12/17/98
SAND has filed the following comments during the public comment period now underway regarding the siting and construction of Harborlights Pavilion on Wharf 8.
As required, SAND has addressed these comments to:
- Secretary
- Executive Office of Environmental Affairs
- 100 Cambridge Street
- Boston MA, 02202
- Attention: MEPA Unit
- Mr. Robert Baldwin
- Deputy Director of Industrial Development
- Boston Redevelopment Authority
- One City Hall Square 9th Floor
- Boston, MA 02201
- Mr. Greg Carrafiello
- Acting Program Chief
- Waterways Regulation Program
- DEP
- One Winter Street
- Boston, MA 02108
December 17, 1998
- Secretary
- Executive Office of Environmental Affairs
- 100 Cambridge Street
- Boston MA, 02202
- Attention: MEPA Unit
Re: ENF/PNF/WRDA for Harborlights Pavilion
Dear Secretary:
The Seaport Alliance for a Neighborhood Design is a community group based in the Fort Point Channel neighborhood of South Boston. Our members, including many Boston-area residents and business owners, have facilitated the planning of a "neighborhood" in the Seaport District rather than strictly a commercial district. We have also advocated for protection of the Marine Industrial Park (MIP) from encroachment by Seaport District development. A chronicle of our work on behalf of our constituents is well documented on our website at www.seaportalliance.org.
SAND has informed the proponent of our concerns regarding the conversion of irreplaceable maritime resources within the MIP for hotel, office and retail projects. The proponent is also aware of other concerns, notably the press announcement of Harborlights's relocation to Wharf 8 by Mayor Menino and the BRA without notice or benefit of a hearing by the site's occupants and neighboring communities.
Because we view the occupancy of Harborlights on Wharf 8 as temporary and because we understand that the proponent is working to preserve and improve the maritime capabilities on the site, SAND would support a 5-year siting of Harborlights on Wharf 8 if the reasonable requests outlined in this document were addressed.
Regarding the use of Public Resources
Harborlights has become an important and valuable Boston destination. It should not, however, be construed as a "public" venue on City-owned property. Ticket prices ($25 - $50) do not enable the general public to regularly attend events. Any improvements to the property or public amenities provided by the proponent are of significant importance to neighboring communities.
Regarding Siting on Wharf 8
Discrepancies exist between statements made regarding the short-term and longer-term or potential permanent occupancy of Harborlights. Terms of the lease agreement negotiated between the proponent and Boston Redevelopment Authority have not been publicly disclosed upon repeated request. Whereas the ENF states that "the facility will be removed after 5 years" (ENF Schedules P 2) and returned with improvements, it has been disclosed that the lease agreement includes a renewal option.
Therefore:
- We ask that the proponent fully disclose the terms of the Wharf 8 lease agreement and address any discrepancies between this agreement and the ENF, PNF and WRDA filings.
.- A lease renewal after 5 years should require new ENF, PNF and WRDA reviews to reflect and thoroughly address environmental conditions at that time.
.- Any rezoning or permits required to accommodate Harborlights on Wharf 8 should be temporary to reflect a 5-year occupancy.
.- Satisfactory relocation of existing Wharf 8 tenants must be a first priority.
Regarding Public Amenities
A number of "public" amenities are proposed in conjunction with this private venture, yet the proponent unreasonably regulates the public access to all of these amenities. For example, public restrooms are available to pedestrians along the Harborwalk, yet the proponent restricts access to the Harborwalk (and access to the restrooms) during event hours.
We would ask that each public amenity as listed on the following page - having already been announced to the community and dedicated by the Harborlights organization for public benefit - must accommodate the public during the entire term of the operating season, during event hours and off-hours.
- Public access to Harborwalk must not be restricted. The proponent states that "due to the need to provide emergency egress from a place of public assembly, the general public will be precluded from utilizing the Harborwalk area" (WRDA P 2). This statement is unsubstantiated. The Harborwalk is an important element of the public benefit plan - especially for members of the public who wish to enjoy a summer walk but can not attend a Harborlights event.
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Harborwalk is also an important focus of the ongoing Seaport District master planning effort, long in progress and slated for completion within the term of Harborlights's occupancy. The proponent must make the Harborwalk accessible at all times, providing an alternate emergency egress for patrons if so required. Public access to outlying edges and to the Harborwalk pathway at the rear of Harborlights' former Fan Pier location during its first 2 years of operation served as an excellent example of public accommodation.
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If the proponent wishes to limit visibility of the concert venue by pedestrians on Harborwalk, or increase security for performers, or provide egress to patrons, appropriate construction may be permitted within the confines of the concert site. Furthermore, the proponent must not be allowed to use private security guards to selectively enforce restrictions on Harborwalk and pathways outside the venue, as was the case during the last 2 seasons of Harborlights on Fan Pier.
.- Public restrooms should be maintained and accessible during event hours and during a reasonable number of daily off-hours (i.e. dawn to dusk) during the entire season. The proponent has offered public restrooms as a public benefit yet does not state hours of operation and may intend to limit public access during event hours or during off-hours.
.- Access to ferry service (if arranged for access to events) must be available to the general public and not limited to ticketholders. Existing area attractions, including restaurants and hotels, would be well-served by the addition of a ferry service.
.- Use of the water and docking facilities for Harborlights-related commercial enterprises (i.e. ferry service or party boats) should not preclude access to this area by other ferries, private and/or commercial boats or other types of water-based activity.
Regarding Transportation
To its credit, the proponent indicates an interest in providing shuttle service to and from South Station. Furthermore, by offering free parking to ticketholders, the proponent avoids potential problems caused by the use of South Boston residential parking by eventgoers.
Considering the proximity of Wharf 8 to residential South Boston and to the MIP, the proponent has not provided adequate support of public transportation. Whereas the proponent embeds parking costs in the ticket price as a marketing tool, no similar accommodation is made to provide and encourage free shuttle service between South Station and the venue.
Changing conditions within the Seaport District, especially considering construction schedules for completion of the Convention Center, MBTA Silver Line and Massport parcels will affect traffic on a 24-hour basis. For example, starting January 14, 1999, the MBTA construction will require New Northern Avenue to be a one-way from East Service to Sleeper, requiring a signaled right turn from Sleeper (near the Barking Crab) onto New Northern Avenue for all traffic attempting to approach the Moakley bridge. The proponent has not, and can not accurately predict traffic patterns in this district based on existing conditions.
The number of idling passenger vehicles must be minimized because South Boston residents continue to experience a well-documented, serious decline in health conditions due to traffic exhaust.
- To discourage passenger vehicles, the proponent should be required to provide free shuttle service to and from South Station, and perhaps to offer a discount or coupon for those arriving by shuttle.
Although the proponent states that the EDIC garage is "a convenient 1500' walk" (Transportation Sec. 4 II-D P14), this is actually a fairly long walk (over 1/4 mile) to the facility entrance. Eventgoers in private vehicles will likely use the passenger drop-off at the foot of the facility.
- The proponent should provide shuttle service between the garage(s) and the drop-off area, and should restrict passenger vehicles from entering the drop-off area.
Regarding Sound Mitigation
Harborlights, as it existed on Fan Pier, was a welcome neighbor of many SAND members. The noise level from Fan Pier to the residential community of the Fort Point Channel was tolerable and often an enjoyable addition to our eclectic neighborhood. With the Federal Courthouse completed as the last season of Harborlights began, the sound level increased within the residential district due to the amplification or redirection of sound waves off the new courthouse side-wall. Even so, the sound was still tolerable in this community - one familiar with urban noise, bagpipers at the Fire Museum, horses and occasional airplanes.
That said, the proponent has not adequately prepared for effects of amplified music on the neighboring South Boston residential community. Based on our experience with music from Fan Pier traveling through the Fort Point Channel neighborhood, it is likely that music will be audible within South Boston. A level of planning, mitigation and enforcement should be provided.
- The proponent should be required to adjust sound levels upon notice of disturbance by a reasonable body of residents.
We appreciate you consideration of this matter and look forward to working with your office as we move forward with this project.
Best regards,
- Steve Hollinger
- On behalf of:
- The Seaport Alliance for a Neighborhood Design (SAND)
- c/o FPAC, 300 Summer Street, Boston, MA, 02210, 617-423-4299
- www.seaportalliance.org
- cc: SAND Membership