, Suite 900 Boston MA 02114

Dear Secretary Bowles: LivableStreets Alliance appreciates the opportunity to comment on Harvard’s Expanded Environmental Notification Form for the proposed long-term development of the North Allston Campus as well as Harvard’s 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

Mr. Bowles, Re: EEA #14069 Harvard/Allston Science Center 6 September 2007 Page 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 impacts of 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 and attending 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

September 6, 2007

Secretary Ian A. Bowles EOEA, Attn: MEPA Office Briony Angus, EOEA No. 14069 100 Cambridge Street, Suite 900 Boston MA 02114 Re:

MEPA Public Comment on Harvard Master Plan / Science Complex EOEA No. 14069

Dear Secretary Bowles, I am writing to you in opposition to Harvard University's request for a waiver of full environmental impact review by MEPA. I find the following relevant issues to be lacking in Harvard's proposal to build the science complex and their 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 is awful. I am a bicycle commuter who often must travel through the neighborhood, and I fear it every time. Too many intersections are dangerous and too many street surfaces are in dangerous condition for night-time commuting. Public access (bicycle and pedestrian) from North Allston to the 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 improved access as a result of their project, but Harvard has submitted no plan for it. Finally, the science complex has a fundamental design flaw: the green space is in a private, enclosed space encircled by four buildings, rather than being an inviting space; maintaining this closed design can only be mitigated 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 overtaxed and cannot support added usage. Harvard's own analysis shows that 38% of their morning/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” with approximately 25,000 vehicles using it daily. Harvard's project (both construction and steadystate usage) will heavily over-burden this intersection, requiring additional study. Other intersections 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 of Harvard's proposed project. Many of Harvard's employees will be using MBTA bus #66, which is already one of the most over-used bus routes in the city; Harvard's argument that travel will only be 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 the developer, should be required to assess the project's impact. 3. Need for an alternate access to the route for construction vehicles. Harvard owns neighboring property that they could use for construction vehicle access which would not overburden Storrow Drive – a parkway on a regional natural resource, the Charles River. Harvard can do it with their

own property, so further study should be required. 4. Rodent control program is needed for the construction phase of the project. Allston-Brighton already has a serious rodent problem that verges on a dangerous public health situation. Harvard should be required to study their project thoroughly to put forward an intelligent rodent control program. 5. Underground streams should be examined. North Allston has a number of natural streams that were historically put underground. Harvard should be required to examine the impact of their development on these waterways, including studying the possibilities of “daylighting” one or more of them. 6. Enforcement. Independent, dedicated enforcement officers are needed to ensure that environmental damage is minimized and that Harvard implements all agreements. Suffice it to say that Harvard has received bad press recently due to their failure to implement agreements made a decade ago. 7. Segmented, rather than comprehensive, planning. Contrary to MEPA policy and regulations, Harvard's science complex proposal represents a segmented review process. Harvard’s request for a waiver allows them to bypass the necessary review of issues of State and regional importance. These issues come under the jurisdiction of the MBTA, MTA, DEP, EOTC, among others. As a result of these weighty and unresolved issues, I request that you require a full environmental impact review of Harvard's proposed science complex and their institutional master plan. Sincerely, Dr. Michael Pahre 76 Foster Street Brighton, MA 02135 [email protected]

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AllstonBrighton2006 Alex Selvig Harvard/MEPA Letter Alex Selvig Alessandro (Alex) Selvig Candidate, Boston City Council District 9, Allston-Brighton PO Box 35755 Brighton, MA 02135 Secretary Ian A. Bowles EOEA, Attn.: MEPA Office Briony Angus, EOEA No. 14069 100 Cambridge St., Ste. 900 Boston, MA 02114 Dear Secretary Bowles, I am writing to voice my opposition to granting a Phase 1 Waiver as requested by Harvard University for their planned science complex in North Allston. As presented, the university plan would not qualify for such a waiver under the current, established guidelines. The environmental impacts directly or indirectly caused by the Science Complex are far from insignificant, and the existing infrastructure is certainly not ample and unconstrained. Examples of this include, but are by no means limited to, the following: · According to the DPIR compiled and provided by Harvard, winds created 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 should be noted that the Boston Transportation department has disagreed publicly with Harvard's mode share numbers. · Quality of life for abutting residents will be severely impacted due to noise, air pollution, debris, rodents and other factors associated with construction of such enormous scale. · Groundwater, drainage and aquifers, some feeding into the Charles River, may be adversely affected by release of materials and pollutants currently on site or commonly used in the construction process, 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. The addition of several hundred large construction vehicle trips at these severely stressed points will have a devastating, negative effect on transportation. This project is highly complex, and Harvard has failed to conclusively demonstrate that it meets the criteria for granting the Phase 1 waiver. Detailed, deliberate, meticulous planning must be carried out in order to definitively protect the residents and the environment in the vast area impacted. A full review would be the only prudent, responsible, and reasonable way to work towards a positive end result. Sincerely yours, Alessandro (Alex) Selvig

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AllstonBrighton2006 Fwd: Comments on Harvard Science Center, Allston [email protected] ************************************** Get a sneak peek of the all-new AOL at http://discover.aol.com/memed/aolcom30tour [ Attached Message ] From:[email protected] To:[email protected] Date:Thu, 6 Sep 2007 22:28:36 EDT Local:Thurs, Sep 6 2007 10:28 pm Subject:Comments on Harvard Science Center, Allston Dear Ms. Angus, I am writing to request that MEPA deny Harvard University's request for a waiver for the science building/complex they are proposing in Allston. This project has been descried as a key element of the Allston campus, despite the request to treat this as a severable project. Despite, the assertions in their request, this project will have significant negative impact in the surrounding neighborhood. You have received comments from other neighbors that eloquently detail the current situation we are managing in regards to traffic, pollution, rodent control, and noise. The proposal will dramatically increase those problems. Any approval of this request should have such strict conditions that the need for such a conditioned response indicates that this proposal is not ready for approval by the various public agencies involved in the review process. Harvard has submitted voluminous materials for review by a dedicated group of local residents over the summer and has not allowed sufficient time to address the scope of the proposal and the many issues it raises. Requests from the task force they have worked with for years, residents and several local officials have been dismissed. This response is quite concerning given the 50 year plans and aspirations Harvard has for the Allston portion of their campus. Given Harvard's insistence on the current deadline, I would urge you to deny the request and allow an opportunity for a proper review of their entire plan for Allston. Sincerely, Karen Smith 70 Athol St. Allston, MA 02134 ************************************** Get a sneak peek of the all-new AOL at http://discover.aol.com/memed/aolcom30tour

http://groups.google.com/group/AllstonBrighton2006/msg/77405c54e85e7e60?dmode=print 7/29/2009