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

re: Commonwealth Flats Development Area, EOEA #11882 Open Space Notice of Project Change

attn.: Ms Laura Rome, MEPA Unit#

Dear Secretary Durand,

SAND would like to commend Massport for providing this Notice of Project Change to the Commonwealth Flats Development Area. In general, we find that it clearly expresses and refined elements which had been described, but not detailed in earlier filings, and improves the quality of the public realm from the prior state. While open space has been improved and elaborated there still remain several areas where additional improvements can and should be made in order to fully achieve the promise of this development and to maximize the benefit to the public and the Commonwealth. Our comments have been limited to those areas which we believe require further examination, design efforts, and improvement before they should be permitted to be constructed. We want to note, however, the extent which Massport has gone to incorporate prior comments and reconcile the issues which have presented themselves. SAND looks forward to the continuing evolution and improvements of this design as plans move forward and are further refined.

The exclusion of Jimmy's Harborside from the project limits, Parcel E (Building 4), is problematic from standpoint of understanding relation of Commonwealth Flats to the water & the role of the Harborwalk in the larger, emerging urban context. Similar comments can be made regarding the relationship to the Fleet Pavilion. Moreover, there appear to be minor inconsistencies between the text and several of the illustrations regarding precisely what buildings or installations are to be constructed on the present Jimmy's site.

General Streetscape Guidelines

Sidewalk design guidelines should provide a baseline minimum of eight feet (8') uninterrupted, unimpeded sidewalk width, with additional width devoted to street furniture, plantings and additional sidewalk width, as appropriate to specific locations. There should be no need for any sidewalk to fall beneath the citywide standard of 8' clear.

There should be pedestrian crossings on all sides of each intersection, marked and signalized similarly to City standards, without exception.

It would be useful to see cross sections of roadways at intersections where additional turn lanes or islands have been introduced to be able to understand the characteristics of the pedestrian crossings.

Where additional traffic lanes will be provided, consideration should be given to eliminating any additional width of the right hand travel lane to eleven feet (11'). Wider lanes are not required on roads not anticipated to be primary bicycle routes. Striping of a wide curbside lane to indicate a bicycle pathway will assist in organizing vehicle flow and reducing travel speeds to posted levels.

A diagram detailing primary bicycle routes should be provided, with accompanying information on street furniture and its specific location, such as bike racks and lockers, signage and other amenities to be provided to encourage additional bicycle usage.

All medians should be re-examined to determine their need, and most, if not all eliminated, as they encourage speeding by motorists and degrade the pedestrian environment. Two foot flush, textured or striped medians should be the standard throughout the district, if needed.

Light fixture deployment should be examined with an eye towards reducing the number of styles that will be in use. It is more important to provide a unity of high quality fixtures generally throughout the district, and particularly linearly along roadways to establish identity and pleasing rhythms. D Street should not have six separate lighting systems deployed along its three block length. Viaduct Street should have a single consistent lighting type. The continuity with and relationship to lighting and signage of abutting areas should be described and studied to promote appropriate integration of designs. The height, luminosity, and color of the lighting should be reconciled amongst the various fixtures, and any strategy for contrasting effect clearly stated and modeled. Particular attention should be placed on avoiding upward scatter and light pollution, and to providing lighting which will be pedestrian scaled, avoiding glare, and energy efficient.

Pole supported span wires should never be employed to suspend lighting, signals or signage or any other appurtenance. Mast arms should be used in all cases. Any intersection too wide to permit the use of mast arms should be redesigned until it is narrow enough to employ them. If any intersection cannot be sufficients reduced in scale to employ mast arms, and there are no indications that this would be necessary, then spanning tube armatures, such as those placed by the Central Artery/Tunnel Project should be used.

Mast arm fixtures might better have projecting arms which incline from the horizontal, rather than projecting at 90 degrees. The included angle will permit longer arms to be used. Care shouldbe taken to ensure that the base diameter of all poles adjacent to public walkways are less than eighteen inches.

Street tree plantings should be comprised of different, hardy species able to look elegant in all seasons while resisting the harsh local climate. Single species of equal age are susceptible to many diseases and will require replacement at one time. Trees should be spaced closely to provide a full, interlaced canopy prior to maturity, and be of 3" caliper, or greater, when planted.

Chapter 4 Urban Design Guidelines

Steel elements should be carefully considered and designed to reduce the likelihood for rusting and consequent accelerated maintenance and replacement schedules.

Building Massing & Orientation: Building floor plates should be reduced by requiring no single floor plate above 75 feet to be over 20,000sf., through the use of multiple towers or other means. Building shafts should become more slender still above 125 feet. Those area reductions should be clearly stated.

The ten foot clear sidewalk dimension minimum should be adhered to in all cases.

Use of canopies, roof extensions, arcades, pergolas etc. should be carefully considered on the North facing sides of buildings to avoid casting too deep a shadow over the sidewalk or creating street level building faces that appear empty and lifeless. City daylighting standards should be employed to determine that hose areas will not be overly dark for pedestrians to use and appreciate.

Connections to and from Viaduct Street and the roads below should be made primarily through exterior circulation elements, which should be the clearest and most direct circulation route in all cases.

All through building connections should be subordinate to sidewalk circulation paths.

Environment: Undercut building elements should be avoided as they enhance any tendency towards exacerbating wind tunnel conditions, as well as casting excessive shadows on sidewalks.

The effect of building shadows on open space should be described and referred to when planning parks, to avoid shading planted areas and areas where people can be expected to gather. Where those effects cannot be eliminated or minimized, mitigating features should be described and provided.

Accessibility: All buildings providing public accommodations of any type must contain the services and amenities described and be fully available during all hours the lobbies are staffed, at minimum.

Sustainability: The sustainable strategies enumerated should be considered an adequate starting point. Ambitious goals for attainment in each category or by each method should be set and considered as minima.

Additional areas that should be included would contain: Design to the performance standards of a certification system such as LEED; Graywater reuse; Storm water retention/irrigation/graywater usage; Operable windows; Natural building ventilation & cooling methodologies; Use of renewable building materials from certified sources; Super-insulation levels to be specified clearly for various conditions and materials; incorporation of fuel cells and hybrid power generation methods, Use of building mass for energy and thermal storage; Transportation demand management must set and show attainment of aggressive goals for private car use reductions; Car sharing programs should be implemented.

Proposed Open Space Plan Elements OS-4

#3 The 'raised viewing plaza' in Eastport park may interfere with the view of the Harbor from other locations along D Street.

#5 The grade differential at Portal Park prompts concern for personal safety of users of the park, being particularly below the level of D Street and without direct line of sight from adjacent roadways, further compounded by what appear to be dense plantings. Additional stairs, lighting and elevation changes might be called for

#6 Park parcel at easterly portal of approach to the Ted Williams Tunnel is not described or otherwise illustrated.

I-90 Ramp Islands promote overly fast vehicle traffic, particularly at off peak times, requiring far too much roadway area, and consequently make for an extremely long and dangerous multi-legged pedestrian crossing environment. These should be redesigned to tighten roadway radii and provide additional land to Parcel A-2 and the parcel to its West, minimizing or eliminating all islands; lessening pedestrian crossing times, or the need to seek refuge on an island to await subsequent signal changes to complete a roadway crossing. Curb radii at B Street are far to large and should be reduced to the greatest degree possible.

#8 Additional vertical circulation elements should be provided from Viaduct street to the roadways below at what would be termed intersections by pedestrian standards. These would include an additional, Westerly link at the World Trade Center, and 2 at the Seaport Hotel Block so that there would be one at each corner.

Pedestrians should be able to exit to the D Street side of Parcel C

#9 Parcel A-1 fronting to Viaduct Street should be better described and illustrated. There should not be a vehicular forecourt.

#10 Canopy over pedestrian way of Viaduct Street should be evaluated to provide sufficient levels of weather perception & perceptual continuity while not being overly enclosing or trapping vehicle exhausts. Present design section (fig. OS-28) suggests a heavy canopy which fully covers the sidewalk which seems to create an interior condition. The roadway should also be balanced with a complementary canopy on the West side of the roadway.

#11 Berm plantings @ plaza of Parcel D-1 should be described and illustrated.

Elements of the plaza should include high quality pedestrian scale lighting and emergency call boxes, public telephones, water fountains and other amenities, such as art sourced from the surrounding community.

There should be trees and other, substantial plantings at the level of the plaza equal to that of the other, signal open spaces of the district, not simply hardscape.

#13 Complementary open spaces of the World Trade Center & along Northern Avenue frontage of Fish Pier should be fully described to the extent that they are currently known or contemplated.

#12 Summer Street Pedestrian Tunnel requires further description

The underground link to the Parcel D-2 building to the Convention Center site should be re-examined carefully. The surface crossing must be the obvious, safe, direct and preferable crossing of that intersection for pedestrians. Any entries and exits should give directly onto the street. Any below grade link should be sized solely for usage during inclement weather.

#14 Consideration should be given to providing additional banner-style fixtures on D Street at Summer Street and at at the Western corner of Parcel E, to serve as gateway marker, and to better establish the relationship to, and connectivity with, the water.

#15 Congress Street Facade uses, activation & adjacencies: the entirety of the street needs to be considered in the context of the scale and uses of the existing street.

#17 Pedestrian connection along Viaduct Street needs to be emphasized, through & continuous.

Greater description of activities and purposes of the promenade should be made, particularly its ability to be fully animated by users during good weather. Increase of planted areas should be considered. It is unclear what grade transitions will be called for & should be clarified. Paving patterns should be described as well as the use of smooth paving materials on primary walkways to eliminate tripping hazards and difficulty to people with mobility needs.

#18 Park area alongside the Connector Road should be appropriately resolved to screen the boat section and to provide enjoyable respite for pedestrians and those waiting for the Transitway connection.

Illustration Specific Comments

OS-5 Diagram omits all East-West moves that would be anticipated from the standpoint of pedestrians, and would be expected to be a significant desire.

OS-7 Eastport Parks are divided by heavily trafficked leg of D Street and cannot be compared with Post Office Square Park; comprised of 3 rather than 2 parcels. Eastport Park is attached to an office building and side streets may be more heavily trafficked, all suggesting a significantly different park. The location & size of restrooms is important and should be described.

OS-9 Have pedestrian corridors been omitted, or have they failed to reproduce in the document? The axes shown do not match what would be anticipated for pedestrian movements, and should be amended. Harborwalk does not conform to routing shown elsewhere Axis of 'Harbor Views' shown should be studied in accurate perspective, and used to inform design moves. Renderings do not show that the water is capable of being perceived from the outlet of the transitway station on D Street Describe further the 'structures frame harbor view' elements.

OS-11 All legs of Harborwalk should be identified & noted. Additional pedestrian Zones should be identified at: ground level of Northern Avenue beneath, and extending to each side of, Viaduct Street; Congress Street beneath and to the side of Viaduct Street; Congress Street between Parcel C-3 , the Seaport Hotel and the East Office Building; at D Street between Parcel C-2 and Parcel F-1; Congress Street Extension and Northern Avenue; all other locations generally describing an intersection or major pedestrian desire line

OS-35 The 9' raised median proposed for Congress Street should not be used, that land being better used for a narrow flush median with the additional area given over to enlarged sidewalks and curbside plantings.

OS-36 & 37 Illustrations do not indicate the continuity strip to be used on Viaduct Street and for a portion of D Street.

Congress street shows an unbalanced relations between the two continuity strips to be used. It is important that there be neighborhood consistency as well as consistency in use on each individual street. If the Congress Street median was to be reduced or eliminated that additional cross section could permit the South side of Congress Street to be a full 8' continuity strip between B and D Streets.

OS-37 The abundance of special condition plantings seem to suggest that there may be great difficulty in providing any sort of consistency of tree planting along many streets, much less the entire district. Summer Street, D Street and Congress Street Extension are all major thorofares which deserve consistency of approach.

Condition 3 Street Trees should be placed on the plaza opposite the Convention Center.

OS-39 The twenty foot travel lane shown should be reduced to the minimum width or made into two, ten foot lanes.

D Street Corridor: Widening the Summer Street Bridge by four feet does not appear to be able to yield the area to provide both a wider sidewalk and a raised median.

There should be consistency of sidewalk in width, alignment, and balance on both sides of the roadway. The Summer Street median should be eliminated or converted to a narrow flush median.

OS-41 The sightline indicated does not take into account varying grades and elevations along D Street which preclude perception of the Harbor from many locations along it. It should also be observed that this axis aligns to a service area of Logan Airport on the East Boston shore.

Massing along D Street: Parcels F-1 and F-2 should maintain strong base and cornice lines of approximately 75 feet along the D Street sidewalk with pedestrian scale detail and materials, holding the major shafts of the building towers above further back from the sidewalk, by one structural module at minimum, to prevent the sidewalk and street from being overpowered and claustrophobic.

OS-44 Northern Avenue cross section showing curbside lanes of 15 feet should be reduced with additional area located in each sidewalk. The center flush median should be identified as no greater than 2', if required at all.

Congress Street Guidelines: The concentration of unactivated facades and vehicle entries and service areas present on the North side of Congress Street is cause for significant concern and should be avoided elsewhere in the district, and particularly on major roads such as Congress Street.

Southern side of Congress Street should have a double row of street trees to balance those on the the Northern side.

OS-47 Congress Street section The center median does not scale at the three feet which would remain if other lanes are the width indicated. Consider reducing the median width or eliminating altogether.

OS-49 Congress Street Section Shared travel lanes of 18 feet should be reduced to minimum widths. Additional width should be given to the Western sidewalk.

OS-51 Market Street Section Sixteen foot shared travel lane is too wide and should be reduced to the minimum dimension. Additional width should be given to each sidewalk to provide a minimum clear walkway of 8 feet.

OS-52 New Fish Pier Road Section Sixteen foot travel lane is too wide and should be reduced to the minimum width. Additional width should be given to both sidewalks, particularly the Southerly side to provide a minimum clear width of eight feet.

OS-53 West Cross Street Section Sidewalk dimensions are too narrow and should be widened to a minimum of 8' clear.

OS-54 East Cross Street Section Sidewalk dimensions are too narrow and should be widened to a minimum of 8' clear.

OS-55 Seaport Lane does not show a sufficient level of street furniture and pedestrian amenities. It also has too few opportunities to enter the buildings facing the street.

OS-56 Connector Road Section Sidewalk dimension on North side is too narrow and should be widened to a minimum of 8' clear. Travel Lanes are too wide and should be reduced to minimum sections. Taller shrubbery and more extensive ground cover should be provided in open space areas.

OS-57 Connector Road Section Travel Lanes are too wide and should be reduced to minimum sections. Median width should be reduced to minimum section. Additional width should be granted to sidewalk , particularly at the transitway stop.


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

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