Executive Office of Environmental Affairs
Anne Canady, MEPA Environmental Analyst
October 30, 2005
Thank you for organizing yesterday's site visit. I am offering a few comments about the project while they are fresh in my mind:
1) Wetlands, Waterways, Wastewater, etc.
I don't feel able to evaluate these aspects of the projects myself; I would hope, however, that the analysis and opinions of the Somerville Conservation Commission and the Mystic River Watershed Association have been sought and will be weighed in this process.
2) Transportation – Traffic Generation
Traffic Impacts and Permits
In connection with the estimated increases in average daily traffic on the state roadways serving the site, I would observe that the “existing” trips, based on counts from spring of 2004, do not reflect soon-to–be-existing trips generated by the soon-to-be opened retail “power center” in the location of the old mall. These trips will be both on Rte 28, north of I-93, and on Middlesex Avenue, where an enormous new truck loading dock is being constructed.
As I mentioned to you at the site visit, I question how the mall reconstruction could have proceeded without MEPA review. I suspect that the project meets one of the ENF thresholds for adts, and for the changes to the curb cuts along Middlesex Ave., in connection with the truck loading area. Yet there was no ENF, and while the anticipated traffic impacts of the new mall have not been quantified for a MEPA process, these will undoubtedly increase trip counts beyond the 2004 base level used in the Main Street ENF.
I suggest that EOEA make the proponent re-calculate the “existing” trip numbers based on trips that will be occurring when the new power center opens, as this will reflect real conditions by the time that “Main Street” will be developed.
Also, I would suggest that traffic conditions on the urban (Cambridge/Somerville/Medford) portion of Route 28 are entirely interconnected. I would urge the MEPA unit to consider the collective traffic impacts of all existing and permitted developments in this corridor. The new Super Stop & Shop just south of Assembly Square, for instance, received a MEPA waiver, but clearly has impacts on 28 north and south of I-93, and on Mystic Avenue, another state road that is part of the same traffic system. I urge you to look at projected traffic impacts for this whole corridor as of the time that “Main Street” proceeds, not just the Route 28 north/Middlesex segment as of spring, 2004.
Site Access and Circulation
I understand that the “Waterfront Access Drive” is an important development from the point of view of traffic circulation on the site. I am dismayed, however, that the Commonwealth would allow to continue unmitigated the practice of allowing roadways to separate public recreational lands from residential neighborhoods. Dilboy Field, a major DCR recreational facility in West Somerville, is cut off from Somerville's residential neighborhoods by Route 16, typically resulting in one or more pedestrian fatalities per year.
The lands along the Charles River in Cambridge are also cut off this way, but at least enjoy access via a public footbridge in Cambridgeport, and by the closure of Memorial Drive to vehicular traffic on summer Sundays.
I would urge that the project proponents here be required to provide pedestrian and bicycle access to the DCR parklands along the Mystic in a similar manner. Otherwise, public recreational lands are reduced to little more than a visual amenity for private development.
Pedestrian and Bicycle Amenities
I strongly support the suggestion of Somerville staffer Steve Winslow that the bike/ped amenities not only be mapped out on the site, but shown in the context of their connection to existing Somerville transportation routes. Figure 13, provided by the proponents, is laughably weak, ignoring the relationship of the project even to the abutting recreational land, let alone the surrounding city. As I have stated, the public recreational lands along the Mystic River are of little practical value if they cannot be accessed in a safe and practical manner by residents.
I am concerned, too, about the health and safety effects of locating bicycle routes to Assembly Square within the rights of way used by vehicular traffic – as well as the general health effects of increasing the already heavy motor vehicle traffic in Somerville. I attach to these comments an article I clipped from a newspaper this summer regarding the adverse health effects to bicyclists from breathing motor vehicle exhaust. I would expect that such health effects are among those for which the MEPA process will require mitigation – certainly we do not require that air be clean for its own sake, but for the sake of those who must breath it.
Transit
There is a vast difference between the proponent's commitment to fund a study of an Orange Line transit stop at Assembly Square, and the actual creation of transit alternatives. Many of us in local government feel that the measure of success of any development proposal for Assembly Square is whether enough jobs are created, and residents housed, to push the transit-boardings-per-day numbers to a point that justifies creation of an Orange Line stop. Any study reaching the conclusion that there is insufficient potential ridership to justify creation of a station at Assembly Square would be a study that indicts the whole redevelopment plan upon which it is predicated.
In the long term, an Orange Line stop will be essential both to mitigate the traffic impacts of the site's redevelopment, and to maximize access for all potential retail visitors and other users of the site. In the short term, mass transit at Assembly Square means busses. That transit option is not just insufficiently addressed in the ENF, it is omitted altogether, to the detriment of many present and potential users of the site.
Leaving the site visit last week, I passed people waiting at existing bus stops, squinting and huddled against the cold wind. I would suggest that the project proponents be required to supply bus shelters at minimum. I would also suggest that the project proponent be required to go beyond this step; to analyse transit routes to the site, and fill the gaps, just as the developer of the Cambridgeside Galleria was obliged to provide shuttle bus service to existing transit nodes.
I think it is fair to say that much of the public support for the reconfigured mall was due to the extraordinary popularity of the Christmas Tree Shop among Somerville residents. Yet many of those residents so eagerly awaiting the opening of this shop have literally no way to get there. In the last two weeks, I have visited over a dozen residences in this city for senior citizens: assisted living facilities, public housing, and private subsidized housing. Mobility is an issue for our seniors. They would like to get to Assembly Square to shop, but most cannot. The only existing transit access from Somerville is the #90 bus, which runs infrequently, is not accessible to many senior buildings, and, especially in the absence of shelters and seating at bus stops, is just too arduous a trip for most seniors.
I would strongly urge consideration of requiring the project proponents to provide a shuttle bus route to Assembly Square, from multiple stops within Somerville, particularly senior housing developments. Otherwise, the people living closest to the site, and bearing its environmental burdens, will be among the least able to visit it for shopping or recreation. The proponents could mitigate their traffic burden by giving access to Somerville people who consider this development to be a major local amenity.
Thank you for providing the opportunity to visit the site and to comment on the ENF, and for your consideration of these comments.
Sincerely yours,
Denise Provost
Alderman-at-Large
City of Somerville