(also see an alert, from The East Arlington Good Neighbor Committee, on this topic)
Daniel Kamman
(number omitted) Harvey Street
Cambridge MA 02140
October 4, 2000
Robert Durand, Secretary
Executive Office of Environmental Affairs
251 Causeway Street, Suite 900 Boston, MA 02114
Attn: MEPA Office, Laura Rome, EOEA File #12307
cc:
Alan McLennan, Chief Planner, Arlington Town Hall
and
George Laite of the East Arlington Good Neighbor Committee
Please follow the complete Environmental Impact Report process, including a draft report and an opportunity for additional public comment. at an evening public meeting in Arlington.
Below are my comments on the Arlington Mugar Parcel Environmental Notification Form, August 31, 2000.
Summary of my major points
I live in North Cambridge and am concerned about area traffic and wetlands preservation
Traffic growth rate projection by Rizzo Associates is based on data that is
inappropriate and, therefore, misleading
incorrectly referenced and difficult to find
- The public needs new traffic projections based on appropriate data.
The answer/description on shading/shadow is inadequate (incomplete, insufficiently detailed) - The public needs a detailed description of shading/shadow impacts.
Why I am interested in the Mugar Parcel
I live in North Cambridge, a few blocks from the Arlington-Cambridge line at Massachusetts Avenue.
Driving near Route 2/Alewife Brook Parkway, I struggle through congested - and often ill-mannered - traffic.
I want to preserve Alewife wetlands.
Traffic growth rate projection by Rizzo Associates is based on data
that is inappropriate and, therefore, misleading
(as well as being both incorrectly referenced and difficult to find) Traffic growth rate projection (quoted from the ENF - Appendix C, page 12, 3.1 Growth Rate)
"…count station #4798 located on Route 2 West of Pleasant Street in Lexington, the annual growth rate between 1995 and 1998 was approximately 1.4 percent per year (see Appendix C). The limited count data obtained from MassHighway count station #4130, located on Route 2 in Arlington at the Lexington town line, indicates an average yearly growth rate of approximately 2.6 percent per year between 1991 and 1998. Averaging these two rates yields an annual growth rate of approximately two percent. The two-percent annual growth rate was applied to the existing traffic volume networks as a first step in developing the 2005 No-Build traffic volumes."
Data used for traffic growth rate projection (quoted from the ENF)
From Appendix C of Appendix C, on the page labeled (at top) Section III Traffic
Volumes by City/Town and (at bottom) page 44 of 95 is this average daily traffic
data for #4798 (on Route 2 West of Pleasant Street in Lexington)
1990
1991
1992
1993
1994
1995
1996
1997
1998
1999
127,000
107,000
70,300
69,749
71,730
74,265
74,335
From Appendix C of Appendix C, on the page labeled (at top) Section III Traffic Volumes by City/Town and (at bottom) page 5 of 95 is this average daily traffic
data for #4130 (on Route 2 in Arlington at the Lexington town line)
1990
1991
1992
1993
1994
1995
1996
1997
1998
1999
64,340
67,000
70,500
75,900
Why the data used is inappropriate:
one of the locations is not near the Mugar property
#4130 (on Route 2 in Arlington at the Lexington town line)
is closer to the Mugar property than
#4798 (on Route 2 West of Pleasant Street in Lexington)
and thus is more likely to reflect traffic trends near the Mugar property.
#4130 (on Route 2 in Arlington at the Lexington town line) data, sparse as it is,
consistently shows an increase in average daily traffic
[table previous page; chart of table data below]
This seems consistent with increasing development in the area
of the Route 2 - Alewife Brook Parkway intersection, near the Mugar property
and, thus, helps make it more a more appropriate source of data than #4798
#4798 (on Route 2 West of Pleasant Street in Lexington) data
shows relatively large decreases from 1991 to 1992 and from 1992 to 1995
[table previous page; chart of table data below].
(this seems inconsistent with increasing development in the area
of the Route 2 - Alewife Brook Parkway intersection, near the Mugar property)
Why the data used is misleading:
the appropriate growth rate is 30% higher than the growth rate used in the ENF
The growth rate calculated from the appropriate data,
#4130 (on Route 2 in Arlington at the Lexington town line), "approximately 2.6 percent per year"
is 0.6/2.0 x 100 percent = 30 % higher than
the growth rate calculated from the average of the two rates (one appropriate, one inappropriate) "approximately two percent"
that "was applied to the existing traffic volume networks as a first step in developing the 2005 No-Build traffic volumes".
The public needs new traffic projections based on the appropriate data.
Why the data used is incorrectly referenced:
the referenced year range is "between 1995 and 1998",
although the year range of the data used is actually "between 1995 and 1999"
Repeating, for convenience, the data shown on page 1 -
From Appendix C of Appendix C, on the page labeled (at top) Section III Traffic
Volumes by City/Town and (at bottom) page 44 of 95 is this average daily traffic
data for #4798 (on Route 2 West of Pleasant Street in Lexington)
1990
1991
1992
1993
1994
1995
1996
1997
1998
1999
127,000
107,000
70,300
69,749
71,730
74,265
74,335
from which I calculated the following % changes
(change is for a year compared to the preceding year)
1990
1991
1992
1993
1994
1995
1996
1997
1998
1999
-15.7%
-0.8%
2.8%
3.5%
0.1%
the calculated average of the % changes between 1995 and 1999 is 1.4%.
Although this calculated average agrees with the quoted average in Appendix C, page 12, 3.1 Growth Rate (see quote near the start of my letter), note that the quoted average is for "growth rate between 1995 and 1998".
Calculating the average between 1995 and 1998 gives 1.9%.
I assume that quoting a year range "between 1995 and 1998" and presenting an average using data between 1995 and 1999 is the result of a typographical error
- assuming that the intention was to present data for 1995 to 1999.
This disparity raises a question - are there other, less innocuous data errors, in the ENF?
Why the data used is difficult to find:
reference is to Appendix C, even though the sentence that does the referencing is in Appendix C
From Appendix C, page 12, 3.1 Growth Rate
"…count station #4798 located on Route 2 West of Pleasant Street in Lexington, the annual growth rate between 1995 and 1998 was approximately 1.4 percent per year (see Appendix C)..."
Since
the line above appears in Appendix C
Appendix C appears to be on the order of 100 or more pages
the direction "see Appendix C" is useless until the user figures out that the reference is to Appendix C of Appendix C (a labeling method that, to me, is unconventional and confusing).
Inadequate (incomplete, insufficiently detailed) answer on shading/shadow
Section
Wetlands, Waterways, and Tidelands Section - II Wetlands Impacts and Permits - E
Question (on page 8)
"Describe the project's other impacts on wetlands (including new shading of wetland areas
or removal of tree canopy from forested wetlands)"
Answer (on page 8)
The proposed buildings may have shadow impacts to the wetland resources on the project site
Why the answer is inadequate (incomplete, insufficiently detailed):
the answer mentions, but does not describe, the impact of new shading
There are established methods of calculating shadows from building height and position.
The height and position of the proposed buildings are known.
The wetland resources (presumably including plants) at the location are known.
The impact on the growth patterns of any existing wetland plants
should be determinable from the above data.
The public needs a detailed description of shading/shadow impacts.
Contact the Alewife Study Group, North Cambridge Massachusetts, by email at information@alewife.org
