FW: from Kelley Brown
Bill Logue
Kelly had sent this yesterday and asked me to forward it to the Task Force.
Bill
From: Kelley Brown
[mailto:kbr...@PLANT.MIT.EDU]
Sent: Thursday, October 28, 2010 8:52 AM
To: Bill Logue
Subject: FW:
Bill – please forward my comments on to the Task Force when you have a moment.
Thanks - Kelley
From: Kelley Brown
Sent: Wednesday, October 27, 2010 5:51 PM
To: 'Bill Logue'
Subject:
Bill:
Just a couple of comments and responses to fellow Task Force members– but no particular amendments. I think you did an outstanding job of gathering up our many disparate thoughts…
I second Wendy Landman’s suggestions on the issue of the bridge expansion, reducing our unanimity to “largely” supporting bridge expansion and saying that the expansion is needed to “provide space for a comfortable sidewalk and safe bicycle accommodation (whether with a two-lane or three-lane vehicle release into Charles Circle).”
I would like to re-state my understanding of how the 4(f) and Section 106 procedures would be affected by the wall move and respond to the comments sent by Sarah Kelly and Steve Miller:
· MassDOT and FHWA cannot propose an alternative that impacts 4(f) or Section 106 resources if there is a feasible and prudent alternative to doing so or unless all planning to minimize harm is done. MassDOT already went through the historic preservation piece of this analysis in the state-level environmental review, which concluded with a finding of conditional no adverse affect (as Sarah K. notes). The consideration of the new pedestrian bridge to the Esplanade is the only major feature impacting historic preservation that is likely to change in the EA, so there is no reason to think the State Historic Preservation Officer (SHPO) will change her mind. I am sure that MassDOT can adhere to the plan review and other administrative requirements in the original SHPO finding.
· If it is prudent and feasible to have a one vehicle lane inbound on the bridge and a two-lane release in Charles Circle, without impacting the 4(f) resources, it must be done – MassDOT and FHWA would have no other choice. However, in Appendix 2, this alternative is shown and it provides a pinch point of 2’2” on the sidewalk – not compatible with ADA requirements. Further, on the traffic table provided to us in the July 27 meeting (attached), MassDOT demonstrated that the two lane release into Charles Circle would result in further degradation of vehicle traffic (already at LOS F in the PM), potentially doubling the queue length from 47 vehicles to 96 vehicles at the PM peak. Notwithstanding the preferences of some of the Task Force members, this cannot be considered a feasible outcome for a $255 million bridge rehabilitation project. The purpose and need of the bridge project to provide mobility to all modes of transportation that use the bridge, including vehicles, would not be upheld in this alternative.
· It is not acceptable to object on 4(f) grounds to a project that impacts the resources because of vehicle requirements, but not other impacts on the 4(f) resources caused by accommodating other modes of travel. It is the travel use of any kind impacting 4(f) resources in a federal highway project that is at issue.
· Once the impact on the 4(f) resource is proven to be unavoidable, the next test is whether the planning to minimize the harm has been done. This is both about limiting the extent of the impact to only that required to fulfill the project’s purpose and need and also properly mitigating any residual impact. In this case, the scale of the impact compared to the scale of the resource, i.e., the Esplanade as a whole, is an important consideration. I am a supporter of the proposed Esplanade pedestrian bridge and the other alterations near Charles circle that have been discussed and I think the Task Force is right to recommend them as a key portion of the overall project. However, I think a mitigation program that is estimated to be $10-12 million is not necessarily in balance with the 4 (f) harm in this case. If Task force members and other concerned parties honestly feel that the parkland and historic resources have not been properly planned for in the EA, then comment to that effect is warranted. Suggesting a priori that only one particular set of mitigation measures meets this standard is not respecting the environmental review process.
- Kelley
Kelley Brown
Senior Campus Planner
Campus Planning + Design
MIT Department of Facilities
77 Massachusetts Avenue, NE49-2100
Cambridge, MA 02139
T) 617-452-2410
Sarah Kelly
I spoke with Steve Miller and we both certainly want to express that we are heartened by the openness and willingness of DOT to take all of our concerns and suggestions about the need for mitigation into account. Regarding the historic reviews, I intended primarily to point out that they have not concluded; rather, they are ongoing through each stage of the project’s evolution in order to avoid adverse effects on historic resources. It is our sincere hope that everything will go as smoothly as possible with the reviews, that DOT will be able to incorporate the additional improvements that the Task Force has discussed, and that we’ll have a timely resolution to the issues that the Task Force has worked so hard on.