To read a related SAND comment letter with a timeline of Archon/Goldman activity, click here.
To read SAND comments regarding Archon/Goldman's plans, click here.

April 10, 2008

Kristin Kara
Project Manager
Boston Redevelopment Authority
One City Hall Square
Boston, MA 02201

Dear Kristin,

We are writing in response to the PNF for 49/51/63 Melcher Street filed by the W2005 BWH II Realty, LLC, “the proponent”, who will also be referred to as “Archon” or “Archon/Goldman”, the names by which the proponent is known within the community.

Executive Summary:

The proposal for 49, 51 and 63 Melcher Street sets a number of troubling precedents and we therefore ask for your consideration in re-working the plan. The project a) proposes an oversize addition that should have setbacks to reduce visibility; b) proposes two in-fills that obscure dozens of windows, loading docks and two functional courtyards; c) if approved as filed would be the beneficiary of significant height and density without any measure of incremental progress toward fulfillment of civic, cultural and green-space goals; d) fails to meet the residential goals articulated in the 100-acre plan within existing stock; e) has decimated the arts and cultural uses once populating these spaces without any progress toward FPAC goals and f) proposes an architectural scheme with faux-industrial masonry that is without consideration to the draft FPCLD’s design guidelines.

Planning Context:

49, 51 and 63 Melcher Street are three buildings within the 100-Acre planning area, expected by all participants to evolve as a mixed-use urban district. Fort Point is presently at 85% office space and these projects are proposed as office space. With the conversion of these buildings, the entire south side of Melcher Street will become office space. Thus the proposed use within this planning context is in violation of the spirit of the 100-Acre Master Plan.

49, 51 and 63 Melcher Street were included along with eleven additional historic buildings in the proponent’s portfolio as part of an Archon/Goldman “Vision” for the district. This “Vision” was proclaimed by the proponent, the media and the Boston Redevelopment Authority as a great step in the evolution of the district, and was used as an argument to gain traction while artists and cultural uses within the buildings were displaced.

Once these tenants were displaced, the Archon/Goldman “Vision” was abandoned, and we find ourselves here today considering a proposal that converts the three buildings into one large office block.

These three buildings, built by the Boston Wharf Company, are among the finest industrial-era buildings located on one of the most recognized historic streets in Fort Point. The Fort Point Historic district is on schedule for designation as a Boston Landmark District this summer, following almost seven years of collaboration between our community and the Boston Landmarks Commission.

The Mayoral-appointed Fort Point Channel Landmark District Study Committee is currently drafting design guidelines for this district. A draft of the guidelines is available on the City of Boston website at:

About the Project as Proposed:

While we support the adaptive re-use of the buildings, and the proposal of “retail” use for the ground floor(s) in concept, there are a number of issues we would like to raise as concerns regarding the project as proposed in its current filing.

The project proposes a roof top addition and two in-fills comprising 48,500 square feet of new development to the three existing historic buildings. This new construction, by its architecture and relationship to the existing buildings, will have a net negative impact on the historic fabric of Fort Point.

There have been many successful recent building renovations within the district that have been completed without additions, yet the proponent has not provided any evidence to support that this additional square footage is required in order for the project to be economically viable. We would like the proponent to reconsider this project without the additions to the existing buildings.

A Missing Component:

Notably absent from the PNF was any consideration toward the renovation of the overhead bridge from 51 Melcher Street to 281 Summer Street. This bridge is already demonstrating signs of benign neglect with broken panes in the windows on both sides of the bridge. Since no provision is made for the preservation and renovation of this signature architectural element within the filing, we can only assume that the proponent intends to continue to neglect this feature. Archon/Goldman should be required to refurbish this distinctive feature now and as part of this project, in particular since this project could represent the only opportunity to restore the bridge within the next 100 years.

Regarding the rooftop addition to 51 Melcher Street:

The current proposal shows a rooftop addition to the entire building of 51 Melcher Street without providing any set back. This addition would make the new base building 143 ft tall. We are opposed to this addition for a number of reasons:

  • If built, it has an immediate negative effect on the historic fabric of the district and is contrary to the draft language of the Fort Point Channel Landmark District guidelines. SAND supports a moratorium on ALL additions until the FPCLD guidelines are adopted. SAND intends to support the FPCLD guidelines once they are in place. In the meantime, SAND does not support the construction of additions on Melcher Street buildings that are visible from ANY public or private street or way that is open to public travel (including Necco Court and Necco Street).
  • The proponent has violated the language included in the 100-Acre plan regarding additions, as well as the spirit of the draft language currently being considered by the FPCLDC in its guidelines, by aggregating the total space in three buildings to form a single large addition. The addition proposed is far greater than the 10% allowable under the 100-Acre plan and the 100-Acre Plan makes no mention of including the size of neighboring buildings to get to 10%. The rationale that aggregation of additions allowed for sensitive treatment of smaller buildings is unsuitable. FPCLD’s draft visibility guidelines for the lower buildings would not have allowed for additions on 49 and 63 Melcher Street – if any additions were considered, it is possible that an addition with a set-back on 51 Melcher Street would have been viable, while limiting visibility to pedestrians on the street.
  • The proponent has not provided a compelling argument that this addition is required in order for the project to be economically viable.
  • We do not accept that this addition is “as of right under PDA 69” and does not require a variance, which is what the developer repeatedly claimed during the public meeting.
  • This is already one of the tallest buildings within Fort Point, we do not support the additional height.
  • If allowed, this addition would make the new building 143 ft tall, however, the current PNF does not call out the additional height, scale and impact created by the rooftop mechanicals related to this project or this addition. The mechanicals are shown on the roof of this addition in some of the drawings. This is contrary to the draft FPCLD’s guidelines which require mechanicals to be integrated into the design of allowed additions rather than simply placed on top.
  • The proponent has violated the spirit of the 100-Acre plan, proposing an office project in a district of over 85% office space, with an addition that adds height and density beyond what was purchased as of right by the proponent, without a single incremental step proposed in the plan towards fulfillment of civic, cultural and open space obligations of the 100-Acre plan.

Regarding the infill to the rear two corners of 51 Melcher Street and the two adjacent properties:

The current proposal shows two “infill” additions to 51 Melcher Street and each of the two adjacent properties at the rear of the buildings along Necco court. The current proposal does not show any mechanicals on the drawings related to this project or these additions.

The proposal to add two infill buildings to the rear of the building along Necco Court, obscures many of the historic details of this building, including but not limited to windows, fire escapes, and loading docks.

We are opposed to these additions for a number of reasons:

  • The two courts provided by the original building footprints form one of the districts most beautifully articulated facades, which include a matrix of three hundred and five (305) existing single and multi-paned sash windows, four loading docks and nine fire escape doors. These original features will all be eliminated with the proposed infill.
  • If built, they have an immediate negative effect on the historic fabric of the district and are contrary to the draft language of the Fort Point Channel Landmark District guidelines.
  • The two existing courts at the rear of 49, 51 and 63 Melcher Street under this proposal are to be replaced with two in-fills of new masonry. These courts, if left open per the original building designs would be ideal locations for hard-scape outdoor café and social spaces, adding to the social life of the city - as Goldman proposed in its so-called “Vision plan” for the neighborhood, and which would activate Necco Court in addition to A and Melcher Streets.
  • The in-fills proposed remove important and interesting articulation at the rear of the three buildings. This articulation also has a practical function today, bringing light onto Necco Court and breaking up the formation of a wall of wind.
  • The use of new masonry and the design of the proposed in-fill are contrary to the draft FPCLD guidelines. The resulting building façade is half original and half faux-industrial. We believe masonry was the material of choice so that viewers of the rendering would not know they were looking at a bloated version of the original building. Fort Point deserves architectural ideas that transcend such mediocrity.
  • The proponent has not provided a compelling argument that these additions are required in order for the project to be economically viable.
  • We do not accept that these additions are “as of right under PDA 69” and do not require a variance, which is what the developer claimed during the public meeting.

Regarding Proposed Use:

The proposal calls for retail use on the ground floors and office space on the floors above. The 100-acre plan/PDA 69 calls for a vibrant mixed-use district and specifically allows residential/mixed use for this site. Since this project does not propose any residential use, we are extremely concerned that the neighborhood is falling behind on the residential goals for Fort Point. The proponent should re-consider this project as a residential one, including incorporating artist live/work.

Given that Archon/Goldman have flipped the majority of their portfolio, and given that the flipped buildings that were in Archon/Goldman’s portfolio are now proposed office space, and given that the BRA has awarded new height and density to Archon/Goldman under PDA #69, SAND requires that all three of these buildings be primarily residential. On Archon’s own website, they state that five of their buildings “are being converted to residential condominiums”. They have already flipped two of the proposed residential buildings (now also under consideration by the BRA to be changed to office buildings as proposed by the new owner). If the Melcher Street buildings are to be permitted as office space, Archon/Goldman should certainly not be allowed any additional height or density.

Regarding Retail:

The proposal calls for 33,000 square feet of retail space. While in general we support the use of ground floor spaces for “facilities of public accommodation”, we do not support that the additions are required to the existing building to make this feasible. We would also like to see a more detailed strategy for activating the street:

  • How will the proponent attract retail use to these buildings?
  • What is the plan to activate the street if no retail tenants are found?
  • What other uses beyond typical retail would they consider? (Arts/community/civic space, for example).

Regarding Community Benefits:

There are currently no community benefits proposed with this project, yet we understand that the BRA is interested in having community benefits for every development project. We would like the proponent to engage honestly and proactively with the community & provide details of any tangible community benefits this project could provide. This benefit should be included in the final proposal and not left out as an afterthought, where there is no guarantee of it ever happening.

Regarding the Arts Community:

91 artists, 2 galleries and a bindery were displaced as these buildings were prepared for this project. One of the galleries displaced, Studio Soto, was a central hub of the communities activity. There are currently no artist live/work or arts related spaces proposed within this project. We stress again that we would like the proponent to engage honestly and proactively with the community & provide details of any tangible opportunities for artist work or live/work and arts related uses this project could provide.

Regarding Traffic:

The project shows significant traffic increases to the neighborhood, with lowered results of D, E and F already occurring in multiple locations. However, the affect of the traffic study should be based on there being 3 empty buildings not as Table 2.1 illustrates under “existing conditions” which show the buildings as occupied. Additionally, Table 2.8 shows 316-322 Summer Street as a residential project. How does the current proposed change of that project to office affect the traffic build/no build analysis?

We would like the proponent to study the traffic situation more carefully. If no additions were made to these three historic buildings, this may alleviate the traffic problems and bring the project to a more acceptable scale for the neighborhood.

Regarding Environmental Concerns:

The project does not incorporate any sustainable urban design requirements, such as solar power, carbon-neutral materials, energy consumption or any of the Mayor’s publicly stated requirements for LEEDS rating of buildings. The proponent should consider how to incorporate any and all technology available to it.

In Conclusion:

Archon/Goldman have already flipped 62% of their original purchase at a profit, and will likely sell the Melcher Street buildings as soon as possible if they are permitted as filed for renovation as office space. They have already publicly stated that they intend to sell 319 A Street and 327-337 Summer Street as soon as final details of its “exceptional public benefits” are negotiated with the BRA. It appears that Archon/Goldman will leave Fort Point without renovating one single building or creating one residential unit.

Given the scope of these precedents and the repetitive failure of Archon/Goldman to fulfill stated objectives across the entire district, the BRA should deny approvals for this project until Archon/Goldman can demonstrate consideration for the existing community and the unique historic character of the district and commit to their responsibility in carrying out the objectives of the 100 Acres Master Plan.

We also ask that the BRA considers implementing a moratorium on any rooftop or building additions to existing historic structures within the district until the FPCLD Study Committee have completed their work and the guidelines have been formally adopted and in place. The integrity of the social and historic character of this district is at great risk.

We hope you take these comments as intended, which is to help guide the developer in its responsibilities and enable the BRA to achieve our shared goals of a vibrant mixed-use district for Fort Point Channel.


SAND (Seaport Alliance for a Neighborhood Design)


John Palmieri, Director, BRA
Kairos Shen, Director of Planning, BRA
Senator Jack Hart
Representative Brian P. Wallace
Michael Flaherty, Boston City Council
Bill Linehan, Boston City Council


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