June 10, 2014
Secretary Richard Sullivan
Executive Office of Energy and Environmental Affairs
c/o Deirdre Buckley, Director
100 Cambridge St. Suite 900
Boston MA 02114
Re: Comments on EEA #13989, Notice of Project Change: Assembly Row Revised Program for Partners Healthcare Site
Dear Secretary Sullivan:
This note is in response to the Notice of Project Change for the Partners Healthcare site in Assembly Square, Somerville. I am excited that Partners Healthcare is moving its administrative offices to Assembly Square, bringing in up to 4500 jobs, together with fees in lieu of Somerville property taxes. The comments that follow are intended to make an already good development better for the employees of Partners Healthcare, the Somerville community, and the Commonwealth of Massachusetts.
Loss of Street Grid
Ref. V. 1, p. 1-2. “The Project will utilize urban streetscape design and provide improved accessibility to the Mystic River Waterfront.”
The current design for the Partners Healthcare site does not use urban streetscape design principles, nor does it provide enhanced circulation and access as mentioned on pp. 1-3, 1-6, 1-21, and elsewhere. The primary problem is that the design combines six potential city blocks into one block, resulting in a design suitable for a suburban industrial park, not for a city. The Phase A building along Revolution Drive is three blocks long and the parking garage along the Community Path is at least that long.
At the Revolution Drive end of the Partners site, Assembly Row terminates at a walk-through into the Partners Healthcare site. While there are public amenities, such as ground-floor retail, along Revolution Drive, these amenities end on the other side of the walk-through. The ground floor on the other side of the walk-through is almost entirely specific to Partners Healthcare, and there are no amenities on the other side of the parkland, just a parking garage. While members of the public can enter the parkland, there is little for them to do there besides walk, with nothing in particular to walk to.
At the Lombardi Street end of the site, citizens of Somerville entering from Sullivan Square are confronted with the entrance to the Partners Healthcare parking garage. There are no amenities, such as ground floor retail, nor any access to the rest of the Partners Healthcare site without parking and walking through the garage (which may not be allowed for non-employees in any case). There is no access to Draw 7 Park from the Lombardi Street end of the site. To reach the rest of Assembly Square, a driver must continue along Grand Union Boulevard all the way to Revolution Drive. When, at a future date, the defunct Circuit City site is repurposed to office/R&D drawn to the area by the presence of Partners Healthcare, the employees working there will be confronted by a very large parking garage with no amenities.
Loss of Sight Lines to Boston
Ref. V. 1, p. 3-10. “Non water dependent uses must be developed in a manner that protects the utility and adaptability of the site for water-dependent purposes by preventing significant conflict with structures or spaces which can reasonably be located on or adjacent to the site.”
Part of the value of the river for water-dependent uses is viewing the Boston skyline from the river. The proposed Phase A building and parking garage together block the sight line from the Mystic River along Assembly Row toward the Boston skyline except for a small walk-through space. The windows above the walk-through are not configured to allow skyline views. The proposed Phase B building and day-care center block the sight line completely.
* Vehicular exhaust from the parking garage venting at ground level will adversely affect riders along the Community Path, as well as users of the proposed day-care center on the Grand Union Boulevard side of the parking garage and of the proposed Partners Healthcare parkland.
* The phased opening of Assembly Row has already brought traffic jams to Rt. 28, Middlesex Avenue, and other roads bounding the site. However, the Transportation Management Association (TMA) mentioned on p. 1-22 does not yet exist. In addition to the growing need for traffic management on the site, both the Final FEIR and the settlement agreement with the Mystic View Task Force require the creation and funding of the TMA.
* Some of the bicycle access improvements, such as the pedestrian walk lights under I-93, have been completed, but the I-93 walk-through, bounded as it is by salt piles on one side and vacant concrete on the other, is very uninviting, particularly after dark.
* The Shadow Study in Figure 3-3 of the Notice of Project Change includes diagrams that have been scaled and cropped too tightly to allow realistic evaluation. In particular, the diagrams for December AM and PM make it appear that the shadow of the parking garage is longer than that of the main building, which is almost twice as tall as the garage. Because the shadow of the main building will fall across both Assembly Row and Grand Union Boulevard, both of these streets will probably experience heavy shadow for much of the day in December, a situation that requires mitigation.
* The air-quality analysis in the proposal used out-of-date air quality standards, particularly with regard to the effect of black carbon on climate. The analysis needs to be updated for compliance with the new standards.
Suggested Design Changes
I suggest that Assembly Row be routed through the building and bent to the right to join with Grand Union Boulevard at a point past the site of the proposed day-care center. If upper-story connections between the two sides of the main building are required, they should be constructed with full-height, full-width, high-transparency, infrared-blocking windows rather than with, as at present, ordinary windows above waist-high, view-blocking walls. Such windows will not only provide improved views of the Boston Skyline from the Mystic River end of Assembly Row, they will provide employees of Partners Healthcare a matchless view of Boston, Assembly Square, and the Mystic River.
Instead of stopping public amenities after the pass-through, the design should include ground-floor retail on the right side of Assembly Row and the Partners Healthcare parkland on the left. This will give Partners Healthcare employees and Assembly Row patrons access to common amenities, integrating Partners Healthcare into the community and making it a better place to work.
At the Lombardi Street end of the site, I suggest that the parking garage be designed from the first as a long narrow rectangle extending to the Lombardi Street corner of the lot, allowing better sight lines and more parkland. On the Community Path side of the garage, I suggest that a green barrier be provided along the building, and that the first floor be designed with solid walls to vent automobile exhaust up and away from users of the Community Path. On the Grand Union Boulevard side of the garage, I suggest that retail and other first-floor amenities be included, with the second floor garage again venting up and away from users of the day-care center and of the parkland on the Partners Healthcare site.
To further improve air quality around the parking garage, I suggest that a green roof be added to the garage, with access provided from Partners Healthcare, from the Community Path, from Grand Union Boulevard, and from Somerville citizens entering from Lombardi Street. This amenity would improve the life and health of Partners Healthcare employees and citizens of Somerville, and provide a model for healthy mixed-use developments worldwide.
I hope that these suggestions will be adopted and that they will make this development, already good, even better for Partners Healthcare, the City of Somerville, and the Commonwealth of Massachusetts.
Thank you for your attention.
25 Hancock Street
Somerville MA 02144