March 11, 2001

Mr. Robert Durand, Secretary
Executive Office of Environmental Affairs
251 Causeway Street
Boston, MA 02114-2136

Re: Beacon Capital Partners: Midway Proposal (Fort Point District)

Dear Secretary Durand,

We are writing to request a Fail-Safe Review for Beacon Capital Partners Midway project. The proposal is for the redevelopment of a 6.8 acre site located within the Fort Point Channel section of South Boston. The project includes 1.75 million square feet of development, including 1.1+ million square feet of office space, approx. 125,000 s.f. of live/work units for artists (100 units), one 300-foot office tower, three additional office towers ranging from 120-150', 800,000 proposed s.f. of rehabilitation to existing turn-of-the-century warehouses, and a parking garage for 1200 vehicles.

We are concerned that because the project is segmented into two phases, the public has inadequate information regarding the environmental impacts. We would like to see all phases of this proposal, including the impacts from the recently completed Fort Point Place undergo full MEPA review as a safeguard for the public against potential negative environmental impacts.

We have identified a number of areas in which MEPA review thresholds are met and anticipate additional triggers for MEPA will be identified by other commenters.

Historic Structures:

A petition has recently been filed with the Boston Landmark Commission to designate the Fort Point Channel Historic District as a Landmark District. Midway Street and the surrounding areas are included in this application currently under consideration. The Midway project includes historic buildings from the late 18th and early 19th century, three of which are slated for demolition. The ensemble of buildings constructed by the Boston Wharf building since their initial purchase and filling of this district some 150 years ago are unique and significant. It is a unified suite of structures, designed by only two in-house architects to meet the warehousing needs of the owners. These buildings describe almost moment by moment the changing needs of the shipping industry in Boston and the gradual evolution of industrial building technology as it advanced from small unit masonry and timber frame to concrete reinforced construction. The pace of structural improvements, such as widespread introduction of steel, and technology such as electricity and the advent of elevators displacing hoistways, is embedded within these buildings. These buildings are also unique in that their materials and detailing represent an extraordinarily high level of finish for warehousing buildings. The construction of these buildings has proven so responsive to the changing needs of their users over the past century that they are still able to house a wide variety of new, differing and unheralded industries, suffering minimal structural interventions in the process.


According to 11.03 Review Thresholds: 11.03 (1) 6: Approval in accordance with M.G.L. e. 121A of a New urban redevelopment project or a fundamental change in an approved urban redevelopment project, provided that the project consists of 100 or more dwelling units or 50,000 or more sf of non-residential development 11.03 (1) 7: Approval in accordance with M.G.L. e. 121B of a New urban renewal plan or a major modification of an existing urban renewal plan.


The project anticipates a net increase in sewer generation of 97,540 gpd. (MEPA review if Secretary so requires: 100,000 gpd). The projected generation is within any calculations margin of error from the threshold.


11.03 (6) 7: Construction of 1000 or more New parking spaces at single location. While the Beacon proposal suggests a net number of new parking spaces at 800, they are basing that number on the fact that there are currently 400 deeded spaces on their property. In reality, less than one hundred cars currently utilize the property. Their development will in fact increase the amount of active new parking to 1100 cars on site. In addition, they recently added 102 new spaces at their Fort Point Place development bringing the combined total impact to over 1200 New spaces.

Beacon's estimated adt for full build out is 2231. Because this information was based on a study conducted in August, when traffic is minimal compared to the rest of the year, it does not accurately represents the full impact. In addition, the impacts from Beacon's Fort Point Place project, which generated additional adt (see attached), have not been accounted for. There has not been a full traffic analysis on phase 2 of this project. With the threshold for MEPA review at 3000 adt we feel MEPA review is warranted due to the long term impacts of this and future development in the district.

The access point to/from the haul road will potentially degrade the previously permitted projects of: the BCEC, Logan Airport, Massport Commonwealth Flats, BMIP/EDIC, CA/T Ted Williams Tunnel- I-90 Extension functionality. Any additional imposition on the ability of these projects to continue and to perform at the level of service detailed in their MEPA certificates cannot be condoned, and will generate cascade effects which will exacerbate congestion regionally, degrade air quality, require the consumption of additional gasoline and diesel fuels, and increase the likelihood of fuel and oil spills and deposition which may then pollute soils and waterways.

Additional concerns regarding transportation include the fact that is an existing rail spur on the property. "Railroad tracks and cobblestones are visible through the broken asphalt." (Midway Project Notification Form, page 2-1)

Beacon Capital Partners has provided information for the first 252,000 sf of development, but because they have divided their project into two phases, there is little information for the additional 1,498,000 sf of development being proposed. Without this information the public is unable to adequately determine the full environmental impacts of this proposal. Due to the size and potential impacts from the full build scenario of this project, we are requesting a fail-safe review. This is necessary to ensure that any damage to the environment is avoided or minimized. We would like to proceed as quickly as possible so as not to hold up the project any longer than necessary.

We appreciate your consideration on this matter.


[signatures, 10 petitioners]

cc: Senator Stephen F. Lynch
State Representative Jack Hart
City Councilor James Kelly
Ms. Susan Hannon, Sr. Project Manager, BRA
SAND membership

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