SAND has filed the following letter with the Secretary of Environmental Affairs during the public comment period for construction of an office tower on South Station. SAND members have been attending hearings and discussions regarding this project.


Secretary Bob Durand
Executive Office of Environmental Affairs
215 Causeway Street, Suite 900
Boston, MA 02114

Attn: MEPA Unit #9131

Dear Mr. Secretary,

The Seaport Alliance for a Neighborhood Design (SAND) respectfully requests that you deny in full this application for DEIR status. SAND is a proponent of large dense development, particularly at transportation hubs, and will champion the appropriate development of the public's air rights at South Station when a responsible plan is submitted. This is not that plan, and the appears to be significant doubt as to whether the proponent actually has the full and appropriate approvals and agreements needed to proceed to the DEIR filing stage. As we review the filing document and the recent presentation by the developer, we find many more elements of the project which are of grave concern and will bring damage to the city, to continued operations of South Station, impacts which cannot have any positive benefit.

South station and Dewey Square are the gateway, entry, and living room of of the Fort Point Channel neighborhood. It is the place where we meet the rest of the city, a place where people meet people, the closest we currently come to neighborhood shops and markets. It is special and we cherish it. And we cannot stand by to see its best qualities and important functions eviscerated. The waiting room and the terminal building must not be reduced to the doormat of a massive commercial building.

The project proponent is clearly only interested in the construction of the largest and most massive commercial building possible, and their interest in the needs of the public and the public trust are incidental at best. While we understand the interest of the developer in maximizing their own benefit, it cannot be facilitated by municipal and regulatory bodies, making use of public lands and facilities, which have been brought into being by significant effort and investment by the public sector, including federal appropriations. This project should, rather, maximize the continued benefits to the public of these prior investments, and any development should be appropriately respectful of this.

Project Concerns

Lack of Conformation to original Project Guidelines

It is significant that prior planning principles for this site specifically excluded any construction above the existing waiting room area. No necessity for this has been advanced, only the developer's desire. Similarly, City zone has established a PDA cap of 400 feet for this site. The developer has not established a rationale for any need for this wholesale abrogation of recently placed zoning, nor has they provided an as of right study comparison. They should be required to provide both in sufficient detail that evaluation of the project can be made on its merits.

We believe that the only apprpriate method to amend maximum heights would be through comprehensive review of area zoning, made in a public forum with adequate opportunities for review.

Tower a Hazard to Air Navigation

The proponent has not adequately identified, discussed or provided mitigation for the significant impacts that alter airplane flights paths will introduce to the downtown area. Should the new Logan Airport runway be opened to regular traffic we can expect significant increases in overflights of both the South Station and Fort Point Channel districts. These planes will need to take action to avoid collision with the tower of this development, which will require additional maneuvering, engine thrust and turning movements. The impacts of those mandated actions are currently unknown and will involve noise, vibration, air pollution, particulate deposition and the like, in addition to additional consumption of aviation fuels and increased wear on engine and airframe components of the individual aircraft, requiring additional servicing (or potential system failures), costs which will further the cost of doing business and serving the Boston market, likely transferred to the public in the form of higher fares.

Imposition on Acela Introduction & Viability of Amtrak

The continuation of public intercity rail service in the United States is completely dependent on the survival of Amtrak, which is currently operating under legislation from Congress requiring a rapid transition to profitability, a feat which the national rail service of no other country currently achieves. This satisfaction of this difficult task is fully reliant on the successful introduction and growth of the recently initiated Acela high speed service, with route termini in Boston and Washington DC, to successfully compete with established and profitable air shuttle service.

No action can be accepted which impedes any aspect of the Acela Service. This includes the ticketing and dedicated waiting room functions, luggage handling, rider circulation from any point within the existing building to the train platform, riders access to the existing station from all other transit modes which may stop at or near South Station, both public and private, for both the construction and end states of this proposed project. Perhaps, as mitigation for any impacts which result in Acela or other existing or planned rail service to South Station failing to meet projected targets of ridership, or in Amtrak's case its profitability targets, for the proponent to post a bond in the amount of those ridership dollars which may be negatively impacted.

This project might have a catastrophic effect on rail transportation policy in this country, if Amtrak's viability is threatened. There is no commercial construction project of any size or in any location which is so important, or justifies this magnitude of risk to national inter city rail service. The pollution reduction (including greenhouse gasses, particulates, NOx and hydrocarbon emissions, congestion reduction and associated trip reductions and reduction of vehicle miles traveled, passenger safety enhancements, and energy conservation benefits of Acela service, much less the other commuter rail and local and regional transportation hub services of the South Station complex are far too great to permit their diminution by construction impacts or the final state of this project.

Lack of Residential Component

This site above the air rights of South Station is an ideal location for high residential occupancies. We are currently seeing the conversion of loft buildings in the Leather District to accommodate some of the burgeoning demand for center city residences by professionals, empty nesters and families who are once again recognizing the benefits of living in downtown Boston. It is significant that over the past ten years we have produced millions of square feet of new commercial office space in Boston, while only building a few thousand housing units citywide in the same period. This unbalanced provision of commercial space is a prime factor in the continued and increasing strain being placed on the entire regional transportation infrastructure, increasing congestion, pollution and time wasted in lengthier commutation.

This site is valueable not only in its being able to house people who work downtown. People who need to commute to other regional locations can make use of the return leg of the transportation system, both by road and rail. Those legs are currently nearly vacant as they depart South Station. Reverse commuting is an under appreciated transportation mode which, if properly recognized and utilized can nearly double roadway and transit capacity with no additional capital or operational funds, thereby significantly improving the operational economies of transportation agencies. Lack of Connection through project to Join with PO Site & Fort Point Channel The proponent must provide discussion and viability of future potential linkages from their development, above the existing train tracks, to provide future links between Atlantic Avenue and the Fort Point Channel. These should be in addition to any potential connection using the existing train or bus stations. We commend the proponent to the designs of the BCEC convention center: at the request of SAND the architect was able to provide full public accessibility across the site via internal bridges over the convention hall. This has enriched the design, made the building more fully public, and has enhanced the design and operability of the facility to the satisfaction of the BCEC. As this project is of the same scale and similarly involves public lands and monies, it should be no less public and accommodating. This project must demonstrate and understanding or areawide planning objectives and be willing to play its role in bringing them to fruition.

Scale & Impact on Dewey Square

Dewey Square requires additional spatial enclosure which new building can provide; however, this proposal and the renderings provided prove that this tower will not produce any of the needed spatial definition. The existing terminal building already provides this and is the single successful building in shaping Dewey Square currently. We should be concerned about the tower's truncation of the Federal Street view corridor.

Shadow studies provided are incomplete & have been selectively provided to inaccurately minimize the full shadow impacts produced throughout the year on water bodies, streets and open spaces and historic resources. Full sets, from dawn to sunset for all equinoxes and solstices must be provided to fully gauge the impacts generated, especially for Mass Hort.

Inadequate Modeling of Pedestrian Movement

South station is now used by substantially more than 40,000 transit riders daily. Project growth in ridership and the introduction of additional rail lines and service modes, along with a potential doubling of bus station gates might bring daily users well above 100,000 per day within a five year time horizon. We have yet to see any detailed analysis which describes how the proposed development will adequately facilitate this growth. Rather, we see clear indications that this project will hamper, if not cripple existing operations, and add insupportable burdens on any hopes of expansion. We must be assured in all areas and at all times that the will be ample facilities for the movement of pedestrians, and for the other, continued and expanded operations of the South Station complex.

Boston Is 'America's Walking City', and pedestrians are by far the most flexible, adaptable and space efficient transportation mode. Nearly all of us are pedestrians at some point during each day. But pedestrians are not infinitely flexible and will make choices to vary their routes and even their mode when faced with sufficient adversity. The peak volumes of pedestrians at South Station at rush hour, both morning and evening, overwhelm vehicle circulation which can generally dominate every other situation in the city. We can plainly see that the width of passageways and portals will be inadequate, both during the construction and in the final state, even to handle current levels of service. The project proponent must model in much greater detail and accuracy the existing and anticipated volumes and movements of pedestrians, and their interaction with vehicle for a one block radius from the site in all directions. This modeling must take into account incidental uses of South Station in addition to commuter uses, and the loading and servicing needs of the complex. The proponent must provide a detailed design which provides for better than adequate pedestrian accommodations, both in terms of physical dimension and wayfinding ability, but also in amenity and materials, commensurate with the existing historic structure.

'Sky Street'

The proposed 'Sky Street' is completely unacceptable. There are no other actions which are so harmful to the cities and the public good as the privatization and interiorization of circulation by pedestrians, which naturally belongs on the streets and sidewalks of the city. There is no discussion of how access to this street is to be signed, how access might be limited or restricted, to whom it will be available, under what conditions, how it is to be policed and maintained. Most importantly, no argument of need or necessity has been advanced to demonstrate that this 'sky street' is required or that the anticipated volume of pedestrians cannot or should not be accommodated on the sidewalks of Atlantic Avenue.

Interior Circulation from Bus to Train Station:

The proposed circulation has too many turns, the hallway is too narrow & the angle of the turns too abrupt. These problems need to be corrected to ease wayfinding and access.

Lack of Continuous Streetwall

Alternating glass and brick is offensive and needless. The construction of pastiche facades which bear only a faint resemblance to the fine buildings of the Leather District are highly offensive.

Lack of Ground Floor Retail

There is a significant shortfall in retail space on the Atlantic Avenue streetfront of this proposal. Far too much space is given over to storage and operational uses of the building. The lobby spaces of the development should include significant retail space beyond retail which is oriented and accessed from the street. This lack of an active streetwall is a significant shortcoming of this project and works aggressively to discourage full use and activation of the sidewalk zone and the public realm.

Lack of Additional Public Amenity

This project proposal seeks to use and remove from use by others the publics air rights above South Station's rails and waiting room, and all of the remaining street frontage of one side of Atlantic Avenue between Kneeland Street and Essex Street. In return the proponent will enlarge and encumber the waiting room, shorten platform length, provide air quality reductions, and tremendously inconvenience the public during construction, at minimum. This constitutes woefully inadequate compensation to the public, and is unacceptable.

The proponent must conclusively demonstrate that they are providing the public with enormous benefits, benefits commensurate with gift which the Commonwealth is making the developer. Currently, most of the benefits the developer proposes will be the responsibility of other parties, such as the enlarging of the bus terminal or potential connections to Fort Point Channel. Additional areas should be provided to the public, art culture and activities should be provided, the highest quality materials should be employed, seating and amenities should be expanded, retail concessions should be increased, better ticketing and baggage handling facilities provided. These must be substantial improvements for the public, not merely replacements or primarily for the benefit of the commercial development.

Atlantic Avenue Amenities

The large street frontage of this project demonstrates that no concern or consideration has been made for it. Pedestrians and the public realm are not even an afterthought to this developer. There is no discussion of materials, plantings, street furniture, amenities and services, or the ongoing management and maintenance of these elements. This is clearly unacceptable, and does not even rise to the level of inadequate. The proponent must provide full sets of schematic and design products to remedy this and to ensure that public spaces are superlative in every regard.

Tower should be Placed Over existing Railroad Tracks

The proponent has demonstrated an ability to construct successfully over the live railroad tracks and platforms of Grand Central Station in New York City, yet in Boston they have somehow decided that they can only place the tower over and into our existing waiting room. The proponent should be required to prepare full feasibility analysis, with supporting data, to explore the location of the tower element ( in current and modified forms) over the existing platforms or other portion of the site, leaving the existing waiting room in its existing condition. The proponent also should provide daylighting analysis of the existing waiting room area and the waiting room in various configurations and locations of the tower element, throughout the year

Prior Experience

The proponent has ably demonstrated their ability to construct significant buildings in New York City over the live platforms of Grand Central Station. We cannot believe that more difficult construction conditions will be encountered in Boston. Studies should be provided that explore the viability of reconfiguring the development plan to avoid any construction over the waiting room.

Scale & Proportion of Space

Assertions have been made that the proposed increase of modified waiting room height will in some fashion compensate for the intrusions of other building elements. This has not been supported in the materials supplied. While the space will increase in volume it is not apparent that this will meaningfully improve the space. No comparison to the existing spatial qualities has been supplied. The proportion of the space will be entirely different. It may well be that the proposed waiting room will make people feel small and insignificant, or trapped at the bottom of and enormous light well. Currently we feel quite the opposite, and the dynamic spatial character that is experienced by moving through and using the waiting room area should not be negatively impacted.

Intrusion into Waiting Room: Columns, Escalators, Mezzanine

The present value of the space, which is the preeminent public room in Boston (a nationally recognized fact) is comprised by it's large, broad clear span space, filled with direct sunlight and the activity generated by the many services and restaurants, and amply accommodated by the many chairs, tables and benches, all freely available to the full spectrum of the public. Any changes to any aspect of this configuration must be carefully studied, and conclusively proven to provide a significant improvement. Anything short of substantial improvement would not be sufficient to justify the construction impacts.

Loss of Direct Sun to Waiting Room

Direct sunlight in the waiting room is among its top attributes, and its loss is unacceptable. It cannot be mitigated for by the provision of rooftop skylights. Evaluation and discussion should be made of the amount, intensity and quality of daylighting to be provided by the various alternatives in comparison with the existing condition as a precursor to determining the most appropriate disposition of the building elements.

Column & Escalator Intrusion

A primary characteristic of the waiting room is that it is column free clear span space. This provides an expansiveness to the room that would not be possible if it was pierced by a series of columns and escalators. In our ability to understand the fullness of its space, it is our Pantheon. Columns, escalators and landings cannot help but to interrupt this space and diminish it. The provision of additional area ( taken from existing concourse and train platforms, will never be able to adequately compensate for this loss. Project redesign should investigate alternatives which remove and eliminate these intrusive columns through relocation of building mass to areas over existing railroad tracks. Should columns, escalators and any other appurtenances be impossible to relocate then those elements should be organized to be expressed as engaged columns or piers against the existing interior wall of the waiting room, and done so with minimum additional disruption to the space. These alternative studies should be provided for review.

Reconfiguration of Concourse Circulation

The size and circulation configuration of the existing concourse at the head of the rail platforms has been altered and reduced and will cause additional congestion for train riders. If anything, the width of the concourse should be enlarged to promote more convenient access.

Diesel Pollution of Platform Areas

The air quality impacts associated with covering the rail platforms has not been adequately studied, and the health impacts on riders and train personnel are unknown. It is clear, however, that the project proponent does not consider mitigation of the health effects to be their responsibility. Studies of these health effects should be made and mitigation strategies involving increased ventilation of the platforms, or the conversion of all rail traffic to electric, must be made.

Train Platform Ceiling Height

Several analogies have been made by the project proponents regarding the amplitude and spaciousness of both the waiting room and train platforms. Reference was made to the superb spatial qualities of New York City's now demolished Penn Station. Most people refer to the qualities of the train shed when they refer to that building, for the basilica form of the soaring space, and the sky lighting which suffused the space, and the muscular expressiveness of the exposed structure. These elements combined to make a grand and fitting entry to the city, which privileged train riders as if they were presiding over mass in a cathedral, which captured and embodied the spirit of the age and worked at the limit of the available technology.

In contrast, the train platforms proposed will more resemble the platform areas of today's Penn Station, which are hardly suited to the storage of trash barrels and bear no comparison to any notion of a grand arrival or ceremonial space. We recommend that most of the removed parking area should be done so that there can be a high, lit and vaulted space over the train platforms, creating a gracious character that befits South Station.


There is no call for the excessive parking provision proposed for this site and for these uses. To maximize the value of this site and the superior transportation accommodations currently in place (already the preeminent transportation hub of New England) and with many new services just entering service and others now planned or under construction which could easily double the transit ridership handled by the station currently, there should be the absolute minimum number of new parking spaces provided. These air rights are too valuable and too important to the public to be allocated to a lesser use such as parking.

Construction Phase Impacts

A full, complete and detailed construction phasing plan must be provided by the proponent prior to consideration of this filing. All impacts upon the public and the environment must be clearly identified by area, amount, duration and significance, with full mitigation of those impacts in all regard specifically made.

The public has patiently borne with the impacts associated with the Central Artery/Tunnel Project and the South Boston Transitway, work which will not be completed for at least another four years. The public deserves the time to appreciate and use South Station and the Dewey Square area subsequent to the completion of the CA/T and Transitway efforts. We should not be asked to bear the significant and disorienting burden of these transportation projects simultaneously with additional and highly onerous impacts from this project.

The few diagrams presented at the recent Move Mass forum clearly showed significant and unacceptable impacts, particularly to commuters during the entirety of the construction phase. Some of the impacts noted in the brief time they were shown indicate: substantial reductions in effective width of pedestrian ways and choke points; substantial lengthening of distance pedestrians must travel to reach train platforms; significant reduction in the access to the primary interior red line connection; ticketing booth placed at the furthest possible distance from platforms; elimination of most if not all concessions, waiting room area and seating; lengthy, convoluted and disoriented wayfinding through the construction site; loss of the light and air of the waiting room; among others.

We are certain that the actual impacts are far more extensive and severe than as represented by the project proponents. The magnitude of these impacts could be sufficient to significantly reduce transit ridership and exacerbate roadway congestion by private cars, jeopardizing the MBTA's efforts to transition effectively to a forward funded budget, recently enacted by the Massachusetts legislature.

Elimination of Retail & Seating

It is unacceptable that construction phasing has been designed for the ease of the developer at the expense of the public. A revised and detailed construction phasing must be provided which retains or minimizes the loss of all amenities within the existing waiting room.

Construction Phasing Plan

Discussion of construction impacts in conjunction with continued construction and dislocation caused by CA/T and South Boston Transitway construction must be expressly described in detail, with all impacts successfully mitigated in kind and amount by the project proponent.

Environmental & Sustainability Issues

The proponent should commit to creating a fully LEED certified building. The 'Hines Process' elements, while superior to a basic building program, fall far short to full implementation of available best practices, and aggressive reductions of energy and resource consumption, genuine sustainability implementation, or the pollution reductions that other developers are now performing as a matter of course, and as a demonstration of respect for the locality and our fragile ecosystem.

We commend you to the comments submitted (among many other worthies) of the Alliance of Boston Neighborhoods, Walk Boston, and the Boston Preservation Alliance. We also believe that the work provided by Howard Stein Hudson to Beacon on behalf of the operations entity of South Station deserve close scrutiny, and that their cautions be heeded.

In light of those concerns and the ones which we have raised above, we find that this proposal is so significantly and fundamentally flawed that it cannot be approved, unless it is thoroughly transformed and refiled. The damage this project would do to the city, the environment, and the Commonwealth oustrip any benefits that it might provide. In the recent Municipal Harbor Plan deliberations it was stated repeatedly that the options of the City and the Commonwealth were limited because they did not own or control the land in question, leading to a limited pallette of options for ensuring the public good and guiding development in the most productive manner. In this situation the land and air rights are under the full administrative purview of multiple governmental agencies. We call on you to exercise your office to the fullest extent in this matter, and to deny this filing.


Jon Seward,
for SAND

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