Kevin Prior, Chairman
Somerville Planning Board
93 Highland Avenue
Somerville, MA 02143
February 5, 2003
B. require at minimum satisfaction of all the points identified by
the Somerville's Director of Traffic and Parking in his various
letters of review and recommendation regarding Assembly Square's
internal roadways, and their intersection with state and MDC roads;
and
C. the study referenced in par. A above should also independently
model air quality impacts, based on predicted traffic volumes and
patterns.
The Planning Board should also retain continued jurisdiction over
the site in order to require future mitigations.
The Boston Metropolitan Planning Organization (MPO) is sufficiently
concerned about the traffic impacts from the great number of new
development proposals that they have recently approved and funded
a study of the entire Route 28 corridor. The scope of the study is
at this moment being determined. Yet permitting for IKEA is running
far ahead of the MPO study. Our own Assembly Square Traffic Study
is not yet completed. Rizzo Associates, the consultants performing
that study, have told me that impacts on Rte 28 are outside the
scope of that study, in any case.
At the same time, some state agencies have been inexplicably
neglectful of the development impacts on traffic in the Route 28
corridor. At your October 17, 2002, hearing on the IKEA PUD Master
Plan, Traffic Director Bill Lyons testified, somewhat bitterly,
that Mass. Highway and the MDC had shown "no interest" in the IKEA
proposal, and had made no comment at all to EOEA in response to
IKEA's EENF or DEIR filings. Mr. Lyons added that it was all he
could do to evaluate impacts on city streets, and that he "relied"
upon the state agencies to take care of the roadways under their
jurisdiction.
Certainly some others are taking note of the increasing development
/traffic pressures on Route 28. In the Sunday Globe North edition,
Jan. 16, 2003, in "City may team up on traffic circle design,"
Globe correspondent Kathleen Conti describes new transit-oriented,
mixed use development in Medford, relates Medford's concerns on how
IKEA and other proposed developments are expected to impact traffic
negatively at Wellington Circle, and state's Medford's interest in
a regional solution. More, recently, on the front page of the
January 25, 2003 Boston Globe's Real Estate section, the story
"Major Project slated for Medford," begs for comparison with the
IKEA project just across the Mystic River at Assembly Square.
National Development of Newton (ironically) has bought the 15-acre
former Cabot, Cabot, and Forbes site adjacent to Wellington
station, where they plan to build a $130 million mixed used complex
called Mystic Center. Eight buildings, built in phases over 5
years, will house 500-600 apartments and condominiums, office and
retail space, and a 150-200 room hotel with restaurant. The Globe
quotes Medford Mayor McGlynn as saying, "These projects are very
exciting, but I think it's important to get the infrastructure in
place first. Medford is spending $10 million on the infrastructure
[using a transportation bond]." (emphasis added) The Globe further
reports that "Medford, Malden, and Everett plan to spend a combined
$5.4 million in state funds to redesign Wellington Circle."
Where is Somerville's $15.4 million in infrastructure funds? Where
is our commitment from the MBTA, or funding through the MPO, for an
Assembly Square Orange Line stop - an amenity already enjoyed by
the Medford site just across the river? The Mystic Center site
consists of 15 acres, very close in size to IKEA's 16.6 acre site,
and also accessed by Rte. 28, and bounded by the Mystic River. Yet
our transportation needs for the site are going largely unassessed,
and thus unaddressed.
Because our permitting process precedes the MPO's planned Route 128
Study and even the results of the city's own Assembly Square
Traffic Study, the Board should require IKEA to fund a complete,
independent traffic simulation study, to allow the city to evaluate
impacts, and obtain whatever help may be necessary from the
developer and the state, based on those impacts. Steve Cecil's
Assembly Square Planning Study made it clear that 'big box' retail
could be a compatible use at Assembly Square only if it did not
extinguish traffic capacity on the site. We do not yet have the
assurance that IKEA will not extinguish additional capacity on the
site and the highways that access it.
Steve Cecil's optimistic, and quite preliminary and vague,
recommendations bear harder scrutiny at this point. You will
remember Cecil's slide show of Emeryville, CA, as a model for
development in Somerville, and as evidence that 'big box'
development could be a successful component of "mixed use." The
attached editorial from The Cupertino Courier, a local weekly
published by Silicon Valley Community Newspapers, casts doubt on
the validity of the Emeryville, CA, model.
None of us want to see Somerville emulate that city, about which
this editorial says: "Emeryville wanted so much so quickly that the
community wasn't prepared for the consequences." We have the
opportunity to gain an idea of the consequences of an IKEA through
a traffic simulation study. We must prepare for those consequences
now, or deal with those consequences, unprepared, later.
It is good to see that the Planning Board, in item 7 (page 46)
of its October 29, 2002, Conditional Approval of the PUD Master
Plan for this project required ongoing monitoring of traffic
volumes on the site, in order to compare actual volumes with
applicant's traffic projections. Apart from data collection,
however, there are no obligations for applicant, or anyone else,
for mitigation of any untoward traffic consequences that may appear
once the project is built. I am concerned that this condition
provides the city with too little information, and too little
leverage, too late in the game.
This project is being permitted based on too little data, too
little evaluation of impacts, and too few funding commitments for
mitigation. This Board has not even so far required the applicant
to even make the intersection modifications and install the traffic
signals stated in the Board's own conditions, prior to IKEA's
commencing operations. If the necessary approvals from the state
have not yet been given for improvements at intersections with
state highways (e.g., Rte 28), the applicants is only required to
escrow funds for the work to be done in future (Condition 2)i, page
45). This condition can, and should, be strengthened.
For some of the more localized impacts that have been identified,
there are additional steps that this Board can take toward ensuring
mitigation. Bill Lyons, in his October 16, 2002 letter to your
Board, continues to dispute IKEA's contention that improvements at
the intersection of Mystic Ave. Northbound and Lombardi
Street/Assembly Square drive will be made by the state as part of
the Central Artery Project. Assuming these improvements to be
essential, IKEA should be required to make them, and as a condition
precedent.
In the fifth paragraph of page 4 of the 10/16/02 letter, Mr. Lyons
identifies level-of-service drops for several signalized
intersections apparent from IKEA's capacity analysis. The Board
should require that IKEA mitigate these impacts, as recommended by
Mr. Lyons, as well as those described in several subsequent
paragraphs of Mr. Lyons' letter ( pars. 6, 7, 8, 9, and 10
[regarding the notorious "weave"]). These mitigations should be
conditions precedent to any certificate of occupancy for the site.
Conditions precedent to issuance of any building permits should
include the applicant's completion of its "Kensington Avenue
Pedestrian Walkway Improvements" plan, production of any and all
executed agreements necessary to implement these Improvements, and
production of any and all executed agreements necessary for the
construction and maintenance of the new "Main Street," ( as
outlined in Mr. Lyons' Sept. 13, 2003 letter.) The Board should
also implement Mr. Lyons cumulative "Recommended Findings" from his
comment letters.
As previously noted, Executive Office of Environmental Affairs
(EOEA) Secretary Durand, in his Feb. 1, 2002 Certificate, stated
that "[E]ven under the most conservative estimates, traffic will
increase substantially in and around the Assembly Square area,
further burdening the existing infrastructure, and resulting in
increased traffic congestion and air quality degradation." There
has been brought to my attention, and to yours, compelling evidence
that the air quality data in IKEA's FEIR does not reflect their
adjusted traffic volumes. It is understandable that IKEA's error
might be overlooked by the very busy MEPA staff. It would be
inexcusable for that error to be ignored, now that it has been
identified.
Bill Lyons has pointed out what he tactfully describes as areas of
"professional disagreement" with IKEA's traffic engineers: their
calculation of certain traffic volumes based on data collected
post-Rutherford Ave. overpass closing; their failure to make a
"shared trips" deduction from the trip generation data for the
existing development at Assembly Square, their "inability to
analyze the weave analysis for the area where Route 28 northbound
traffic exits the tunnel and rejoins the surface roads."
Mr. Lyons, with his staff of one, identifies and trenchantly
describes many errors and omissions in the documentation supplied
by IKEA's fleet of traffic engineers. Yet Mr. Lyons only has
jurisdiction over the local roads portion of this project, and is
not an air quality expert. Neither does Mr. Deshpende, the city's
Environmental Officer make any independent review of the
applicant's air quality data or analysis ( Planning Board 10/29/02
Letter of Findings and Determinations, pages 29, 41). It appears
from the record that Mr. Deshpende only commented, and only
minimally, on the Brownfield re-development and energy
consumption/greenhouse gas features of the building.
Since Secretary Durand himself noted the potential for air quality
degradation in the vicinity of the site, and since errors have been
discerned in IKEA's FEIR air quality conclusions, an independent
study is called for. Good scientific practice calls for a fresh
look at both the data and methodology. Since the Environmental
Justice Committee of the Boston MPO considers East Somerville to be
a "community of concern," it is more than appropriate for the
Planning Board to put to satisfy the concerns raised about the air
quality impacts of the proposed IKEA, for purposes of planning any
necessary mitigation.
(I would urge again the Board's consideration of a paper prepared
by economist and specialist in urban economic development Dr.
Elloit Sclar, of Columbia University, which I have previously
submitted.)
The mixed-use component of the project provides most of the tax
benefit and employment. It introduces the kinds of use that support
mass transit by generating fewer vehicle trips than retail per day
and per job created. Yet there is still no time frame in IKEA's
Special Permit applications for building the mixed-use portion of
the project, nor has one yet been required.
IKEA states that its plans for building these components will be
"as dictated by market conditions." The IKEA project in full
buildout is so automobile-dependent that it puts the creation of an
Orange Line stop at risk. It is likely that if only Phases 1 and 1A
of the IKEA project are built, the devotion so much urban land by
so little development density is certain to scuttle Somerville's
chance for justifying mass transit at Assembly Square. At minimum,
the Planning Board should impose an enforceable schedule for
construction of the full, mixed-use project.
Article 16 of the Somerville Zoning Ordinance, governing Planned
Unit Development, does not address phasing directly. Section
6.4.6.2. of the IPD zoning ordinance states that "[a]n IPD Special
Permit shall continue in full force and effect if the first phase
of a phased project is commenced within two (2) years of issuance
and subsequent phases are commenced pursuant to the terms of the
IPD Special Permit. (emphasis added) It seems clear that the
Planning Board is not only authorized to, but expected to, lay down
a schedule for phase construction. I ask the Board to do so.
As I've stated in my previous written testimony to your Board, the
density and variety of the mix of uses in this project could one of
its redeeming features. I would like to incorporate my former
testimony and exhibits by reference into this testimony, and urge
the requirement of a mix of diverse uses, with the aim of creating
a pedestrian-friendly, 24-hour district, as contemplated by the
zoning for the district. I also encourage the incorporation of
residential uses in this project as a "market" friendly alternative
to office space.
(This arguments are made in my previous written testimony)
(Please see my previous written testimony)
(Please refer to my previous written testimony)
Thank you for your consideration of what have again become lengthy
comments. Again, I have tied to be as brief the importance of this
project allows me to be.
Respectfully submitted,
Denise Provost