SAND has filed the following comments on the Environmental Notification Form (ENF) recently filed by Massport regarding development of "Waterside Place" on agency’s Core Block parcel.

To read a related article regarding the Core Block, click here.

Ms Ellen Roy Hertzfelder, Secretary
Executive Office of Environmental Affairs
MEPA Office
100 Cambridge Street
Boston, MA 02114

Attn: Will Donham
MEPA Analyst Re: EOEA #13367 Waterside Place ENF/PNF

Dear Secretary Herzfelder,

SAND, the Seaport Alliance for a Neighborhood Design, welcomes the filing of the project proponents for the Waterside Place development for Massport parcels C-1, C-2, C-3, the Air Rights Garage parcel and parcels D-1 and D-2, including Viaduct Street and frontage onto Summer, Congress and D streets. The proposed project is generally consistent with the prior Commonwealth Flats Development Area Draft Environmental Impact Report and the determinations of the Secretary of environmental Affairs.

In many ways this filing demonstrates the benefits of continued thought and consideration of the area, and has moved to better fit the project to the circumstances and promise of its location. Still, we believe that there are several areas in which this project can improve from modifications to this current filing, and that additional project elements, emphasis and efforts are needed, before this project optimize its use of this site and role in the development of the district and emerging South Boston neighborhood.

Height and Massing

The location of the development parcel is such that it can readily accept substantial increases in building height and overall massing without detriment to the project, the district, or to the waterfront and environmental factors. We encourage the proponents to increase the height of the building elements to further approach the FAA height regulations.

This additional mass is anticipated in the BRA’s Public Realm Plan, and would assist the development of a pyramidal massing for the district, helping it achieve a greater overall coherence. While this additional height and mass may require additional regulatory review and approval, SAND believes that the goals are supportable and achievable in this instance. The Merging of the C and D parcels and the Air Rights Garage provides a sufficiently large parcel for this new bulk to be deployed without causing inappropriate impacts to the public, given proper consideration. We encourage the location of additional building mass, perhaps making use of building setbacks at the current cornice line, for the D Street and Summer Street frontages, ensuring an appropriate street frontage and human scale.

Summer Street frontage should be carefully studied in conjunction with that of the new Convention Center and with the anticipated development of the headquarters hotel and parcel D-3 development site massing. The massing must create a pleasant and attractive streetscape while emphasizing the importance and centrality of this site to the district.

Study of building massing should also address the relationship between the proposed development and the tower element of the WTC Silver Line station tower. The sculptural marker function of this tower should continue to have visual prominence, with proposed building mass giving it further contrast and focus. As the success of the Silver Line will be dependent upon its generating ridership rapidly, concern should be give to providing greater visual emphasis to the station and by creating or establishing additional visual or signage elements to give greater prominence to the station.

In general, we believe that this site is a splendid location for groundbreaking architectural expression of the type which the project team has shown itself capable, giving form to a forward looking Boston. The opportunity provided at the exit to the Ted Williams Tunnel will give many visitors their first glimpse of this district and the city. A striking and highly articulated façade suggested in the initial renderings should be thoroughly explored and refined as the project progresses, with opportunities to differentiate the various facades and perspectives.

The relationship between the primary development and the Visitor’s Center bracketing Viaduct Street should be carefully considered. A potential exists for an unbalanced and uncomfortable juxtaposition of the smaller scaled Visitor’s Center to the larger and higher massing of the retail component. Efforts should be made to create additional prominence and assertiveness for the Visitor’s Center, and to instill the retail façade with a more intimate and human scaled aspect and detailing. We believe that the sidewalks of Viaduct Street might be enlarged to provide more engaging places for pedestrians, and to provide more suitable locations for sidewalk cafes, vendors and other activities.

The project filing does not seem to b indicate mechanical equipment and other appurtenances, which often add to and disturb the appearance of other building projects. We hope that these elements can be contained within and below the primary complex to the greatest degree, and where they must be exposed, will be carefully integrated into the visual language of the complex.


The proposed uses are consistent with the prior filings, and this site is appropriate for a richly intertwined mix of needed uses. SAND finds, however, that the ratio of the project elements should be adjusted to improve the project mix and to increase the viability of the project, and the future development and character of the larger district.

The housing element of the development should be substantially increased. This site should be able to accept a residential element in excess of 100% greater than that proposed, and might best be located in upper story areas fronting onto D Street and Summer Streets.

The parking component of this project is excessive and should be reduced substantially. A reduction in the parking provided, on the order of 50% or greater, should be contemplated. The presence of parking elements as a dominating feature of the D Street frontage, particularly at grade, is excessive and should be eliminated, or minimized to the greatest possible degree. Ground level areas should be better activated with uses oriented towards pedestrians.

While this area is well situated to benefit from the retail demand of tourists, workers and anticipated residents, we are concerned about the amount of area provided, the interior orientation to this retail component, and the apparent need to provide for a phased uptake of this retail area as demand follows surrounding development. It is clear that current and permitted Seaport development will be insufficient to support the planned level of retail area, and substantial future retail competition can be expected from development in the Fan Pier and McCourt parcels areas.

There are relatively few and constrained access points to the interior retailing spine. Most of those entrances require level changes or changes of direction which mask the presence of those stores. There is no access to the retail spine or to the movie theaters from D Street, even though the D Street façade will provide a primary signage point and become a visual marker for traffic emerging from the Ted Williams Tunnel.

We fully agree with the comments expressed at the initial public meeting for this project, that the affordable housing component of this project should be located within the project site itself, and not placed offsite.

Ground Level Activation

It is clear that much care has been taken to provide interesting and active facades for this development. However, there are several areas where this level of care and success has not yet been achieved, and those areas should be redesigned and remedied in the next level of design effort.

The D Street elevation is the most egregious and inhospitable portion of the façade and streetscape. More than 300 linear feet in the central portion of this façade is given over to blank walls fronting parking garage decks and to three vehicular portals. These areas should be enlivened and provided with active uses and entries, directly accessible from the sidewalk.

Further, the initial 120 feet of D Street frontage extending from Summer Street, as currently configured, will not permit entry from the D Street sidewalk. This should be corrected, and multiple retail bays created, each of which can be accessed from D Street. We are also concerned that the scale of the D Street sidewalk may be overly broad for the expected pedestrian traffic and insufficiently provided with street furniture, trees and plantings, and other elements which would attract usage and create a more enjoyable environment.

We are encouraged that the current design has made allowances for the ‘T Under D’ Phase III Silver Line realignment project to proceed with additional complication. We hope that other projects, proponents, and state agencies will be able to move rapidly in permitting the final Silver Line phase, such that the underground realignment may happen in concert with Waterside Place Development, or in advance of that construction. We also look forward to more advanced designs for Waterside Place incorporating active uses for the area now being held to permit the ‘T Under D’ project.


The parking element of this project is unnecessarily over emphasized, over scaled and detrimental to the function of the complex, and harmful to the public realm and streetscape. The number of parking spaces provided in this project should be substantially reduced, and additional emphasis given to other transportation and circulation modes. Earlier filings stated that only an absolute minimum of parking would be constructed and that shared parking strategies would be aggressively pursued. This filing is silent on those points.

The Secretary’s Certificate grants the right to site 1.1 parking space per 1,000 square feet of project area. The 2,350 spaces called for in this filing nearly double that ratio, and represent 190 additional vehicles compared to the earlier filings, while the built project area has been substantially lessened.

In the interval between the Commonwealth Flats EIR filings and today, the necessity of reducing private vehicle trips and encouraging transit and pedestrian modes has become much clearer. The superb location of this development at a Silver Line station, alongside bus routes and near to the South Station commuter rail hub and the waterfront ferry services, all point to this location as a prime site for a Transit Oriented Development based project.

We are confident that this project, partnering with the Seaport TMA organization will be able to reduce private auto ridership and trip generation numbers to level equal to or surpassing those of other businesses and developments in the Seaport district.

Bicycle accommodations should receive attention equal to that provided to autos and other transportation forms. It is reassuring to know that bike racks will be provided, but there should be considerably more detail shared on this. We would recommend that attractive, secure and visible provision for bicycle storage be provided for no less than 5% of total transportation demand. Bicycle storage should be readily accessed by the public, residents and employees on all sides of the complex. Consideration should be given to providing bicycle lockers and to provide changing rooms and showering facilities for employees, to encourage additional bicycle usage.

We anticipate that the proponent will work closely with the MBTA to provide appropriately generous and appealing bus stops and signage to encourage greater use of multimodal public transportation facilities in the district.

Sustainability and Energy Use

It is heartening to see the proponents taking steps towards sustainability and moderation in energy usage for this project. We fully believe that this is necessary and appropriate for development on the Commonwealth’s property, and will serve to motivate other developers and landowners in future projects of their own. The proponent should take the lead in setting goals for sustainability which far exceed the minimums of the building code and the LEED program.

We encourage that the LEED category of Silver or Gold be selected for this project, and that all possible efforts to reduce the embodied energy of the project, to source materials locally and regionally. Great heed should be paid to lifetime energy demand and maximizing the ability to reuse and recycle building components. Similarly, artwork and decorative elements for this project should be sourced from the Fort Point Arts Community and within Massachusetts, to enhance to community aspects of sustainability and to give greater prominence and distinction to this project.

The provision of a ‘Green Roof’ for this project will bring great benefits. In particular, the reduced burden on stormwater drains and water quality in Boston Harbor will reduce environmental stresses. The lowered heat island effect of a vegetated roof will benefit the city as well as the project. We hope that all of the roofs of this project can have significant areas of plantings, not only the lower levels. We also hope that portions of these green roofs can be made available to the public, for their enjoyment as well as for the educational value. A successful green roof in this project could have profound benefits in encouraging others to call for and construct green roofs throughout New England.


We are heartened to see the innovative approach being taken and the improvements over prior filings, leading to an exciting and creative design and project. SAND looks forward to continuing to work with the project proponents, and assisting in the rapid permitting of a project which is highly successful from all standpoints. We remain available to provide additional detail on these comments, at your convenience.


Steve Hollinger
Christina Lanzl
Jon Seward

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