The following SAND comments were submitted to Trudy Coxe, Secretary of Environmental Affairs in response to the BRA's Convention Center Environmental Impact Report (EIR) that had been submitted to the Executive office of Environmental Affairs (EOEA) to address environmental impacts of the Boston Convention Center. Comments received during the public comment period have not yet been addressed.
NOTE: The public comment period ended on November 24th and the Secretary approved the Boston Convention and Exhibition Center EIR in a record 48 hours.
To read EIR comments submitted by a Boston bicyclist, click here.
Ms Trudy Coxe, Secretary
- Executive Office of Environmental Affairs Department
- 100 Cambridge Street
- Boston MA
re: Comment on ENF for BCEC
Dear Secretary Coxe,
The Seaport Alliance for a Neighborhood Design (SAND) a South Boston community group of artists, business people and residents based in the Fort Point Channel neighborhood wish to support the construction of the proposed Boston Convention and Exhibition Center with all due speed, but have a number of significant concerns regarding design and operation of the facility. Those reservations require immediate actions to evaluate and remedy prior to permitting this project, to avoid unduly burdening the City and the neighborhood, and so that the benefits and successful operation of the BCEC may be realized. In general, we feel that the design, construction and operation of this facility should not create problems which then require mitigation, but should be planned so those problems are not created; the Center will then have far greater benefit to all. We hope that you will call for these analyses to be made, and for these problems to be rectified during the EIS process, protecting and enhancing the environment of our city and region.
These concerns may be broadly grouped under the categories of urban design, transportation planning, and environmental concerns. Urban design issues relate to creating the optimum fit of the facility into the existing and anticipated city fabric, so that existing uses will not be harmed and the proposed growth of the area can proceed, allowing for the creation of a newly vibrant district of the City. Inclusion of existing schematic design drawings should have been made, for reference, by the proponent.
Transportation planning is required so that our roadways will continue to function acceptably and that they can evolve into lively, pedestrian friendly places. In these areas, several decisions and assumptions have been made in the ENF which will jeopardize the ability to achieve these fundamental goals. They must be corrected in the Environmental Impact Statement process, and solutions to those critical problems found.
There are concerns about water quality, and they suggest that there is an opportunity for the planning of the Boston Convention and Exhibition Center (BCEC) so that may exemplify how projects of this magnitude can make great contributions to the improvement of the environment through minimization of wastes, conservation of materials, and economical use (and likely, production) of energy. Such a requirement, indeed, all the actions which we propose you require, need not impose any financial burden on the project, but are likely to be to its ultimate financial benefit, and to the Commonwealth's.
The correct and thoughtful implementation of a process of urban design will result in a project that will greatly improve the built environment of this area. Much work is required to ameliorate the impact that the sheer size and volume of this project will have on the opportunities for the natural and sustainable growth of the surrounding neighborhoods. The exterior surfaces of the BCEC, their uses and activities, are particularly critical to the development of this area.
The communities of the surrounding neighborhoods, particularly the St. Vincent's neighborhood and the Fort Point Channel Arts District, should have particular standing in the future discussions regarding the design of this project, as they are existing, abutting residential communities seeking to grow and thrive, and will be the most greatly impacted by the BCEC.
All of the edges of the proposed Convention Center have been inadequately considered and will not provide acceptable visual faces to the public, promote the establishment of viable community, or be an asset to the City. As planned, the Center will be an enormous, aloof object, blocking and separating areas and uses which require connection.
In particular, the Summer Street and D Street facades will do great harm. Both sides should be built to the back edge of the sidewalk and contain active, ground level uses (likely commercial) which are immediately accessible from the street. The sidewalks should be consistent with those abutting.
Allowing most of the proposed Summer Street frontage to function as a taxi cab and limousine drop off will turn the sidewalk into a vehicular zone; holding back the building face will destroy any possibility to create a continuous street edge in this difficult area which will be encumbered by a bridge over the Haul Road, and the forbidding Vent Building among its ramps below. There was no rationale stated for the 'grand scale' of the Summer Street forecourt. This should be corrected.
D Street and Cypher Streets should not have one side blighted by a fence or wall, no matter what materials; dead to activity, its sole usage for truck docks and trailer storage. That street frontage is too important and valuable. For these streets to develop properly they must have active, complementary uses on both sides. Those uses can serve the many needs of the BCEC as well as the neighborhood currently planned to emerge in the 'Enhancement (nee Buffer) Zone'. There is also a need for the BCEC's building elements on that side to build down from the anticipated height of 85 to 150 feet high, to a level much closer to that of the existing two and three story neighborhood. One hundred feet high might be the equivalent of an eleven story apartment building; completely out of character in comparison to the two and three story row houses and triple deckers which predominate in South Boston.
The Haul Road edge of the Convention Center should also be designed with attention to its appearance from and relation to the Fort Point Channel side, as it will be visible from various locations, over to the South Station area. Bridging connections over the Haul Road to permit pedestrians to enter the Fort Point Channel Arts District have been envisioned which would benefit both the BCEC and the District.
View corridors through the district and especially to the water sheets of the Harbor and Fort Point Channel need to be established and protected. There is no mention that the view corridor or C Street will be eliminated by construction of the Convention Center. The B Street view corridor will be greatly impacted by the construction of the West Concourse drop off areas. The mass of the building will also eliminate harbor views for many in South Boston. Minimization of total height, bulk, and the occlusion of views should be investigated.
The articulation of the wall surfaces of the Convention Center should be closely examined. With an enclosed area of approximately 30 acres, it will be the largest building in Boston by a factor of four (4) or greater. The average building in South Boston has a frontage of about twenty (20) feet, most of the existing buildings adjacent have street frontages in the range of 200 feet and floor areas less than 20,000 square feet, while the Convention Center will be 900 x 1500 feet, with a floor area of approximately 1,350,000 square feet. The scale of the convention Center must relate to these smaller buildings through development and modulation of the wall planes for it to begin to fit into the district.
Articulation of the roof plane should also be undertaken, with the goal of minimizing the apparent mass of the structure and improving its aesthetic characteristics. The roof will be visible from the side in many locations, from above through the windows of many existing and planned buildings, and will also be a striking sight from the air. That will be most conventioneers' first sight of the BCEC, and of Boston. Bold, articulated roof design is especially important, and will also aid in orienting the visitor to Boston.
The statement that the Convention Center will have "scale and proportions consistent with surrounding development" is ambiguous. Which characteristics and development, and how it will respond should be clearly stated and elaborated upon.
Venerable buildings, which perfectly express the "scale and proportions consistent with surrounding development" have been blithely scheduled for demolition. No mention of their importance, function in the urban fabric, history or possibility for reuse in concert with the Convention Center has been made. These should be carefully examined and their potential to enrich new development evaluated with an eye towards adaptive reuse. If demolition is necessary, prominent features might be saved and later incorporated, in some fashion, in the new structure.
The 'Expansion Area' of the BCEC is not discussed, with the exception of certain operations being permitted to continue for an indeterminate period of time, and its opportune role for construction staging. There is no mention of the timing or form of this anticipated expansion, its form, capacity, or effects. All of these should be clearly studied and stated in the EIS so that their impacts will be known and may be planned for. There is an opportunity to provide recreational facilities for the South Boston community during this 'interim' period on that site. The expansion site should not be permitted to become open air storage or parking. Fencing this zone off from the neighborhood is also an inadequate response to what should be a neighborhood resource.
There has been no mention of a Landscape Buffer area, nor any prior discussion in public forums, though it is a requirement of the legislation. It is unclear what this is to be or how it will be created, or for whose use. Skillful landscaping can be a tremendous amenity to all, and provide a multitude of environmental benefits. These should be examined.
Assumptions about future hotel construction are erroneous. 2,800 rooms must be permitted, under construction, or open by the year 2000. 4,800 rooms must be open by the opening of the BCEC, by legislation. The ENF assumes that only 1,000 rooms will be available in the Seaport District by that time. By that allotment, 3,800 rooms must be located elsewhere and no evaluation of any impacts have been made. Further there are internal BRA assertions that some 5,000 new hotel rooms may ultimately be located in the Seaport District. There is no mention or evaluation of the impacts of such occurrences, either on the Seaport District or on Boston and Cambridge, as a metropolitan area.
There is no analysis of the 'no build' uses which will be displaced, the number and type of jobs to be displaced, the areas where those businesses would move to, or the relative economic implications of this project, etc. Hence, there is no frame of reference for decision making and evaluating the relative benefits to be derived.
The transportation analysis presented in this volume is inadequate and misleading, likely vastly underestimating the traffic burden and impacts related to construction of the Convention Center. This work should be updated, base assumptions be brought into congruence with other cities worldwide that more closely match Boston, and evaluate impacts and alternatives should various key elements of the plan, not in place presently, fail to be constructed.
In particular, the blithe assumption that the vast preponderance of conventioneers will avail themselves of shuttle van service(s), both from the Airport and many outlying hotels, though this is not further analyzed or described is shocking. None of these potential routes have been described in any detail. Traffic in the Back Bay, where many hotels are located is quite congested throughout most days. Delays in transporting conventioneers may well cause many to seek alternate routes such as taxis or rental cars that would exacerbate congestion. This plan is dependent on creation of new Massachusetts Turnpike Extension ramps, which have already met with significant criticism from the community. Routes from other locations in the region may fare no better. Further explanation of this system must be made, and options for responding to various alternative future conditions established.
The estimate of 1,900 shuttle bus trips per day has also not been evaluated for its effects. Having stated that conventioneers' patterns do not replicate other peak uses, the proponents then use CA/T vehicular projections (which did not include the BCEC) to assert that there will be no impacts. At a minimum, this should be clarified. Those shuttles represent a substantial new fleet on city streets with various impacts. The implications should be satisfactorily resolved, and alternate methods of moving conventioneers about Boston evaluated for implementation.
The discounting of the number of visitors who will be driving, and those drivers conveying additional passengers are optimistic past credence. As a single example, the assertion that in a national conference there will be an additional 7,500 attendees (25,000 total, the actual maximum capacity and its effects remains unstated), but that these will not be full day visits or require any parking facilities whatsoever, accommodation on shuttles or in any other way, and that this requires neither mention, study, or planning for their effects, is stunning. There was no discussion as to how this maximum attendance number was arrived at, why attendees car pool in greater numbers than commuters, where displaced commuter parking would relocate to, what adjacent parking facilities would be under contract for overflow use and what would become of their regular patrons. The surrounding area can expect to have great pressures placed on its already stressed on street parking supply. No evaluation of impacts of plans to prevent or remedy this were made. This should be corrected.
The full significance of an additional 8,245 daily trips to this site must be analyzed as an addition to reasonably anticipated future development, which will have a horizon far beyond the year 2010, and result in 15 million additional square feet of development as a likely minimum. Various scenarios evaluating differing mixes of residential, commercial, and industrial development in the area, and their impacts, should be made.
The proposed vehicle concourse on the West side should be developed more like a city street than an airport. Perhaps there could be an entry from B Street and Cypher Street, permitting access from the community, and integrating it more into the City.
Proposed roadway design changes are all skewed towards a great enlargement of paved areas and the creation of a highway architecture. They are antithetical to good city planning, encourage additional vehicular usage, endanger pedestrians, and will likely not function as anticipated. These changes should not be permitted to be implemented. Study to determine means which will maximize the 'pedestrian friendliness' otherwise expounded in the ENF should be undertaken.
On site parking should be strictly limited and held far below the 1,825 number stated. Provision of ample, on-site parking encourages greater use of low occupancy private vehicles and detracts from the opportunity to provide transit. Greater reliance on better management strategies to limit employee and vendor private vehicles should be studied and implemented.
There was no analysis of the parking freeze program or the effect of the Convention Center upon it.
Bus parking has been alluded to on site, though not described. This is not appropriate, particularly as an exposed or at-grade usage. Provision for over-the-road bus service needs to be provided and routing and storage for out of service busses provided for. Various options need to be evaluated prior to implementation.
There was no analysis of the potential for, or impacts of, the relocation of the railroad right of way. Availability of sufficient rail service will likely play a major role in maintaining and enhancing the viability of the industrial port area and the Moran Terminal. No options should be precluded or diminished in planning for the BCEC.
The evaluation of opportunities for use of mass transit facilities is astonishing in its brevity and short sightedness. Comparisons have obviously been made with cities which do not have the transit, infrastructure, or density of Boston,or the adjacency of transit to convention center. No evaluation has been made of passenger rail and the terminus at South Station as a means of arrival. Commuter rail is similarly slighted as a means of delivering regional conference attendees and should be studied. Means of improving and making our existing transit facilities desirable and useful to conventioneers should be studied. The impacts of plans for future transit improvement and expansion should be evaluated.
The Convention Center will be located at a distance from Logan Airport which is comparable to the passenger terminal - terminal distances at other airports. This advantageous situation lends itself quite well to non-roadway transit options, particularly in conjunction with current transit planning. There should be analysis of transit usage should conventioneers automatically receive a visitor 'T-pass' upon registration for an event.
Water taxi and ferry use has not received any attention as an additional vector of travel between Logan Airport and the Convention Center, or regionally. It is easy to imagine this being a favored way to enter the city, attracting many users who, under current plans, would have no direct means to get to the Convention Center.
Truck access and circulation has several serious problems. Using Summer Street as a truck route implies a significant increase in trucking on A Street and through Dewey Square, areas which are already severely congested throughout most of the day. CA/T analysis admits that congestion will remain at Level of Service F (LOS F) and be further degraded, following completion of the Central Artery project, on A Street . Existing truck traffic on First Street, already problematic, will be degraded as a result of these changes, leading to greater pressures on the existing industrial users in that area. Final determination on the proper solutions should be made in concert with the City's comprehensive transportation analysis study, which will commence this Summer.
The anticipated number of truck trips generated per event is remarkably low. Further, there is no discussion of the maximum event schedule or any consideration that smaller events, which will likely be the predominant usage, may require many more trips, proportionally, as they will be supplied and serviced by many more vendors with differing schedules. This impact should be evaluated. Car trips generated by vendors while setting up and during shows which do not seem to be factored. Steps to provide for co-location of vendors and nearby siting of other suppliers of goods and services to the BCEC would greatly reduce this traffic, and increase other efficiencies.
Energy and Resources
The proposed Convention Center will be a focal point of the Boston Region and an exemplar of what we can accomplish. The message it sends to visitors of our dynamism, resourcefulness, and ingenuity are paramount concerns. The quality of life, the character of our community, and the high value which we place on the environment are essential elements which distinguish Boston and contribute greatly to our competitive advantage. These should be exemplified by their physical presence in the BCEC. The size, scale, function and numbers of visitors it will host give great prominence to issues of sustainability. We need to demonstrate that Boston and New England are at the forefront of this critical issue, for our people, industry, communities, and environment; and that they are inseparable.
Resource conservation, use of local, sustainable materials, locally made and recycled products should be prominent features of the construction. The proponents should evaluate opportunities for their use.
The Convention Center should be designed so as to minimize its energy usage. No evaluation of annual or life-cycle energy use has been made, neither of operations nor embedded energy.
The BCEC should be constructed so as to maximize its use of passive solar collection and other sources of renewable energy, to offset fossil fuel consumption.
Active solar collection for various uses, and incorporation of locally sourced high technology components and systems, in general, should be studied and used as appropriate.
Minimization of the production of all forms of waste should be studied, both during construction, and later, throughout the life of the Convention Center. Reuse on site should be evaluated. Trucking to off site landfills should be the last option considered. On site composting of food and vegetable waste should be implemented. The separation and on site composting of human wastes should be evaluated. Demolition contracts should encourage the recycling, rather than landfilling of the greatest possible portion of existing structures. A full separation recycling program should be instituted.
Management of water, as rain, surface and waste water should be more creatively examined and implementation strategies effected. There are several assertions that the area is nearly impervious presently, and casual inspection will show that this is not the case. Even paved areas are full of cracks and failed areas allowing for percolation of a significant fraction of surface water.
Rainfall on site should be collected, diverted and stored as a resource, or allowed to fall on landscape and porous pavements. These should be the preferred methods of utilizing rainwater. Development of a comprehensive grey water management system in conjunction with water usage reduction should be required. The roofed area of the Convention Center will provide an excellent opportunity for the capture and use of rain fall. Every effort should be made to lessen the burden on MWRA facilities and prevent surface runoff to waterways.
No contribution should be permitted from this facility to any combined sewer overflow (CSO). No surface water should be introduced into a combined sewer. Steps should be required which will prevent this occurrence.
Open space, recreation areas and landscaping should be established to permit rainfall to percolate into the soil.
Many significant questions about design, operation and impacts on the public welfare remain unanswered, or have inadequate examination and evaluation. Those enumerated above should all be required to be fully explored and resolved satisfactorily, in consultation with the community and other affected parties, prior to the permitting of the project. This process needs both to be formalized and enforced by the EOEA as a condition of permitting, and to continue throughout the construction and operation phases to ensure its successful implementation. Though we favor implementation of the Boston Convention and Exhibition Center, it cannot be successful until the steps outlined above are taken.
on behalf of
The Seaport Alliance for a Neighborhood Design