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PAL Report No. 1396.01 213
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214 PAL Report No. 1396.01
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PAL Report No. 1396.01 215
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PAL Report No. 1396.01235
William Francis Galvin, Secretary of the Commonwealth
Massachusetts Historical Commission
March 18, 2005
Secretary Ellen Roy Herzfelder
Executive Office of Environmental Affairs
100 Cambridge Street, Suite 900
Boston, MA 02114-2524
Attn.: Richard BournS, MEPA Analyst
RE: MBTA Urban Ring Phase 2, Boston, Brookline, Cambridge, Chelsea, Everett, Medford, and
Somerville. MHC# RC.19101. EOEA #12565.
Dear Secretary Herzfelder:
The Massachusetts Historical Commission (MHC) has reviewed the Draft Environmental Impact
Report (EIR) for the proposed project referenced above and have the following comments.
The reconnaissance identification of architectural resources appears to be consistent with that which was proposed by the MBTA and the MHC looks forward to coordination and consultation with the Federal Transit Admin istration (FTA) and the Massachusetts Bay Transit Authority
(MBTA) concerning the FTA's determination of eligibility for listing in the National Register for the properties within the right-of-way pursuant to 36 CFR 800A. The MHC previously commented on the proposed area of potential effect for the project as proposed by the MBTA.
The DEIR appears to be consistent with that which was proposed by the MBTA (100 foot corridor, to include 50 feet on either side of the corridor's right-of way center line, in areas where bus routes and stations are proposed and a 200 foot corridor for the project alignment that would encompass abandoned rail corridors). MHC advised the MBTA and the FTA that in areas where construction of the BRT stations may occur, the APE should take into account the effects the project may have based on each construction project. That is, MHC advised that the APE may be wider or larger than 50 feet on either side of the right-of way. The identification of historic resources and the should thus take into account a wider APE.
The MHC has the following general comments on the DEIR. The MHC recommends that supplemental environmental information prepared for this project should include a more comprehensive and detailed analysis of potential effects to historic propeliies so as to allow the public and the agencies the oppotiunity to make substantive comments about these effects.
Chapter 5 indicates solely that there will be visual effects that may need to be mitigated and alignment issues that may need to be re-examined in order to avoid or mitigate effects. While the survey information is useful in list form, and a general description of the likely effects to historic properties is presented in a summary, the MHC requests that the proponents prepare comprehensive maps-which depict the p,ropos,ecistations-- bus m.aintenalAce. facilities, platforms,
LLO MorrJ1isey Boulevard. 'l:)osron, Massachusetts UL I L'j
(617) 727-8470· Fax: (617) 727-5128 www.sec.s[are.ma.us/mhc
geometric roadway improvements and routes with the adjacent historic properties identified on them. Furthermore, the DEIR contained only a list of historic districts within the Urban Ring
Corridor. The MHC suggests that supplemental environmental studies prepared for the project should include the architectural reconnaissance information for public comment. The maps prepared as part of the architectural reconnaissance survey would serve as a useful basis for this, and the architectural survey would make a useful appendix for review purposes. Labeling should be consistent; station names should appear on these maps to match those which are stated in the
DEIR narrative. Additionally, MHC B Forms should be prepared for properties adjacent to and within the APE for stations, platforms, maintenance facilities, and geometric roadway improvements if they do not already exist.
Where the impacts are likely to be physical and visual in nature, such as stations and platforms and geometric modifications to existing roadways, the MHC requests more detailed project plans and information to review and comment on. MHC understands that approximately 60 stations and platforms are proposed for this project, and it is important to begin to examine each of these within the context of historic properties. Toward that end, MHC looks forward to the FTA and the MBTA's determination of effect with regard to stations and platforms and geometric improvements, and encourages consideration of design alternatives that respond directly to the contexts which contain historic properties.
Although the MHC is unable to determine what effects the proposed project will have on historic properties without the above requested information, the MHC offers the following specific comments on the project based on the information contained in the DEIS. The MHC is pleased to see that no demolition of above-ground historic architectural properties is proposed for this phase of the Urban Ring project. However, while there is no demolition of architectural resources proposed, it is noted that there may be modifications to historic parkways within the APE. This is of concern to the MHC and it is imperative that the public and the agencies be given the opportunity to review detailed conceptual plans for these alterations. For example, the DEIR notes that the project contemplates alteration of a traffic island along Memorial Drive. MHC is concerned about the nature of the effect on this historic property (a National Register-listed property within the Charles River Basin Historic District) but is unable to determine from the limited information contained in the DEIR what the modifications may have. Another area of concern, for example, is the impact area in the Fenway (Brookline Avenue and the Fenway) where the addition of a turning lane could alter historic fabric. The MHC requests more detailed information concerning this proposal, and reiterates the need to see the project impact areas mapped in tandem with the identified historic properties. The format followed in the visual analysis contained in Chapter 4 of the DEIR is useful in that it approaches the project in segments. Such a format to describe historic properties in narrative form as well as in figure form
(maps) would be particularly useful. It should be noted that much of the parkland discussed in the DEIR is also historic-either listed in or eligible for listing in the National Register of
Historic Places-- and part of the Metropolitan Park System of Greater Boston. Future environmental study should focus on this fact.
As noted in the Draft ErR (pp. 4-59 to 4-61; 5-50 to 5-5 I), limited portions of the project area of potential effect are considered to be archaeologically sensitive. The Draft ErR contains an accurate reporting of provisional information conveyed in a draft archaeological report for the project, and proposes that additional ai'chaeological investigations will be conducted for archaeologically sensitive portions of the project area. MHC reviewed the draft reconnaissance survey archaeological report and offered technical comments and suggestions. Taking these technical comments into account may result in some adjustments in the recommendations for additional archaeological investigations in parts of the project area of potential effect (Tables 4
33,4-34,5-32 & 5-33 at pp. 4-92 to 4-94 and pp. 5-88 to 5-89). The Draft EIR contains some additional useful graphical information and more refined project information that should be included in the final reconnaissance survey archaeological report. MHC looks forward to reviewing the final reconnaissance survey archaeological report to offer more specific recommendations for which portions of the project area of potential effect may require systematic archaeological testing as part of an intensive (locational) archaeological survey (950 CMR 70).
The general procedures outlined in the Draft EIR (pp. 5-51) to identify, evaluate, and avoid, minimize or mitigate impacts to significant archaeological properties are consistent with professional historic preservation practices and applicable laws and regulations. These procedures could be amplified in a Programmatic Memorandum of Agreement for the project.
These comments are offered to assist in compliance with Section 106 of the National Historic
Preservation Act of 1966, as amended (36 CFR 800), Massachusetts General Laws, Chapter 9,
Sections 26-27C (950 CMR 70-71), and MEPA (301 CMR 11). If you have any questions or need further information, please feel free to contact Edward L. Bell or Ann Lattinville at this office.
Sincerely,
Brona Simon
Deputy State Historic Preservation Officer
State Archaeologist
Massachusetts Historical Commission xc: Peter Calcaterra, MBTA
Andrew Brennan, MBTA
Holly Palmgren, IvrnTA
Peter Butler, Federal Transit Administration
Peggy Foley, Federal Transit Administration
Local Historical Commissions: Boston, Brookline, Cambridge, Chelsea, Everett,
Medford, and Somerville.
Deborah C. Cox, PAL
William Francis Galvin, Secretary ofthe Commonwealth
Massachusetts Historical Commission
July 9, 2004
Deborah C. Cox
PAL
210 Lonsdale Avenue
Pawtucket RI 02860
RE: Circumferential Trar:sportationLl1provements in the U!"ba,n Ring Coni do!": Phase 2, Boston,
Brookline, Cambridge, Chelsea, Everett, Medford, and Somerville. MHC #RC.19101. PAL
#1396.
Dear Deborah:
Staff of the Massachusetts Historical Commission have reviewed the draft report, Archaeological
Reconnaissance SunJey, Circumferential Transportation Improvements Urban Ring Corridor:
Phase 2, and offer the following comments and suggestions. The Cambridge,HistoricaL,
Commission has a particularly detailed understandmg of land use history in that city as it relates to archaeological sensitivity, md so 'please have them review and comment on relevant portions of the report. Similarly, the BostoriCity Archaeologist should have the opportunity to review and comment on the Boston sections ofthe report.
The project route passes through some of the most heavily developed portions of the state, and tracing the land use history of the project area was a formidable task-one that was generally very well-conducted as the written and graphic results are clear, concise, and organized. The use of web-based and other digitized resources provided an efficient methodology to assist in undertaking some of the background research required to evaluate the archaeological sensitivity of the project area, and in presenting the results in the draft report.
There have been a considerable number of historic and archaeological investigations conducted in the project area. It is challenging to review and consider the vast number of previous survey results, and to collate the resulting data and findings with the present project area. However, additional effort should be made to integrate previous relevant research results for the archaeological sensitivity evaluation for the APE.
Please review the MHC's Bibliography ofArchaeological Survey and Mitigation Reports to locate OJ1d cite other, pertinent or applicable survey and excavation reports for segments of the project
Some' possibly relevant archaeological reports a~e,poted below. Additional reports and other useful information may become evident as these aciditionalefforts'are undertaken.
While
cif these 'arid other reports to be located may hilV,e surveY: areas outside the APE, the results should be considered'fo{characterizing expected'resQurces in areas;witha similar land use history, and for offering reconllnendations and, in future, for developing a detailed research design and methodology. Please also review and consider relevant portions of Nancy S.
Seasholes' (2003) book, Gaining Ground for particular findings as well as additional
220 Morrissey Boulevard, Boston, Massachusetts 02125
(617) 727-8470· Fax: (617) 727-5128 www.state.ma.us/sec/mhc
documentary sources that might be useful to the research team For those stations and segments considered to be archaeologically sensitive and recommended for archaeological testing, please review utilities maps and also take that information into account in the sensitivity assessment and recommendations.
The Segment 5 MIT BRT Route (near Fort Washington in Cambridge [see Goodman 1975]) is presently not recommended for testing. This route appears to be within a railroad corridor, however I seem to recall that there are reports of unmarked burials in this vicinity. Please note the reports by Mair (2001) for the Kendall Station Interconnect, and by Deaton and Mair (2003) for the Cottage Farm CSO, in this general area of Cambridge.
Please consider that Melnea Cass Boulevard was part of the former Southwest Corridor project, and several reports by Bower, et al. for the Southwest Corridor project may include the present project area, would give additional information concerning expected resources, and might disclose additional information concerning previous impacts. Additionally, since Melnea Cass
Boulevard is very recently constructed, please consult local or state engineering records
(construction photos, 100% design plans, etc.) to further evaluate previous construction impacts in the Melnea Cass Boulevard portion of the project impact area.
Please consider the data on the Water Street Site in Charlestown (Shaw, et al. 1984) and the
Town Dock Prehistoric Site (Ritchie et al. 1994) as examples of the sort of expected resources that might possibly be present at Segment 4, Station 15 (Bunker Hill Community College).
The Management Abstract contains several typographic errors in the numbering system of the stations. Please correct these numbers to be consistent with the report text and tables.
These comments are offered to assist in compliance with Section 106 of the National Historic
Preservation Act of 1966, as amended (36 CPR 800), Massachusetts General Laws, Chapter 9,
Sections 26-27C (950 CMR 70-71), and MEPA (301 CMR 11). If you have any questions or need further information, please feel free to contact me.
~
Edward L. Bell
Senior Archaeologist
Massachusetts Historical Commission xc: Diana Parcon, META