Many community members have expressed concerns about the site plan, traffic circulation problems, and very high density of BDG’s proposed Cleveland Circle mega-complex. Research into the very low truck delivery estimates provided by Howard/Stein-Hudson in BDG’s PNF revealed significant errors in those projections, meaning that there will be dozens more trucks making deliveries to the project every day. This reality will further clog the already overloaded interior courtyard. All good reasons to worry that Cleveland Circle will suffer from traffic gridlock if BDG’s project is approved by the BRA in its current form.
In the midst of these valid issues, the project’s impact on air quality has not received much attention. But it stands to reason that concentrating the emissions from delivery and trash trucks, taxi cabs, service vehicles and all the cars driven by hotel guests, apartment visitors and cars waiting to pick up or drop off medical patients inside a small interior courtyard surrounded by 5 story buildings will make the air in the courtyard less than healthy. Won’t those exhaust fumes take a toll on the pedestrians and patients who have to walk around inside the courtyard to get to the hotel and medical offices and the people who live in apartments facing the courtyard? Will those same emissions reach the ball players and kids using Cassidy Playground just a few feet away from the project?
BDG does have a discussion about air quality in its proposal. However, just as in the discussions of traffic and design, BDG presents a heap of technical jargon and tables to justify their project plan and leaves it to the reader to figure out if any critical information is missing (or if there are any calculation errors, outdated standards or inaccurate data.) Here, for example, is BDG’s conclusion about the Cleveland Circle project’s air quality impact:
The highest eight-hour traffic-related concentration predicted in the area of the Project for the modeled conditions (2.1 ppm) plus background (1.5 ppm), is 3.6 ppm, for the same case. Both concentrations are well below the one-hour NAAQS of 35 ppm and the eighthourNAAQS of 9 ppm. (BDG PNF 3.5.3 Microscale Analysis Results)
Does that sentence give you a lot of confidence about what BDG has studied and measured to ensure that its project won’t be polluting the air that Cleveland Circle neighbors and project users have to breathe every day? No? Well read on to find out what might be missing from the current BDG analysis of air quality.
Where Did BDG Go to Measure Project Air Quality Impact?
Here are the locations that BDG chose to consider in their air quality analysis:
- Commonwealth Avenue and Chestnut Hill Avenue
- Beacon Street and Chestnut Hill Avenue (aka Cleveland Circle)
- Dean Road and Chestnut Hill Avenue
- Boylston Street (aka Route 9) and Chestnut Hill Avenue
Do you notice any missing locations on this list? How about the inner courtyard of the project itself? You know, where all those trucks will be idling every day side by side with cabs and cars? Where exhaust fumes will be trapped inside a bowl of five story building walls?
If a developer really cared about understanding (and disclosing) the real impact of its project on Cleveland Circle air quality, you might think that such a developer would go out of its way to use the best and most current emissions models to study the emissions “hot spot” that its project design is creating inside the courtyard. However, BDG ignores the courtyard in its study, citing the letter of the law in the selection of the “nearby intersections” it chose to study as follows:
The Proponent is required to analyze local effects of the potential increase in traffic on ambient air quality near specific intersections. This microscale analysis is required for the Project at intersections where 1) Project traffic would impact intersections or roadway links currently operating at Level of Service (LOS) D, E, or F or would cause LOS to decline to D, E, or F; 2) Project traffic would increase traffic volumes on nearby roadways by 10% or more (unless the increase in traffic volume is less than 100 vehicles per hour); or, 3) the Project will generate 3,000 or more new average daily trips on roadways providing access to a single location.
Interestingly, even this justification fails to excuse BDG’s lack of study of emissions impacts on the actual project site. The proposed main entrance/exit to the project on Chestnut Hill Avenue is on the site of a current road cut, and according to Howard/Stein-Hudson’s own study, that entrance/exit intersection would be congested enough to immediately be rated as “F” when it starts operating. So why isn’t BDG required to study the impact of new emissions in this location?
Good news! BDG’s Cleveland Circle Project Won’t Pollute the Air on Route 9
What Tools Does BDG Use for Air Quality Measurement?
BDG uses the MOBILE 6.2 software to do their air quality analysis. Is that the best available tool? The EPA web site says:
MOBILE6 has been replaced by MOVES as EPA’s official model for estimating emissions from cars, trucks and motorcycles.
BDG is using an outdated model and deprecated software for their analysis. The current recommended software is the MOVES program which has been available since 2010. Since the Massachusetts and Boston authorities still accept the older program, BDG isn’t required to change to MOVES, despite the many documented problems with MOBILE6.2. It doesn’t even have to disclose those shortcomings, even though this disclosure has become standard practice for many developers who want to be forthcoming with the community about their air quality study methodology.
So all we can hope is that BDG is accurately applying MOBILE 6.2, warts and all, to measure the traffic and air quality situation it is proposing to create in Cleveland Circle.
Types of Vehicles
MOBILE 6.2 considers 28 vehicle classifications. Roughly half of these are vehicles that could visit the inner courtyard (Passenger Cars, Motorcycles, Light-Duty Trucks). Others one hopes never would (Heavy-Duty Diesel Vehicles (>60,000 lbs. GVWR), Diesel Transit and Urban Busses). In commenting on the vehicle classifications, the MOBILE 6.2 user’s manual warns:
These class divisions are not likely those used in local vehicle registration systems or in reporting VMT data to the Federal Highway Administration’s (FHWA) Highway Performance Monitoring System (HPMS), so care must be taken when relating vehicle types across these data sources.
What vehicle classifications did BDG use? Who knows?
The claim by BDG in its PNF that “The current version of MOBILE 6.2 does not explicitly calculate idle emissions.’’ is strange. On page 69 of the user MOBILE 6.2 guide we find the command IDLE PM EMISSIONS with the description:
The term ‘Idle’ in this context refers to the mode of vehicle operation commonly referred to as ‘idling’ or ‘idle mode’.
And again on page 108 we find the command SPEED VMT with the description:
The 14 average speed fractions (0.0000 through 1.0000) must add up to 1. The first of the 14 preset speeds is “idle,” and the other 13 average speeds range from 5 mph to 65 mph in 5 mph increments.
Setting the first number to 1.0 and the rest to 0.0 in this set of parameters would model idling in the inner courtyard. There are model input values for other aspects of idling in EPA-420-F-98-014 of April 1998: Idling Vehicle Emissions.
BDG’s assertion that the lowest speed in MOBILE 6.2 is 2.5 mph is true for the AVERAGE SPEED command but it is not true as we can see for MOBILE 6.2 overall. Why BDG decided to ignore the idling capabilities of the model is anybody’s guess.
But let’s press on.
Documentation – Old Standards
As with estimating counts of the number of delivery trucks, BDG cites old documentation for their air quality estimates. On page 3.25 of the PNF we find:
||U.S. EPA Guideline for Modeling Carbon Monoxide from Roadway Intersections
||U.S. EPA Screening Procedures for Estimating the Air Quality of Stationary Sources
Table 1: Documents used for Air Quality Estimates
Not only are these documents 10 years out of date, but they completely ignore the work that has been done by the Department of Environmental Protection of the Commonwealth of Massachusetts. For example, we call to attention Massachusetts 2012 Air Monitoring Network Plan of September 6, 2012.
As another example, if BDG had been using MOVES, the currently recommended air quality analysis software, it would have found EPA-420-B-10-041 of December 2010: Using MOVES in Project-Level Carbon Monoxide Analyses.
For any readers still awake, you now have more information to make your own conclusion about the accuracy and the credibility of BDG’s Air Quality impact assurances. If the project is built as proposed, the truth will be out there, in the air around the new hotel, medical offices and apartment building. Just don’t breathe too deeply in case it comes with a heavy dose of CO and other pollutants.