September 3, 2000 Secretary of Environmental Affairs Executive Office of Environmental Affairs ATTENTION: MEPA Office, Dick Foster RE: EOEA 11085R 251 Causeway Street, Suite 900 Boston, MA 02114 Dear Mr. Foster: I am writing to you as a life-long resident of South Weymouth and an elected official of Weymouth to comment on the ENF prepared by the South Shore Tri-Town Development Corporation (SSTTDC) for their proposed redevelopment of the former South Weymouth Naval Air Station. My first objection is to the possible Special Review Procedure which would allow the SSTTDC to submit the Environmental Impact Review (EIR) in phases. They have allegedly cut down the size of the proposed Mills Corp. Megamall/Entertainment center but there will be nothing to stop them from increasing the mall at a later date if the whole development is not addressed up front. At the ENF meeting held at the base on August 22, 2000 the possibility of a Citizen Advisory Committee was raised and that perhaps the existing SSTTDC Citizen Advisory Committee could fill that role. Please be advised that seven of that eleven member board were members of the 33 member Naval Air Station Planning Committee (NASPC) which, after floundering for over 18 months in their efforts to find a use for the base, when presented with the Mills Corporation Megamall/Entertainment, immediately embraced it. When the former chairman of the NASPC asked where the opponents were during all their meetings, let me state that I attended many, many of them along with a number of concerned citizens. When we were able to voice our opposition to the "plan" we were met with total inattention and in some cases snickering and derision. To say that there was citizen input to these "public hearings" is ludicrous. If a Citizen Advisory Committee is appointed it should consist of ordinary residents including those who will be adversely affected by this proposal. I understand that the Secretary is primarily interested in environmental issues but I think a discussion of some of the financial ramifications is in order. In Appendix B of the ENF on page 12 a reference is made to the $238 million in revenue this project will return to the three towns over a twenty year period. These projections were totally erroneous when presented and when I, an elected Weymouth Assessor for 30 years challenged them, I was ignored. It is interesting to note that while they have reduced the size of the Mills Corp Megamall/Entertainment center by some 1,000,000 square feet and realized that 10 acres of retail space on Route 18 is wetlands and cannot provide revenue to the SSTTDC, they continue to use the same projected revenue figure of $238 million over 20 years. Is it any wonder that people are skeptical of ANY numbers presented by the SSTTDC? TRAFFIC/AIR POLLUTION We are told that the daily traffic count to the base after the Megamall/Entertainment center is built will range from 45,000 to 75,000 vehicles per day. This will be like having a New England Patriots football game 365 days per year. It is interesting to note that in the Associated Transportation Infrastructure Improvements Sections of the ENF in none of the plans, such as Figure 1-1, Figure 1-2, Figure 1-3 or any other Figure does it show the existing Kingston/Boston tracks of the Old Colony Line. When they talk of the Connector Road from Route 3 to Route 18 they do not show a bridge which will have to span the tracks as well as Route 58 in Abington nor can I find any cost associated with it. The original plan approved by the three town meetings indicated that the Route 3 Connector would exit the Base on Trotter Road. That has quietly changed, even though any changes to the "plan" were supposed to be approved by the three towns. Another reason for citizens to be skeptical? The pollution generated by these huge numbers of cars (the average numbers will be much larger on weekends) will be intolerable. The light pollution from a 10,000 car parking lot will be discussed later. In the summer months the Cape Cod traffic on Route 3 on weekends is a nightmare and any of the minor adjustments to traffic in the SSTTDC proposal will have minimal effect on this problem. LIGHT POLLUTION It should be noted that the three town meetings unwittingly ( I say unwittingly because many town meeting members had no idea that they were zoning for a high rise hotel on the base) allowed the height zoning in the center core to be 125' which allows for a 10 to 12 story hotel to be built. No where in Weymouth would current zoning allow a structure of this size. The light pollution from a high rise hotel plus the lights from a 10,000 (est.) car parking facility would guarantee that neighbors will never again be able to view the stars, a passing satellite or any other celestial event! PURCHASE AND SALES AGREEMENT I realize that you are not primarily concerned with matters financial, but I feel that the recently signed tentative purchase and sales agreement with Mills Corp for their Megamall/Entertainment Center only adds to the general skepticism which many citizens feel towards the SSTTDC. In the P.&S. Mills agrees to purchase 155 acres of land for $153,000 per acre. House lots in Weymouth are selling for in excess of $100,000 per lot and you can get at least two lots to an acre. Mills has emphatically stated that they will not buy unless all the public improvements, including the access road from Route 3, are guaranteed. In the P.&S. Page 12 the seller, SSTTDC, is obligated for the "demolition and removal of existing improvements located on the Site, including, but not limited to, buildings, runways, roadways and underground utilities É" The buyer, Mills Corp, will "contribute $500,000 to the costs of such demolition É". The costs of these improvements will run into the millions. The 155 acres of IMPROVED land which Mills will be purchasing is worth close to $450,000 per acre rather than the give-away price of $153,000 per acre. ALTERNATE USES I have always felt that some form of Research and Development would be the ideal use for the SWNAS. It would create real jobs, rather than minimum wage mall jobs which will be difficult to impossible to fill. One of my constituents suggested a pharmaceutical research and development center which could be very successful in this area. There are literally hundreds of uses for the South Weymouth Naval Air Station which would be far superior to a Mills Corp Megamall/Entertainment Center. On paper some of these uses might not appear as economically viable as a retail mall but the quality of life, the horrible effects on traffic on the entire South Shore and the overall assaults on the environment far outweigh any POSSIBLE monetary advantages. (Have you ever seen an authority such as the SSTTDC return any monies to a host community?) WATER AND SEWER To date the issues of water and sewer have never been properly addressed. At the ENF meeting of August 22, 2000 at the base, Mr. Ken Goff, Director of the SSTTDC, stated that they were going to begin seismic testing of the two aquifers located on the base property and to install some test wells for water quality and quantity. This work cannot be completed before the December 15, 2000 date before which Mills or the SSTTDC can back out of the P.&S. On page 19 of the ENF one of the possible alternative solutions for the water supply includes "service from the town of Weymouth municipal system". There was an absolute guarantee that NO WATER OR SEWER SERVICES FROM WEYMOUTH WOULD BE USED FOR THE DEVELOPMENT OF THE BASE. How can you possibly be expected to issue an EIR when the issues of water and sewer have not been adequately addressed? CONCLUSION There are many sections of the ENF which I will allow people with more expertise than myself to comment upon. Some of these are the Rare Species Section Pg. 13, Wetlands, Waterways etc. Section, Pg. 14, Air Quality Section, Pg. 28 and Historical and Archaeological Resources Section, Pg. 30 among others. Polls in the local newspaper and contact with scores of voters through letters, e-mails and the telephone lead me to believe that a large percentage of area residents are vehemently opposed to this project. DO YOU BLAME THEM FOR BEING SKEPTICAL? Sincerely, Paul J. Leary Town Council President District 5 Councilor 187 Pleasant Street Weymouth, Ma 02190-2507