Seaport Alliance for a Neighborhood Design (SAND)

November 13, 2001
via facsimile and hardcopy
Mr. Mark Maloney, Director
Boston Redevelopment Authority
One City Hall Square
Boston, Massachusetts 02201
Re: Midway Project DPIR
Dear Mr. Maloney:

Please accept our comment letter to address the recent Draft Project Impact Report (DPIR) for the Midway Project. These comments are supplemental to SAND's PNF and NPC comment letters submitted to the BRA regarding this project over the past year.

SAND members continue to advocate diligently for an urban plan for the South Boston Waterfront - one that achieves the mixed-use urban neighborhood delineated in the BRA's South Boston Seaport Public Realm Plan.

Urban Design Guidelines absent a Master Plan

For nearly two years since the BRA's publication of the South Boston Seaport Public Realm Plan and one year since publication of the Municipal Harbor Plan, SAND has awaited the agency's codification of a "Seaport Zoning Amendment" as instructed in the Public Realm Plan (p106).

Without a completed Master Plan for the Fort Point neighborhood, SAND would expect the BRA to observe established urban design parameters in its consideration of this project. These include:

Even with some flexibility, the Midway proposal does not achieve objectives stated by these BRA-established planning guidelines.

By all existing standards at City Hall, the Midway project falls short on residential units, and far exceeds an appropriate density of office space. By disproportionately increasing housing demand without boosting supply, these excesses will result in detrimental impacts on the area for surrounding communities.


· Existing Zoning: Proposed building heights and densities are well in excess of the existing zoning. The DPIR suggests a height of nearly 200% that of existing zoning (zoning: 80 feet), and a density of approximately 133% that of a 6.8 acre site with an M-4 density. The project offers office space component at 1.2 million sf - over 75% of the project size.

· Seaport Public Realm Plan and subsequent Executive Orders from Mayor Menino: The Seaport Public Realm Plan expects that the "Fort Point Historic Subdistrict" evolve as a mixed-use urban neighborhood, with an expected residential count of 2000-2500 units south of Summer Street.

This expected population, along with consideration of Mayor Menino's objectives for housing, should require the provision of 400-500 housing units in a 1.55 million sf development. According to the DPIR, Midway would contribute approximately 175 onsite units. Offsite unit calculations included in the DPIR are incorrect, using any mathematical guidelines including those suggested by the DPIR itself, and those required according to the BRA's Scoping Determination (see below).

According to Mayor Menino's executive order limiting office space development, the Midway project would provide 500,000 sf of office space. Instead, the project proposes upwards of 75% of the project reserved for office space, more than twice the stated limit.

· Midway Impact Advisory Group (IAG) recommendations: The Midway IAG, appointed by the Mayor and elected officials, has meticulously recorded its comments on Midway in response to the PNF, NPC and continued meetings. In its review of the Midway PNF, the Midway IAG clearly delineated a number of important concerns regarding housing, commercial, traffic, public realm - much of which has not been addressed by the NPC or DPIR.

Although SAND members have not endorsed the BRA's concept of the IAG process in general (which serves to distance project review from every community), our members have registered unqualified support for the appointees of the Midway Project IAG - a group of citizens who have diligently reviewed the project and provided our Fort Point community with exceptional guidance.

We strongly recommend the BRA's consideration of Midway IAG comments.


SAND members remain concerned that the BRA has enabled this DPIR to proceed with disregard for the agency's own internal residential requirements stated in the Scoping Determination for the Midway project.

Under the most generous calculations - even those which alternatively include or exclude West Second Street and Fort Point Place, the Midway project offers less than 26% of project size as a residential component - far less than the expected 33% required by Mayor Menino's executive order (and a goal of 1/3rd established by the DPIR itself).

According to the Scoping Determination, confirmed earlier this year at a public meeting hosted by the project's former BRA Project Manager Susan Hannon, the proponent would be allowed to include Fort Point Place in fulfillment of its housing requirement. Ms. Hannon informed attendees that the BRA's Scoping Determination concluded that the proponent would also be required to include (2) adjacent Wormwood Street Office buildings in the calculation.

With regard to Fort Point Place (a condominium no longer owned by the proponent), the proponent has not added the density (187,000 sf) to the total Midway project size of 1.5 million sf stated in the DPIR. Though Fort Point Place square footage was not added to the Midway project size, the DPIR has conveniently included Fort Point Place residential square footage in calculation of its total residential ratio.

Further, the proponent has not included the Wormwood Street office buildings in its calculation of project size, disregarding the BRA's Scoping Determination.

Below are the corrected residential calculations, following the BRA's own Scoping Determination:

Thus, the housing Requirement using the Scoping Determination and applying the Mayor's Executive Order of 1/3rd would be:

1,858,000 / 3 = 619,333 sf

The Midway DPIR proposes 183,500 sf of onsite housing - only12% of the project size claimed by the DPIR of 1,550,000 sf.

If we include Fort Point Place per the Scoping Determination guidelines, the Midway project proposes 370,500 - only 20% of the project size suggested by the Scoping Determination (1,858,000 sf).

We have learned in the Boston Herald this week that the proponent has announced development of an offsite residential component on West 2nd Street. As the Midway project has passed through its PNF and NPC comment periods, it is disappointing that the proponent has not publicly released information regarding this development to further analysis.

SAND members agree that the West 2nd Street site may be appropriate for housing, and this site is in proximity to the Midway project. However, we are unsure whether the proponent actually owns or is capable of developing this former industrial site. We are not aware that the West 2nd Street site has cleared even basic hurdles for residential development (i.e. tests for contaminants, concerns of abutters, etc.). Certainly, the neighborhood has not publicly reviewed this new proposal.

If approved, the West 2nd Street site would contribute approximately 150,000 sf to the Midway project (extrapolating from 130 units published in the Herald).

Accepting the West 2nd Street project, the Midway DPIR would provide approximately 333,500 sf of onsite housing - only 20% of the project size of 1,700,000 sf (1,550,000 sf suggested by the DPIR + 150,000 sf of West 2nd Street).

If we add West 2nd Street, and Fort Point Place and the Wormwood Office per the Scoping Determination guidelines, the Midway project proposes 520,500 sf of housing - only 26% of the project size suggested by the Scoping Determination of 2,008,000 sf (1,858,000 sf per Scoping Determination + 150,000 for sf West Second Street).

Artist Live/Work

SAND strongly supports objectives outlined by the Fort Point Cultural Coalition in its DPIR comment letter. Our members have unanimously endorsed the FPCC's development proposal.

The FPCC (and member organization FPAC) has set a national model for success in development of artist space - both in rental workspace and permanent housing.

It is important to note that artist live/work space already provided by the proponent in Fort Point Place (included as part of the Midway project) has already failed to meet minimal standards of affordability and suitability.

SAND recommends that the artist live/work component of the Midway project include a residential requirement, and that the BRA zoning reflect this designation. Fort Point must continue to evolve as a neighborhood, and this particular development should add to the 24/7 nature of the district.

Office Space

The Midway project proposes 1.25 sf of office space, a startling 80% of the total project size of 1.5 million sf. This density of office construction is not supported by any planning doctrine suggested by the BRA, and is nearly three times the office space density limit suggested by Mayor Menino's executive order.

The Midway project offers space for 6500 office workers and housing for only a few hundred. The socioeconomic impacts of this type of project will be significant on existing communities, and on the project's potential to contribute to a broader urban planning vision.

Unabated office space development in Fort Point and the Waterfront continues to undermine the viability of this area as a vibrant, 24/7 mixed-use neighborhood. Overdevelopment of this area with offices has already limited most public appreciation of the South Boston Waterfront to business hours, has already contributed to traffic problems, and represents a failed opportunity for City planners to address Boston's worsening housing situation.

Technically, the overpopulation of the Waterfront with offices is a violation of principles of the Seaport Public Realm Plan and the Mayor's executive order regarding office space.

Open Space

The Midway DPIR is unique in that it has avoided the inclusion of a section dedicated to the project's public realm, from sidewalks to greenspace. For a 6.8 acre parcel - in a project of 1.5 million sf - in a neighborhood without a single patch of greenspace - in a neighborhood that has commented to the BRA in hundreds of comments for a number of years - it is disheartening that the BRA has allowed the developer to provide scant guidelines for its public realm.

We have continually asked the BRA to refrain from allowing developers to include streets and sidewalks in fulfillment of Open Space measures. And we have continually asked the BRA to refrain from allowing developers to include hardscape and landscaped areas in fulfillment of combined active and passive greenspace.

The Midway project, in particular, does not respond to either the public realm needs of its own office workers, nor the comments of numerous community members at public meetings. The DPIR introduces a new term "parklets" which has stunned neighborhood advocates and others with its blatant disregard for expected contributions of a 1.5 million sf project to an area it will impact.

In response to repeated concerns, the proponent recently indicated that the Boston Civic Design Commission (BCDC) supported infill development with a conclusion that the "gritty" feel of Fort Point be preserved. SAND supports the concept of a "gritty" industrial fabric within Fort Point. However, this is a project that will have to meet the real world needs of its own - adding thousands of office workers and hundreds of residents to the daily life of the area. Some of this liveliness should be expected, and accommodated, outdoors.

Furthermore, in 1998 and 1999, the proponent developed Fort Point Place residential property by suggesting (in its PNF and marketing materials) that ample recreational greenspace would emerge - At that time, we concurred with the proponent that the site precluded such opportunities. Today, the proponent has not fulfilled minimal expectations with its new undeveloped properties on Midway Street.

SAND recommends the creation of a small park at the corner of Binford and A Street, complementing the historic Sporto building façade, the abutting artist live/work building at 249 A Street and adjacent Fort Point Place condominium. A letter recently sent to the Massachusetts Historic Commission (attached) has received the support of SAND.

Height and Density

In past filings, SAND members have not opposed a suggested height of 150 feet for an office tower on Richard's Street.

We can not lend support to this height, nor the height of infill areas, because the more important subject of appropriate density for the site has not been subject to attention - either in public meetings with the BRA or in the DPIR (which does not address density).

According to all urban planners we have spoken with, it is density that should be the first measure to help us determine the shape and scale of a project. Yet both the BRA and the proponent's DPIR have failed to address the issue of appropriate density.

This project exceeds the area's suggested density of M-4 (which we believe is appropriate for this site) by approximately 30% (using a standard calculation of square footage per acre).

Within a density of M-4, a tower height of 150' might be acceptable - and would certainly help shape appropriate heights of infill sections. A zoning of M-4 could provide meaningful contributions to the project's public realm.

By exceeding the existing M-4 designation, this project overburdens existing gaps between buildings with opportunistic density, and renders the public realm an afterthought.

With regard to consideration of alternatives in the DPIR, the proponent suggests that a reduction in density would result mainly in elimination of the project's most desirable benefits. An alternate lower-density proposal included in the DPIR suggests that a 20,000 sf gallery offered by the proponent's preferred (i.e. higher density) design would be eliminated. An outdoor movie screen proposed in one of the parklets is eliminated in the lower-density alternative rendering. These types of egregious conclusions serve only to hinder adequate consideration of alternatives.

Historic Structures

SAND does not support demolition of Fort Point's historic warehouses. We have supported the recent landmarking of Fort Point as a Historic Landmark District, and also appreciate the proponent's stated support for historic preservation.

Demolition of existing buildings, and of significant portions of building facades and fabric, should be minimized or avoided altogether. All renovation work should be accomplished with utmost sensitivity to the existing, historic structures.

Infill construction should not replicate historic structures, seaming together buildings with additional brick-and-beam construction for example. We support complimentary architecture to juxtapose modern ideas with respect for the historic buildings.

Public Access

In its fulfillment of a truly public realm plan, SAND requests that the proponent offer a full and public easement on Midway's streets, sidewalks and open spaces. Public access should at no time be a private, revocable right relegated to owners or tenants. In exchange for such public access, the City of Boston should meet its own obligations in providing necessary public maintenance and ancillary City services.

Thank you for your consideration of our comments.
Steve Hollinger
Seaport Alliance for a Neighborhood Design (SAND)

To read SAND's comments of 6/6/01 on the Midway Notice of Project Change click here.
To read SAND's comments of 3/7/01 on the Midway Project Notification Form click here.
To read the Midway IAG comments of 3/9/01 on the Midway Project Notification Form click here.

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