Mr. Bob Durand, Secretary Executive Office of Environmental Affairs
251 Causeway Street
Boston, MA

re: Transportation Summit: Challenges & Approaches

Dear Secretary Durand,

The Seaport Alliance for a Neighborhood Design supports your efforts to bring clarity and consistency to the difficult issue of transportation access to the South Boston Waterfront district. Since our founding we have examined the assertions and implications regarding transportation, and have been concerned that there would be a significant shortfall in service. Without a holistic approach and proper remedies, development in the are will be uneven and plagued with congestion.

Events have clearly outstripped the viability of Green Book based projections. Close to ten million square feet of new development is underway or in the permitting process currently, and more is expected shortly. While we anticipate the benefits of the new MBTA Transitway and completion of the I-90 extension, it is all too apparent that they and other transit will not be adequate to the demand that full buildout will place upon them.

SAND does not believe that action on any one problem area which we have identified can provide an adequate remedy, nor would it be desirable. Rather, concerted action is necessary to create a broad spectrum, full service residentially focused neighborhood, in combination with enhanced transit, to provide the greatest, lasting benefits at the least public expense, and leveraging the existing twenty billion dollar public investment.

This will not be easy, but it must be done. We are faced with a problem, but also with an historic opportunity to fully remake one thousand acres which is Boston's last frontier, and one of its finest resources. It will be easier to act expeditiously than to craft the proper solutions. But if we permit the promise of this area to go unfulfilled we will have failed in our duty to the City and the Commonwealth, to our neighbors and ourselves, and to the land. History will not be forgiving of an opportunity such as this, squandered.

We look forward to participating in the upcoming transportation summit, seeking balanced and worthy solutions. Your leadership and determination is crucial to the success of this event, and for this district, and we are grateful for that courage. SAND is confident that we can build well on our success here and create a neighborhood that truly is exemplary.


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

Transportation Challenges facing the Waterfront:

The primary transportation issue, now widely apparent, is the overwhelming dependence on single-occupant private autos by employees working in the Waterfront District to reach their jobs each day. This problem has three main causes: 1. Lack of Residents within the Waterfront currently and in the future; 2. Land Use Mix heavily weighted towards commercial uses reliant on schedules that require arriving and leaving at peak hours; 3. Insufficient Transportation Infrastructure, particularly grade separated mass transit, leading to buses and shuttles which will be stuck in the same traffic jams as autos, creating further disincentives for transit usage.

1. Currently, only two economic sectors are being focused on, both in current planning efforts and by development interests: Class A offices and tourism. Up to 13 million square feet (msf) of office space is contemplated (5 msf of which is in construction or review), if extrapolated to the remaining parcels will outstrip that figure. Between the 1.6 msf Convention Center and the anticipated 3,500 hotel rooms (50% of Boston's current hotel space) will amount to some 3.5 msf of development area. This discounts the restaurants, nightclubs and other tourism focused businesses that will emerge to serve that clientele. This amounts to 18 million square feet.

The 5,000 dwelling unit minimum goal will add an additional 5 msf to the buildout, about 20% of the total. If the housing number was doubled, as is contemplated (which SAND and the BSA consider a practical minimum) that would be only 36% of total buildout. By contrast, the Back Bay is approximately 60% residential, and contains far greater civic, open space and cultural resources than are contemplated here, as well as significant commercial occupancy. The valued and memorable aspects of cities are associated with residential neighborhoods, and the residential density required to economically support them. This limited tally only accounts for 22 msf, but is more than the BRA Public Realm Plan (PRP) maximum total district buildout.

2. At the minimum housing buildout we can expect no more than 2,000 area residents to work in the district, and as these dwellings will primarily be for the affluent, that number may not crest 1,000. By contrast, the general space allocation for office workers is 200 gross square feet per person. This indicates a maximum office staffing of 65,000, exceeding on its own the 2020 projections by 19,000 commuters. Although we don't discuss other sectors here for the sake of simplicity, up to 10,000 additional jobs must be taken into consideration. District hotel occupancy may be assumed to be 5,000, with BCEC capacity of 25,000.

The backbone of the transportation system will be the MBTA Transitway, with a claimed peak hour capacity of 3,800 riders, equal to Red Line capacity after second phase articulated vehicles are acquired, transporting about 7,500 persons during the two hour rush hour peaks. Water transit is expected to supply about 500 people per peak hour, or 1,000 more. Walking and cycling may anticipate a 15% share, up to 10,000 people. The total is 18,500 for non-auto modes, plus 1,000 in-district for a grand total of less than 20,000, about 30% of office employees.

The remaining 70% must come by motorized vehicles on roads. There are some fourteen lanes of traffic which enter the district on major roads. If we assume each lane can carry 1,000 vehicles per hour with a two hour rush, then up to 28,000 vehicles will be able to enter the district. Accounting only for new office development, there must be an average ridership of 1.6 persons per vehicle to deliver employees, about the current occupancy rate. We face a shortfall approaching 50% in the ability of the transportation network, under the anticipated buildout and economic mix. Therefor, exceptional and aggressive measures must be enacted to accommodate development beyond PRP limits, for office construction, to bring conventioneers and tourists, for service vehicles and trucking, for the industrial and maritime users of the Waterfront, and others.

3. Currently, and foreseeably, there will not be funds for conversion of the Transitway to heavy rail or to complete it to Boylston Station, nor are there funds for a rail-based urban ring or additional water transportation. It is significant that the Transitway must cross traffic at grade at D Street, twice on each circuit. D Street is highly susceptible to delays, congestion and gridlock which will prevent the Transitway performing to the required 3 minute headway. Carpools, vanpools, shuttles and buses will all be caught and delayed in the same congestion as private vehicles, limiting their preferential adoption by commuters as viable replacements to the auto. The distance of a large part of the district from other transit hubs will reduce incentives for commuters to walk or bicycle, adding to the vehicle congestion, and there will be growing competition from downtown and South Station area development. Consideration must be given to those impacts, and that of the displacement and elimination of current parking in the district, which largely serves downtown needs today.

There will be great temptations to redesign roadways to speed traffic and increase capacity. This will be fruitless, attracting more congestion and leading to a degradation of quality of life in the area, and great danger to pedestrians, cyclists and those with mobility concerns. The only real solutions are greater proportions of residential occupancy, less overall building mass, aggressively enhanced transit, and provision and enforcement of roadway use preferences for high occupancy vehicles.

Approaches to Transportation Alternatives

SAND has consistently advocated measures which would address the root causes of congestion and provide the robust, effective transit needed to deliver people to the district. Boston continues to thrive because of its immense natural advantages, history and embedded investment, and high quality of urban life and opportunity. Boston is the hub of a regional and national transportation infrastructure, and transportation efforts should be focused on the highest quality and highest capacity systems which are operationally separated from roadway traffic, and its endemic congestion.

High residential densities reduce the number of people who require transit or vehicles to get to work in the district. Affordability must be assured in the mix of housing built, representative of the employment to be created and in commensurate percentages. If the minimum threshold of residential units was raised to 10,000-15,000, and a better fit of occupants to jobs provided, a resident employment base well over 5,000 could be created, substituting for up to 25,000 office jobs, and reducing transportation demand by 30,000.

Broader diversity among economic sectors will reduce the number of commuters on a 9-5 schedule. Land uses such as residential, arts and cultural, recreational, maritime, high tech research, educational, industrial and service sectors must be emphasized. Many of these require 1,000 gsf per employee or user. Housing required by commercial linkage fees should be built within the district. Additional area devoted to those uses (double or better) will also reduce the area available for commercial uses. The Boston Parks Department standard of a minimum of 5.5 acres for every 1,000 residents should be adhered to, and does not include roads and sidewalks.

Reduced buildout will limit the maximum number of occupants in the district. Development permitting must avoid cherry-picking by early, large projects which cannibalize available transportation resources, reducing or precluding later development of other sites, in ways inconsistent with the Public Realm Plan. There must be enforceable methods to ensure the attainment of ridership goals advanced by developers. This indicates that early development should be smaller scale and incremental, rather than that now being discussed. Total buildout should be limited (including all above grade parking) to a height of 150 feet and an FAR of 4.0, like the buildout out of the historic Fort Point Channel district, exclusive of all area in roads and sidewalks, islands and medians, and the elimination of all Planned Development Area zoning.

Enforcement of PRP standards such as pyramidal massing of the area, setbacks from the water, open space provision, reduction of the number of building elements permitted above 150 feet to a maximum of ten percent of new structures, retention of future opportunities for water dependent and industrial uses. The BSA Barometer should be used as a guide to the emerging trajectory and implications of area development and its relative success.

Enhanced transit provides realistic alternatives to road (and congestion susceptible) based routes. Collateral benefits emerge, with less area provided for vehicles and an improved public realm. Funding and scheduling must be put into place for the MBTA expand the capacity of the Transitway, and provide continuation of rail service to Washington Street. The Urban Ring must be extended and linked to, as rail, perhaps utilizing the right of way of the South Boston Bypass Road, with a stop at the Convention Center, and continuing to Logan Airport. Additional water transportation options need to be put into place. Transit service must be regular, economical, reliable, and available 24 hours a day. San Francisco's Night Owl service may be a model for late night skeleton service. Ridership goals should be time and development specific, with funding and implementation plans in place, and be based on current operating performance and historic service delivery levels.

Emphasis on neighborhood based development makes bicycling and walking more reasonable alternatives to the car. One sidewalk can carry over 5,000 pedestrians per hour, at capacity; bicycles require only one-eighth the roadway (and less still storage) area as each car. Efforts to increase these modes are economical, will pay early dividends, and will humanize the district, making it more successful.

Your comments as a visitor to the SAND website would be appreciated and forwarded for discussion.