SAND has submitted the following comment letter during a public comment period in response to Massport's recent filing of an Environmental Notification Form (ENF) and Project Notification Form (PNF) for the proposed development of Commonwealth Flats. [An ENF is a State Environmental Office document required for approval of large development proposals and a PNF is essentially the same document required for consideration and approval by the City of Boston/BRA.]

Commonwealth Flats is a 30-acre land tract situated on the South Boston Waterfront's inner harbor, bounded by New Northern Avenue, Summer Street, the Marine Industrial Park and the McCourt property.

For the purpose of planning, Commonwealth Flats is divided into a number of separate parcels of land. One of these parcels identified as Parcel F includes the already completed Seaport Hotel tower and Fidelity office tower, and is the site of two towers under way. To read SAND's comment letter regarding this specific parcel, click here.

In our pursuit of an urban mixed-use neighborhood at the western portion of the waterfront and in the Fort Point historic subdistrict, along with support for community ideals in the D Street area east of the Convention Center, SAND supports development of the Commonwealth Flats area as a fairly dense commercial district with the possible inclusion of a residential component. This area could serve the Convention Center with hotels and offices, and could support a higher density of commercial development in order to ease commercial pressures in outlying areas of the South Boston waterfront requiring a critical mass of residential development. Our concerns also remains focused on the long-term vision for protection of truck routes for the Marine Industrial Park -- an area that is an invaluable resource for shipping and maritime commerce.

For a bit more recent history of this ENF, click here...
To read SAND's prior comments on Commonwealth Flats, click here.


Mr. Bob Durand, Secretary
Executive Office of Environmental Affairs
100 Cambridge Street
Boston, MA

attn.: Ms Laura Rome, MEPA Unit

EOEA # 1182, Commonwealth Flats Development Area, DEIR

Dear Secretary Durand,

The Seaport Alliance for A Neighborhood Design has awaited this filing (EOEA #1182) with interest, and in large part can support the many changes and recommendations which have been adopted. Although this document is much improved it still contains items of significant concern which should be addressed and corrected in the subsequent filing. Our following comments will focus exclusively on what we believe still remains to be remedied so that these development projects can do justice to the site, appropriately leverage the immense public investment in this area, assist in the creation of a neighborhood in this district, and avoid overtaxing the fabric and infrastructure of Boston and the region. Currently, this document falls significantly short in several areas, which could threaten these proposed projects as well as this entire district. We ask that you require the proponent to make such modifications, mitigation and additional study as are required to rectify these problems.

We applaud Massport for voluntarily joining these proposed developments into a single filing so that a large portion of the district can be considered in a holistic fashion. We appreciate the desire to secure the preliminary permitting of these sites to reduce uncertainty and improve their marketability, reducing the time required for construction to begin. But we also cannot lose sight of the fact that this is a commercial and somewhat speculative real estate venture on the part of an Authority of the Commonwealth, almost entirely unrelated to the furtherance of their core responsibility.

This proposal further constrains the area and viability of port and industrial activity in the area, valuable and important economic sectors which already experience significant pressures. Because of this, it becomes absolutely vital that any development contemplated in Commonwealth Flats should provide the highest amount and quality of returns for the public, in every aspect. Environmental and social aspects of this proposal must return the greatest benefits possible to the public, and this site holds enormous potential. We seek a greater diversity of uses, sufficient housing at all affordability levels to provide the core of a residential community, increased public open space and parks, ecological and social sustainability, and a roadway and transportation infrastructure which is sufficiently robust to provide high quality service without inducing or exacerbating congestion. This is a lot to ask for, but it is no less than Boston and the public deserve.

Character and Land Use of Commonwealth Flats

This DEIR proposes to create a commercial district characterized by large office buildings, hotels, parking garages and an enclave of housing. The orientation is towards replicating the commercial downtown business district of Boston, attenuating any civic life or activity, and requiring total dependence on transit and auto transportation. There should be a far greater diversity of uses in Commonwealth Flats, and each building should be designed and permitted to accommodate a variety of uses.

SAND has a strong concern that what is being contemplated will only result in a commercial and entertainment district, with none of the life and activity which results from a true twenty four hour neighborhood. The housing proposed, for example, will be about one-half of the amount necessary to support even limited neighborhood retail and service businesses.

Massport's proposal would, in total, amount to one-third of the maximum development anticipated by the BRA for the entire South Boston Waterfront. SAND supports greater density, and even building height, where appropriate. Massport's site is indeed appropriately located for exceptional height and density, an opportunity which we believe has not been sufficiently studied. But this filing proposes density and uses which exceed and are incompatible with the ability of the anticipated transportation infrastructure to provide adequate service. We believe that the only practical solution to emerge is to increase the ratio of housing in the neighborhood.

Viaduct Street is one of the unique features of the district, which needs to be handled properly to deliver the anticipated benefits. Generally, it is quite difficult to entice the public to use elevated circulation routes and open space. It is essential that the vertical access to Viaduct Street and its associated buildings and parks be available to the public around the clock, without restriction, and be clearly accessible, inviting and well signed.

Industrial Uses

SAND is concerned over the continuing reduction of proposed industrial uses by 50% to only 25,000 sf, and reduction of traditional maritime uses to be housed in the Commonwealth Flats area. This represents an overall reduction of 83% from some 814,000 sf of industrial usage in this district prior to Central Artery construction. The BMIP is accommodating much of that, but also has limited area. We may soon come to a point where the port area has become too small, either by pier or back end space limitations, to accommodate a resurgent marine industry. We want to ensure that marine operation components are focused first on industrial uses such as fishing, fish processing, and shipping, rather than tourism and pleasure craft.

Residential Use

Housing availability in Boston is now as limited, if not more scarce, than office space, and many developers are finding that housing will provide greater returns than commercial space. SAND is pleased to see the substantial increase in housing to be provided in the area, relative to the prior filing. The amount of housing is still far too little, and should be required to be greatly enlarged to the point where a small neighborhood is created. As proposed now it does not even rise to the lowest level of the BRA's goals for housing provision in the South Boston Waterfront. As plans proceed we will want to see that units are provided at all levels of affordability to provide a diverse and economically integrated neighborhood in the district. With increasing pressure being focused on the existing South Boston arts community, we would like to see a detailed examination of the feasibility of providing artists live-work lofts as part of the Commonwealth Flats development.

Since this district is well served by transit stations we believe that a large portion of the housing provided could have a reduced parking ratio, with various simple measures to ensure compliance. This would reduce the effective cost of providing housing, reduce congestion and air pollution, permit additional bicycle and pedestrian activity, and increase the likelihood of people co-locating to their jobs.

Massport Projects Proposed but not included in Filing

We would like to see a detailed discussion of Massport's other planning initiatives for this area, including for the relocation of the block containing Jimmy's Harborside Restaurant, and any projects on Fish Pier. SAND is aware of plans to redevelop both of those areas, yet they are not even addressed in a tangential fashion in this filing. The continuing exception from consideration in DEIR of a major air rights garage project, now anticipated to contain 1,730 parking spaces within the development area continues to concern us greatly. There is an incongruity to providing a major parking facility over a transit hub in a downtown location. We are concerned that this structure will attract conventioneers, downtown commuters, or travelers heading for Logan Airport, adding congestion.

We question the purpose for the incorporation of Jimmy's Harborside building into 'Project Consistency Zone 3' and request a discussion and possible change of these designations. Jimmy's would seem more naturally to belong in Zone 2 or in a class of its own. It should not simply be classed with a dominant use of office/parking. Grouping with Fish Pier seems most appropriate, as in CA/T sub-zone 86J.

Additional Air Rights

Covering of Central Artery ramps and boat sections should be a primary benefit of any project along or over those alignments. Consideration should be given to extending Parcel D-1 South over the Haul Road extension to the plaza parcel fronting on Summer Street. There may be other ways of profitably incorporating lands around the Summer Street Vent Building into a deck or building which could provide additional circulation routes for pedestrians to Congress Street, or otherwise provide additional amenities for conventioneers.

Parks and Open Space

Massport's proposal appears to provide significant open space for the district on first glance, but turns out to be far less on closer inspection. SAND has been consistent in its call for the provision of the average City ratio of 5.5 acres of parks and open space per thousand residents throughout the South Boston Waterfront, and particularly that recreational amenities be located near housing. Further, the spaces being proposed are almost entirely in sidewalk and plaza areas, as ornaments and programmed for passive recreation. There needs to be an expansion of the open space to provide an adequate amount in the proper locations, including green space, active recreation, playgrounds, community gardens and other uses. Open space meeting the needs of a community can be entirely consistent with the needs of the hundreds of thousands of visitors, tourists, conventioneers and workers expected in the district.

The one-third of proposed park land that will flank Viaduct Street and serve as the frontispiece for the Hotel and West Office Building needs significant management and design efforts to become welcoming to the general public. As currently indicated (and built in the case of the Seaport Hotel) these parks seem clearly intended to primarily serve parking and circulation needs of the clientele of those buildings. They are not designed so much for public use as for appealing patterns to be seen from upper floors.

That only 24% of the total open space in Commonwealth Flats is anticipated to be provided in parks and plazas deepens our concern for the location of 'Seaport Square Park' and its ability to provide for the many recreational needs of its various users. The remaining park spaces are in two instances essentially planted medians. Should office buildings be built at the foot of Fish Pier, as previously indicated by Massport, 'Seaport Square Park' will be significantly impeded in its aspect to the water.

SAND continues to be perplexed as to the necessity of providing a park between the split legs of D Street. It appears to duplicate the benefit of the park which Massport is already constructing adjacent to that location, but will suffer from having a busy roadway on all sides. With limited open space being provided within the Commonwealth Flats district we wonder if that open space might better be deployed elsewhere, such as adjacent to the foot of Congress Street, where it could serve the residential community and have a direct link with the Harbor. The left turn turning movements from D Street onto Northern Avenue, whose purported difficulty was the original rationale for the division of the roadway, are now calculated to be sufficiently low that they can be readily accommodated, particularly if a two lane left turn is provided. The retention of the current D Street alignment would also enhance truck access to Fish Pier and accentuate its measured, symmetrical procession to Massport's Conference Center.

Calling plantings along a major regional truck route open space is a misnomer. It is no more than decoration, and cannot adequately serve any park function. While potentially attractive, it cannot be considered open space or host any activities of the public.

The sole remaining open space is denoted 'Portal Park' overlooking the entrance/exit and toll plaza by the access to the Ted Williams Tunnel. The narrowness of this park will be an insufficient buffer to the noise, smell, grime and air pollution found above a highway. It is clear that no other use could be identified for this area and its location directly across D Street from a proposed parking garage. This 'park' should incorporate sufficient wall or screening elements to attenuate, if not eliminate, impacts associated with operation of the tunnel.


We continue to be skeptical of the ability of public transportation,m as currently proposed, to adequately deliver the anticipated ridership to the district and to serve its many users. The recent filing for Fan Pier also assumed a large transit ridership, which would absorb more than half of peak transitway capacity - operating with additional train sets and at exceptionally low headways. SAND is enthusiastic in its support for public transit, and strongly advocates for all non-auto forms of transportation, from pedestrians to water transit. However, it is becoming abundantly clear that current projections by the MBTA and other transit providers, such as Massport, will not be able to ramp up to full service rapidly enough and that structural and operational limitations, much less cost, will make the achievement of these projected maximum capacities difficult, if not impossible, to achieve.

Massport's filing anticipates that the Commonwealth Flats development area will absorb fully 40% of transit demand, yet this development area covers far less than 40% of the South Boston Waterfront. Users from those areas adjacent can be expected to compete for limited transit seats, causing many would-be transit riders to use private autos and increasing congestion. Clearly this problem must be faced squarely and solutions found before developments are permitted which will cause intractable congestion.

SAND would like to refer the proponent to the recently completed BTD South Boston Transportation Study, which identified a significant and increasing shortfall in the ability to provide sufficient transit capacity within the next ten years. This study also predicts rapidly declining levels of service in the roadway network, which will cause significant impacts locally and regionally, such as increased air pollution, increased travel times, increased congestion, and the inability of surface transit services to maintain regular schedules. And this in an area which is essentially being built from scratch and which should be a local and regional exemplar for sound urban planning. It should be noted that the future alternative options proposed in that study have largely been precluded and no expectations should be entertained that any additional, dedicated transit capacity can be provided without significant , uncontemplated infrastructure investment.

Massport should continue to refine its planning to integrate and upgrade the level of service which transit can provide with improved waiting rooms and shelters, and by improving the links between different transit modes. By encouraging a truly intermodal transit system in the district, the levels of ridership projected will more nearly be able to be reached. High quality materials and design, clear signage and information display, co-location and other methods will assist. These improvements should be detailed in future filings.

As we seek a robust and integrated transportation system that links all modes and areas for rapid, pleasant and continuous service, we are disturbed by Massport's continuing resistance to link its AITC service to the dedicated Convention Center transit stop beneath Summer Street. The BCEC has gone to significant lengths to provide a stop which can handle a significant volume of visitors and conventioneers, most of whom are expected to fly in to Boston, and deliver them directly to the Convention Center and its headquarters hotel.

The BCEC has also identified several routes by which the AITC could readily travel with minimal interface with surface traffic. A future benefit of this link could be an at-grade connection to a spur of the Urban Ring, which could greatly expand the utility and ridership of public transit and reduce pressure, not only on the use of local and regional roadways, but also on the traffic operations of Logan Airport. In the abscence of this AITC link we can expect to see an increasing reliance on the use of private vehicles, rental cars, taxicabs, and dedicated shuttle buses to transfer visitors between Logan and the Convention Center, which will exacerbate congestion and lowered esteem for the capabilities of Boston and the region.

Roadway Design

On the whole, the roadway cross sections included in this DEIR are a great improvement over current conditions and lend greatly to an ability to create a neighborhood in this district. There are several elements, however, which should be addressed, improved and included in future filings. Fifteen feet is overly wide for travel lanes on secondary roadways, particularly as they will also contain a center flush median of two feet. BTD Major Roadway Design Guidelines should be incorporated into the roadway design standards in general.

Travel lanes should typically be no wider than 11'. Bike lane widths should be called out and width specified separately. No sidewalk should have a minimum clear width of less than 8' at any point. Several street designs appear to reduce sidewalk widths to unacceptably narrow dimensions. The proponent should refer to the Pedestrian Issues Forum, STAF, and BTD Major Roadways processes and documents for data and examples of roadway design. Traffic calming measures should be fully incorporated throughout the district to better manage the flow of traffic, particularly in off peak times, and to enhance both pedestrian and vehicle safety.

Bike lanes require consistent and continuous striping and signage at the start of a segment or its merging into general traffic lanes to alert and caution bikes and vehicles. Bike lanes should be on the order of five feet wide, and never less than three feet wide. Appropriate design modifications should be made.

The cross sections provided should be drawn to an accurate scale and representative figures placed on the sidewalks to illustrate how people will pass each other without crowding when carrying parcels, in groups and pushing strollers. Market and Cross Streets will be far too narrow to serve pedestrians. The cross sections provided for Connector Road also show a far too narrow sidewalk. In this instance there must be better accommodations for Transitway riders to wait, queue, and enter/exit the vehicle without crowding or impeding the flow of other pedestrians. Plans for transitway stops and accommodations which Massport will be providing should be shown and described.

The new Fish Pier Road should be denoted as a secondary street on diagrams and developed as a minor roadway. This segment could be ideal as a pedestrian way.

A new roadway should be placed to delimit Parcel K-1 from Parcel K-2 and to improve access to and circulation about each of those projects. This will also help to separate industrial and residential uses appropriately.


There are several assumptions or decisions which have been made during the transportation analysis that should be corrected. They include unsupported mode split assumptions, and absorption of a larger share of transit availability (whether based on acreage, employees anticipated, or building volume). These assumptions are arguable at best and tend to be contradicted by current observations and practice elsewhere. No matter how much we desire to have a great deal of development in this area, it must be able to be supported by an adequate transit infrastructure. To avoid the problem will only limit solutions and create intractable congestion.

In essence, and without accounting for additional contributions from other land uses anticipated, the Commonwealth Flats development proposed will overwhelm the future capacity of both the roadway network and the transit system in the South Boston Waterfront District. The magnitude of this shortfall and the cascade effects it will set off, both within Boston and regionally, will be staggering. Although Massport is not responsible for the provision of roadway and transit services to meet the entire needs of this district, its development should not outstrip the ability of the district to provide needed services.

We ask that requirements be established which will prevent construction starts for individual development projects within this district, unless a comprehensive transportation study (conducted for each project, within one year prior to the desired start of construction) definitively proves the availability of sufficient roadway and transit capacity for that project. With this district to be the beneficiary of some $15 billion of public investment, made over a generation with significant impacts for many communities, its success cannot be risked.

Traffic analysis cannot be based on assumption that most users will visit the area in off peak times when the greatest volume will be built to house commercial offices (the most intensive land use per person) which require most workers to be present during standard working hours. Discussion of specific methods to be adopted to mitigate this condition should be required.

Assumptions relating to the ability to generate a 62% transit mode share should be based on information such as: the ability of transit to deliver passengers to locations near specific development sites; maximum transit ridership should be based on transit capacity that has been committed or funded, and not on hopeful projections or assumptions about the acts of others which cannot be enforced; factors which acknowledge a fall off of transit ridership when multiple transfers must be used to reach given destinations; that commuters make rational decisions regarding use of autos relative to transit primarily based on comparisons of time spent getting to specific destinations; ease and flexibility of use; comparison of cost of gas and tolls relative to cost of commuting. Comparisons with other cities may be instructive but are no substitute for a focus on the limiting factors of local conditions and systems.

Vehicle occupancy rates are similarly optimistic. A factor for transit and vehicle occupancy rates should be incorporated, or there should be a transportation study done which examines current rates for the district to provide a baseline understanding of vehicle occupancies. We anticipate that observation and study would show private vehicle occupancies much closer to 1.0 ppv for most land uses than anticipated.

If we were to grant Massport's assumptions regarding mode share, we will find a need for the capacity to accommodate approximately 10,000 peak hour transit riders in both the morning and evening rush hours. That capacity does not exist, is not proposed to be created, and structural limitations of the district will likely preclude this level of service from ever being provided. And this is without considering the simultaneous demand for transit service related to the BCEC, Fan Pier,

McCourt, and other development proposals which may be anticipated for the area.

Peak hour vehicle trips calculations show that an assumption has been made that office occupancy will at the rate of approximately one person per 1,000 gross square feet of development. This is economically unsupportable, and a visit to any workplace will demonstrate that the true rate is closer to 200 gsf per person, and most definitely well under 500 gsf/person for Class A commercial space. Massport should be required, and to require its designated developers, to seek certificates of occupancy for no more than one person per 1,000 gsf of development to ensure that no greater burden is placed on the district.

Truck Traffic

The proposed truck route plan is unrealistic. We can expect that all of Congress Street and D Street will be used by trucks, and that Northern Avenue will be a preferred route to reach I-93 Northbound. Requiring trucks to use other routes to I-93 NB is likely to exacerbate congestion and air pollution at other times, and be widely disregarded by truckers. We need to accept the presence of trucks on our streets, constructing and maintaining roadways and buildings to minimize noise transmission.


Transitway capacity is based on vehicles that do not exist, with headways which are not achieved elsewhere in the MBTA system. It will require a high level of coordination between MBTA and Massport operations for service vehicle schedules to mesh without conflict, and for which no financing exists to purchase the additional fleets necessary to provide such service. We hope that all of these concerns will be solved rapidly and successfully, but do not believe that it is prudent to permit projects based on so many factors well out of the control of the proponent. Even Massport's most optimistic evaluation projects a significant shortfall in the ability of the transit system to deliver riders, on the order of 10%, to meet required demand. Those five hundred to one thousand people will be forced into cars, exacerbating congestion and air pollution, and straining parking capacity further. For proposed mitigation to be successful all of the proposed elements must be put into operation, all must work perfectly, and all must achieve their maximum riderships at all times. There is no single transit system, let alone a widely distributed and uncoordinated collection of transit types, which can work at this level of perfection, and it is unreasonable to expect that these proposed mitigation measures can achieve anything like the ridership being projected.

The Transitway crossing of D Street should be made in a manner that permits the bus to have priority signal override of intersecting traffic at all times. Should there be difficulty or delay in clearing vehicles from the intersection, significant delays and degradation of Transitway service could result.

The proposed Urban Ring will not be a one-seat ride, but may require several transfers along its route, reducing its utility to provide service and passengers to this district, either directly or through connections with other transit. The line, and a spur to this district, is a concept which is not fully designed, does not have funding, and may require a vehicle of fueling type which is not in production. As such, while highly desirable, it should not be used in any way to provide anticipated ridership numbers.


It is interesting that Massport anticipates that pedestrians and others will provide only 5% of peak hour trips. Just the unlinked trips, at 2,200 to 3,500 are twenty percent to one-third of the expected transit demand for the entire district. In downtown Boston well over 50% of trips are made by pedestrians, and at many times of the day pedestrians outnumber autos on many street segments. We believe that pedestrians are being underaccomodated in this district, which will limit the benefit they can lend towards reducing congestion.

There should be a full discussion of pedestrian circulation movements, particularly during peak hours, with particular attention to the provision of adequate marshaling or queuing space on the sidewalk while pedestrians await a walk phase, and to ensure that waiting pedestrians are all able to cross the street safely on that phase.

Calculation of pedestrian Levels Of Service should include a factor which acknowledges that differences in clear width have effects that are not linear. A sidewalk with a clear width of six feet has much less than half the carrying capacity of a twelve foot sidewalk, for example. Since pedestrians prefer to use widths of three to four feet per person, the clear width of a sidewalk should be in even multiples of that to be most useful. Only nine feet of the total width of a ten foot sidewalk might be used to derive a calculated capacity, whereas a twelve or fifteen foot sidewalk would count its entire clear width. Since sidewalks of greater than fifteen feet clear width have such a large capacity, widths in excess of that should only be considered in highly unusual circumstances. There is a concern that with growing width there will be a lessening of any feeling of connection or urban scale between one side of the street and the other, which may tend to encourage vehicle behavior more suited to highways.

Open sidewalk areas not included in the clear travel path will need to be intensively programmed, landscaped and maintained, particularly when their width grows beyond six feet. More thorough description and design is needed, particularly to indicate how corridor and district continuity will be created and maintained, and that the liveliness and pedestrian aspect engendered on the sidewalks will inform the entire street. Public amenities should include regularly spaced and straightforward signage, trash cans, benches, art, plantings, pedestrian scaled sidewalk lighting, water fountains, and free public toilet facilities. These should be detailed for each roadway segment, building on current proposals.

It is essential that the right sidewalk be in the right place. When calculating the adequacy of sidewalk width pedestrian generation rates of each parcel should be contributory to the total load of a pedestrian corridor. A given sidewalk may be outside a relatively low generator of pedestrians, but its location on a heavily traveled route would require additional width to provide adequate service. As with vehicles, pedestrians are generally heading towards a given destination, and pedestrian numbers will increase with proximity to that destination, and increasing clear sidewalk widths should be constructed to accommodate those flows adequately.

There should be pedestrian crossings which 'box' every corner of each intersection. There should be pedestrian controlled walk buttons placed at each corner which overrides signal timing in the immediately subsequent phase, and of sufficient duration to permit crossing of the entire intersection width during that phase, without need for recourse to refuge on islands or medians. Signal timing of intersections should be adjusted to permit this at all intersections.

Bicycles and alternative vehicles

Bicycle lanes should be clearly identified and provided as part of a continuous network. Some thought might be given for accommodating other low speed vehicle types, whether motor or human powered, and variously fueled in the district. This has a natural adjunct with consideration being given for provision of alternate fueling stations for LEV or ZEV users. All buildings and parks should incorporate curbside bicycle racks, and interior bicycle storage areas should be integral to every vehicular garage. The potential also exists that with adequate, adjacent bicycle storage the effective range and utility of public transportation can be vastly increased, helping to take pressure and pollution off the roadways. There should be a strategy which permits a rapid and efficient increase in bicycle amenities as use increases.


The right Transportation Demand Management tools have been identified and incorporated; however, there needs to be a program which identifies specific and global goals for reducing the use of single occupancy vehicles and increasing the use of higher efficiency transit options. Programs and methodologies to implement, should practice fall short of goals, should be identified and in place as part of the development package for each site. Having a plan should in no way be considered an adequate response for actual and measurable attainment, which needs to be tracked, modified, and improved over time.

The scope of the TDM measures should include car sharing programs. An individual or company may avail themselves of what is essentially a short term rental car for emergencies or travel when and where transit is not available. This could greatly increase willingness of commuters to rely on public transportation, be highly economical, and reduce congestion.

Freight Rail

No actions should be taken which degrade the operation of the rail line adjacent to the Haul Road extension. Improvements or extensions to rail service should receive the highest priority.

Sustainability and Energy Use

Massport should initiate and pursue a sustainability program which looks at energy use and production, regional materials supply, elimination of waste products in construction and operation, indoor air quality, design for adaptive reuse, avoid contributing to CSOs or placing stormwater directly in the harbor when it could be used on site, and other elements. This project should be done with the assistance of BASEA, ASR, CLF, SAND, and other knowledgeable parties and incorporated in future filings. This will prove to be in Massport's best long term interest as it will add value to the buildings while reducing maintenance and operating costs, attract higher quality tenants, produce buildings with longer productive lives, reduce demolition costs and hazardous waste disposal fees.

Heat Island effect should be reduced by requiring all buildings to have light colored roofing. This no cost effort will reduce operating and fuels costs while improving local microclimate.

Opportunities to provide district steam lines to more efficiently serve development projects should be incorporated in site development efforts. This economical and environmentally friendly power and heat source will reduce operating costs and permit less of the building to be used for mechanical equipment and eliminate the need to store flammable fuels on site.

Solar access for power and power/heat generation should be protected and guaranteed to all developers. Open space should not be in shadow. The massing proposed does not indicate that it has been studied with any level of detail, or effect. This should be done and incorporated into subsequent filings.

Parcel Specific Attributes

K & J as housing sites are too close to truck routes.

C Parcels should be developed as a series of smaller structures within each sub parcel to limit the potential to create a monolithic structure. There should be many publicly accessed entrances, closely and regularly spaced, and an articulation of the facade and setback limits to further activate the street edge.

Parcel D-2 in particular will need to study air quality issues related to the CA/T vent building along Summer Street to ensure that pollutant levels are moderated in the vicinity of the building, particularly for pedestrians.

Parcel D-3 should be studied as part of the DEIR to ensure that its future uses will, in fact, be compatible with other planned uses, that it retains developability, and will not be precluded by other developments or contribute factors which degrade the functionality of the district.

Parcel G should in no way be connected with Parcel J.

Limiting Parcel K-2 to only 20,000 sf is wholly inadequate either for industrial area or for massing to contribute both to the urban fabric or as a buffer for abutting residential uses. 600 at grade parking spaces should be considered purely an interim condition with a limited and specified lifespan, and never a final or desirable result.

Parcels G, J, and K-1 should have sufficient set backs of upper residential floors to distance residents from the majority of line-of-sight traffic noise, using lower commercial floors, cornices, canopies and the like to buffer and reflect noise away from residence.

Air Right Garage, or Southern corner of Parcel C-1, should provide direct link to Viaduct Street to assist riders wishing to access BCEC, saving several hundred feet of travel by foot and enhancing utility of the Transitway.

C Parcels should be designated primarily for upper story transit oriented housing, with a 50% reduction in office usage. This could be designed to permit artist live-work housing at various levels of affordability

C Parcels public accessways should be presented and reviewed in concept or schematic form as part of the DEIR review process.


We are eager to see Massport proceed rapidly and successfully with their development program, but we are concerned that its success will be jeopardized if the concerns which we have raised are not adequately resolved. The public, the adjoining neighborhood, city and region all require this if we are not to suffer adverse ill effects from this project. These issues are important but their resolution in no way poses a threat to the viability of the project, rather they will make it stronger overall. Prudence and responsibility indicate that we should not build something which provokes a harm to the greater community, and without modification and in tandem with other projects, both permitted and proposed, immense harm will be suffered and the viability of this emergent district is at risk. SAND remains available for discussion of these issues with you, and the proponent, at your convenience.


Jon Seward, on behalf of
Seaport Alliance for a Neighborhood Design

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