Secretary Robert Durand
Executive Office of Environmental Affairs
Attention: MEPA Office
Analyst LeAndrea Dames, EOEA No. 12672
251 Causeway Street, Suite 900
Boston, MA 02114
January 25, 2002
I am writing to comment on the ENF for the proposed IKEA at Assembly Square. In my
capacity as Alderman at Large, I am elected by the people of the entire City of Somerville, and
have an obligation to advocate for the interests of the entire city. Standing alone, the IKEA
project will have an enormous impact on Somerville. Yet it is but one large project among
several large projects arrayed along McGrath Highway (Route 28) through Somerville, from one
municipal boundary to another. Some of these projects are already permitted; others are
undergoing permitting, including permitting under EOEA.
Project Context: McGrath Highway as Somerville's Strip of Sprawl
EOEA would not allow the proponent of a single a single project to reduce its threshold of
scrutiny through "segmentation." Each one of the projects I will be listing below, however,
represents a segment of what is collectively a massive redevelopment of the McGrath corridor
through Somerville. The IKEA ENF acknowledges (and underplays) the Home Depot and Super
Stop and Shop projects, and, interestingly, makes reference to the Gateway Mall project in
Everett (ENF Sec. 5.1 et seq.) Yet other projects planned adjacent to McGrath Highway to the
south and east has been omitted from mention. They should not be omitted from consideration
in the MEPA permitting process.
At a recent seminar at the Kennedy School's Rappaport Institute, MAPC Director David Soule
asked me about progress at Assembly Square. I mentioned that I was concerned about the
cumulative impacts of all the projects presently under consideration. "You should be," Mr. Soule
replied. Around the same time, with reference to the relationship between road building and
"sprawl" development, Mr. Soule was quoted as saying, "We want people to ask - 'What
happens if you build it and they come?" (Boston Sunday Globe, Dec. 9, 2001, p. B6)
That is the question I am asking now. What happens if you build the projects now in the
pipeline: IKEA at Assembly Square, the proposed new Home Depot at Assembly Square
(permitted by city, but will need Chapter 91 license to develop fully, per Memorandum of
Agreement with Mayor); the proposed Yard 21 redevelopment (its developer was selected in
November by Somerville Redevelopment Authority), the proposed Super Stop & Shop (permitted
by city after grant of a MEPA waiver), the new Target store outside Union Square ( an as-of-right project, permitted to go into the site of a defunct Bradlee's), the expanded Star Market at
Twin City Plaza ( EOEA No. 12527), and the proposed North Point redevelopment (EOEA No.
12650; mostly in Cambridge, but 5 acres of which are in Somerville), "and they come?"
You yourself were quoted, Secretary Durand, in the same Globe article referenced above, as
saying that the development around the new interchange of I-93 and Route 128 in Woburn "is
a good example of how not to do something. The impact around that interchange, encouraging
big box development - in the long-term that could have an adverse impact, as the interchange
becomes unusable because of congestion."
Planning, transportation, and Environmental Justice
The area of the McGrath Highway/Mystic Avenue/I-93 confluence presents an even more
compelling example of the kind of development you decried in Woburn, because of its tightly-built, land-poor urban milieu, and because much of the area retains its original residential
character. McGrath Highway, when it was constructed in 1925, was laid through - and required
the demolition of - large swaths of residential neighborhood. The remains of those
neighborhoods border McGrath for a good part of its length throughout the city.
McGrath retains its character as a local road adjoining, uniting - and separating - residential
neighborhoods built at the turn of the century on a small scale urban street grid. McGrath
Highway borders the city's largest park, now the MDC's Foss Park, just south of the McGrath/
Mystic Avenue intersection. Within two blocks to the east of McGrath and Broadway one finds
a branch library, the Cambridge Health Alliance's Cross Street Clinic, the city's Edgerley
Education Center, ( early education programs, especially bilingual and special needs programs,
and the city's alternative junior high school and high school are housed here) and the East
Somerville School (K-8).
A little to the east of these schools is the parochial Little Flower School. Just south of its other
public schools, Somerville broke ground this week on a third school of 80,0000 sq. feet, to
house 400 students, in what is presently a city park. Less than a quarter of a mile east of
Broadway/McGrath is the city's main fire station, and less than a quarter mile east of there, on
Broadway, the Cambridge Health Alliance is completing work on a large neighborhood health
center. The 2000 census showed East Somerville to have the greatest population growth of any
area of the city. Over 15% of the city's population overall is foreign-born, with the highest
concentration of immigrants and of poor people living in or adjacent to the McGrath corridor.
Not just co-incidently, McGrath is also a major commuter roadway. As such, McGrath already
fills beyond capacity at several of its intersections at peak times of the work week. The
Massachusetts Highway Department has neglected the area, and has shifted responsibility for
long-overdue safety improvements to several of its intersection to Stop & Shop. (IKEA ENF,
pp. 5-19, 5-20) One assumes that this investment is being made in consideration for expedited
approvals for a project which never should have received a MEPA exemption.
Even with these intersection improvements, McGrath still has the deplorable intersection with
Mystic Avenue, and the infamous "weave" where northbound vehicles headed for Assembly
Square must cross two other lanes of northbound traffic, The area remains problematic with or
without the $50 million in funding for improvements to the I-93/Mystic intersection just cut by
the Transportation Plannind and Programming Committee of our MPO from its draft twenty-five
year transportation plan. As it stands, McGrath does not have the capacity to handle the increase
in vehicle trips for all the projects proposed. The city is working for restoration of the $50
million, but even if the state invests in improving one Mcgrath intersections, the area simply
becomes more like the Woburn example, minus a coherent intersection with I-93.
Because of these concerns, I ask EOEA to consider IKEA at Assembly Square not in isolation,
but in conjunction with the impacts of all the other projects listed within this letter. Individually,
the project raises a number of serious concerns, which only increase when all current projects
are considered collectively. Cannot some mechanism be devised to consider all projects along
this corridor as a whole?
Consistency with Local Plans
The Board of Aldermen requested in year 2000, and the city administration has promised to
conduct, a planning study of the Route 28 Corridor and its redevelopment potential. The city has
for over a year been working on a plan for the revitalization of Union Square, which lies
adjacent to and under McGrath Highway. These plans are not yet completed.
The city in year 2000 engaged the Cecil Group to conduct a planning study of Assembly Square.
That study concluded that introduction of mass transit, in the form of a stop on the MBTA
Orange Line, was essential to the realization of Assembly Square's potential. The Cecil's
October 2000 planning Study also stressed that all developments in the area needed to be
evaluated carefully to ensure that they retained some of Assembly's Square's admittedly limited
capacity to carry traffic.
The Board of Aldermen on March 14, 2001, enacted interim zoning for Assembly Square. This
zoning is intended to move the area toward the mass transit oriented, higher-density, mixed-use
development envisioned by the Cecil Report. The applicable sections of the Somerville Zoning
Ordinance, 6.4.6.3., requires that proposed projects be evaluated against "the Assembly Square
Transportation Plan."
This Plan is defined as a "comprehensive, multi-modal transportation plan developed during the
period this Assembly Square Interim Planning District is in effect. The Office of Housing and
Community Development shall develop this Transportation Plan in conjunction with the
Massachusetts Highway Department and the Executive Office of Transportation and
Construction, as well as any other appropriate public and private entities. It is intended that this
Transportation Plan should be consistent with Executive Order 385: Planning for Growth...."
(S.Z.O. sec. 6.4).
The interim zoning for Assembly Square expires on May 31, 2003. (S.Z.O. sec. 6.4.2.) The
Assembly Square Transportation Plan has not been completed. Nor has the developer of Yard
21 designated in November, 2001, yet had time to perform the promised feasibility study for the
Orange Line stop. There is no way to evaluate the impact of IKEA's plans on the feasibility
Orange Line stop, or measure it against the not-yet-extant Assembly Square Transportation Plan.
Like the other big box retail developments down the Mcgrath corridor in Somerville, IKEA's
mostly big box retail proposal has excellent potential for squandering the significant
transportation infrastructure that Assembly Square has (the Orange Line, plus two commuter rail
lines), while greatly overtaxing its limited roadways, highways, and traffic intersections.
These effects cannot be well quantified at present, since the underlying transportation planning
has not been done. Some of that work needs to be done by the MBTA, but has not been done
yet (See, e.g., Somerville's comments on the ENF for Circumferential Transportation
Improvements in the Urban Ring Corridor, EOEA No. 12565).
Moreover, apart from the transportation components, IKEA's plans are not consistent with other
elements of Somerville's interim zoning, including block size, setback from the MDC Park on
the Mystic River bank, relation to the river, and design elements. I know these are primarily
local issues, but you should be aware that they are likely to be raised locally.
Conclusion
Somerville desperately needs both commercial development and transportation improvements -
mass transit and pedestrian improvements most compellingly, but also highway improvements.
The poor and immigrant population of east Somerville will not benefit from the continued lack
of public or private investment in their neighborhood. That very neighborhood, however, is in
peril of being overtaken by exactly the kind of development which would probably no longer be
allowed on Route 9 in Framingham.
I ask that MEPA approve Somerville's McGrath Corridor projects collectively, and only on
condition of assurances from other state agencies and from the MBTA that they will provide the
funds, resources, and other support for planning and building the infrastructure along the
McGrath corridor that will allow for and promote appropriate, sustainable, high-value
development in East Somerville.
Thank you for the opportunity to comment.
Very truly yours,
Denise Provost
Alderman-at-Large