FPRA comments on Planning Board case #SP330 (55 Wheeler Street)

Dear Members of the Planning Board,

On behalf of the Board of the Fresh Pond Residents Alliance (FPRA), we politely submit the following comments regarding tonight’s Planning Board case #SP330, a proposal to construct 526 new residential units on a site located at 55 Wheeler Street in West Cambridge. To begin, let us say that we appreciate that the project has evolved from its original design in several positive ways. A significant number of the questions that we and others raised have been answered. That said, there are still aspects of the project which concern us greatly.

Before discussing our concerns, let us once again affirm our support for the significant points previously raised by abutters at the Reservoir Lofts. Regarding their concerns about increased traffic volume, problematic traffic patterns, construction timing, on-street parking, and construction noise and other impacts, as well as their support for ownership units, we are in complete agreement, and we ask that you support all of the conditions proposed by the Reservoir Loft owners in their letter of October 24^th.

Next, we would quickly mention our prior letter to the Planning Board on September 5th, a copy of which is attached. Though some minor questions that we previously raised have been answered by the applicant, we do not believe that the bulk of our concerns regarding neighborhood impacts, fire safety, traffic increases, mobility/connectivity issues, excessive building scale, limited public open space, regional context, unit ownership, community building, environmental concerns, and resiliency in the face of climate change have as of yet been addressed. As such, we hope that you will review these prior comments as a part of your deliberations.

We would also draw your attention to the matter of community outreach. Though the applicant has continued to meet with City Councilors and abutters since their last hearing, no further outreach has been initiated by the applicant towards the neighborhood associations. We do not believe that this extremely narrow outreach by the applicant is in keeping with the requirements of the Zoning Ordinance or the Planning Board’s own rules. In short, it is difficult to engage in a community process without actually engaging with the community.

As for our specific concerns, we have several. Though we are strongly supportive of the applicant’s proposed 20% Inclusionary Zoning percentage, we continue to believe that the proposed scale of this project is much too large both for the specific site proposed and for the larger Quadrangle district. Despite comments by Planning Board members to the contrary, we do not believe that this proposal is in keeping with the spirit of the ongoing Envision Cambridge process. For example, in their presentation to the City Council last week, the Envision Cambridge team presented a Quadrangle district FAR of 1.62 at 100% buildout. Conversely, the proposed Floor Area Ratio (FAR) for 55 Wheeler Street is 2.26, a 40% increase over Envision guidelines. The new Envision guidelines translate to an approximate unit count of 377, not the 526 units proposed by the applicant. Even at 377 units, this would still be the third largest project built in West Cambridge in the past 45 years. As a result, we continue to believe that this lower unit count is a significantly better fit for this disconnected, dead-end site.

More globally, we must question whether this project is in keeping with all the components currently under review through the Envision process. How do this stock of proposed new residential units and its projected population “fit” with current master planning targets (if there are such target guidelines?)  For example, are we unintentionally increasing “dumbbell” economic conditions by building an 80% luxury/20% affordable unit mix? Instead, would more middle income units better fit with long-term City goals? What about schools? Libraries? Public utilities? In her prior letter to the Board, Susan Lapides stated the problem quite succinctly: “Think about it. Are the numbers good for the future of our city? Or only good for the developers today?”

Similarly, we are not convinced that such targets will be achieved by approving large projects of this type without a corresponding public investment in local infrastructure projects. According to the just released draft of the Cambridge Climate Change Preparation & Response Plan (CCPR), “the Quadrangle area is isolated from the rest of the Alewife neighborhood since it is bordered by the railroad on its north and east edges and by the Alewife Parkway on its south edge.” Yet, the Envision planning process has yet to address any of the fundamental issues at play in this district: namely, mobility, livability, and resiliency.

Perhaps our most fundamental concern for the Alewife region, and the single factor that most prevents it from becoming a proper neighborhood, is the lack of connectivity through and across the district. Enhanced connectivity provides relief from traffic, connects neighbor to neighbor, enhances economic equality, and creates safety in the face of climate change.

As such, we believe that no development can proceed at this site without an integrated City plan to finally solve the area’s connectivity issues. Such a plan must include concrete and near-term steps to link all four quadrants of the Fresh Pond-Alewife seamlessly. Components to be addressed as a part of that plan include clearly aligned bike and pedestrian connections, the completion of a clear network of surface streets, linkages over/under/across the rail tracks, a new commuter rail station, enhanced public transit options, enough public open space to contribute to community livability, and an Alewife Mobility Task Force to oversee any planning efforts.

We believe that the 55 Wheeler Street site sits at the heart of this district, and as such, must contribute to solving these issues in cooperation with the City and local residents. In the same way that New Street was rebuilt to clear the way for new development, Wheeler Street requires enhanced connections in all directions to facilitate better livability for all residents. In addition to prior connectivity promises, we require the following additional actions by the applicant:

1. Clarify site circulation patterns to ensure that pedestrian paths align with neighboring properties and that noise from deliveries and trash collection don’t impact abutters at neighboring properties. Are they negotiating with neighboring properties?  Their comment regarding a “mid-block connection between Fawcett and Wheeler Streets at this location as early as completion of construction of the Project” would suggest that they are.
2. Consider allowing short-term public parking in the proposed surface parking lot next to the park. In the latest filings, the small surface parking lot is now described as “resident parking,” even though it abuts a public street and a public park.
3. Demand that the City address concerns with traffic entering from and exiting to Concord Avenue by making Wheeler Street one-way “IN”
4. Negotiate and pay for a connection from Wheeler Street  to Terminal Road
5. Contribute to the creation of an off-street, separated bikeway in place of on-street, unseparated lanes

Much remains unknown about our future climate, but it is almost certain that it will be wetter and hotter than today. Given the increasing uncertainty regarding just how wet and just how hot, we believe it is imperative to confront such concerns directly and with great caution when planning for the City’s future. Such a thoughtful approach has been demonstrated in the City’s commitment to the creation of the CCVA and CCPR Plans. In reviewing this proposal, we question whether this project demonstrates a similar commitment. To begin, we question whether it makes sense to build a so-called “resilient building” in an extremely non-resilient location (i.e. a dead-end street in a 500-year flood plain). Besides that, our continuing issues with the current design are the following:

1. The creation of an internal “common room” for sheltering in place. Will such a space be sufficient for and accessible for all 1000+ residents? What will be its capacity and location? Will it be protected from flooding? How will it ensure clean water and proper sanitation? What duration is it intended to serve for? We need more details to adequately appraise such a proposal.
2. The ground floor location of transformers, generators, electrical, and HVAC equipment is problematic and not in keeping with established resiliency strategies.
3. The placement of residential units on the ground floor. The recently approved project at Lanes & Games moved all residential spaces to the second floor and above.
4. Will upper story units have operable windows? Such openings are critical in cases where ground floor access is not possible due to flooding.
5. Will the proposed tree plan create enough of a tree canopy to offset the district’s serious heat island effects? If trees can’t be located alongside the electrical substation due to easement issues, what is the backup plan for shielding the site?

Regarding environmental issues, we would again emphasize our concern for the soil conditions onsite. According to the applicant, “A subsurface investigation of the property identified concentrations of lead and cadmium in soil above applicable reporting and remediation standards.  The concentrations were reported to the MassDEP in accordance with legal requirements. The RAO that was filed by the Licensed Site Professional concluded that lead and cadmium detected in soil was below the default background standard for historic urban fill in the area of the property, and therefore presented “No Significant Risk” to human health or the environment. “In response, we would note that just because the soil has contaminant levels lower than what is typically seen in urban fill doesn’t mean that it is “safe”. Almost all urban fill is heavily contaminated and must be cleaned up responsibly. In light of this, we hope that the applicant will see fit to follow the careful procedures adopted by the developers of 75 New Street.

Regarding Community Development’s latest memo on the project, we would only point out that we find it inappropriate to compare this project to the outdated Goals and Design Guidelines of the 2006 Concord-Alewife Plan. The Concord-Alewife Plan is at this point completely discredited. Instead, we would prefer to see the project evaluated in comparison to the newly evolving Envision Alewife standards, regardless of whether or not the zoning has been updated to reflect those new ideas yet.

In their October 19th memo commenting on the current 55 Wheeler Street proposal, CDD staff has listed numerous issues that they recommend studying further as conditions of permitting, either by continuing in a future Planning Board hearing or in ongoing design review by staff if the Board decides to grant the special permits now. We are concerned that such ongoing design reviews have often yielded results that are less than what was promised to or expected by the community. This is particularly true if such a review is based on outdated goals and design guidelines, as are found under the Concord-Alewife Plan.

In reviewing the latest memo produced by the Traffic, Parking, & Transportation Department, we have four specific concerns:

1. Changes to Wheeler Street Circulation: Regarding the circulation patterns on Wheeler Street, such as prohibiting left-turns from and to Concord Avenue or having Wheeler Street be one-way to or from Concord Avenue, TP& T expects to monitor the street and determine the most appropriate changes (if any) as the project is completed or at some point thereafter. We do not believe that “monitoring” alone is sufficient. We have asked repeatedly for such changes to be included in a revised Traffic Study, so that the community can better assess these possible improvements. We now ask for a revised TIS to address all of the following: Wheeler Street direction changes; a connection to terminal Road; and the impacts of new Concord Avenue traffic lights at both Fawcett Street and Smith Place. Good ideas should not be dependent on the approval of large development projects to come to pass.
2. Ongoing Hubway Support: To support the Hubway bike share system, which will provide a sustainable mode of public transportation for residents and their guests, the Permittee Station is expected to pay an annual fee to support the operations and maintenance of the installed bike sharing system. However, the memo states that “this requirement may be reduced or eliminated upon approval by the Traffic, Parking and Transportation Department, and the Community Development Department, based on an assessment of the utilization of the Hubway bike sharing system by the residents of the Project.” In our opinion, this makes no sense. The viability of a single Hubway node can’t be tied to usage by a single building’s residents, because without that station, all Hubway users would suffer.
3. Terminal Road Study Contribution: Though we are glad to see the applicant stepping forward to contribute $250,000 towards local infrastructure planning and design, including much needed “access across the MBTA rail line and/or other enhancements that improve connection between the Alewife Quadrangle and Alewife MBTA Station”, we would also point out that the City has previously received $1 million in developer contributions to study this bridge crossing. As such, we would ask that the entire $250,000 be expressly dedicated to studying the critical Wheeler Street-to-Terminal Road connection.
4. Car Sharing Spaces: When the applicant proposes to “make available up to 2 publicly available car sharing parking spaces,” we would only note that  “up to 2” is functionally equivalent to zero. Instead, we would ask for “at least 2” car sharing spaces. In addition, we would request more than the proposed 4 electric car charging stations.

In addition, the applicant has stated in their application that “Construction sequencing has not been finalized and delivery of the units could occur in phases.” After watching projects at 603 Concord Avenue, 75 New Street, and 95 Fawcett Street be effectively mothballed indefinitely, this comment is extremely concerning to neighbors and local residents. As a result, we would request more detail about expected phasing, as well as details about how the applicant would manage the site in the case where short- or long-term delays are encountered. Such plans should be in writing and be a condition of the Special Permit.

Other issues with the applicant’s revised documents include the following:

1. They make no mention of the city’s prohibition against construction work on Sundays.
2. Their dust control measures are insufficient. 75 New Street has much more comprehensive guidelines.
3. They need to connect to Fawcett Street and install the new traffic signal BEFORE beginning excavation. Otherwise, all the construction traffic will need to exit Wheeler Street directly on to Concord Avenue next to the rotary.
4. How many days per week will trash be picked up? The document says 5 days per week, but I believe I previously read “every day.”
5. The projected truck turnaround patterns for CVS/Trader Joe’s are untenable and likely to shut down the street for extended periods of time. All these contortions go away if Terminal Road can be connected, but only if the southern route is selected. The northern path (through the heart of the substation) will actually make truck deliveries worse.
6. In light of recent fire safety concerns tied to the construction of large, stick-built, multi-family projects, we would respectfully request a completed fire safety planto protect neighboring residents and businesses during construction.
7. The applicant should assess the feasibility of preserving the Abt interior courtyard and its mature trees and plants for the residents, for the neighborhood, for open space, for the temperature of the urban environment, and for local climate mitigation. Such physical space with historic notes can inform the future of the past: the elements of invention, public service, and thought that have always gone on in Cambridge as a contribution to the life of the future.  This connection adds texture to what otherwise has been and is, sterile development housing short-term residents.

Related to that last point, there has been much mention of the “possibility” of ownership units in the southern building (Building #1), but nowhere in the application is this mentioned in writing. We would request that such ownership units be made a condition of the applicant’s Special Permit.

Thank you for considering our comments; we look forward to continued discussion. In the meantime, please don’t hesitate to contact us should you have further questions.

Yours sincerely,

The Officers of the Fresh Pond Residents Alliance