December 7, 2005
Secretary Stephen Pritchard
Executive Office of Environmental Affairs
Attn: MEPA Unit
100 Cambridge Street, Suite 900
Boston, MA 02114
Subject: Museum of Fine Arts NPC, EOEA #12555
Dear Secretary Pritchard:
Thank you for the opportunity to comment on the Notice of Project Change recently filed on this project. The Boston Groundwater Trust was established by the Boston City Council to monitor groundwater levels in sections of the City in which building foundations are threatened by reductions in groundwater levels and to make recommendations for solving the problem. The Trust is a signatory to the Memorandum of Understanding that established the City-State Groundwater Working Group and is a member of that group. Our comments are restricted only to groundwater related issues.
In the October 2, 2003 Certificate of the Secretary of Environmental Affairs on the Final Environmental Impact Report on this project the Stormwater/Wastewater section included comments related to groundwater. The Secretary noted that "The proponent has also committed to consulting with the Boston Groundwater Trust to monitor groundwater levels, and potentially increasing groundwater recharge of site runoff." I am pleased to be able to report that the proponent has been reporting groundwater levels on a regular basis. However, there has been no discussion with the Trust about potential recharge.
As you may know, the Boston Redevelopment Authority has proposed a Groundwater Conservation Overlay District, one of the most important results of which would be to mandate recharge in areas of concern where previously pervious surfaces are covered by new buildings or paving. While this zoning has not yet taken effect, the MFA is clearly in an area of such concern. In addition, the readings provided by the museum have indicated two wells, OW-3 and OW-7, where readings are consistently over a foot lower than at the other monitoring wells. These may indicate a depression in the area that could be related to something happening at the museum. Discovering and, if possible, repairing the cause of these low readings would, in addition to recharge, help to raise groundwater levels in the area.
I appreciate the cooperation that the Museum has shown to the Trust so far. I hope that they will look to helping to raise, and not just monitor, groundwater levels as their expansion project moves ahead.
Very truly yours,
Elliott Laffer
Executive Director
