LAW, ADVOCACY & POLICY

Charles River Watershed Association Advocacy

Recent Comment Letters

Every year, Charles River Watershed Association writes dozens of letters to the Massachusetts Environmental Policy Act Office (MEPA) analyzing the environmental impacts of potential developments within the watershed. Comment letters constitute one of the most important tools of advocacy CRWA and the public has at their fingertips.

Under the Massachusetts Environmental Policy Act, (MEPA), development projects that exceed specified environmental impact levels and require a permit, financial assistance, or a land transfer from the state, are subject to public review and comment.  Comment letters are accepted at many levels of MEPA analysis of any given project. MEPA review begins with the filing of an Environmental Notification Form (ENF) by the developer describing the projects and its environmental impacts. The public has 20 days to submit written comments on the ENF to the Environmental Affairs Secretary. If the project is not initially approved, an Environmental Impact Report (EIR) may be issued analyzing the direct and indirect potential environmental impacts of the project.

The developer must reproduce each comment letter and respond to it in the EIR. The final EIR as scoped by the Secretary narrows the issues requiring further analyses from those discussed in the draft EIR. CRWA comments on most MEPA projects in the watershed, and thus has a strong environmental advocacy presence and helps force key decision-makers to take additional factors into consideration.

MassDEP Regulatory Reform

Draft Action Plan for MassDEP Regulatory Reform- December 5, 2011

CRWA favors thoughtful reform, designed to move permitting along, but without losing transparency or effectiveness.

EF Office Building

EF Office Buliding Chapter 91 Comments- December 9, 2011

EF Office Building EENF comments- November 3, 2011

EFEKTA House, Inc. is proposing to build a 10–story building for office and educational uses on a site located on filled Commonwealth tidelands of the Charles and Millers Rivers next to the North Point Park in Cambridge. The project is currently undergoing review pursuant to the MA Environmental Policy Act (MEPA) and has filed for a Chapter 91 waterways license with MassDEP. CRWA is very concerned about building massing and impacts on river viewscapes, pedestrian and bike access through the site, stormwater management and most importantly the proposed easements on public trust lands, open space agreements and mitigation measures being proposed.  

Remediation at the Former Medfield State Hospital

Phase II Comprehensive Site Assessment - November 10, 2011 New!

Request for Superseding Order of Conditions- September 8, 2011 New!
401 Water Quality Certification - August 12, 2011

Immediate Response Action (IRA) Plan - August 2, 2011

NOI/NPC for Former Medfield State Hospital - August 2, 2011

CRWA has been closely tracking the proposed cleanup of the former Medfield State Hospital (MSH). The site, owned by the state,  is contaminated with coal ash, oil and hazardous materials , metals, asbestos and polycyclic aromatic hydrocarbons in close proximity to the river.  CRWA objects to capping rather than excavating and restoring the abandoned dump area adjacent to the river.  We are particularly concerned  about contamination continuing to migrate into the Charles, and use of riprap along the banks, which capping could require. Restoration should also include the removal of contaminated sediments from the river, but the state is proposing instead to use a material called “AquaBlok” to cover and leave the sediments in the river.   

EENF for Former Medfield State Hospital - March 19, 2010

Former Medfield State Hospital ENF - August 18, 2009

This project proposes to clean-up three G.L. c. 21E sites pursuant to the Massachusetts Contingency Plan (MCP) and five non-MCP sites on the former Medfield State Hospital property. The project involves two phases: clean-up of current contamination and redevelopment to include 440 dwelling units, office space and a community center.

The former State Hospital site is severely contaminated, and CRWA suggests that more comprehensive remediation take place prior to the construction of a proposed residential development. River sedimentation and other river risks are present with site development, and the developer should commit to a full Environmental Impact Review (EIR), including both a draft and final EIR for both the clean-up and redevelopment.

The Commons at Prospect Hill

SDEIR on The Commons at Prospect Hill - February 18, 2009
CRWA is particularly concerned that the Proponent has not committed to achieving the pollutant reductions necessary to comply with the Charles River Nutrient and Pathogen TMDLs.  In addition, this project has numerous outstanding issues:

• There is only a .7 acre reduction in impervious area and the proposed areas for porous pavement are very minimal in comparison to the project’s size and are not clearly defined.
• The overall loss of vegetative cover is significant and there do not appear to be any green roofs
• Stormwater management alternatives are not considered in the alternatives analysis and the should be a vital driver of planning and development processes for this site given its proximity to water resources.

Urban Ring Improvements

Urban Ring Phase II Revised Draft EIR - February 10, 2009
CRWA appreciates the significant progress that has been made in the review process.  Pending more detailed analysis, we support the LMA tunnel.  We agree that the BU bridge is not a desirable Charles River crossing route for the Urban Ring and that there is a real need for improvements to pedestrian pathways in the Charles River Parkways and the modifications to the Grand Junction Railroad Bridge present an excellent opportunity to investigate alternatives. 

CRWA views as a major oversight the fact that the RDEIR does not even discuss stormwater impacts in its discussion of the impacts of the preferred alternative. Decisions about the types and locations of stormwater BMPs should be made early in the design process.  The Urban Ring presents many opportunities to develop improved stormwater management approaches and we believe these opportunities need to be examined fully in the process leading to the development of the FEIR.

View CRWA's comment letters from 2005, 2006, 2007, and 2008.