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.

Shoppes at Bellingham Draft Environmental Impact Form, April 28, 2008
The Shoppes at Bellingham is a large-scale development planned for the southwest corner of Hartford Ave (Route 126) and Interstate 495.  This development will alter 100 acres of land, create 63.5 acres of imperviousness, and destroy about two acres of wetlands in the watershed.  The area’s water resources are already strained by increased development, reduced recharge, and wastewater export which results in less water for the Charles and its aquatic life.  This is a massive project that could have severe impacts to the Charles. CRWA has provided extensive comments to MEPA arguing for a reduction in the project’s size as well as environmental mitigation measures.

Read the Secretary's certificate, filed on May 2, stating that the Shoppes at Bellingham DEIR did not adequately comply with MEPA, and requiring that they file a Supplemental DEIR. (Of particularly interest are pages 5-7 on the alternatives analysis and stormwater.)

Glen Ellen Country Club Senior Residential Community (Millis and Holliston) Environmental Notification Form, March 31, 2008
Since this project site is near Bogastow Brook, and important Charles tributary, CRWA recommends that low impact development (LID) techniques be utilized to minimize the impact of polluted stormwater runoff. Transportation and parking lot alternatives should also be considered by the developers, as well as water conservation efforts.

27 Washington Street, Wellesley Notice of Intent, March 14, 2008
The site of the former Grossman’s in Lower Falls is being redeveloped after years of unsuccessful proposals.  The project is a mixture of retail and residential, and will include a riverfront restoration with public pathways and native plantings.  CRWA provided the Wellesley Natural Resources Commission (NRC) and the developer with comments and suggestions, and the NRC hired an outside consultant for a third party peer review.  As a result, the stormwater management plan will now fully meet the new Mass. stormwater standards, including treating and recharging runoff from the entire site.  The developers have agreed to install signs explaining the on-site rain garden in the public parking area.  CRWA has also encouraged protection of the town-owned strip of land adjacent to the site, providing a visual and pedestrian connection from Washington Street to the river.

Wyman Street Redevelopment (Waltham) Single Environmental Impact Report, March 7, 2008
CRWA's comments stated that the project's SEIR did not avoid, minimize or mitigate damage to the environment to the extent feasible. The project will increase paved surfaces and car trips, while ignoring transportation alternatives. Now low impact development (LID) or stormwater management considerations were made, and thus the development will negatively impact water quality in the area.

Read the Secretary's certificate, filed March 14, which agrees with CRWA's complaints and requires the filing of a Supplemental EIR.

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