SAND has filed the following comments regarding a recent Notice of Project Change (NPC) filed by the Central Artery Project. The Central Artery made a repeated commitment to the Fort Point community to turn a significant parcel in the historic subdistrict over for conversion to a park once the Artery project was completed. Subsequent to these community discussions (and midway through construction of the Ted Williams/Masspike connector through the Fort Point subdistrict), the Central Artery ceded the parcel to the US Postal Service to satisfy its outstanding mitigation requirements.

Although this parcel has been identified as a park in the BRA Public Realm Plan, the USPS intends to use the parcel for use as a parking lot as it studies future development options.


Mr. Bob Durand, Secretary
Executive Office of Environmental Affairs
100 Cambridge Street
Boston, MA
attn.:Mr. Arthur Pugsley, MEPA Unit
EOEA # 4325, CA/T NPC USPS mitigation

Dear Mr. Pugsley,

Members of SAND have been following and awaiting the provision of open space in the Fort Point Channel district since the inception of this project. We have had ongoing conversations regarding the provision of open space with representatives of the Central Artery Tunnel Project (CA/T) and the Massachusetts Highway Department (MHD) for several years. Representatives of the Project and MHD had earlier made representations regarding the provision of substantial open space in the neighborhood by the Project. They had identified the privately held parcels which were taken by the state as the site, and the area to be approximately one block. We were under the impression that we had an agreement, honorably determined and without recourse, that would provide the first open space park parcel to this neighborhood.

Recently we learned that the CA/T and MHD have participated in a series of land swaps with the United States Postal Service (USPS) which had the effect of removing those parcels which had been taken on A Street and earmarked for open space and consolidating them with other USPS property, placing these lands in federal control and beyond the reach of any local zoning enforcement. This has been predicated, in the current NPC filing, on the intent of allowing the USPS to maintain an agreement with its union to provide parking for each employee in one, single surface parking structure. Its result has been to eliminate our opportunity for open space and to provide the Postal Service with a property which has enormously increased development potential.

The FSEIS clearly states that future land use would be controlled by the City of Boston through an open and cooperative process, yet this exchange removes property from the regulation of the City, potentially in perpetuity. Plans for the South Boston Seaport Public Realm, completed this Spring, delineate a park of multiple parcels totaling four acres, stretching from Fort Point Channel to the mid point of the proposed Convention Center, providing a direct pedestrian linkage through this area. This can certainly not be accomplished if this NPC is approved.

At no point did any representative of MHD of CA/T suggest that any land transfer would remove lands previously denoted for public open space or parkland from that future use. The March 15, 1996 South Bay/South Boston NPC, nor other documents we were made aware of by the Project of MHD, did not disclose any change of anticipated land ownership in this area. At no point did the Fort Point Channel community or any of its members or representatives state any wish to reduce the provision of open space within this National Register district. We have additionally recently experienced the loss of urban wilds, adjacent to Summer Street, during current construction without any notice, remediation or mitigation efforts, one of which had previously been offered as a potential open space parcel.

As part of this series of land trades the Artery has also exchanged land which permits the USPS parcel to extend fully to Summer Street, adjacent to the proposed Convention Center site. The CA/T has engineered and built tunnels and boat sections in this area to be able to accept building loads to an unspecified degree above the standard load criteria. And the Project has traded formerly privately held lands so that the USPS can have frontage onto A Street. No representation has been made as to the equivalent values of the properties which were exchanged, though we are told that the additional engineering and construction costs range into the millions of dollars. The Postal Service has never denied that it may relocate its General Mail Facility on Dorchester Avenue and has plans for speculative development of these properties under discussion. This action was exceptional, violates the spirit of the FEIS, and should have been fully discussed with the community and abutters before proceeding. We question the necessity and propriety of these actions, and request detailed investigation and documentation to be provided.

We fail to see how the CA/T and MHD must act to fully satisfy the terms of a contract between an employer and employees which have an interest in these properties. Satisfaction of employee parking needs is firstly the responsibility of the employer. In other portions of the Project the Artery has been far more creative in the provision and location of replacement parking. No explanation has been made of any attempts to find alternate means to satisfy the intent of the contract, whether by additional parking facilities, mass transit, or transportation demand management techniques. The USPS has operated a shuttle service to its parking lots since well before the CA/T Project began construction in this area. We would wish that the Artery had shown equivalent for the various types of on-street parking which has been lost to construction in this district, losses which become ever more severe. Some of these losses can be attributed to USPS personnel who park on city streets rather than in lots.

The design of the parking lot which is promulgated by this NPC has not been designed. Only a preliminary layout exists and that has not been distributed. It should be included in this filing. We have no assurance that the lot actually will accomplish what it is proposed to do, and that the prior size of the lot was sufficient to house ancillary uses for which there is no mitigation requirement. From a brief look, it is clear that there is also no provision for street trees, no design of drainage, little consideration of pedestrian circulation on site, and no concern for its impacts on adjacent properties.

The 6,000 square feet of park which appear at the end of this NPC are an enigma. We are offered no specific information as to how this area is to be provided, what will be its ultimate disposition, where the budget is to be found to provide it, how it will be maintained and managed. Certainly there is no discussion as to how it is to suffice for the needs of the community. We do not know if this park is equally illusory as the prior one. We do know that it is only perhaps one-tenth the size of the park which had previously been committed to. We ask that you direct the Project to provide all previous drawings of that park to yourself and to the public for comparison.

This action, in concert with the recent loss of all funding for previously promised arts projects in the district, and reductions in landscaping elsewhere without any compensatory mitigation, leads us to question whether we can communicate, discuss, negotiate and resolve problems with the CA/T or MHD, and whether the regulatory controls which have been established to provide precisely the sort of safeguards we require are meaningful or enforceable.

If this is the fate of agreements which were painstakingly and solemnly arrived at by all parties, then all of our other work and negotiation are equally meaningless and invalidated by this act. These agreements were conceived of as irrevocable and to stand as partial mitigation for intrusive impacts of a ten year construction sequence which surrounds and bisects the community, which has (and continues to) extend itself to facilitate the speedy and efficient completion of the nation's largest and most expensive public works project. We are forced to ask where is the openness and accountability in government and the public sector, which is the cornerstone of our society. If we must find other avenues by which to remedy and secure the interests of the community, they will invariably prove more costly and time consuming to all parties than our previous working relationship.

It is a matter of simple justice that this community receive a modicum of open space commensurate with what has been promised by the authorized official of CA/T and MHD. Every other neighborhood which this Project has impacted has received open space commitments and new parkland. The downtown park parcels have been promised additional landscaping and art on the order of $15 million above that required by certificate. Our neighborhood encompasses the largest community of working artists in New England, viable and productive members of our regional economy, many of whom find it impossible to work or whose work is damaged as a result of construction activities.

Mr. Secretary we ask you to deny this NPC in this form and to require that additional analyses mentioned above, including full assessment of all environmental impacts, be required to be conducted and submitted prior to any further consideration of this matter, and that other methods of satisfying the parking issue be employed. We ask that you require public open space to be provided, in no less area and quality than previously promised, and in a location consistent with the BRA public Realm Plan and community needs. We further request that you require a formal and enforceable process by which issues can be resolved expeditiously with full community participation so that we will no longer be faced with a recurrence of this type. We assert SAND's right and standing as an interested and affected party to this Project and ask that we have full voice and representation in all future actions. We remain available to meet with you and to answer any questions, at your convenience.


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

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