Brad S. Nicoll, PE, MBTA
George Kober, PE, MBTA
Dear Messrs. Miller, Nicoll, and Kober,
I am writing on behalf of the Alewife Study Group (ASG), a City of Cambridge Representative Neighborhood Group, that has been deeply involved with activities and issues at the former W.R Grace site, now IQHQ, as well as Russell Field and nearby areas, since 1995.
ASG is the neighborhood representative for the Activity Use Limitation (AUL) and Public Involvement Plan (PIP) of the former W. R. Grace, now IQHQ, site. See background information HERE. ASG has engaged extensively with IQHQ, other community groups, and City of Cambridge Councilors and staff, over the last four years regarding the development and community benefits at the IQHQ site.
ASG received the PIP notice about the Alewife Hi Rail Access Tunnel RAM Plan (MassDEP Release Tracking Number 3-0000277) on September 10, and then the Press Release about this project on September 16. Since then, ASG has been informing and listening to many other community members about this project. ASG has also begun communicating with MBTA staff about the project.
Members of ASG were among more than 100 interested and concerned residents who attended the MBTA’s September 30 public meeting to introduce the project and present the RAM Plan.
Based on our review of the RAM Plan and other aspects of the project, along with the input of many other community members, both at the September 30 meeting, and directly to us, ASG now requests that the RAM Plan comment period be extended from the current October 30 deadline to the following schedule, with reasons to follow:
Request:
- The first deadline for submitting written comments on the current draft of the RAM Plan shall be extended from October 30 to November 30
- The MBTA will then hold a second RAM Plan public meeting, as soon as they are ready, and with at least 2 weeks’ notice to the public. At the meeting, the MBTA will present any changes to their RAM plan, respond to written comments and questions received so far, and then answer questions and hear comments from participants at the meeting.
- The community will then have another 30 days to submit additional written comments. This 30 day comment period shall begin on either the date of the public meeting or the date that written changes to the RAM plan are posted to the PIP list and the project webpage, whichever is later).
- However, if this second comment period includes some or all of December 21 to January 1, (when many people are celebrating holidays, traveling, visiting family, etc.), then the comment period shall be 45 days.
- As we know, the MBTA will then submit its final proposed RAM plan, along with responses to community comments, to MassDEP for approval.
Reasons:
ASG supports adding a second Hi Rail Access Tunnel to the Alewife end of the Red Line to improve subway maintenance and reduce service disruptions. Many in the community have also expressed support.
However, the community at large was not at all included in the process to select the specific location at Alewife. We only heard a brief description of the selection process at the public meeting on September 30, in response to a question from a member of the community. The MBTA missed an opportunity to hear valuable information from ASG and other community members before choosing the access tunnel location and developing their RAM Plan and Notice of Intent (NOI).
ASG and members of the community are still evaluating the proposed site. ASG has told the MBTA that we might propose an alternative site, along with our reasons, sometime soon.
There are important and complex issues at the site:
- Soil that is heavily contaminated with asbestos, and very close and upwind to busy youth playing fields and neighborhood homes
- In the 100 year floodplain and bordering wetlands
- In a planned nature preserve with a conservation restriction that plays an important role reducing the large heat island effect at this site, which is one of Cambridge’s six extreme heat focus areas.
- Crosses one new bike-pedestrian path plus one likely future bike-pedestrian path.
Given the purpose of this letter, we will only focus on issues under the scope of the RAM Plan.
ASG and many members of the community are very concerned that the Plan does not follow the Cambridge Asbestos Protection Ordinance (APO) requirement of “tenting and venting” during removal of the upper layers of soil, which ASG believes does apply to this project. See more information about this issue below. ASG also has some other areas of concern with the RAM Plan.
MBTA scheduled the RAM Plan meeting (September 30) and first Conservation Commission hearing (October 21) very close together. The RAM Plan and Notice of Intent (NOI) both include large amounts of technical information. This concentrated schedule of information release and meetings does not give the community, and ASG (in our representative role), anywhere near enough time to review and respond to the RAM plan.
For ASG, our response also now includes communicating directly with the MBTA about the benefits and feasibility of using “tenting and venting”, as opposed to the current plan of misting, during removal of the upper layers of soil. We hope that we can reach an agreement with the MBTA that can be included in a revised RAM Plan, and then presented to the community at a second RAM Plan meeting, as proposed above.
ASG believes that our proposed revised RAM Plan comment and meeting schedule allows reasonable time for both the MBTA and the community to work together to achieve a significantly better plan for protecting the health of youth and adults during construction of the HI Rail access tunnel (if the project does happen at the currently proposed location).
With construction of the access tunnel scheduled to begin in June 2026, ASG believes our proposed revised RAM Plan comment period leaves plenty of time for the MBTA to complete its permitting, real estate, design, and contractor hiring processes soon enough to begin construction on time.
More about asbestos
Asbestos at proposed location
In June of 2024, the MBTA took 147 samples from 64 locations. More than 57 percent of all locations tested positive for asbestos. ASG created the map below to show results of asbestos testing by the T in June. It also shows the results of earlier asbestos testing on the W.R. Grace site, now IQHQ, and where IQHQ has replaced the top 12-18” of soil with clean fill.
This map is composed of several maps on top of each other, with Whittemore Ave on the left and Rindge Ave on the right.
- 1999, Haley & Aldrich map: Every red dot is an asbestos hit, a location where there is enough asbestos that the nearby community could be harmed by dust from any soil released from this location. Every black dot is a non-detect of asbestos.
- 2024 IQHQ map: 18” of clean replacement soil is colored green
- Fall 2024 of the planned T access tunnel: (center-ish, depicted with two parallel curved lines). Every dot between the parallel lines represents a test for asbestos. Every red dot is an asbestos hit. The blue are non-detects.
More about tenting and venting
- IQHQ has followed the Asbestos Protection Ordinance (APO) , including “tenting and venting” where required, in their development of this site. IQHQ’s LSP and construction managers now have extensive experience with how to use these methods on this site.
- The City of Cambridge followed the APO, with “tenting and venting” on a few locations, where required, when it completely rebuilt Russell Field in the early 2000’s. Members of ASG worked with the City to design, implement, monitor, and analyze the soil sampling and remediation for this project.
- Additionally, the City of Cambridge followed the APO when undertaking their underground sewer infrastructure project that involved the current IQHQ site, as described in their RAM Plan: Release Abatement Measure Plan, 62 Whittemore Avenue, Cambridge, MA, CAM 400 Sewer Improvements Project, Release Tracking Number 3-0277, March 10, 2011
- Link to read the Cambridge Asbestos Protection Ordinance.
- The following late 1980s report, ‘EPA – Dust and Vapor Suppression Technologies for Excavating Contaminated Soils”, concluded that “Self-supporting structures are generally more expensive than other control techniques, but they provide the most reliable and effective control of off-site migration of dusts and vapors.”
- Page 65 of the report states that experiments conducted by the EPA showed that effectiveness of wetting ranged from 42% to 69% in terms of the percentage of particles contained relative to the condition with no mitigation. They used a tracer in the soil to be able to measure this accurately.
More about lack of community input until very recently
- ASG recently found out that the MBTA has been discussing the Alewife Hi Rail Access Tunnel project with the City of Cambridge since at least July 2023.
- On March 31 of this year, ASG first heard about the project from another member of our neighborhood.
- On April 2, ASG then discussed the project with IQHQ, which owns the land the MBTA wants to use for the project.
- IQHQ recommended to the MBTA that they engage with ASG about this project, because of ASG’s deep knowledge of the site and issues.
- On May 2, the MBTA’s public relations sub-contractor emailed ASG to offer a survey or a meeting.
- On May 3, ASG replied requesting a meeting and documents.
- It then took 3 ½ months for ASG to get a meeting with the MBTA’s public relations sub-contractors in mid-August, and then another month to hear from a MBTA project manager regarding ASG’s request to discuss the project and issues with MBTA technical staff.
Conclusion
Given the lack of community involvement until very recently, the complexity of the issues at this site, in the RAM Plan, and the NOI, the need to communicate complex information to many neighbors and other interested parties, plus the upcoming holidays, a RAM Plan extension, as outlined, is essential.
And, given the proximity to youth playing fields, children’s playgrounds, and resident’s homes, the severity and extent of the asbestos contamination, and the toxicity of asbestos, and given both the City of Cambridge and IQHQ have established precedent to “tent and vent”, we believe the MBTA should and can follow the Cambridge APO requirement to tent and vent. ASG is ready and willing to assist anyway we can, to figure out how to use “tenting and venting” with the particular construction methods of the Hi Rail Access Tunnel.
We anticipate years of working with the MBTA on long term construction projects in North Cambridge, including the proposed 22-33 acre public-private partnership proposed for the Alewife garage and environs.
Establishing good protocols, including both adequate time for community engagement and input, and following the Cambridge APO, will go a long way toward establishing good relations between the MBTA and the local community.
We look forward to hearing from you.
Sincerely,
Joel Nogic
For the Alewife Study Group