The Longfellow Bridge between Cambridge Street in Boston and Main Street/Broadway in Cambridge is finally in the design stages of a long-awaited rehabilitation. Much of the minor steel framing needs repair/ replacement, the entire deck needs replacing, and the towers are leaning and need to be rebuilt.
Good news: Mass. Highway Dept. (MHD) has the design under way and just filed its Environmental Notification Form (ENF), part of a state environmental review process for projects.
Not so good news: This is a vital transportation link (Red Line, pedestrians, bicycles and motor vehicles) and these links need to be better accommodated during construction.
I have copied my letter of comments on the ENF below, which details my concerns regarding how the project is accomplished.
Though I may have some concerns, it is paramount that the project proceed as soon as possible, once the construction staging issues are incorporated into the project plans.
___________________________________________________
Secretary Ian A. Bowles
Executive Office of Energy and Environmental Affairs
Attn: Anne Canaday, EEA #14384
100 Cambridge Street, Suite 900
Boston, MA 02114-2524
Anne.canaday@state.ma.us
RE: Massachusetts Highway Department (MHD)
Reconstruction of Longfellow Bridge
Boston & Cambridge, MA
Comments on Environmental Notification Form
Dear Sec. Bowles:
Thank you for the opportunity to comment on this important project. For the ease of identifying comments in contrast to statements and discussions, my comments are in underlined italics.
The Longfellow Bridge is an important multi-modal link connecting Boston and Cambridge and part of a regional system of roadways, transit lines, walkways and bicycle facilities. It is also an important route for emergency preparedness, in that it leads directly to a major hospital (Massachusetts General).
I have multiple interests in this project.
First, around 1982, I was the project engineer with DeLeuw, Cather & Company, consultants for the MBTA for the design of the platform extensions of Charles Station onto the Longfellow Bridge:
- MHD and their consultants (Jacobs) can blame me for the difficulty of the pinch point created where the platform extensions reach onto the bridge. I designed those pinch points into the roadway to accommodate the platform extensions.
- Back in 1982, I stood with Dave Lenheart of the then MDC on Span #1[1] of the bridge with the deck opened up as we looked upon the rusted structural steel. Thus, I can say personally that this repair project is long overdue and MHD should expedite this project to the extent possible.
______________
[1] Span #1 is labeled on sheet 32 of 59 (titled “Construction Stages, Stage 1, Sheet 1 of 4”) in Attachment 2 to the ENF.
Second, I use all 4 modes of the bridge, particularly in getting to work. Normally, I take the Red Line (over the Longfellow Bridge). When the weather is nice, I try to bike in once or twice a week (over the Longfellow Bridge). When I need a vehicle for work-related travel, I drive (over the Longfellow Bridge). And sometimes if the weather is nice (like after the MEPA hearing last week) I walk home (over the Longfellow Bridge).
So, clearly I have a stake in ensuring that the project will maintain all four modes during and after construction.
Final Configuration
I applaud the project design as presented in the Environmental Notification Form (ENF) in its inclusion of all four modes at the end of construction: pedestrians, bicycles, the Red Line and motor vehicles.
Alternatives for Eastbound (Inbound) Boston ApproachPage 6 of the ENF describes three alternatives were developed to address the pinch point caused by the inbound platform extension I designed some 27 years ago.
At first, I would agree with the preferred alternative 1 for the Boston approach (as described on page 6 of the ENF). This alternative accommodates a sidewalk, a full bike lane and 3 approach lanes to the Charles Circle signalized intersection.
However, it moves one retaining wall into parkland. Regarding this issue, there are both state and federal concerns:
- From a historic resources perspective, I agree with the ENF’s assessment that although there is some loss of parkland, this is compensated by the historically-sensitive treatment of the relocated wall. Assuming the Massachusetts Historic Commission (MHC) and the Boston Landmarks Commission (BLC) concur, this issue should not delay the project in terms of the historic approval process on the state and local level. The MHD should confirm that moving the wall is acceptable to the MHC and BLC.
- On the other hand, this is a 4(f) parkland taking from a federal perspective. Since MHD intends to use federal funds in part for this project, MHD should address this issue of whether the 4(f) issue will delay the project start-up by requiring a separate environmental review under the federal NEPA process. The MHD should address this issue of possible project delay due to 4(f) issues related to federal funding.
Conclusion on Alternatives:
I have different conclusions that depend on whether there would be a delay in federal funding due to 4(f) issues:
- If there are significant schedule delays in project startup due to parkland taking, then I agree with the ENF’s conclusion that Alternative 1 is the best.
- If there are significant schedule delays in project startup due to parkland takings, then I recommend Alternative 3 (no wall relocation) combined with the widening of the sidewalk over Span #1 as included in Alternative 1.
Construction Staging
During construction, it is essential that all four modes be accommodated. But more than that, construction presents an opportunity for an exemplary approach: incorporating energy and environmental policy by shifting modal use from motor vehicles to the more modes that expend less energy and pollute less (i.e., walking, bicycling and transit). The MHD should look into ways to reduce motor vehicle trips and shift trips to the other 3 modes.
Page 7 of the ENF describes two options, both of which raise some concerns.
Option 1 would take an estimated 12 to 18 months less than Option 2. It would maintain Red Line service and one 10-foot wide sidewalk for pedestrians. However, it would maintain only one inbound travel lane a little over 14.5 feet for both bicycles and motor vehicles. Outbound bicycles and motor vehicles would be detoured over the Cragie Bridge. Problem with this approach include the following:
- The outbound bicycle detour is simply not reasonable. Bicyclists will not detour to the traffic-congested Leverett Circle area. Rather, they will travel westbound on the open sidewalk. A better plan for two-way bicycle accommodation during construction is needed.
- The outbound motor vehicle detour into the traffic-congested Leverett Circle is equally unreasonable. The peak hour delays waiting for several light cycles at the Circle and at the Land Blvd./Gilmore Bridge/O’Brien Highway intersection. I would also detour traffic towards the site of the relocation of Lechmere Station for the Green Line Extension at the exact same timeframe as this project. Furthermore, consideration should be given to detouring traffic towards the Harvard Bridge (Massachusetts Avenue). A better detour plan is needed that considers a more regional approach and considers other EOT projects (e.g., Green Line Extension)
- However the greatest concern is for emergency access. With MGH at Charles Circle, the Longfellow is an important ambulance access route. Likewise, the bridge is used for other emergency purposes including mutual response to fires as well as police and other law enforcement agencies. Let me emphasize the importance of this issue. Two years ago, my son and I went bike riding. Once home, his heart rate did not decline. After a few hours my wife took him to Cambridge Hospital. Once they realized the situation, they were immediately rushed to Massachusetts General Hospital where they had the experienced doctors who know what immediate action was needed. My son is fine now, in part because the ambulance was able to cross the Longfellow Bridge without delay.I cannot underestimate the importance of maintain emergency access in both directions.
o MHD should consult with Boston, Cambridge and state emergency departments (police, fire, EMS) before any further consideration of Option 1.
o MHD should not pursue Option 1 without provisions for two-way emergency access across the Longfellow Bridge 24/7/365 throughout construction.
Option 2 would take an estimated 12 to 18 months longer than Option 1. It would maintain Red Line service and one 10-foot sidewalk in all phases. It would maintain motor vehicle access in either direction in one or two lanes. It is unclear from the plans included how bicycles would be accommodated during construction.
- Option 2 is clearly superior with regards to emergency access and the detouring of traffic. Still, construction activities will inevitably cause some motorists to seek alternative routes, be they the Craigie or Harvard Bridges or other routes.
- Option 2 does not clearly indicate how two-way bicycle accommodation will be maintained during construction.
- Comments:
o Option 2 should be considered the preferred option
o MHD should better describe how two-way bicycle access will be provided through all the states of construction.
Storm DrainageThe ENF states on page 10 that it is not practical to meet all stormwater standards. In particular, the ENF states there is no room on the bridge for sediment collection or pollution removal systems. Also, with the exception of the first 2 spans in Boston, no runoff will be diverted to existing storm drainage systems. For the spans over water, the scuppers will simply drain into the river.
While full diversion of flow does not appear practical, improved water quality could be obtained if it were possible to divert the water quality volume (WQV) or first 1 inch of runoff to some form of sediment control and/or water quality enhancement device.
Consideration of attempting to treat about 1” of runoff was brought up by the representative of the Charles River Watershed Association at the ENF meeting on April 30th.
Based on that comment, my thought was to see if there could be one device per span, maybe located over the pier. The scuppers would drain to this device, which would retain the WQV and let the excess flow discharge to the river. This would at least provide some treatment for the initial runoff, which is more heavily laden with contaminants.
As the ENF does not include any WQV calculations, I have provided a calculation of the WQV for one span of the bridge, based on 1” of runoff:
A = W x L
A = (2’ +11’ + 11’ + 5’ + 10’) x 150’
A = 5,850 SF
A = 0.134 Acres (based on 1 acre = 43,560 SF)
WQV = 1” x A
WQV = 1” x 0.134 Acres
WQV = 0.134 Acre-Inches
WQV = 487.5 CF
This represents a rectangular tank approximately 6’ x 8’ x 10’. Other shapes could be used. The device would need convenient accessways from the roadway to allow inspection, cleaning and other maintenance.
A tank to hold a WQV based on 1/2" of runoff would be half that size.
I am not familiar enough with the structure to determine if such devices could be stowed somewhere above the piers, so they are maintainable but do not create a visual impact.
MHD should consider whether it is feasible to provide some sediment removal and water quality enhancement, be it for a 1” WQV or even 1/2" WQV. This could be by a tank, maybe with a vortex device or a filter, located in the piers. Flows greater than the WQV would overflow, either at the scupper itself or at the tank.
Other Comments
- Section III (Consistency) should include discussion of:
o Consistency with Grown Policy, and
o Consistency with the Massachusetts Bicycle Plan.
Thank you for the opportunity to review the ENF for this very important project. I look forward to seeing the bridge under construction soon and restored to structural good repair in the years to come.
John,
ReplyDeleteHere is my MEPA comment. It does not fit very well on this tiny scren, but here goes.
I suppose for two engineers entirely in sympathy with good hopes for the Longfellow Bridge, we certainly approached the process and the design in different directions.
=============================================
To : MEPA Unit of EOEEA,
From : Stephen H. Kaiser, PhD.
Environmental Notification Form and EIR/Scoping Decision for the Longfellow Bridge, Boston, Mass. EEA # 14384
The Longfellow bridge may be the most famous bridge over the Charles River basin, and after the Federally funded rebuilding of the Harvard Bridge, the Longfellow now appears to be the oldest. It was built in 1906 as the first phase of a public-private partnership. The state built the bridge itself on the site of the old West Boston bridge, while a private entity (the Boston Elevated Company, owned by famous financier and tycoon J. P. Morgan) would construct the transit structures, including the station at Charles Circle, in 1912.
As fate would have it, the design for the privately-funded transit tracks contained a design flaw, a spacing of several inches on either side, which was hastily filled with concrete. Over the years, these concrete sections cracked and leaked and with the increased use of roadsalt on roads starting in the 1950s, the corrosion of the bridge increased, with considerable damage in the center of the bridge. With the passage of years, the corrosion extended to other sections of the bridge, so that the past decade has been a lengthy period of inspection and repair.
In 1959, a new deck was installed on the bridge, providing for three ten-foot travel lanes and at several locations left severely narrowed, almost unusable sidewalks. Painted bikelanes were added by the MDC in 1973, and wiped out in the 1980s during station platform extensions by the MBTA. MDC in later years slowly
painted increasingly wider bike lanes until they appear as they do today.
In 1989-1990, the Secretary of Environmental Affairs John DeVillars made a valiant but unsuccessful effort to have repairs made to the Longfellow Bridge as part of the Charles River mitigation for the Big Dig bridge crossing known as Scheme Z, but state and Federal transportation officials nixed the idea. I do not remember the exact budgeted figure, but it was in the low tens of millions of dollars, in contrast to the estimated cost of $280 million for this project today. Around 2000 MDC offered to handle the repair and rebuilding project, but MassHighway insisted on taking control of what it considered to be a "prestige" bridge project.
To their credit, MassHighway has shown great sensitivity to historical preservation of many elements of the structure. The bridge is on parkland and widening on the Boston end will required extending the highway elements onto parkland. For that reason, a Federal Environmental Assessment will be required to deal, at a minimum, with issues of historic preservation and consideration of parkland preservation/alternatives associated with Section 4(f) of the Highway Act of 1966. At the April 30 MEPA consultation meeting, I offered the suggestion during the public comment period that a possible resolution of the matter of an Environmental Impact Report would be that a MEPA EIR could be a document identical with the Federal Environmental Assessment and having a similar public review period. The MassHighway representative responded to my suggestion without mentioning "EIR" or "Environmental Impact Report" even once.
The failure to discuss the role of Environmental Impact Reports was not limited to MassHighway. It was fundamental to the MEPA presentation itself. As an introduction to the detailed MHD PowerPoint display, the MEPA director spoke from her own PowerPoint presentation -- included in a handout and as Attachment A to my comments.
The MEPA process was presented in eleven slides, not a single one of which mentions the words "Environmental Impact Report" or "EIR." There is no mention of projects that are categorically excluded from review or those which may be categorically included for review, namely to prepare an EIR. A project like the Longfellow Bridge is in the gray area of requiring an ENF but not an automatic EIR.
This fact was not presented to the audience on April 30, not was it included in the slide show.
This omission is most peculiar. The standard certificate of the Secretary on the Environmental Notification Form (issued after the end of the public comment period) begins with the finding that "Pursuant to the Massachusetts Environmental Policy Act (G.L. c.30, ss 61-62J) and Section 11.06 of the MEPA regulations (301 CMR 11.00), I hereby determine that this project does / does not require the preparation of an Environmental Impact Report (EIR)."
Here we have a self-evident fact that the purpose of public input is to assist the Secretary in making a determination on whether or not an Environmental Impact Report is required, and the key public meeting in this process made no mention of the words "Environmental Impact Report" until the question was raised from the audience. The emphasis in the presentation and handout would suggest that because of the identification of the triggers for filing at ENF (slide 7) and of the time that MEPA review ends (slide 8) with no mention of an EIR, that a decision has already been agreed to by EEA and understood by MHD that an EIR will not be required.
In other words, the public is not being told the full extent of their rights under the law and regulations.
Such an omission could have been seen as innocent, if it did not also occur at a MEPA consultation meeting in Greenfield for a controversial $250 million biomass plant for which the Secretary on on April 24 determined that no EIR was necessary. Again, neither MEPA staff nor the proponent made any mention of the possibility of an EIR or that the Secretary would be making a decision on whether or not an EIR would be required.
The Longfellow Bridge consultation meeting had the benefit that at least the EIR issue was raised from the floor, and that the discourse was conducted in a courteous manner. In the hope that MEPA and MHD have not predetermined whether an EIR should be required or would be prepared to reverse any such decision, I will identify
the issues which I believe warrant consideration of further MEPA review in some form.
The ENF is intended to identify those state permits which maybe required. In the matter of possible Article 97 actions, the ENF indicates that no Article 97 actions are required, because the bridge is now and will remain under the care and control of the Department of Conservation and Recreation. I agree that this interpretation is correct, provided that the Legislature and Governor do not approve any bill proposing to transfer DCR bridges to MassHighway -- as currently advocated by the Senate version of the Transportation bill.
The ENF on page 2 indicates that no Chapter 91 will be required. On page 17, the MHD uses the passive voice to claim that "chapter 91 authorization is not believed to be required for this activity because the entirety of this historic filed tidelands is not considered filled tidelands under regulatory control in an area like the Charles River Basin that is outside a designated port area." The changed retaining walls "is just beyond" a distance of 250 feet from "the limit of mean high water."
Both of these criteria are mentioned in 310 CMR 9.02 in the definition of "landlocked tidelands" yet the ENF makes no specific reference to landlocking or its implied claim. If indeed MHD is claiming landlocking for this site, that would mean that every site upstream of the Longfellow Bridge would be similarly judged to be landlocked -- and it is my understanding the DEP Waterways has traditionally asserted licensing jurisdiction for filled tidelands adjacent to the Charles River and, I believe, the Muddy River. I am very aware of Chapter 91 licensing activities in the Broad Canal, immediately downstream of the Longfellow Bridge. Thus MHD would need to overcome DEP licensing jurisdiction along the Charles River Basin as DEP's traditional and existing policy indicates.
Based upon the February 2007 SJC decision in Moot vs. DEP and in subsequent discussions and interpretations, earlier attempts to apply standards of "flowed tidelands" do not apply to a fresh water basin (such as Charles and Mystic Rivers) controlled by a dam to limit tidal effects. However, the tidelands remain and the
criteria for landlocking is the presence of a public way that "entirely separates" a filled tidelands area facing the sea from one facing inland. A bridge with an opening to allow access underneath such as water, yachts, duck boats, etc. does not provide for entire separation. A physical line of crossing such as edge of pavement might so separate, as might a legal line such as a defined right-of way. But for the Charles and Mystic basins, the entire system is a park and is one continuous piece of parkland -- with bridges, parkways and other facilities attached to it. The bridges do not separate, and hence the land around Longfellow Bridge is not landlocked tidelands.
Suppose we adopt the viewpoint attempted by developers in Moot vs. DEP and in DEP testimony in a recent tidelands case, In the Matter of the Coalition to Preserve the Belmont Uplands, Docket No. 2008-069. The claim that a plan view perspective can be applied is not defined in the regulations but has been interpreted as looking at a map and if a bridge crosses a river channel, then a plan view perspective would provide a separation line and any passage space underneath the bridge would be ignored. By this criterion as applied to the Charles River Basin, all filled tidelands upstream of the Zakim Bridge would be landlocked. Chapter 91 review would be sharply curtailed.
Even more dramatic would be the precedent established by application of this "plan view" concept. The General Edwards Bridge from Revere to Lynn could in plan view be seen as "entirely separating" and thus the entire Saugus Marshes could become vulnerable. Because 310 CMR 9.00 makes no distinction regarding illegal filling of tidelands, anyone filling in the Saugus Marshes could now declare themselves landlocked and beyond all regulation and enforcement.
The bottom line here is that a Chapter 91 license is required for the Longfellow Bridge. This requirement should not be a major problem for MassHighway as long as they recognize their legal obligation.
For the Historical reviews described in pages 25-27 of the ENF, I could find no reference to the requirements of M.G.L. Chapter 9, Section 27C. This section requires that the MHD contact the Mass Historical Commission so that within thirty
days of such notification the MHC will "determine whether such project will have an adverse effect" on a state register property. The Longfellow Bridge is a contributing element in the state-registered Charles River Basin Historic District.
The ENF says nothing about the required notification of Section 27C or a decision on possible adverse impact. There appear to be on-going discussions relative to Federal Section 106, but there is no evidence of compliance with Chapter 9 of state laws.
In the matter of alternatives, MHD has proposed alterations to the bridge connections to Charles Circle, with widening of the pavement and sidewalk widths to allow for existing traffic, a bicycle lane and a suitable sidewalk. The alternatives proposed by MHD deal in a sensible way with altering the approach, while retaining the architectural appearance and integrity of the bridge masonry on the approaches. The parkland affected has been made minimally accessible by historical filling to create the Storrow Esplanade and Storrow Drive/Embankment Road, so that the parkland affected by the widening of the bridge approaches is of lesser value than parkland closer to the river.
The issue of alternatives that is much more crucial for me is the need to repair the bridge with minimal changes to those design elements which are structurally adequate and warrant historical preservation. The current bridge has three prominent design defects or limitations :
1. A poorly design deck added in 1959 and now needing complete replacement,
2. Crossbracing needed to deal with seismic contingencies
3. The already-mentioned defective design adjacent to the transit track supports
Otherwise, the Longfellow Bridge is superbly designed, with design safety factors well above what is required for bridge structures constructed in the past half-century. Its design integration is so interdependent and multiply supported that an entire structural collapse as occurred in the 1965-vintage Minneapolis bridge is virtually inconceivable.
For these reasons, I am worried about more extensive modifications to the bridge, such as replacement of interior arches with straight beams and other wholesale changes while will not only change the historical nature and integrity of the bridge but will significantly increase its cost. The ENF talks loosely of MHD design standards and of bridge rehabilitation -- terms which could result in final design with significant alteration in the bridge structure, appearance, historical integrity and cost.
It is fair to note that the reconstruction of the Harvard bridge in the 1980s involved the complete replacement of the superstructure, while retaining the original stone piers from 1891. This bridge had a severe design defect in its dependence on eye-bar supports which were critical structural elements whose failure could result in the loss of an entire span of the bridge. Thus the Federal design goals were looser and allowed for a new bridge which at least reflected the original design without duplicating it. The Longfellow Bridge, with its superior design and survival of many steel elements in reusable condition, is a candidate for a much stronger objective of pure preservation, both for historical reasons and for the evidence of excellence in structural design.
It is for these reasons that I recommended at the April 30 consultation meeting that an alternative be considered which was more historically accurate, that utilized more of the surviving steel where structurally adequate, that all arch ribs be preserved or repaired, and that the support stricture above the ribs also be retained or repaired. Again, I reiterate my support for this alternative and recommend that this alternative be considered in the Section 106 and Chapter 9 Section 27C reviews.
In these times of severe infrastructure decay and limited budgets, I cannot see justification for unnecessary capital expenditures, when other projects may go begging. Where the Longfellow Bridge is basically a sound design, restore it to its original excellence as the public would prefer. Give the public back the salt-and-pepper bridge in all its original grandeur. This bridge, originally estimated a decade ago to require $50 million in repairs, could be restored to (another) full lifetime for $150 million to $200 million. Such a cost is still sizable and the upper limit is equivalent to the notoriously expensive high school proposed for the City of Newton.
The lower cost limit is close to the high school costs in Wellesley and Cambridge. It may even be that all of the vital construction can be done for less than $150 million.
At the April 30 meeting I mentioned the needs of other bridges, such as the Braga Bridge in Fall River. When I last saw the Braga, it was posted for an 18-ton load limit. Yet I observed numerous trailer trucks hammering the expansion joins with the telltale deep thumping sound of a bridge in severe trouble. The current posting on the MHD Website shows the proposed Braga work in two work elements totaling about $28 million scheduled for this critical 1957-vintage interstate structure -- only 1/10 the amount proposed for expenditure on the Longfellow:
FALL RIVER- SOMERSET- BRIDGE PAINTING, F-02-058=S-16-008, ROUTE I-195 OVER THE MHD $15,542,256.50 Fall-2007 Summer-2008 Fall-2008 Fall-2011
TAUNTON RIVER (BRAGA BRIDGE)
FALL RIVER- SOMERSET- BRIDGE PRESERVATION, F-02-058, I-195 OVER THE COMB SR 79 & MHD $12,847,800.00 Spring-2008 Fall-2009 Winter-2010
TAUNTON RIVER (BRAGA BRIDGE)
As much as I support the repair of the iconic Longfellow Bridge and retention of its vital historical elements, I cannot support spending ten times more on the Longfellow Bridge than on the Braga Bridge, which even sounds in greater distress.
Furthermore, DCR currently employs the world's most knowledgeable expert on the Longfellow Bridge, so I would advocate that DCR accept the responsibility for the further design supervision and historical preservation. At the moment, I have full faith in their ability to achieve the cost savings I have outlined above.
Finally, DCR has hired a very competent traffic consultant to assist in handling traffic operations caused by construction and periodic shutdowns of sections of the Storrow Tunnel. The agency also hired another competent traffic consultant to oversee the design and construction of the reconfigured Charles Circle -- a vital element in how the Longfellow Bridge functions. I believe that these two traffic
consultants could develop a feasible and minimal-impact traffic plan that would allow for the staging of construction of roadways and transit on the Longfellow.
At the April 30 meeting, MHD proposed an "alternate" traffic plan whereby the outbound traffic headed towards Cambridge on the Longfellow Bridge would be required to detour due to road closure. The alternate route would be to take a left turn at Leverett Circle, and then another left turn at either O'Brien Highway and Land Boulevard ..... or at Lechmere Square (with its heavy volumes of pedestrians crossing Cambridge Street). I could counsel compassion for whoever thought up this traffic plan, but I would expect some of my traffic engineering compatriots to be far less compassionate.
It should be sufficient, in this era of attempted reform in transportation, to follow the best rule for seeking out the most competent and experienced people we can find. It would be wise to place two such traffic engineers in the position of judging how traffic might be handled and detoured with minimal disruption during the reconstruction of the Longfellow Bridge. Appointing excellent personnel should be considered a form of mitigation.
Sincerely,
Stephen H. Kaiser, PhD