Newsletter #45, March 15, 2025 – Alewife Study Group

The ASG Newsletter includes the following articles:

MBTA Public Meeting about Hi-Rail Access Tunnel near Alewife T Station – Tuesday, March 18 at 6:00 PM
ASG Comments on MBTA Access Tunnel project
Updates on MBTA’s “RAM Plan” for controlling asbestos and other contaminants
Updates on MBTA’s Conservation Commission (ConCom) Process
Upcoming Meeting on April 4, 2025 About Sewage Dumping into Alewife Brook

MBTA Public Meeting: Tuesday, March 18, 6:00 PM on ZOOM

Re: Hi-Rail Access Tunnel near the Alewife T station.

Meeting info here, and link to register here

This might be the last MBTA public meeting about this project.

Please attend to show strong community interest and concern about the impacts of this project that have not yet been adequately addressed by the MBTA. These include the risk of exposing the community to asbestos, and the loss of many mature trees.

Please share this newsletter with others who might be interested, and encourage them to attend the meeting and speak. See below for Alewife Study Group (ASG) comments and updates about this project.

For background information and previous updates, see ASG Newsletters 39-44, and in the Explore Issues section of the ASG website, see Asbestos, Transportation, and Habitat and Ecosystem.

ASG Comments on MBTA Access Tunnel project

ASG Supports adding a second Hi-Rail access point somewhere on the Cambridge side of the Red Line.

However, without any community knowledge or input, the MBTA chose a bad location for this project, because of significant negative impacts, as explained above and in previous ASG newsletters.

ASG does appreciate that the MBTA’s community engagement on this project has improved in some ways since September, and that some beginning progress has been made addressing the large negative impacts of this project. See ASG Updates below for more.

However, there has definitely not been enough progress for ASG to support having the Hi-Rail Access Tunnel in the currently proposed location.

So, ASG advocates that the MBTA either:

Work to find a better location for this project, this time with meaningful input from the community, and maybe as part of the design process for the Alewife Station rebuild.
Or, hold a more in-depth two-way conversation with the community about why no other location is possible, AND, continue working with ASG and other community stakeholders in a timely manner (before the final design is completed and before seeking final approval of the RAM Plan and ComCom Order of Conditions) to adequately address community concerns about asbestos exposure and tree loss.

MassDEP RAM Plan Updates

If the Red Line Hi-Rail Access Tunnel is built at the currently proposed locations, ASG and many others in the community strongly advocate that the MBTA use “tenting and venting” during excavation. See ASG’s December 8, 2024, RAM Plan Tent and Vent Comments Letter for our proposals and reasons.

See the Asbestos section of the ASG Website for all four of ASG’s December 8 RAM Plan Comment Letters, and for the Cambridge City Council’s December 9 Policy Order encouraging the MBTA to follow the City’s Asbestos Protection Order “tent and vent” requirement.

The MBTA’s February 6 RAM Plan Comment Responses outlines their beliefs that the current RAM Plan (which does not include “tenting and venting”) is “highly protective of human health and the environment”, and that ““the requirement of the Cambridge Asbestos Protection Ordinance (CAPO) to perform this work under enclosures with negative air pressure…has the potential to have negative impacts to workers health and safety, and would have more than a negligible effect on MBTA’s ability to fulfill its essential government functions of maintaining a safe transit system for the Commonwealth.”

To support these claims, the MBTA cites a third-party review of the CAPO, and a “study…conducted by Haley and Aldrich through a grant administered by the Licensed Site Professional Association (LSPA) that evaluated airborne fiber monitoring data from 14 asbestos in soil remedial sites.”

However, the MBTA response does not provide the third-party review of CAPO or the Haley and Aldrich study. It is not possible for MassDEP, ASG, or anyone else to properly evaluate the MBTA’s claims without access to the full contents of any review, study, or other information the MBTA is using to support their Response to the community RAM plan comments.

Therefore, ASG requests that the MBTA share with ASG and the public, without delay (including with a PIP notification and on the Massachusetts Energy and Environmental Affairs Data Portal associated with this site), the full content of the third party review of CAPO, the Haley and Aldrich study, and any other documents or information that the MBTA is using to support their position.

Also, at the beginning of its response to the Comment emails from Lisa Birk and David Bass, and from David Bass and Joel Nogic, the MBTA states, “Due to the length of the email, only requested action items were included. The full email is included at the end of the comments.” And, at the beginning of its response to the Verdantas LLC Comment letter (prepared at the request of Alewife Neighbors, Inc.), the MBTA states, “The full email and letter are included at the end of the comments.”

However, none of the three above cited Comment emails or letter, including ASG’s cover email of the Verdantas LLC Comment letter, are included at the end of the MBTA’s comments. And, we have not found any of them in the Massachusetts Energy and Environmental Affairs Data Portal associated with this site. Therefore, ASG requests that the MBTA, without delay, correct these omissions, both to everyone on the PIP Notification list for this site, and in the Data Portal for this site.

In it’s RAM Plan Comments, the MBTA also states, “However, due to feedback from the Alewife Study Group, Alewife Neighbors, Inc. and the general public, the MBTA is currently evaluating the economic and technical feasibility and effectiveness of performing the top 4 feet of soil excavation under tent enclosures with negative pressure. The top 4 feet of soil exhibited concentrations of asbestos up to 1.92 percent, which is higher than the 1 percent threshold regulated under the

CAPO. Asbestos was detected in only 3 of 20 soil samples in the 4-6 foot depth range, exhibiting concentrations below what is regulated by the CAPO. MBTA will continue to evaluate this option as an

additional protective measure for containment.”

This aligns with part of ASG’s proposal in our “Tent and Vent” Comments, based on the same soil sampling results cited by the MBTA above, and also based on feasibility discussions with the MBTA last fall. The ASG “Tent and Vent” Comments Letter requests:

“that excavation or other disturbance of the top four feet of the fill layer, which has been shown to have widespread, significant asbestos contamination, be done within a temporary structure maintained at partial vacuum, with offgas from the evacuation system treated with HEPA filtration;
that excavation or other disturbance of fill below four feet also be done within a temporary structure, to the extent practicable;”

ASG is currently reviewing all of the MBTA’s RAM Plan comments, and will review the MBTA’s third-party review of CAPO, the Haley and Alrich study, and any other reviews, studies, or information the MBTA has used to support their RAM Plan Comment responses. ASG’s review of the MBTA’s Response and supporting documents will include third-party peer reviews as needed.

Once ASG completes these reviews, we will share our comments with the MBTA, MassDEP, other stakeholder organizations, and the community at large. ASG asks that the MBTA then engage with ASG and other stakeholders in a timely manner, well before the RAM Plan is finalized, regarding the methods of asbestos protection in the RAM Plan for this project.

See here for the Data Portal for MBTA RAM Plan and related documents

The MBTA’s RAM Plan will remain in draft form. Final RAM Plan will be submitted to MassDEP closer to time of construction.

Updates on MBTA’s Conservation Commission (ConCom) Process

The Hi-Rail tunnel project will involve the removal of 28 mature and semi-mature trees with a total diameter of 279”, plus many smaller trees.

The MBTA team met with ASG, Green Cambridge, Mass Audubon, and Cambridge4Trees two times in December to work together on improving the planting plan for the site, with IQHQ attending one of these meetings. The Director of the ConCom attended both meetings.

These meetings led to an increase of tree planting diameter from 74” to 111”, and a better selection of native plants that will improve the habitat value of the area. The revised planting plan has now maxed out the number of trees and shrubs that can be reasonably planted in the less-than ½ acre area chosen by the MBTA for this project.

ConCom’s January 5, 2025 final Order of Conditions includes the special condition that “the MBTA will continue to work with community stakeholder groups to develop the final planting plan”. This was based on proposals from ASG before and during the November 18 and December 16 ConCom hearings. At the December 16 hearing, the MBTA agreed to this special condition, including planting more trees near the access tunnel site.

ASG advocates focusing on the MBTA’s drainage easement at and near “Parkway Pond”, which are just north of the Alewife T Station’s Russell Field entrance and nearby construction trailers. These spaces are overrun with invasive species, including Knotweed and Tree of Heaven. The MBTA has legal responsibility for these spaces, and they could be significantly improved as part of the MBTA’s work in this area. Continued public pressure on the MBTA to manage invasives in these areas and plant additional trees could help to secure these important improvements through discretionary funds allocated to the Hi-Rail tunnel project.

Upcoming Meeting on April 3, 2025 About Sewage Dumping into Alewife Brook

There will be a listening session on Thursday April 3, starting at 6:00pm with the cities of Cambridge and Somerville and the Massachusetts Water Resources Authority (MWRA) related to the Updated Combined Sewer Overflow Control Plan project. Register and receive the Zoom link here.

This event will be an opportunity for community members to speak and share their thoughts about this multi-year project to manage sewage and stormwater sent into Alewife Brook. Project staff will be in listening mode and are not presenting. This is a significant opportunity for the community to speak up about the importance of developing near-term plans to manage the sewage dumped into the brook and improve the brook’s ecology for the health of animals and people.

It is also a chance to emphasize opportunities, like the forthcoming MBTA Alewife Station rebuild, which can and should include green and grey infrastructure to help with stormwater and sewage discharges. Green infrastructure is natural wetlands, like at Alewife Reservation. Grey infrastructure is storage tanks, similar to what is under the new Tobin School. The spot where most of the sewage is currently dumped into the brook is on the Western edge of the MBTA garage (CAM401A), and the MBTA station rebuild is not currently part of this 50-year planning effort to manage CAM401A and other sewage discharge points along Alewife Brook and The Charles.

Participants are asked to get up to speed on the project before they attend. If you did not attend the Jan 22 public meeting, you can look over the following to learn more:

Project website	https://voice.somervillema.gov/joint-cso-planning	An overview of the project and materials from all previous public meetings.
Presentation slides from Jan 22 CSO Control Plans Public meeting	https://voice.somervillema.gov/19901/widgets/63634/documents/65028	To see the presentation slides from the most recent public meeting. See slides 15-27 for the project overview.
Recording of the Jan 22 CSO Control Plans Public meeting	https://voice.somervillema.gov/19901/widgets/63634/documents/63868	To watch the most recent public meeting. Includes several presentations about current work and overall timeline. See minutes 0:00-7:35 and 11:40-24:45 for a project overview.