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Tag: Allston

Comment Letter on Paul Dudley White Construction Period

Comment Letter on Paul Dudley White Construction Period

February 7, 2019

Stephanie Pollack
Secretary of Transportation
Commonwealth of Massachusetts
Transportation Building
10 Park Plaza
Boston, MA 02116

Leo Roy
Commissioner
Department of Conservation & Recreation
251 Causeway Street
9th Floor
Boston, MA 02114

Dear Secretary Pollack and Commissioner Roy:

We, the undersigned organizations, applaud MassDOT’s decision to rebuild the interchange of I-90 in Allston by reconstructing the Turnpike in a way that will result in wider riverside parkland and, we anticipate, restored riverbank. In addition to its environmental benefits, this will enhance facilities for the walkers, cyclists, and runners who flock to the area for recreation and commuting. We write to respond to the announcement that construction of the I-90 Intermodal Project will require an extended closure of the Paul Dudley White (PDW) path.

We urge you to develop a plan to retain the path during the construction period. We acknowledge that the project design next steps involve extensive mitigation, that stakeholders will continue to actively participate in stakeholder discussions, and that there is an immediate need to flag concerns regarding the PDW path.

The construction of the I-90 Project cannot and should not require closure of the Paul Dudley White (PDW) path for 8-10 years. The number of people who use the path and rely upon it as a commuter route is simply too large (and growing) to result in PDW users’ diversion to Cambridge. The proposed detour routes through Cambridge are difficult to maneuver and involve unsafe situations where path users will be forced to cross dangerous intersections and cyclists will be directed toward narrow sidewalks causing hazardous conditions for pedestrians sharing the walkway.

Our understanding is that closure of the PDW is an anticipated result of construction in the Throat area. We also understand that other parts of the project site, which are not as confined, offer places where the PDW path can be integrated safely with the highway construction. The law requires that MassDOT implement “all possible planning to minimize harm to the . . . recreation area” during and after construction. To comply, MassDOT and DCR must mitigate construction impacts in the Throat area allowing the PDW path to remain open for as much of the construction period as practicable, preferably on land or, if there is no other option, on a temporary structure in the Charles River.

In the past short temporary boardwalks have been built in the Charles River — for example, to bypass the Bowker interchange reconstruction. Temporary boardwalks have been used safely and effectively in the Indiana Dunes National Lakeshore park in Indiana, Jones Beach State Park in Wantagh, New York, and at beaches in the Cape Cod National Seashore and in Duxbury and Sandwich, Massachusetts.

We urge you to incorporate plans to ensure access to the PDW path on the Boston side of the Charles River as you proceed with the difficult design work in the I-90 Throat area. The provision of a temporary Boston-side walking and biking path during construction is a necessary and legally required project element to mitigate any interruption in access to the permanent PDW path and prevent the safety problems that a Cambridge detour would bring to pedestrians and cyclists. Given the potentially lengthy roadway disruptions, alternative modes of transportation on the PDW will be critical to the Project’s success. We further request that the PDW path construction phase plans be added to the agenda for an upcoming Allston Multimodal Project Task Force meeting.

Thank you very much for your consideration and we look forward to your response.

Wendy Landman, Bob Sloane, WalkBoston
Margaret Van Deusen, Pallavi Mande, Charles River Watershed Association
Laura Jasinski, Harry Mattison, Charles River Conservancy
Staci Rubin, Conservation Law Foundation
Michael Nichols, The Esplanade Association
Galen Mook, Executive Director, MassBike
Becca Wolfson, Boston Cyclists Union
Stacy Thompson, Livable Streets

CC: City of Boston, Mayor Marty Walsh, Chief of Streets Chris Osgood
City of Cambridge, Mayor Marc McGovern, Transportation Program Manager Bill Deignan
Town of Brookline, Transportation Board Chair Chris Dempsey
FHWA, Division Administrator Jeff McEwen, Assistant Division Administrator Ken Miller
Senator Joseph Boncore
Senator William Brownsberger
Senator Sal DiDomenico
Representative Michael Moran
Representative Kevin Honan
Representative Jay Livingstone
Representative Tommy Vitolo

Unchoked: Dual Paths included in MassDOT’s plans for massive Allston I90 Project!

Unchoked: Dual Paths included in MassDOT’s plans for massive Allston I90 Project!

“Unchoke the Throat!” – the rallying cry to improve the Charles River park and river edge in the I-90 Allston Interchange project – grew out of WalkBoston’s call for separate paths for people walking and biking along the river within a landscaped park. Joined by the Charles River Conservancy and community residents, the idea came to life when Sasaki produced drawings showing a vision of how it could be done. WalkBoston produced a video showing how the massive highway project could be an opportunity to create a better place for people running, biking, and walking along the Charles River.

People from around the region wrote letters to MassDOT expressing their support for dual paths and a better park in the Throat. Of the 500 letters MassDOT received during the FEIR public comment period, over 150 referenced our “#UnchokeTheThroat” video proposal.

MassDOT listened! The notion of dual paths, nonexistent in most of the planning prior to #UnchokeTheThroat, is now in nearly every paragraph of Transportation Secretary Pollack’s explanation of her January 10th decision to pursue a new concept for the Throat (see today’s Boston Globe Mass. Pike in Allston, Soldiers Field Road are set for a major overhaul”).

The chosen plan makes dual paths and a wider park possible with an at-grade Turnpike and placement of Soldiers Field Road on a new, smaller viaduct above the Turnpike. A more generous, straightened park is also included as part of the plan that extends commuter rail to Cambridge via the Grand Junction line across the Charles River. Each of these improvements will help to reduce noise and visual intrusions into the riverside park.

What’s next?

WalkBoston’s advocacy is not done! We have tracked this project since its beginning in 2014, and we will continue our efforts to make it better.

Our focus, along with other advocates and community partners, is to convince MassDOT of the need to prepare for the traffic disruption during construction by enhancing transit access to and from the west and protecting Allston and Brookline neighborhoods from cut through traffic. Maximizing express bus and commuter rail services in the corridor served by the Turnpike and the Framingham/Worcester Commuter Rail Line will be critical. New service should include West Station to enhance public transportation options that provide additional capacity when vehicle lanes on the Turnpike are removed from service during the years of construction. Local bus connections are needed to provide a web of services that get commuters to final destinations; the stations further out, too, will need to be considered, as they will likely see an influx of new riders hoping to avoid driving delays in the construction area. Pedestrian connections to all new or supplemented services are essential.

Work on the project – some call it “the biggest highway project since the Big Dig” – goes on. It is, of course, much more than a highway project. It is a major development with public transportation components that lead outward from West Station, with repercussions that stretch all the way to Worcester – encompassing the Western Corridor and the major employment centers of Harvard Square, the Longwood Medical Area, Kendall Square, Back Bay and Downtown. Boston will gain a whole new neighborhood that will add over 10 million square feet of new employment and residential buildings that will make the area another of the region’s most important destinations over the next few decades.

The Allston I-90 Project is a once in a generation project that Massachusetts needs to get right. It is our move to call attention to everyday issues that can be improved to make it safer and easier to get around now and in the future.

Comments on the findings of the Independent Review Team for the Throat portion of the I-90 Allston Interchange Project

Comments on the findings of the Independent Review Team for the Throat portion of the I-90 Allston Interchange Project


November 30, 2018­­­

Stephanie Pollack
Secretary of Transportation
State Transportation Building
10 Park Plaza
Boston, MA 02116

Matthew Beaton
Secretary of Energy and Environmental Affairs
Saltonstall Building, 100 Cambridge St #900
Boston, MA 02114

Re: Comments on the findings of the Independent Review Team for the Throat portion of the I-90 Allston Interchange Project

Dear Secretary Pollack and Secretary Beaton:

As advocates for people walking, running, meandering and biking on the paths along the Charles River, we have reviewed the two documents prepared by the Independent Review Team (IRT) on the I-90 Throat area of the I-90 Allston Interchange Project. We have followed the IRT work closely, and appreciate the Team’s ability to deal with time constraints and the complexities of the project while including direct contacts with members of the I-90 Task Force.

The original options for the Throat area have been successfully updated and improved by the IRT. We recommend that they be discarded from further consideration. Whether those options are discarded or not, issues remain that must be resolved prior to MassDOT’s selection of a preferred alternative to carry into the Final Environmental Impact Report (FEIR).

Issues to resolve before choosing a preferred alternative

A. Good pedestrian and bicycle access for the heavily used Paul Dudley White (PDW) path on the Boston side of the river must be maintained throughout the multi-year construction period. The reports state that a replacement is ‘to be determined.’ Here are some possibilities:
  1. A temporary boardwalk in the river.
    • A boardwalk in the Throat would be short – roughly 1800’ long.
    • A boardwalk could maintain access for bikes and pedestrians close to the existing route of the PDW path.
    • Temporary paths can be used in the wider segments of the riverfront at each end of the Throat.
    • The design of a temporary boardwalk would need to be attentive to safety. Wooden boardwalks are often slippery and difficult for users.
  2. Limited fill in the river to support temporary paths.
    • Fill would be relatively minor – a narrow strip roughly 1800’ long.
    • Fill would be coordinated with the mandated ecological improvements to the river’s edge.
  3. Alternatives that detour all walking and biking to the Cambridge side of the river are not adequate. However, improvements must be made to encourage some shifts to the Cambridge path.
    • For walkers and bicyclists coming from the Cambridge path, connections on the Boston side of the river between the Mass Ave Bridge and the riverfront use a steep and narrow ramp that connects only to the downstream sidewalk and bike lane. It is not possible to safely cross Mass Ave at the entry to the ramp.
    • The walking and biking connections across the BU Bridge in Cambridge are difficult, and the path on the downstream side of the bridge is inadequate and unsafe for all users.
  4. A significant wayfinding system is needed to provide safe temporary routings.
B. All options must include ecological restoration of the banks of the river, between the BU and the River Street Bridges, to repair the neglected, unattractive, degraded and eroded bank. Ecological restoration would:
  1. Provide additional parkland, integrated with it and expanding upon the areas in the current options.
  2. Protect the river bank from further degradation by stabilizing the eroded edge.
  3. Restore aquatic habitat for the fish run for alewives, blueback herring and American shad, as they return to the river each year to spawn.
  4. Reduce stormwater runoff discharging to the river via overland flows and outfalls, including the 13 outfalls along Soldiers Field Road in the Throat Area.
  5. Provide flood resilience, control and storage capacity for precipitation-based inland flooding.
  6. Provide a solid footing for construction of improvements at the river’s edge, including a new PDW path or a new SFR.
  7. Develop landscape strategies and designs that provide Section 4(f) mitigation.
  8. Remove invasive species, dead trees and replant with native vegetation.
  9. Help plan for the riverfront parkland, a water-dependent use under Chapter 91.
  10. Help meet historic requirements for the Charles River Basin Historic District included in Section 106 of the National Historic Preservation Act and Massachusetts Historical Commission review.
  11. Comply with the Article 97 no net loss policy that requires replacement of parkland that is to be taken by the Project.
C. Mitigation for the impacts of each option must be provided prior to MassDOT’s selection of a preferred alternative. The full implications of each option cannot be known without exploration of how the impacts of each are to be treated.
In addition, the provisions for treating impacts will vary by option, with some being more attractive than others. Showing what mitigation can do to each option will help with the process of making and justifying a choice:
  1. Physical improvements intended as mitigation for impacts from highway construction must be provided close to the site of the impacts.
    • The IRT documents suggest that the addition of parkland 1,000 feet upriver will mitigate the loss of historic parkland in the Throat. Many Task Force members disagree with that conclusion.
    • Replacing parkland within the Throat area is a valuable and necessary element of mitigation to replace parkland taken by highway uses.
  1. Mitigation can make some options more attractive than others.
    • For example, if the riverbank restoration requires the addition of fill to the river edge, that fill can serve as an extension to the narrow strip of riverfront parkland and integrate with it either as landscaped edging or as a grassy area for exploration, sitting, walking and picnicking.
    • A wider park is a major element of mitigation for localized impacts from highway construction.
  2. Mitigation for each option is required by the federal legislation that governs the use of Section 4F (for parks) and Section 106 (for historic resources).
    • It seems likely that the analysis required by Section 4F and Section 106 will result in an exploration of alternatives to discern the least harmful alterations to the 20th century parkway (a highway bounded by two landscaped strips of land) that this project will be removing.
    • It is important to integrate the work done by Sasaki on pathways along the riverbank to meet the “all possible planning” requirements of Section 4F.

Choosing a preferred alternative

The following comments and questions are offered to help MassDOT select a preferred alternative for the Throat:

A. The Hybrid Variant Option

We are drawn to this option because it is more respectful of the need for improvements along the river’s edge than the other options, providing space for riverbank restoration, dual paths, and landscaping that will enhance the riparian environment and improve the quality of the park for all park users and non-motorized commuters along the river. However, the IRT report has developed the option only in brief outline form. The basic elements of the proposed option must be retained as they form the basis for its attractions.

  1. The dimensions of the riverfront park, as shown by the Independent Review Team on page 219 of the report, must be retained to provide an adequate park width throughout the Throat area.
    • The total dimension of the riverfront park is 42’ between the edge of the river and the wall of the Westbound Turnpike boat section.
      • The goal of two separated paths – one 10’ wide for bicyclists and one 10’ wide for walkers/runners – have been included.
      • A 16’ landscaped buffer is between the edge of the bicycle path and wall of the Westbound Turnpike boat section. This portion may also be used to fulfill many of the stormwater and resiliency goals of the project.
      • A 2’ buffer lies between the river’s edge and the walking path and a 4’ buffer between the bicycle and walking paths.
  1. These dimensions are in danger of being diminished as MassDOT and FHWA resolve questions about adding more shoulder space to the Turnpike.
    • An additional 2’ for a breakdown lane on right side of both WB and EB cross-sections of the Turnpike would take 4’ away from the 16’ landscaped buffer.
    • An additional 2’ for a breakdown lane on both sides of the WB and EB cross-sections of the Turnpike would take a total of 8’ away from the 16’ landscaped buffer.
    • Other roadway dimension issues may still emerge – all widenings of the highway elements of the project will diminish the 16’ landscaped buffer.
  1. If more space is required for highway elements this must be provided without diminishing parkland.
    • Make use of additional land on the south side of the project area. BU has been very helpful on the development of solutions that do not include a Turnpike viaduct and the use of BU property appears to be an integral part of both the at grade and the Hybrid options. The IRT report highlights other opportunities to use BU property. See “Maximum Potential Encroachment on Boston University Property” (Figure 6.1, p. 190 IRT Report).
    • Restoring and enlarging the degraded and unstable river bank, which could add some land that would serve as a landscaped buffer between the paths and the water sheet of the river.
    • The possibility of placing Soldiers Field Road above the eastbound, as opposed to the westbound, lanes of the Turnpike is intriguing and opens the possibility that the park-like setting might be significantly widened and potentially enhanced. We look forward to analysis of the possibility.
  1. Footbridges to connect the riverfront park and its walking and cycling paths with the community must be provided as an integral part of the project over the Turnpike, Soldiers Field Road and the rail lines.
    • Access for non-motorized travelers between the community and the river is severely limited. The existing footbridge over Storrow Drive just behind the chapel on BU’s campus is not ADA compliant and does not include any bicycle access. The next access is Massachusetts Avenue, a half mile east, or the proposed New Cambridge Street a half mile west. None of these locations can directly serve all users or people coming on foot or by bicycle from Packard’s Corner or Brookline.
    • A bicycle and pedestrian bridge has been proposed for a location at the end of Agganis Way, where it currently overlooks the rail lines. Agganis Way already connects to Commonwealth Avenue and a link to the proposed West Station could be readily made from that location and would serve BU students, South Allston and Allston Center, the northernmost neighborhoods of Brookline, bordering Commonwealth Avenue for nearly a mile.
    • An additional bicycle and pedestrian bridge connection has been proposed to connect the riverfront to Commonwealth Avenue near the BU Bridge. An exact location for this proposal has not been defined, but it would serve the area’s many walkers and bicyclists who are currently cut off from the river’s path network.
  1. The Hybrid Variant includes the reconstruction of the Little Grand Junction railroad bridge as an integral portion of the project, which would allow the straightening of the riverside Paul Dudley White Path, and removal of the boardwalk that intrudes into the river under the BU Bridge where it complicates and impacts boating activities.
    • This bridge is not a contributing element to the Charles River Basin Historic District, as claimed in the DEIR, according to DCR.
    • Elimination of the boardwalk under the BU Bridge, made possible by rebuilding this bridge, is a high priority among boaters.
  1. A method of attenuating sound must be included to dampen noise impacts from the Westbound Mass Turnpike on the surroundings including:
    • The IRT addendum report describes the possibility of a noise wall between the boat section and the paths in the riverfront parks, which diminishes the width of the park.
    • Other options must be explored.
B. The At-Grade Option

The At-Grade option remains a viable possibility and must be retained as an important alternative to continue analyzing because of the superior profiles the fully at grade options achieve in the essential Aggasis to Charles River Basin pedestrian and bicycle connection, in comparison with the highway profile required to clear the elevated Soldiers Field Road element of the Hybrid Variant. We have reviewed this option in prior comments submitted about the DEIR.

  1. The At-Grade option removes the viaduct and creates a more livable environment for the BU West Campus and the surrounding neighborhoods. A thorough investigation of ways to make the option more acceptable would have included adding more land from the BU campus to make the right-of-way wider and remove the option from its intrusion onto the river bank, where construction permits become difficult.
  2. The At-Grade option described in the IRT report is difficult to support. The paths and parkland are much too narrow. We suggested frequently that the Paul Dudley White paths could be constructed either on a boardwalk or on limited fill at the river’s edge. These options have not been explored, yet we think they would have been successful in meeting goals related to riverbank restoration, water quality, parkland and the riverfront paths. We suggest that they are still worth looking at to solve problems related to the river’s edge.
  3. Extensive design and environmental studies that describe the visual, accessibility, noise and air quality conditions for walkers and bicyclists are needed for the option that includes walkways suspended or cantilevered above Soldiers Field Road. The option remains interesting because it offers a high-level connection to potential pedestrian and bicycle bridges to Commonwealth Avenue.
C. The Highway Viaduct (HV) Option

We have reviewed this option in prior comments submitted for the DEIR. In view of the numerous objections to this option, we do not think that any Turnpike viaduct replacement option should be carried forward. These objections include:

  1. It is a barrier to an essential pedestrian and bicycle connection between Commonwealth Avenue and the river paths, as needed to provide a complete walking and biking network and as requested by the surrounding neighborhoods of Allston and Brookline.
  2. It cannot remove the horizontal curve on the Turnpike adjacent to the Commonwealth Avenue Bridge.
  3. During construction it cannot maintain two track service on the Worcester commuter rail line, thus negatively impacting riders from the Western corridor, and forcing spillover traffic onto local streets.
  4. The new HV option, at the tightest section of the Throat, has very difficult construction design issues where the Grand Junction is rising, because limited space is available for the Turnpike to hover over Soldiers Field Road.
  5. Boston University has generously offered space for widening the Throat for all purposes, but not if the Viaduct is to be rebuilt.
  6. The Houghton Spur, an early reason for rebuilding the viaduct, is to be abandoned.
  7. It does not include replacement of the Grand Junction bridge, a critical component of rail service into Cambridge, and would, if replaced, allow straightening and widening the Paul Dudley White Path and removing the boardwalk under the BU Bridge.

We believe that the next phase of comparison of plans should compare two options:

  1. A Hybrid combined with a Sasaki plan to make the necessary further improvements.
  2. A fully At-Grade combined with a Sasaki plan to achieve the necessary further improvements.
    This would fulfill the commitment by the Secretary to make each plan as good as it can be before making a final decision on which plan, including its necessary mitigation, should be included in the FEIR.

We have worked long and hard together on this project during the past 4 1/2 years. Now that we are getting closer to the decision among the options, we hope that MassDOT’s choices will reflect the opinions of the Task Force and the many hundreds of comments that have been shared by the public and elected officials.

Thank you for your attention to our concerns.

Sincerely,

Wendy Landman, Executive Director, WalkBoston
Galen Mook, Executive Director, MassBike
Laura Jasinski, Executive Director, Charles River Conservancy
Stacey Thompson, Executive Director, Livable Streets
Becca Wolfson, Executive Director, Boston Cyclists Union
Josh Fairchild, President, TransitMatters
Emma Walters, Executive Director, Allston Village Main Streets
Anthony D’Isidoro, President, Allston Civic Association
Jason Desrosier, Mgr, Community Building, Allston-Brighton Community Development Corporation

I-90 Task Force Members and Allston Residents

Jessica Robertson, Harry Mattison, Paola Ferrer

job opportunities with WalkBoston & partner organizations

job opportunities with WalkBoston & partner organizations

Position: WalkBoston part-time office administrator

Description: WalkBoston is looking for a part-time office administrator to become a core member of our team. The job is a mix of accounting, human resources, and office management. See full job listing

How to Apply: Please submit your resume and a cover letter to jobs@walkboston.org by Dec 15, 2018.


Position: Boston’s Safest Driver Program Manager

Description: The City of Boston is seeking a part-time Program Manager for the second edition of the Boston’s Safest Driver competition set to launch in the winter of 2018. Boston’s Safest Driver is a key educational program element of Mayor Walsh’s Vision Zero initiative aimed at eliminating traffic fatalities and serious injuries from our roadways by 2030. Applicants should be excited to engage with Boston drivers and form new partnerships! See full job listing

Position Dates: December 2018 – July 2019; up to 30 hours per week, pay based upon experience.

How to Apply: Cover letters and resumes can be sent to Kristopher.Carter@boston.gov.


Position: CommonWheels Program Director

Description: A recent recipient of a 3-year grant from Boston Children’s Hospital, CommonWheels Bicycle Collective is now poised for growth and is searching for an energetic and resourceful part-time Program Director to help expand and grow the organization’s programs and outreach. The ideal candidate will have experience in program development and management, excellent communication and relationship building skills, be comfortable working for a small community based non-profit, and have the ability to work independently. Experience with education and youth programming and/or bicycle mechanics are beneficial, but not required. See full job listing

How to Apply: Please send a resume and brief (one page) cover letter to hiring@commonwheels.org with the subject line “Program Director.”


Position: Land Use/Zoning Planner, Pioneer Valley Planning Commission

Description: Under the supervision of the Manager of the Land Use & Environment Section, performs a wide variety of planning tasks necessary to implement Valley Vision, the regional land use plan of our innovative and forward-thinking 21st century Regional Planning Agency, with responsibility for 43 cities and towns in a region of over 630,000 people located in beautiful western Massachusetts.

Requires familiarity with the principles, practices, and methods of land use planning and especially municipal zoning and related planning board technical assistance; strong project management; exceptional communication and community engagement ability; familiarity and experience with planning boards and local development regulations; experience implementing, and knowledge of, Massachusetts zoning and subdivision rules and regulations. See full job listing

How to Apply: Please forward cover letter, resume, and 3 professional references via email by January 5, 2019 to: Catherine Ratté, Manager Land Use & Environment Section cratte@pvpc.org


Position: Housing Planner, Pioneer Valley Planning Commission

Description: The Land Use and Environment Section of the Pioneer Valley Planning Commission seeks a highly qualified and motivated Housing Planner (at either entry level or senior level) to focus on Housing planning while working collaboratively with colleagues in the PVPC Land Use & Environment section. This person will work with cities, towns, the state and federal government, and partner organizations to advance municipal housing planning and policy work, including assisting member municipalities to modify local land use zoning regulations to facilitate housing access and affordability. See full job listing

How to Apply: Submit a cover letter, resume, 3 references, and a brief work sample by target date of 12-07-2018 to Timothy W. Brennan, Executive Director, Pioneer Valley Planning Commission, 60 Congress Street, Springfield, MA 01040, OR – by email to Land Use/Environment Section Manager Catherine Ratté at cratte@pvpc.org.

Letter to Review Team on Restoration of the River Edge

Letter to Review Team on Restoration of the River Edge

From: WalkBoston, Charles River Conservancy, Charles River Watershed Association

To: MassDOT – officials, staff, consultants Review Team on the I-90 Allston Interchange Improvement Project

Date: August 15, 2018

Re: Charles River – Restoration of the River Edge

On behalf of three organizations committed to the protection of the Charles River and its parklands, public access and pathways, and environmental health we jointly request that MassDOT fulfill its responsibilities to this invaluable resource by analyzing and developing options for the ecological restoration of the severely degraded and eroded riverbank in the I-90 Interchange Project area – from the BU Bridge to the River Street Bridge. This Project directly impacts the Charles River Basin , its parkland, ecology, water quality, and overall resiliency; dealing with those impacts is integral to the Project.

A study by MassDOT in advance of the FEIR should include re-establishment of a more natural edge, bank restoration, stormwater management, and increased floodplain connectivity and storage for resiliency. It should explore at least one alternative that creates better habitat and provides flood storage through the use of fill material in the river to accomplish these objectives. We ask that between now and when the FEIR is produced, a detailed analysis of alternatives, carried out in a collaborative manner, be developed so that results can be incorporated in the FEIR.

The DEIR did not adequately consider the need to restore the river bank, improve the park, and improve water quality. The DEIR has chiefly dealt with these impacts by trying to avoid them on the theory that permitting for the Project would be more difficult if river edge improvements are included. We are convinced that the contrary is true: a serious examination of these improvements would enlist substantial support from organizations, municipalities, and agencies committed to restoring environmental quality in this area – support that will be important to obtaining required approvals.

Restoration of this area requires attention to a number of issues and several important state and federal requirements, including:

1. Protect the river bank from further degradation and restore aquatic and riparian habitat. Much of the existing bank is degraded and eroding, eliminating fish habitat. The Charles is an important fish run for alewives, blueback herring and American shad, migratory fish that return to the river each year to spawn.

2. Provide parkland and improve safe walking and biking conditions as part of multi-modal improvement called for in MassDOT’s Project “purpose and need” statement and under Article 97.

3. Reduce stormwater runoff discharging to the river via overland flows and outfalls, including the 13 outfalls along Soldiers Field Road in the Throat Area. Both MassDOT and DCR have regulatory obligations to comply with phosphorus limits established in the state’s Lower Charles River Basin Nutrient Total Maximum Daily Load (2007).

4. Provide flood resilience, control and storage capacity for precipitation-based inland flooding within the context of current and expected climate change impacts.

5. Develop landscape strategies and designs that provide Section 4(f) mitigation. Removing invasive species, dead trees and replanting with native vegetation, in addition to incorporating green infrastructure, should be integral to the study.

6. Plan for the riverfront parkland, which is a water-dependent use under Chapter 91.

7. Meet historic requirements for the Charles River Reservation in the Charles River Basin Historic District included in Section 106 of the National Historic Preservation Act and Massachusetts Historical Commission review.

8. Comply with the Article 97 no net loss policy that requires replacement of parkland that is to be taken by the Project.

One example of how an alternatives analysis could address these issues is the environmental assessment and recommendations prepared for the North Shore Riverfront Ecosystem Restoration Project in Pittsburgh, PA. It provides extensive river edge improvements, including a natural bank, new pathways, landscaped parklands, connected floodplain, and wetlands. It was developed jointly by local environmental organizations and local, state and federal agencies, including the US Army Corps of Engineers. (https://www.lrp.usace.army.mil/Portals/72/docs/ProjectReviewPlans/N%20Shore%20Riverfront%20DP R%20MSC%20Approved%20for%20Release.pdf?ver=20160524161651743)

We are committed to working cooperatively with you in this process in order to evaluate the options and to achieve results in an expedited and cost-effective manner to restore and enhance this area of the Charles River and the Basin parklands.

We look forward to your response.

Wendy Landman, Executive Director, WalkBoston
Laura Jasinski, Executive Director, Charles River Conservancy
Margaret VanDusen, Deputy Director and General Counsel, Charles River Watershed Association

Please join WalkBoston, the Charles River Conservancy and the Charles River Watershed Association at a “Throat” Walk, September 12, 5:30 PM. We will meet at “BU Beach” behind the Marsh Chapel.

Images from Environmental Assessment of North Shore Riverfront, Pittsburgh