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Newsletter #41, Oct 19, 2024

Newsletter #41
October 19, 2024
https://alewife.org
 The ASG Newsletter includes the following updates:

– Conservation Commission Public Hearing on MBTA Hi Rail Access Tunnel at Alewife – Monday, October 21 at 7pm on Zoom 
– ASG requests Extension for Comments on MBTA’s Draft Hi Rail RAM Plan 
– How and When to Submit Your Comments on the MBTA’s Draft RAM Plan
 
Conservation Commission Public Hearing on MBTA Hi Rail Access Tunnel at Alewife – Monday, October 21 at 7pm on Zoom Click on this link for the Meeting Agenda and to Register

Please attend the Conservation Commission (ConCom) hearing to show community interest and concern about this project, especially the impact on trees.  The Alewife Study Group (ASG) estimates that at least 25 mature trees (greater than 6” diameter trunk) and many smaller trees will be cut down for the access tunnel.  This area of Alewife is one of Cambridge’s six extreme heat focus areas.  So, losing a lot  of tree canopy has a significant impact. 

ASG expects that this meeting will be the first of at least two on the MBTA’s proposal.  The MBTA (T) will present their plans, then the ConCom will ask questions and start to discuss the issues. If there is public comment, ASG will advocate for the following steps. 

Please consider including these requests in your comments. 

– Ask the ConCom to hold a public site visit of the proposed access tunnel location before the second ConCom meeting about this project.  This will allow the ConCom and community to see the impact on trees from all parts of the project, including the tunnel, access road to the tunnel, construction staging area, and compensatory flood storage.

-Ask the ConCom to require that the MBTA submit a new tree study of the area of the project (including compensatory flood storage), so that the assessment of the tree impacts is up to date.

– Ask the ConCom to consider, as they schedule future meetings on this project, that the community is also in the process of reviewing the RAM plan of this project, and has requested an extension, because of some serious initial concerns about the RAM plan, and needing more time to review the plan and submit comments. 

For more information about the proposed Alewife Hi Rail access tunnel, including issues and impacts, see ASG Newsletter 39

The Cambridge Conservation Commission (ConCom) administers the Massachusetts Wetlands Protection Act (310 CMR 10.0) for the City of Cambridge.  This includes reviewing, permitting and inspecting projects in or adjacent to Cambridge’s wetlands, floodplains and water bodies.  More info about the Cambridge Conservation Commission can be found here.


ASG requests Extension for Comments on MBTA’s Draft Hi Rail RAM Plan
Here is the first part of the letter ASG sent to the MBTA and their Licensed Site Professional (LSP), who is responsorial for the RAM Plan to protect the community from exposure to hazardous waste during construction: 

Brian J. Miller, LSP, CDW Consultants
Brad S. Nicoll, PE,
MBTAGeorge 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:

Requests:
– 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.” 

To see the full letter, go to either the Asbestos or Transportation sections of the ASG website. The parts of the letter not included here are:
More about asbestos
– More about lack of community input until very recently
– Conclusion

 
How and When to Submit Your Comments on the T’s Draft RAM Plan*

Currently, the T has set a deadline of Oct 30, 2024 for comments on their draft RAM Plan. ASG has requested a later deadline. See article just above.  We will report here once a new deadline is finalized. Meantime, if you would like to send comments before the current deadline of Oct 30, please email your comments, questions and any concerns to: Brian Miller, LSP, CDW Inc., at: bmiller@cdwconsultants.com 

Please also consider CC’ing or forwarding your comments to ASG at
contact@alewife.org, so we can track community concerns. 

Wondering what to include?
You might consider any or all of the following:
– Mentioning if you are a T rider. And that you are eager for improved reliability and service. 

– A flawed public process. The T has given very little notice to the public (just a bit more than 2 weeks) to respond to their proposed tunnel in a highly contaminated site. Ask for an extension.

– A poor location for this tunnel. Yes, this location is relatively far from houses, but it goes through one of the most contaminated areas of the old W. R. Grace site. Please consider a different location.

– The T’s draft RAM Plan does not follow the Asbestos Protection Ordinance (APO), which requires tenting and venting. Ask that they follow the APO.

Thank you!

*RAM Plan stands for Release Abatement Measure Plan
In this case the potential release of asbestos is the main concern. The abatement the T proposes is wetting the soil. ASG wants the better solution of “tenting and venting” to eliminate or reduce inhalation of asbestos fibers.

For questions or comments about issues in our community, contact ASG contact@alewife.org  ASG NewsletterASG will send email updates as needed during the development of the IQHQ site.Click here for previous ASG NewslettersAnyone can sign up (or unsubscribe) for this newsletter by completing the Contact Form at the bottom of the ASG home page: alewife.org We also welcome your questions, comments, ideas, and offers of help!
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