Comments on Task Force Recommendations
Sarah Kelly
Bill,
Thank you for all that you have done in managing this enormously complex effort.
In addition to the comment about project timing that Steve Young has sent on behalf of the Boston Preservation Alliance and the Beacon Hill Civic Association, I have three interrelated and very important comments relating to the draft Task Force Recommendations as were sent to the Task Force on Sunday. Due to an unavoidable scheduling conflict, I had to leave at 11 am from the last meeting, but I made comments relating to these issues to DOT folks on my way out.
First, in the note at the bottom of page seven, it should be stated that the Massachusetts Historical Commission has made a Conditional No Adverse Affect finding. The word conditional is omitted, which improperly characterizes the status of the review. Under the Conditional No Adverse Effect finding, DOT must submit plans for each segment of the plan to MHC to ensure consistency with the Secretary of Interior’s Standards and to avoid adverse effects.
Second, major changes have been made to pages seven and eight since the last version of the recommendations, which the Alliance believes, in accordance with Steve Miller’s comments of yesterday, mischaracterize the support of some Task Force members for moving the wall. On page eight it is stated that there is unanimous support for moving the wall on behalf of the Task Force, provided that full Section 106 and 4f reviews are conducted. However, the Alliance believes that there still exists a potential prudent and feasible alternative to moving the wall if a two-lane approach to Charles Circle is considered. Any possible support from the Alliance for moving the wall would require not only a full Section 106 and 4f review, but also, as I stated in my memo sent to the Task Force on 10/6/10, will depend upon further analysis as would be conducted through the EA to determine whether there is a prudent and feasible alternative to doing so, which will depend upon the “evaluation of alternative designs” to accommodate all users that is described on page 7. Therefore, support for moving the wall pending 106 and 4f is not unanimous amongst Task Force members at this stage and should not be stated as such in the final recommendations.
Third, and related to the point above, at least one figure should remain in the final Task Force Recommendations that shows the wall not moved, as was shown in the previous version that was sent to the Task Force on 10/18/10. This will represent Steve Miller’s comment that some Task Force members believe that without a commitment to certain mitigation measures, “not moving the wall and reducing the "release" into Charles Circle to two lanes would provide the best opportunity for pedestrian and cycling facilities.”
Thank you again for all of your time an effort,
Sarah D. Kelly
Executive Director
Boston Preservation Alliance
Old City Hall
45 School Street
Boston, MA 02108
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