The following letter is SAND's response to the filing of an Environmental Notification Form (ENF) and Project Notification Form (PNF) by the Fan Pier Land Company and Hyatt Development Corporation regarding its proposal for 3.3 million square feet of development on the 21 acre parcel.

SAND issued its response during the public comment period, sending letters to both the Office of Environmental Affairs (Mr. Robert Durand, Secretary) and the Boston Redevelopment Authority (Mr. John O'Brien, Project Manager).

To read additional SAND commentary on the Fan Pier proposal, click here.

The Seaport Alliance for a Neighborhood Design

January 4, 2000

Mr. John O'Brien, Project Manager
The Boston Redevelopment Authority
Boston City Hall 9th Floor
City Hall Plaza
Boston, MA 02201

Dear Mr. O'Brien:

The Seaport Alliance for a Neighborhood Design (SAND) has been involved in the Fan Pier planning process for approximately two years. In February 1998 we filed EOEA/MEPA comments with your office for the earlier Fan Pier proposal subsequently withdrawn by the proponent.

Many comments filed in 1998 were written in an attempt to improve future, revised Fan Pier ENF/PNF proposals such as the one now under consideration. At that time, the City of Boston appointed a South Boston Waterfront Committee to draft comments regarding Fan Pier - a copy of the SBWC comments is attached.

In October of 1998, core members of SAND hosted an intensely focused working session with the proponent's consulting team of Urban Strategies. In January of 1999, SAND again hosted representatives of Spaulding & Slye at a Fort Point community meeting to further discuss the Fan Pier project. SAND members have attended dozens of Fan Pier planning sessions, public meetings and presentations that were held for the benefit of South Boston and greater Boston communities.

The Waterfront: Urban Neighborhood or Corporate Office Park?

Since its founding in 1997, SAND has consistently advocated for the planning of an urban neighborhood on the South Boston Waterfront, from the Fort Point Historic Subdistrict to Fan Pier. In pursuit of this mission during our work with Urban Strategies and Spaulding & Slye, we succinctly identified major elements of the Fan Pier development that would contribute to its success as part of an evolving mixed-use neighborhood.

The major needs as stated were:

We were diligent in our advocacy of a plan which, although on private property, suited a broad public interest. Our basis for asserting community-minded planning ideals was founded on these facts:

As proposed in the existing PNF/ENF filing before you, the Fan Pier project meets few, if any of SAND's objectives.


Unit Count

The Fan Pier ENF/PNF asserts that it will "seek to develop an authentic neighborhood to complement the public realm by providing people to support the public activities and helping to create a welcoming atmosphere for visitors." (ENF/PNF p. 2-22) Yet, the proposal includes only "450 one-, two- and three-bedroom residential units on the site." (ENF/PNF p.2-23)

The BRA plan calls for approximately 5,000 to 8,000 housing units to be created in the Seaport and South Boston (BRA-PRP p. 5).With an estimated total buildout of 15-20 million square feet in the entire waterfront (PRP p. 111) the Fan Pier proposal would have to provide 1100 - 1300 residential units to achieve the desired critical mass.


The Fan Pier ENF/PNF asserts "This neighborhood will include hotel, residential, office and retail space, all of which will be targeted to a diverse mix of incomes and interests..." (ENF/PNF p. 2-22) There is no indication from the proponent's plan that a mix of incomes will be accommodated.

While the proponent had an opportunity to place some residential units along Old Northern Avenue allowing for some variability in value, the proposal instead places all units at the most exclusive portion of the Fan Pier parcel.

The proposal suggests an average residential unit size of 1700 square feet. If the intent is to afford a diverse mix of income levels, the unit sizes should be reduced to a range between 750 and 1500 square feet (averaging 1000 square feet). This would also accommodate a larger number of tenants.


The proponent's retail component states "Project plans call for the creation of an intimate, pedestrian-friendly shopping district on the Back Bay model that has proven to be so successful in Boston." (ENF/PNF p.2-23). There is nothing in the proponent's plan that even comes close to emulating the Back Bay, with its human scale brownstones, pedestrian mall on Commonwealth Avenue, and the public gardens.


The PRP states "The most treasured public resource in Boston is its open space." (PRP p. 63). The proponent's plan falls short in the need for useable open space on Fan Pier. "The signature open space on the Fan Pier will be a tidal landscape at the edge of the Fan Pier." (ENF/PNF p. 2-17). While a tidal pool seems like a good idea, in reality it is not a useable public space. A signature space should be one where people can actively use and enjoy the space.

The PRP states "over 44 acres of the Seaport outside of the industrial area have been allocated to open space." (PRP p. 63). The Fan Pier proposal, with only 13.3 acres of open space (including pedestrian walkways, streets and avenues, boardwalks, piers and docks, protected water) will cause the BRA to fall short of their own stated requirements for open space. The remaining acres of open space recommended by the BRA cannot be expected to be fulfilled by the remaining property owners in the district. It is offensive that the PRP and the proponent's plans can include streets, water, and the likes in their calculations of open space.

The ENF/PNF provides little accommodation for those with limited financial ability who are unable to patronize commercial, civic and cultural establishments proposed on the site. Fee-based and commercial attractions overwhelm potential for all families to enjoy an inexpensive or free experience at the water's edge.


The PRP states "Within the first 200 feet from the bulkhead, buildings are general restricted to 75' in height. In the next zone, building can step up to 100 to 150 feet in height." (PRP p.68). The proponent arrogantly disregards these height restrictions by actually doubling them in some buildings.

The BRA PRP states that the South Boston waterfront zoning will "establish the maximum allowable building heights for the Seaport which will range from 55 to 150 feet as-of-right with a limited number of sites able to achieve higher heights subject to an approved PDA development plan that would balance the heights with public benefits." (PRP p.106). The proponent proposes eight buildings, one 143 feet, one 177, two over 200 feet and four over 250 feet tall. The proponent has the audacity to state that these heights produce an average height of 150 feet (manipulating the word "average" to include base heights and other low numbers).


We remain concerned that in an attempt to maximize private commercial opportunity on Fan Pier, the proponent has manipulated Chapter 91 calculations and misrepresented the true environmental impacts of the proposal.

We are also concerned that the proponent's vision has been shepherded through approvals by the BRA with little justification for variances from the spirit of Chapter 91 regulations and the vision outlined in the Public Realm Plan. Surprisingly, the ENF and PNF both are expected to be considered in parallel with a Municipal Harbor Plan that not yet been publicly reviewed or enacted into legislation.

The Municipal Harbor Plan weakens protections offered by existing state Chapter 91 waterfront regulation. And unlike the Public Realm Plan that resulted from a two-year City-wide effort, the Municipal Harbor Plan is not being shaped according to a universal set of urban waterfront planning standards, but rather by economic interests including the Fan Pier developers themselves. Citizens Advisory Committee (CAC) appointees, for example the Boston Chamber of Commerce, have heralded every grandiose waterfront project including the failed Megaplex and football stadium proposals.

No community meetings have been held by the BRA to help shape the Municipal Harbor Plan. And only a single community leader, one unfamiliar with the South Boston Waterfront, was granted a seat on the Municipal Harbor Plan CAC. The BRA found it appropriate to appoint the Fan Pier planning team's lead architect (and president of the Boston Society of Architects) for a seat on the CAC - that seat was later vacated.


Over the past years, the Fan Pier planners were recipients of a vast wealth of commentary and suggestions for improving the 21-acre parcel as it related to the South Boston waterfront. Concerns were expressed by community groups, waterfront advocacy groups, interest groups and in-response letters addressing the earlier 1998 MEPA filing.

Of these concerns, the most common and frequently stated concerns were with regard to the proposed density and the need for a significant park.

Universal Concerns Dismissed

In 1997, Boston Mayor Thomas Menino appointed a South Boston Waterfront Committee (SBWC) to consider the Fan Pier parcel. The SBWC suggested a density for Fan Pier of approximately 1.5 million square feet (recommendation attached). During 1998, the most often stated remark in planning sessions, whether from SAND, the Boston Society of Architects, the Boston Harbor Association, the Conservation Law Foundation and countless numbers of Boston residents was that the density was far in excess of what was appropriate. Despite this widespread call for a reduction in density, the Fan Pier planning increased the density from 3.04 million square feet in 1997 to 3.3 million square feet today. This is nearly twice the density suggested by the BRA Public Realm Plan and more than twice the density suggested by Mayor Menino's appointed Boston Waterfront Committee in 1997.

The Fan Pier team at Urban Strategies began the planning process by dismissing density as an issue and engaging in fairly progressive discussions of a mix-use neighborhood, including housing, supermarkets, public spaces, signature parks, angled alleys that would converge on the waterfront. In the second year of the planning, however, the planners reduced or eliminated the housing goals, supermarkets, public spaces, signature parks and angled alleys. By January of 1999, the plan had quickly regressed to its original 1997 proportions and it has remained largely unchanged ever since.

The Fan Pier planning team has been credited with achieving the maximum political advantage in the planning dialog. The team has offered such a range of benefits outside the scope of what actually should be put in the ground, from construction jobs, hotel and office jobs, memorials, linkage, funding for collaborative projects, etc., that it has been extremely difficult for SAND members to convince others of the long-term potential for the Fan Pier parcel and the South Boston waterfront.

Many members of our community have been led to believe that public investment in the waterfront and the secession of its natural resources are both justified by immediate economic benefits. Others have been dispirited by a drumbeat of projects and approvals which place an emphasis on commercial opportunity over broad public interest.

The outcome of this development will effect every parcel of land around it, and it will effect the direction the City of Boston takes as it enters the 21st century. This is the time to stand up and create a vision for Boston, driven by long term public interests, and not private agendas.

SAND appreciates the opportunity to comment on the ENF and PNF. Thank you for your attention.


Lisa Greenfield .................................. Steve Hollinger

on behalf of
The Seaport Alliance for a Neighborhood Design
300 Summer Street, Boston, MA 02210



Additional Support, COMMENTS, and Documentation

The South Boston Waterfront Committee
created by Mayor Menino in 1996: June 1998

"It is estimated that when work is completed in 2003, over $20 billion of taxpayer funds will have been expended in the Seaport District and surrounding areas among the Boston Harbor cleanup, the Central Artery project, the construction of the Ted Williams Tunnel, the extension of the Massachusetts turnpike to the new Tunnel, the construction of the Silver Line Transitway into the Seaport District, the construction of the Evelyn Moakley Bridge, the reconstruction of the Summer and Congress Street Bridges, and the reconstruction of New Northern Avenue, Congress and Summer Streets. The combined projects have often been described as the largest public works projects currently underway in the world and the expenditure of those public funds have contributed enormously to the land values of the major development parcels in the South Boston Seaport District which are held by several significant landowners, including the Massachusetts Port Authority."

Other points made by the Mayor's committee, which have been ignored, or minimized:

-- Establish pedestrian friendly street grid and parcel sizes throughout the Inner Harbor Subdistrict.

-- Establish areas of critical mass of active open public space which encourage use in prime development areas.

-- Connect network of public gathering places within Inner Harbor Subdistrict.

-- Promote two front doors for development so that buildings do not turn their backs on Ft. Point and South Boston communities.

-- Encourage developers to create public realm improvements as early as is feasible in the development of their parcels

-- Prevent privatization of open space areas where access to the public is restricted or discouraged (e.g. interior building courtyards, cul de sacs etc.)

-- Avoid canyons, shadows and the like on open space and watersheet where feasible.

-- Utilize zoning controls to mandate a diversity of uses, heights, densities and designs in the South Boston Seaport Inner Harbor Subdistrict

-- Create activity by mixing uses together that generate activity at different times of the day and for different purposes...

-- Respect Chapter 91 requirements, including open space, height and setback requirements.

This is just a sampling of the points from the SBWC which go on to recommend downscaled heights, establishing a strong neighborhood feel, and mandating ground floor retail.

Boston Harbor Conference -
May 21, 1998 National Panel Recommendations.

Panel includes Karen B. Alschuler, Principal and Director of Planning, SMWM, Paul Krugman, Ford International Professor of Economics at MIT, Peter D. Linneman, Director, Samuel Zell and Robert Lurie Real Estate Center Wharton School of Business, The Honorable William F. Weld, ESQ., Former Governor of Massachusetts, The Honorable L. Douglas Wilder, Former Governor of Virginia

The Boston Harbor Conference convened to explore options for development of Boston Harbor and it's waterfront. They state that the the 170 acre Fort Point Channel District "should be developed as a vital living-working waterfront community, animated by commercial office, hotel, retail and residential development, reaping the rewards of the harbor clean-up." Their recommendations include

-- The establishment of a continuous esplanade for pedestrians and bicyclists through the full Seaport District

-- Designate a permanent open space venue connected to the esplanade, designed for major public events such as "Harbor Lights"

-- Create a network of small interior public parks and public squares...

-- Create a livable urban neighborhood consisting of at least 3000 housing units in combination with hotel, commercial office and retail space, attractive to the entire metropolitan area.

The Boston Harbor Association
June 25, 1998

"It is essential that a vibrant public realm with 'more green, more blue, less gray' be created which is inviting, and gives identity to the area. This requires functional public spaces and green open spaces that are well-linked, well programmed, closely connected tot he water both physically and visually, useable the majority of the year, and unburdened by undue wind and shadow conditions."

"The plan should provide a grand, unique waterfront park, on the scale of Piers Park in East Boston or the Esplanade along the Charles River in Back Bay....The waterfront park should be located along the Harbor's edge in order to have true activation of the waterfront."

Boston Society of Architects
June 25, 1998

The BSA calls for "threshold residential development that generates critical mass of residents (minimum of 10-15, 000 residents, 6000 dwelling units...mix of housing types and range of affordability spread through the District." They also recommend:"A district-wide open space system supporting active and passive uses...a neighborhood Park System, centered by squares, surrounded by playing fields and pocket parks..."

The Boston Redevelopment Authority
December 1998
"Effects of Seaport Development on Neighborhood Housing Demand in South Boston"

" is expected that 39% of the jobs created in the Seaport District will be held by people who want to live in Boston, and there would be between one and two workers per housing unit. Listed below is one example of development in the Seaport District that calls for building 16 million square feet of office, retail, and hotel space, which will create 43, 857 jobs, and devoting 4 million square feet, or 20% of the total to housing. Four thousand housing units would be created if 20 percent of the total building space is devoted to housing. If 39% of the new workers choose to live in Boston, that means 17, 104 workers will be looking for homes within the city. At 1.38 workers per household, this translates into 12, 394 housing units needed. Since only 4,000 housing units were constructed under the above scenario, workers will be seeking an additional 8,394 units in present neighborhood housing. Considerable pressure will be placed on the South Boston housing market because of it's proximity to the Seaport District"

The Boston Globe Editorial
"A Better Fan Pier Plan"

"...the amount of development [on Fan Pier], remains at around 3.3 million square feet, most of it reserved for luxury condominiums, high-priced hotels, and office space. It is far from clear that the size and mix of uses will fulfill the goals of state and city planners that the waterfront will be accessible and enjoyable for the wealthy, the poor, and those in between." "The Boston Redevelopment Authority needs to coordinate the plans of the McCourts, the Pritzkers, and Stephen Karp" "The great danger here is that the total impact of the developments, all geared to a wealthy clientele, will physically and psychologically wall the waterfront off from the rest of the city. Avoiding this outcome is worth a fight over every high-rise and every square foot of excessive development." "A downsizing of the building mass and refinement of retail uses will produce a project that is both a profit-maker and an enhancement to life in Boston."

Editorial in the Boston Business Journal
12/3/99 "Building Blocks"

"...there are three main drawbacks of the Pritzker's proposals: The buildings are still too high; there are not enough residential units; and, as far as we can see, the Fan Pier project doesn't take into enough consideration how it can and should set a tone for other nearby developments in the area." "City officials have to realize that the Fan Pier project is turning into a sort of linchpin for the entire district. If the city compromises too much on the Fan Pier project, everything else will be compromised. That's why it's essential for city officials, as well as state officials, to use everything at their disposal to influence the final outcome on Fan Pier...They need to be tough about how high and how close structures can be to the waterfront. They need to stick to city plans to make the entire South Boston Waterfront an attractive, accessible area to both live and work...There's still plenty of time to improve the Fan Pier plan, without scuttling it entirely."

Boston Globe
"We deserve more out of Seaport" 12/17/99 by Brian McGrory

"The conveniently discarded truth about the Seaport District is that the public is entitled to something far greater than the mediocrity that developers and politicians are offering now." "The public, meaning you and I, have turned a ragtag collection of rubble-strewn lots and creaky piers into one of the most coveted swaths of undeveloped land in urban America. We've done it the old-fashioned way: with money...The Pritzkers came in last month with a proposal better than might have been expected, but not as good as was hoped. To its credit, it includes a public skating rink, an art museum, a floating stage in a tidal basin,water sculptures, and boat slips. To its detriment, it squeezes 3.2 million square feet of office, hotel, and residential space into nine city blocks, creating what critics say is a dense, high wall of steel and glass blocking the water from the neighborhood inspired by it...But we, the public, have invested close to $15 billion to instill the district with value, to give this city an opportunity to grow and prosper. It's no time to hope for the best. It's high time to demand it. And right now, we're not even close."

Architectural Record
12/99 by Carl Pucci

"Those who plan the cities of the 21st century should throw out the old urban guidelines and try a new set." Mr Pucci is critical of the short term interests of city planners. "Natural resources are seen merely as development opportunities...there is no official advocate for public areas, new parks, or unbuilt spaces. Public improvements are somehow required to generate self-support, while the direct benefits to the private sector are ignored. There is no vision of a city of vital neighborhoods and coordinated regional development of resources, and no stomach for making land-use decisions that might inconvenience private interests."

Mr. Pucci sets several new guidelines for city planning: "Increase the void amid density. Our cities need more open space and must redirect their energies to public priorities...we have no advocates for public open space. Open-space zoning must be an essential ingredient of rezoning. The void is not an open plaza among office buildings; it is the vital lung and heart of a neighborhood."

"Natural resources are public resources. Natural resources, be they waterfronts, scenic vistas, parklands, or cultural heritage sites, must be vigorously protected and used as public amenities. Large public recreation areas for both active and passive use must be developed via regional coordination and be available within walking distance to neighborhoods. They must be supported by public funds, and they must be dependent on retail and corporate interests...Public rights-of-way must take precedence over private property...Our cities deserve more: more public spaces; more light and air; more conveniences; more collisions of culture, use, and history; and more delight. We demand it."

[recommendation letter from Boston Waterfront Committee of February 1998 filed as attachment]

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