SAND has filed the following comments with the Executive Office of Environmental Affairs (EOEA) regarding Massport's recently proposed Master Plan for its Commonwealth Flats parcels. Commonwealth Flats is a 30-acre tract of land bounded by the World Trade Center, Summer Street and the Marine Industrial Park in the South Boston Seaport District.

Massport is not required to abide by zoning regulations for any of its real estate projects, nor is it required to comply with guidelines set forth by the BRA for successful emergence of the City's Public Realm Plan. The Commonwealth Flats filing is widely viewed as an attempt by Massport to publish a master plan for its South Boston waterfront property in order to stave off continued criticism that the agency lacks a long-term vision. The plan arrives at a time when approximately 50% of Commonwealth Flats is already completed or in progress with the development of hotel and office towers.

For more comment on this proposed Massport Commonwealth Flats Master Plan click here.


Mr. Bob Durand, Secretary
Executive Office of Environmental Affairs
Attention: MEPA Office
100 Cambridge Street, 20th Floor
Boston, MA 02202

re: Comment on Commonwealth Flats Development Area Plan

EOEA # 11882,

Dear Secretary Durand,

The Seaport Alliance for a Neighborhood Design (SAND) takes an active interest in the advocacy for and creation of a vibrant, 24 hour Seaport District. Commonwealth Flats is a linchpin in the potential for this area to support a diverse mix of uses and activities. We are concerned that, though the proponents have the best of intentions, this proposal will ultimately preclude the continued viability of a working port and and industrial base. We believe that Massports' charter and responsibility is such that it should not be permitted to take actions which will diminish the continuing and future viability of the port of Boston and those industries which cannot thrive without the port.

The proponent claims that it has carefully crafted this EENF with those concerns in mind, but the reality is far different. Not only will this proposal drastically reduce the maritime industrial use of this area far below what it was prior to relocations caused by the Central Artery Project, but it will limit the continued viability of other areas, such as Fish Pier, to function into the future. The relocation proposed for D Street will lead to partial or complete demolition of Building 4, with the result of pushing those existing maritime businesses off of the waterfront. Far from providing the necessities for these important existing uses, which is the charge of Massport, the Authority seems bent on becoming a commercial land developer ahead of all other concerns.

Despite assurances that the Authority is working in concert with the City, we see regular evidence that no such partnership exists. Approval of this EENF will likely mean that Drydock 4 will never revert to maritime use once the Harborlights lease expires. As waterfront and piers slip from fishing and industrial uses many of the businesses in the Marine Industrial Park will also have to relocate, change orientation or go out of business.

SAND cannot stress the long term, district wide, detrimental impact that this represents strongly enough. Approval of this plan will seal the fate of the Seaport and preclude much of the city building efforts which we have been engaged in over the past several years. We will be left with a district which can never become a neighborhood, and will replicate with less benefits the downtown commercial core.

Following are a few specific concerns which this plan raises for us. We will respond to the Parcel F filing later, and hope to establish a dialogue which will lead formation of community, diversified and successful uses, and coherence which will do justice to the enormous public expenditures which have been invested in this area, and which the Commonwealth deserves as its proper return.

As so few of the parcel uses have been identified in this filing it is difficult to speak about them. However, we do know that a parking garage has been proposed adjacent of Parcel F, which should be incongruous for this site, particularly with two other enormous parking structures within two blocks. Should a garage use be permitted, additional used should be mandated, particularly at grade on all sides of the garage. No pedestrian bridges from garage to other buildings should be countenanced. No portion of a garage should face the Harbor.

We support height and density for Parcels D-2 and D-3. Both should have continuous street walls with active uses, and doors to the street every twenty feet. D-2 should reach to parallel Viaduct Street and have at least one entrance to it. Parcel D-3 Should be expanded to provide a continuous use to the back of the Summer Street sidewalk line, and also reinforce Viaduct Street. We also support Height, Bulk and density for Parcel C. Parcels D-2 and C should maintain a view corridor from Summer Street, through and over the Air Rights Garage, to the Harbor. Parcels G, J, and K should be reserved for marine industrial uses and built no higher than the World Trade Center.

Open Space is not well represented by this plan. The 'delta' provided on D Street will add little. It only doubles the park already being built immediately to the North, and it will be surrounded by thick traffic through much of the day. It would have been better left in the current D Street alignment with a park in the current location of Parcel J. The two other portions denoted park also serve as no more than median and verge. These elements should not be construed and adding to the public realm in any sense.

The median at the termination of Congress Street is similarly misbegotten. and does not add to the public realm. Congress Street itself to the West of D Street should be redesigned to duplicate the Easterly leg. Its dog-legged T-intersection is arbitrary and confusing, and seems designed to maximize commercial development rather than a legible cityscape. New Fish Pier Road is particularly poorly named, having no relation to Fish Pier, unless there are plans for a new Fish Pier that have yet to be articulated.

The Transitway, as it emerge and crosses D Street on the Connector Road should be accomplished as a grade separated, subterranean continuation of the existing tunnel. This will make far easier the future conversion to rail vehicles, and reduce reduce the delay which the surface crossing conflict would impose. Parcel H should be mandated to accommodate any needed switching, layover and service requirements.

Pedestrian Circulation has not been adequately considered. Both sides of the entirety of Viaduct Street should be developed as continuous and well detailed pedestrian spaces, capitalizing on the unique nature of Viaduct Street. Congress Street Extension should continue its pedestrian focus all the way to the water.The Northern crossing of D Street at Summer Street should be a primary pedestrian link, and it should not be interrupted by an island. The Northern side of Summer Street should become a major pedestrian route and be developed in accordance with the Convention Center side.The Southern side of Northern Avenue should be also emerge as a primary pedestrian path and should be developed to the same standards as the water side. Market Street and New Fish Pier Road also have the ability to be developed as pedestrian friendly, quieter side streets.

We do not believe that Parcel F can serve any useful function housing a residential use if there will not be additional residential uses located on any of the adjacent parcels. To our knowledge this is not currently being considered, and if it is would provide a serious barrier to continued industrial usage of the area. There will be far too few people to constitute any type of a community in this isolated location. It is unlikely that service businesses will locate to serve such a small population.

SAND hopes that these shortcomings will be remedied before any approval of this proposal is made. We remain available for any questions you may have.


Jon Seward, on behalf of
Seaport Alliance for a Neighborhood Design

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