Secretary Robert Durand
Executive Office of Environmental Affairs
Attention: MEPA Office
Analyst LeAndrea Dames, EOEA No. 12782
251 Causeway Street, Suite 900
Boston, MA 02114
May 28, 2002
I am writing to comment on the ENF for the proposed construction of a new Lincoln Park
Community School (LPCS) in Lincoln Park, Somerville. The proposed construction is in
Somerville's Ward 2, an area which has been without a ward alderman since the resignation of
that elected official in March, 2002. Since the special election for a new Ward 2 alderman will
not take place until July, I feel that it is especially important for me to advocate on behalf of my
constituents in Ward 2 at this time.
Many people in Ward 2 send their children to the Lincoln Park Community School (LPCS), and
want a new school passionately. The Somerville School Department wants the project placed on
the School Building Assistance Program (SBAP) list for 90% state reimbursement of its $18 to
$22 million in construction costs. ( The ENF gives an approximate cost of $17.4 million; the
bond authorization request was for $22 million.) The existing school, constructed in 1973 on a
one and a half acre site in Lincoln Park, was not properly constructed, and is a dismal, leaky
place; always uncomfortable, as its HVAC system never operated correctly. Yet rebuilding the
school elsewhere in Lincoln Park, using the vehicle of a Declaration of Surplus/Change of Use
under Article 97 of the amendments to the state constitution, would be ill-advised, and in total
derogation of public process, compounding our history of error and woe.
Serving as Alderman at Large, elected by all the people of the city, I must advocate for the
interests of the entire city, a city that has very little park and recreational land. Somerville needs
a building plan for the LPCS that intrudes as little as possible on precious park land, a public
amenity for all of Somerville, and not just Ward 2. Somerville also needs public decision-making
process about the construction of this school which adheres to EOEA policy, and which is
inclusive, deliberate, and democratic. The present building plan and the process which brought
it about are seriously defective, in the manner set out below.
A. Consistency of LPCS Plan with EOEA Article 97 Land Disposition Policy (Feb. 19, 1998)
Published EOEA policy states that its support of an Art. 97 Land Disposition only in
"exceptional circumstances:" "A determination of 'exceptional circumstances' is subject to all
of the following conditions being met." One assumes that the burden of proof is on the project
proponent to demonstrate that these conditions have been met. I will discuss aspects of the
Policy's part II."Conditions for Disposition Exceptions" in order listed in the policy statement:
1. "[A]ll other options to avoid the Article 97 disposition have been explored and no feasible
and substantially equivalent alternatives exist (monetary considerations notwithstanding)."
I first became aware that there was a specific, versus conceptual, proposal to construct a new
LPCS on March 14, 2002, at a regular meeting of the Board of Aldermen. That night we had
a communication from the Mayor "[r]equesting the appropriation of $1,300,000 for engineering
and architectural services for Lincoln Park Elementary (sic) School and the authorization of the
issuance of not exceeding $1,300,000 bonds of the City to meet said appropriation," as item
number 71 on the Board's agenda. Although the School Committee and the Aldermanic
Committee on Finance, on which I serve, had met jointly regarding the School Department
Capital Plan about ten days before, the Superintendent of Schools, Dr. Argenziano, had not
mentioned to the Finance Committee that he would be making such a request.
At the March 14 Board of Aldermen's meeting, our Mayor, through the chair of the Finance
Committee, asked for a vote on the bond authorization that night. The reason given for the haste
was the need to meet a June first deadline of the Department of Education to be on an eligibility
list for 90% reimbursement for school construction costs. Dr. Argenziano told the Board that
unless we voted that night, there would not be enough time to prepare blueprints before the
deadline, and that blueprints were necessary for a complete application.
The Board was given no site plan, but was told by the Ward Alderman that there had been
neighborhood meetings, and that there was consensus on the plan. Unwilling to make such a
decision in the absence of more information, one of my colleagues and I voted against the bond
authorization, which carried, 9 to 2. The Ward 2 Alderman tendered his resignation from the
Board on April 23, 2002, and moved out of state. I did not see the proposed site plan until May
9, 2002, when I was given a copy of the city's Environmental Notification Form, and a
communication from the City Solicitor containing the draft Article 97 Transfer documents.
After the March 14 vote, I was contacted by several neighborhood residents asked about the
firmness of the siting and design plans. They stated that there had been little publicity about the
few neighborhood meetings, and contradictory information given about the planning process. At
an Aldermanic Finance Committee meeting on May 21, 2002, Dr. Argenziano gave testimony
that project architects had exhibited several conceptual designs at a Sept. 13, 2001 neighborhood
meeting, and that a favored plan was selected by voice vote at an October 25, 2001 meeting
attended by 34 neighbors and four school officials.
Other testimony at the May 21 Finance Committee meeting made it clear that no members of
the Board of Aldermen, with the possible exception of the departed Ward 2 Alderman, were
notified of the neighborhood meetings. Many residents who attended these meetings stated that
they were informed that the site plan was tentative, and subject to future revision. Yet it seemed
apparent from the ENF and from the metes and bounds description of land in the draft Article
97 Declaration of Change of Purpose prepared by the City Solicitor that the siting decision had
been firmly set. Several aldermen expressed unhappiness with the process, but made statements
such as "our hands are tied" and "the damage has been done;" the vote of the Finance
Committee in favor of the bond authorization was 3 to 2.
At no time have I ever seen, or, to my knowledge, has any presently serving alderman ever seen
any alternative site plans for the LPCS to that shown in the city's ENF. One alternative site
plan, obviously, is that the new school occupy the same 1.5 acre parcel previously carved out
of Lincoln Park for it by Special Legislation in 1973. When questioned about that possibility,
the Superintendent of Schools spoke of the high cost of relocating students into alternative space
if the existing building were demolished before the new one was constructed. Mention was also
made that it was considered unsafe to locate the school in its present site along Washington
Street and the MBTA Commuter Rail tracks. The fact that Lincoln Park will continue to be
abutted by Washington Street and the tracks was not acknowledged, and the safety aspects of
dividing Lincoln Park by a new, two lane road combined with parking lot were not discussed.
The Board of Aldermen explored no other options to avoid the Article 97 disposition than to ask
the Superintendent of Schools why the school could not be rebuilt on its present site, and to
receive the answers summarized above. At least one substantially equivalent alternative exists,
i.e., the present site. There may have been other site plans proposed which intrude less into the
park, but these were not shown to the Board of Aldermen. I respectfully request that you find
that the first condition stated above has not been met.
2. "[T]he disposition of the subject parcel and its proposed use do not destroy or threaten
a unique or significant resource (e.g. significant habitat, rare or unusual terrain, or areas
of significant public recreation, as determined by EOEA and its agencies."
Somerville is desperately short of park land. Our entire open space inventory amounts to 3% of
our land area. Half of that amount, 1.5%, is owned or controlled by the City of Somerville, and
the total includes two cemeteries, always locked and inaccessible, and many recreational areas
which are 100% hardtopped. The source for this data is Somerville's current Open Space and
Recreation Plan, submitted to the Commonwealth in May, 1997, and currently under revision.
The "Community Goals" section of this Plan states that "virtually all survey respondents are
seeking a change to the amount and quality of open space. Indeed, when asked, "What do you
like least about living in Somerville?" more than 75% of the responses mentioned crowded living
conditions and the lack of open space." (at p. 67).
According to the inventory in the 1997 Open Space Plan, almost all of the city's parks and
playgrounds are under an acre in size. Many of the larger open spaces, such as the Linear Park
Right of Way owned by the MBTA, are long and narrow, closely proximate to urban density
and traffic. Such is the character of the MDC's Alewife Brook Reservation and Mystic River
Shoreline Park and Reservation, the former bordered by a busy highway, the latter bounded by
roads and parking lots.
At 6.6. acres, Lincoln Park is the largest park owned by the city. It is roughly rectangular, and
relatively undeveloped, making it the one remaining city park where one can be far enough from
traffic to hear the wind, and where the space is wide open enough to give a sense of horizon.
Moreover, it can be reached on foot from crowded residential neighborhoods.
The city's 1997 Open Space Plan rated Lincoln Park's recreation potential as "high," and states
that, since it was purchased with a Land and Water Conservation Fund grant, it is protected "in
perpetuity." Significantly, Section II.A. of the ENF asks the project proponent to "[i]dentify the
current municipal comprehensive land use plan and the open space plan and describe the
consistency of the project and its impacts with that plan(s)." The ENF for this project responds,
"See Narrative," but then does not mention the open space plan or discuss the issue of
consistency in the narrative. Acknowledged or not, Lincoln Park is a unique and significant
resource in Somerville, and I request that EOEA so find, and extend to the park the kind of
protection that it deserves.
3. "As part of the disposition, real estate of equal or greater fair market value or value of
use or proposed use, whichever is greater, ... are granted to the disposing agency...."
The city administration's argument in favor of the Article 97 Disposition is that it 'results in no
net loss of park land.' Scrutinizing Figures 3 and 5 of the ENF, and the recently-submitted
substitute Figure 3, one can see that this is a disingenuous argument. The park is cut in half, cut
by a new road which serves only to access surface parking and a bus turn-around. It is
astonishing that anyone would propose such a wasteful road in a city already too much paved
over. The roadway cannot but degrade the park, reducing its safety, aesthetics, and value as
habitat by the intrusion of motor traffic.
Moreover, the city's Article 97 Declaration understates the amount of park land converted to
school use. The fiction that the bus drop off, pick up, and turning area will continue to be land
dedicated to park use is laughable. Also, the large amount of park land that will become "park"
land immediately adjacent to a roadway/parking lot is a matter of concern, since such land
cannot have the same value in use as park land that does not have a roadway intruding into it,
and clearly has less resource value. I respectfully request that the Secretary so find.
4. "The minimum acreage necessary for the proposed use is proposed for disposition and,
to the maximum extent possible, the resources of the parcel proposed for disposition
continue to be protected."
As previously discussed, there has been no showing that a perfectly fine school cannot be built
with the use of less park acreage. It is also clear from the plan that, far from being protected,
some of the park land still dedicated for park purposes will be paved, made accessible to motor
vehicle traffic, and consequently subjected to the dripping of oil and other motor vehicle fluids.
The access road will open the park to the noise, fumes, and hazards of traffic. I would ask that
the Secretary find that there has been no demonstration that the proposed plan uses "the
minimum acreage necessary," and that the resources of the parcel will not be as well protected
under this scheme as they are presently.
5. "[T]he disposition serves an Article 97 purpose or another public purpose without
detracting from the mission, plans, policies, and mandates of EOEA ..."
The construction of a school is undoubtedly a legitimate public purpose. In balancing the details
of this particular plan with what I understand of the mission and policies of EOEA, I find a lack
of attention to the principles of "smart growth" that EOEA has been advocating for the last
several years. Even if it were proposed for a suburban community with no shortage of open
space, the proposed LPCS site plan makes poor use of existing resources; the plan is utterly
insensitive to the urban context of Lincoln Park and its surrounding neighborhood.
The existing school is situated on Washington Street, just outside of Union Square, one of
Somerville's main commercial districts. Heading west on Washington Street towards the
Cambridge line, the uses change to institutional, as a transition to the residential neighborhood
beyond. One the south side of Washington Street, there is a church and associated parish
buildings, an apartment building devoted to public housing for the disabled, a building belonging
to Catholic Charities that contains offices and a shelter for the homeless. The street is raised as
a bridge over the right of way for the commuter rail tracks; the Lincoln Park School, is just
there, followed by a row of mostly two and three family homes, punctuated by the occasional
small business.
Demolition of the school would make a huge gap in this streetscape. At night, this would be a
zone of darkness, shielded from the eyes of the neighborhood by bridge, tracks, and the
screening wall of the new school building. The new building would create a major visual barrier
to the residential neighborhood that now abuts the park on its south side, where the eyes of
neighbors presently enhance park safety at night. Locating the school on Lincoln Parkway, 40
total width of right of way, is what necessitates the creation of the wasteful new access road to
the back of the school from Washington Street. I respectfully request that EOEA make good
urban design a requirement of any development in public parks.
B. Additional Considerations
As a final remark, I would like to note that the City Solicitor did inform the Board of Aldermen
at its May 23, 2002 meeting that the Somerville Conservation Commission had not voted
unanimously at its May 22, 2002 meeting to declare the pertinent land in Lincoln Park surplus
to municipal, conservation, and open space needs. The Solicitor told the Board of Alderemn,
however, that such a unanimous vote was not required, contrary to her own advice to the
Conservation Commission, and contrary to EOEA policy. The Solicitor did not inform the Board
of Alderemen that EOEA had ever made any policy determinations on Article 97 Land
Dispositions.
The EOEA policy was brought to my attention on May 25, two days after the Board of
Aldermen voted, 8 to 2, in favor of the Article 97 Land Disposition, and 9 to 1 in favor of the
accompanying Home Rule Petition. It is thus hard to say how the Board would have voted had
it been made aware that "any municipality that proposes, advocates, supports, or completes a
disposition of Article 97 land without also following the terms of this policy... shall not be
eligible for grants offered by EOEA or its agencies until the municipality has complied with this
policy. I would like to think that the Board would have voted in conformity with the EOEA
policy, had we known there was such a thing.
Thank you for the opportunity to comment on this proposal. I have not weighted these comments
down with attachments, but would be happy to document the assertions I have made in my
remarks with records from my own file.
Very truly yours,
Denise Provost
Alderman-at-Large