From: WalkBoston, Charles River Conservancy, Charles River Watershed Association

To: MassDOT – officials, staff, consultants Review Team on the I-90 Allston Interchange Improvement Project

Date: August 15, 2018

Re: Charles River – Restoration of the River Edge

On behalf of three organizations committed to the protection of the Charles River and its parklands, public access and pathways, and environmental health we jointly request that MassDOT fulfill its responsibilities to this invaluable resource by analyzing and developing options for the ecological restoration of the severely degraded and eroded riverbank in the I-90 Interchange Project area – from the BU Bridge to the River Street Bridge. This Project directly impacts the Charles River Basin , its parkland, ecology, water quality, and overall resiliency; dealing with those impacts is integral to the Project.

A study by MassDOT in advance of the FEIR should include re-establishment of a more natural edge, bank restoration, stormwater management, and increased floodplain connectivity and storage for resiliency. It should explore at least one alternative that creates better habitat and provides flood storage through the use of fill material in the river to accomplish these objectives. We ask that between now and when the FEIR is produced, a detailed analysis of alternatives, carried out in a collaborative manner, be developed so that results can be incorporated in the FEIR.

The DEIR did not adequately consider the need to restore the river bank, improve the park, and improve water quality. The DEIR has chiefly dealt with these impacts by trying to avoid them on the theory that permitting for the Project would be more difficult if river edge improvements are included. We are convinced that the contrary is true: a serious examination of these improvements would enlist substantial support from organizations, municipalities, and agencies committed to restoring environmental quality in this area – support that will be important to obtaining required approvals.

Restoration of this area requires attention to a number of issues and several important state and federal requirements, including:

1. Protect the river bank from further degradation and restore aquatic and riparian habitat. Much of the existing bank is degraded and eroding, eliminating fish habitat. The Charles is an important fish run for alewives, blueback herring and American shad, migratory fish that return to the river each year to spawn.

2. Provide parkland and improve safe walking and biking conditions as part of multi-modal improvement called for in MassDOT’s Project “purpose and need” statement and under Article 97.

3. Reduce stormwater runoff discharging to the river via overland flows and outfalls, including the 13 outfalls along Soldiers Field Road in the Throat Area. Both MassDOT and DCR have regulatory obligations to comply with phosphorus limits established in the state’s Lower Charles River Basin Nutrient Total Maximum Daily Load (2007).

4. Provide flood resilience, control and storage capacity for precipitation-based inland flooding within the context of current and expected climate change impacts.

5. Develop landscape strategies and designs that provide Section 4(f) mitigation. Removing invasive species, dead trees and replanting with native vegetation, in addition to incorporating green infrastructure, should be integral to the study.

6. Plan for the riverfront parkland, which is a water-dependent use under Chapter 91.

7. Meet historic requirements for the Charles River Reservation in the Charles River Basin Historic District included in Section 106 of the National Historic Preservation Act and Massachusetts Historical Commission review.

8. Comply with the Article 97 no net loss policy that requires replacement of parkland that is to be taken by the Project.

One example of how an alternatives analysis could address these issues is the environmental assessment and recommendations prepared for the North Shore Riverfront Ecosystem Restoration Project in Pittsburgh, PA. It provides extensive river edge improvements, including a natural bank, new pathways, landscaped parklands, connected floodplain, and wetlands. It was developed jointly by local environmental organizations and local, state and federal agencies, including the US Army Corps of Engineers. (https://www.lrp.usace.army.mil/Portals/72/docs/ProjectReviewPlans/N%20Shore%20Riverfront%20DP R%20MSC%20Approved%20for%20Release.pdf?ver=20160524161651743)

We are committed to working cooperatively with you in this process in order to evaluate the options and to achieve results in an expedited and cost-effective manner to restore and enhance this area of the Charles River and the Basin parklands.

We look forward to your response.

Wendy Landman, Executive Director, WalkBoston
Laura Jasinski, Executive Director, Charles River Conservancy
Margaret VanDusen, Deputy Director and General Counsel, Charles River Watershed Association

Please join WalkBoston, the Charles River Conservancy and the Charles River Watershed Association at a “Throat” Walk, September 12, 5:30 PM. We will meet at “BU Beach” behind the Marsh Chapel.

Images from Environmental Assessment of North Shore Riverfront, Pittsburgh