SAND has filed the following comment letter to address development of Massport's Parcel F property (already under development with office and hotel towers and a small number of luxury condo units). This letter responds to an Expanded Environmental Notification Form (EENF) recently submitted for approval by Massport to the Executive Office of Environmental Affairs (EOEA). Public comment on the EENF was solicited.

Related info: Massport recently filed an EENF for proposed development of the entire 30-acre parcel named Commonwealth Flats, including Parcel F. To read SAND's comment letter regarding the entire Commonwealth Flats proposal, click here. Last week, the EOEA issued a decision on Commonwealth Flats, requiring Massport to complete an Environmental Impact Report (EIR), a process that correctly requires Massport to fully examine environmental and public realm impacts in the larger context of an evolving district.

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
Attn: Ms Laura Rome
re: Massport, Parcel F Development
EOEA # 11882

Dear Secretary Durand,

Parcel F is a critical site for future development which will set the tone for other projects in this district, and define the character of the D Street corridor. SAND believes that it is essential that these buildings set a higher standard in all regards, particularly their contributions to the urban fabric and their protection of the environment. We support these projects and hope that they will be able to move forward, but also need to raise some serious concerns regarding specific characteristics and impacts.

The recent decision to require a full EIR process for Commonwealth Flats and individual projects gives us a higher level of confidence that development in Fort Point Channel and the Waterfront will proceed in the best interests of both the locality and Commonwealth. Your continuing focus on this unique area is valued, and will be essential for it to achieve its potential.

The assumption that development of the district will occur incrementally, over many decades, and can be addressed at some later date is incomplete. Massport is now constructing an office tower, has built a hotel, and has plans for three more buildings of nearly one-half million square feet apiece, exclusive of additional development in Commonwealth Flats. The Convention Center will add over another million square feet and will be in construction within a year, to open in 2002. Several hotels of upwards of 400 rooms are anticipated to serve the Convention Center. Fan Piers' owners are now proposing 3.3 million square feet of construction, also to begin construction in the next few years. This construction could all be completed well within the next ten years, and other nearby sites may also move forward simultaneously, leading to perhaps ten million square feet overall of new construction.

General Considerations

The Memorandum of Understanding with the BRA, previously committed to by Massport, does not appear to have been concluded. Without it there is only continuing good will to ensure that local zoning controls and development goals will be followed by Massport. We hope that the MOU can be finalized quickly, and that in its absence EOEA will be doubly vigilant that projects maintain consistency with relevant planning decisions.

SAND should be acknowledged and included as an interested party to this development, and is otherwise claimed as a neighborhood participant in this EENF, having hosted a Massport presentation on their development goals over a year ago and continuing to represent neighborhood concerns and regional interests in this district. We assert our standing on this and other Massport Development projects in the South Boston Waterfront area, and look forward to continuing our constructive dialogue with Massport and other interested and affected parties on these issues.

Building maximum occupancies and users have not been indicated, complicating a full understanding of operation and impacts of this development proposal.


SAND supports varied housing throughout the district as a means of creating community and reducing housing pressure in Boston, but is concerned that this location will be quite distant from other residences. The 88 units proposed will not suffice in themselves. Hotel rooms, while bringing people to the district, do not contribute towards establishing a residential neighborhood. We would hope that there are plans that we are currently unaware of that would provide a significant housing element near Parcel F and link these residential units to others. With a residential density under 32 units per acre it demonstrates that providing a residential mixed-use component on other sites could be readily accommodated, and that the BRA's target for housing could be easily met or exceeded.

This EENF is silent on the provision of an affordability component for the residential units. There needs to be the fullest variety of housing types and income levels so the Seaport does not become an enclave of the wealthy alone. Different levels of affordability should be closely adjacent, if not possible to provide in the same building.

Urban Form

We find that the design of the drop off apron for the hotel is not in keeping with good urban planning principles, violating the street wall and interrupting pedestrian circulation. The deep, shadowing overhang of the hotel will reduce its active participation in the life of Congress Street Extension, discouraging passersby from using the facility. This design will encourage the side of the hotel to become a short term parking lot, similar to the Four Seasons Hotel on Boylston Street. We would prefer an arrangement similar to that planned by the Boston Harbor Hotel as a way to provide access and an improved streetscape, while accommodating other users of the street.

The restaurant location adjacent to the face of the planned park is well chosen, but needs to have entries along D Street, and at the corner of the block, to give activity to the street. Similarly, the retail elements in both buildings should have entries giving directly on to the streets on each side of the building. The office building should provide entry to its lobby from Connector road to ease pedestrian access from the proposed transit station.

Office building and hotel lobbies are not public spaces, though they may meet technical definitions. If the proponent wants to assert the provision of public space, they should then agree to permanent access and use controls no more stringent than those governing public parks.

The retail space facing Market Street appears unlikely to be able to support itself, unless the facing developments are more intensively occupied and have primary entries oriented towards it.


Current stormwater runoff and solids should not be the basis for future performance. Due to greater impervious lot coverage there may be an increase in runoff volumes. Rainwater and graywater generated by the project should be reused to substitute for potable or process water use, or made to perc to ground on site or on the proposed park. There may be cost savings to reducing runoff and water use, such that new BWSC lines are not required. The amount and dimension of solids to be removed should be clearly stated and maximized. No CSOs should be generated by this project. A date for research into downstream capacity be completed should be established. That information be should be submitted for public review and comment prior to permitting.

Building energy usage estimates should be available for review and comment at a point in the design process where improvements can still occur.

Daylighting calculations should be used to maximize the amount and duration of the sunlight that can reach sidewalks throughout the year. Solar glare should be demonstrably minimized. The Seaport Hotel and East Office Building should not become the measure of sufficient performance. We are concerned with the bulk of these buildings and their occupancy of an entire block each. However, SAND is not recommending lower heights or lesser density for this proposal, unless access and servicing constraints are otherwise insurmountable.

Historic fill in this district contains debris and artifacts, from other areas of Boston, of archeological significance. A plan should be created for the identification, retrieval or conservation in place, and preservation of items of historic or cultural interest that may be disturbed or discovered.


SAND supports transit, walking, bicycling, TDMs, and other transportation modes which reduce reliance on private vehicles. However, we feel that the levels being asserted are overly optimistic in the absence of greater detail and more aggressive implementation efforts. With an occupancy exceeding 2,200 persons, the trip generation table suggests that 648 auto trips will be necessary for the office building alone in each peak hour, at least 1.3 times as many as table A-4 indicates. The apparent explanation is that extremely high levels of car pooling are contemplated, or the institution of flex-time hours to such an extent that only half of the employees would arrive during multi-hour daily peaks.

The absence of an existing conditions or no-build transportation baseline evaluation should be remedied. The preconstruction Central Artery evaluation identifies several existing points of congestion in South Boston that will continue to be problematic.

The recent reduction by 1,000 spaces of the Convention Center's parking garage capacity, proposed changes in auto and truck circulation, and continuing uncertainty in the future use of the Pappas parcel at D and Summer Streets suggests that the design of D Street, Summer Street, Viaduct Street and their intersections have not been resolved with any certitude. SAND will not support any design changes which degrade the pedestrian environment. No party should be released from responsibility for these areas until all outstanding concerns have been resolved, and projected traffic volumes have been accommodated or mitigated. Additional design efforts should be required to remedy these issues, and provide satisfactory levels of service and streetscape amenities.

Massport should be aware of capacity and service limitations of MBTA Piers Transitway. The ability of the MBTA to purchase additional vehicles, hire additional personnel, and reduce headways to undetermined practicable minimums sufficient to keep pace with demand has not been demonstrated. EOEA is well informed of the MBTA's delays on projects relating to the CA/T project, some of which are nearly ten years behind schedule, or appear to have been abandoned. SAND strongly advocates for the highest level of frequent and affordable intermodal transit, but is concerned that even the most aggressive program might lag well behind demand in the Seaport. There should be detailed contingency plans developed by Massport, mandated to anticipate and compensate for any emerging shortfall in transit service.

Massport should facilitate WTC transit station planning, so that riders can exit directly to the East or North, reducing the total walking distance. If pedestrians must enter or exit by the Viaduct Street alignment it could double the distance to Parcel F, discouraging potential transit users.

The anticipated Transportation Demand Management measures should be studied to determine the level of transportation improvement they will be able to contribute, and provide a description of procedures which will monitor continuing performance, achievement of goals, and continuing improvement in the reduction of single occupancy vehicle use. Massport should commit to specific timeframes and overall goals for implementation of TDM strategies. We realize the difficulty of setting specific targets for single elements, and it is inappropriate to limit the suite of services that might prove most effective. But this EENF offers no expectation of efficacy or suggestion as to the level of congestion relief that TDM is expected to offer. There should be sufficient experience with TMAs and TDM practices at this point, ranging from the local to national, that can indicate achievable performance levels.

Parking spaces for the 88 residential units should be made available at a maximum rate of 1 per unit, but should not be included in purchase or lease rates. Rather, the costs of parking should be fully understood, and spaces should be sold or leased individually, encouraging occupants to reduce auto ownership. A car-share program or other short-term lease or rental programs should be combined with hotel usages to reduce overall demand for vehicles and garaging requirements.

Some of the sites identified for interim surface parking which would serve Parcel F development currently are occupied by maritime related industries. Existing maritime, industrial and related businesses should be required to be successfully relocated within the Marine Industrial Park or EDIC prior to use of these sites for at-grade interim parking.

Massport is pooling Commonwealth Flats parking demand among several parking facilities, which will be constructed over several years or economic cycles, making it imperative that close attention be paid to their allocation and utilization as new proposals advance. Temptations will arise to over-program limited parking spaces, exacerbating congestion and motorist frustration. Massport should be required to identify specific allocations when calculating parking provision.


SAND appreciates the effort exhibited in the pedestrian streetscape described, and hopes that this will include sidewalks having a minimum of eight feet of unobstructed walkway, clear paths of travel, with street furniture organized at crossings to permit queuing, ready street crossings, clear lines of sight to approaching traffic, and smooth paving materials. We encourage Massport to work closely with WalkBoston to develop exemplary guidelines and implementation for the pedestrian environment.

We anticipate that actual pedestrian usage related to Parcel F development might be twice that projected, when various tourism, shopping, recreational, lunch, after work, and errand related trips are fully accounted for. Pedestrians currently represent the majority transportation mode in downtown Boston, and will need to be predominant in the Seaport if it is to be successful.

There should be pedestrian crossings at several intersections that are not indicated in the EENF: 3 crossings at the intersection of New Fish Pier Road and Market Street; Market Street and Northern Avenue, South and East sides; Service Road at Congress Street Extension and Connector Road; mid-block between hotel and office building entrances; from New Fish Pier Road to the new Park. Crossings should have pedestrian controlled signal override actuation on all roadways with more than 250 vph.

Key pedestrian corridors should include both sides of Viaduct Street, Summer Street and Northern Avenue. The Congress Street corridor should extend to the Harbor. The sidewalk should extend alongside the roadway on the West side of D Street adjacent to the current office development project. The Harborwalk should be indicated, with a timetable for completion of its missing elements.

Signal timing described for D Street appears to make it difficult for pedestrians to cross D Street. This should be examined and modified. Pedestrian cycles should timed so that no pedestrians need be stranded on islands or medians, but can cross each street fully on one phase. Pedestrian signal phases should include both concurrent and exclusive phases whenever possible, and total pedestrian crossing time should be maximized in all cases.

Pedestrian entrances to buildings should be increased in number with several along D Street, no block should be without any pedestrian entries, particularly at corners. An entry at least every 50 feet would be preferable.

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

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