Update 12/99: State Senator Stephen Lynch has offered to help resolve ongoing displacement and relocation issues. Click here for more...


SAND has filed the following comments in response to a Project Notification Form (PNF) currently being considered by the Boston Redevelopment Authority. The PNF, submitted by the Boston Wharf Company, proposes the demolition of a historic Fort Point industrial building for the construction of a parking garage (5 floors) and an office (2 floors).

To read an earlier correspondence to the BRA regarding this project, click here.

November 17, 1999
Ms. Susan Hannon
The Boston Redevelopment Authority
City Hall 9th Floor
Boston, MA 02201
Regarding: SAND Response to 11-23 Stillings St. PNF
Dear Ms. Hannon:
Over the past few days, SAND members and others have considered the Project Notification Form (PNF) for the proposed Boston Wharf Company Parking Facility and Office on 11-23 Stillings Street. Because we were only made aware of this project on October 26th, we have worked diligently to meet the November 19th deadline for public comment.
As mentioned at the November 9th meeting, residents and tenants of Fort Point understand that the Boston Wharf Company is, as the area's largest property owner and landlord, an important constituent of the neighborhood. Many SAND members work and live in Boston Wharf buildings and we look forward to working productively with representatives of the BWC on many issues to follow this particular PNF.
We have a number of concerns regarding this project, many of them derived from reading the Boston Redevelopment Authority South Boston Seaport Public Realm Plan (SB-PRP) and Municipal Harbor Plan (MHP). Some issues, including the displacement of valuable members of the Fort Point community, may fall outside the scope of the PNF, but were certainly part of our discussions and should be here for historical record.
Project Description and attached Photographs
The proposal replaces three two-story industrial buildings, circa 1905, with a new 96-foot structure including five floors of parking garage and two floors of office space. Photographs of the existing building, one taken around 1910 and one taken within the past week are attached. The existing building, already approved for demolition, is quite sound - constructed using the identical brick and beam construction as its cherished neighbors in the Fort Point area.
Public Process
According to Mr. Culver, attorney for the The Boston Wharf Company, project representatives met with our elected officials (Council President Kelly, Senator Lynch, Representative Hart) regarding this project in May 1999. Mr. Culver has stated to us that the elected officials were supportive of the project at that time.
According to Mr. Culver, no courtesy notice was given to these officials or any other members of the public regarding a Boston Landmark Commission Hearing held on October 12, at which the proponent received an approval of demolition of the historic warehouse and a waiver of the standard 90-day demolition delay.
Mr. Culver has stated that he did not notify any members of the community about the Landmarks Commission hearing, and none were present to testify. Lacking the benefit of testimony of public citizens, architects, planners (or even the benefit of our photographs provided to you today), the Landmarks Commission approved demolition and the waiver of delay in a stunningly close 5-4 vote.
We have not confirmed whether or not the Boston Redevelopment Authority was aware of or testified at the demolition hearing, but the proponent indicated that the BRA had pre-approved of the project prior to this hearing.
Having received pre-approval of the BRA and demolition permits without a single member of the Fort Point community (Boston Wharf employees aside) aware of the project, the proponent submitted the Project Notification Form (PNF) to the BRA on October 19. The BRA approved the scheduling of a public hearing on November 1 - with the proponent issuing only two invitations to the impacted community (one in a letter to me days before the meeting dated October 26 and one in a phone call to Becky Dwyer of FPAC on the same day). No public notices were posted, no meeting notices in community newspapers (Tribune, SouthBostonOnline) were printed.
Becky Dwyer and a handful of community members did our best to get people to attend the meeting with only a few days notice. To your credit, you agreed with Mr. Culver at the November 1 meeting to reschedule a second public hearing for the following week, just over one week before the public comment period expiration.
We understand that both you and the Boston Wharf Company followed the letter of the law on this project. Neither you or the proponent were required by law to notify either the community or the elected officials of the Landmarks Commission Hearing. Neither you nor the proponent were required by law to post notices in the neighborhood regarding the Article 80 community meeting. And the law probably allowed you to proceed with a public meeting only days after the proponent informed me and Becky Dwyer - leaving us responsible for collecting appropriate information and notifying others.
It is not clear to us whether or not this PNF violated Article 80 review laws by not having a public meeting announced in a local newspaper.
Surely, Ms. Hannon, we are not as concerned with following the letter of the law as much as we are distressed that the BRA seemingly considers public process as an obligation rather than a benefit. In our view, community members deserved the right to show antique photographs of these buildings to the Landmarks Commission. We deserved the right to speak to you and the BRA regarding this proposal in the context of the two-year South Boston Waterfront Public Realm Plan. We deserved to have some input to the BRA regarding our view of this community before the proponent was empowered to arrive at the first community hearing repeating that "the project is going to happen." Without question, our input would have helped you make a completely informed decision.
This response arrives to you today on behalf of a community that is resigned to the fact that the BRA has already made its decision, and - even if the Board of Appeals reconsidered the project - that demolition will occur.
And, just as we had asked you during our conversations and filings regarding the recent 343 Congress Street PNF, we must again ask you to consider community members in future PNFs which will impact the Fort Point district.
  • Article 80 hearings regarding Fort Point projects should be clearly announced in the South Boston Tribune and SouthBostonOnline at least one week prior to the hearing date. Although we may elect to help set up a meeting, notification to a SAND or FPAC member does not fulfill Article 80 public notification obligations.
    This request for notice is not without precedent - meeting advertisements are a typical courtesy visited upon other areas of South Boston.
11-23 Stillings in the Context of the Fort Point District
According to the Public Realm Plan (PRP) - a document created after two years of planning betweent the BRA, elected officials, community members and waterfront advocacy groups, the Fort Point district is slated to anchor a vibrant mixed-use area with a strong residential component. This district, split into the Fort Point Historic and Fort Point Industrial subdistricts in the Municipal Harbor Plan (MHP), is envisioned as an area where the evolving uses (residential, neighborhood-style amenities, etc.) would co-exist with the industrial uses further south along the Fort Point Channel. A broad vision of the area as a mixed use-residential district with respect for its history was recently hilighted in a very well supported PNF - the one submitted for your approval by Beacon Companies for Fort Point Place.
Consider, for example, that 11-23 Stillings Street would have been a suitable site for encouraging a residential project, a supermarket or other community-oriented retail operation. Due to the relatively small scale of the existing building, the Boston Wharf Company would have had limited ability to exert a best-use claim (as it currently finds the best-use of warehouses is to convert them to sterile office space). And certainly, the community would likely have been more supportive of a re-use project rather than a demolition and reconstruction.
Instead, the BRA succumbed to the continual drumbeat of office, retail, parking garage that we hear repeated by the Boston Wharf Company and Gillette - two companies that were largely absent from the two-year South Boston waterfront planning effort. Only two weeks ago, Mr. Culver stated at a recent Municipal Harbor Plan meeting on behalf of the Boston Wharf Company that Fort Point was the backyard of the Financial District. We at SAND stress that the plans for Fort Point outlined in the Public Realm Plan (PRP) best serve the broad public interest and you must reassure us that you are placing demands on these property owners to see the area evolve as a neighborhood.
Furthermore, the demolition of the historic structures on Stillings Street will violate the integrity of the Fort Point Historic Subdistrict - an area with bounds clearly stated in the Municipal Harbor Plan (MHP) to include these buildings. Fort Point's industrial character is intrinsic to its success as a wonderfully timeless area of the City - a neighborhood that has continually attracted the attention of artists, photographers and filmakers. With the continual additions of penthouses and the demolition of brick-and-beam gems like 11-23 Stillings, the area's fabric is irreparably torn apart.
In fact, the PNF simply states that the buildings to be demolished are "outdated." By that rationale every one of Boston Wharf's buildings stands at risk, and will be at risk as the project is permitted to move forward.
Lastly, it should be mentioned that the Fort Point community will lose between 20 and 35 visual artists who are being displaced by this project. Although SAND does not represent local arts issues (we cede this responsibility to the Fort Point Arts Community FPAC), it is worthwhile to mention that the PNF discusses the addition of new jobs but does not include the number of displaced jobs. Again, the erosion of a valued community and broader impacts detrimental to the cultural life of the City should be considered. For the record, Mr. Culver stated in your presence that the tenants of the building had reached agreement with the Boston Wharf Company regarding relocation. This assertion was proven false at the public hearing.
  • Regarding Fort Point projects, the BRA should require PNF submissions to include a section outlining the value of the proposal within the broad vision of the SB-PRP and MHP.
  • The Fort Point Historic Subdistrict should not be identified in a PNF by any other name (such as the Fort Point Waterfront District as the Boston Wharf Company PNF suggests).
  • If a PNF includes job creation statistics, as are routinely suggested as a benefit of office space construction, job and/or resident displacement statistics should also be required within the PNF.
  • The existing conditions section of a PNF for buildings sited within the Fort Point Historic Subdistrict should be substantiated with photographs.
General PNF Comments on Height and Setbacks
The height of the proposed garage/office, at 96 feet and more than twenty feet higher than zoning would allow, does not warrant the requested variances. Given the scope of traffic problems in the area (detailed in subsequent sections of this document), five floors of garage space is especially excessive, unwarranted and unsubstantiated in the PNF. Although the proponent attempts to enliven pedestrian activity through the addition of office space, there is no explanation of why the two floors of office space did not replace garage space rather than adding on top of it.
Furthermore, granting variances will make the building unduly prominent for its location on the block. No argument has been made to convince that this is the only way to build this structure and that those exceedances are required.
There is a roof line and to maintain some consistency with existing buildings there should be an articulation of the cornice line. The building essentially does not respect its neighbors. There is no relationship or continuity of floors, window openings, cornices and accent lines, much less height and setback.
It is likely that this project is being considered as a partner to the renovation of the adjoining building on Congress Street. If this is so, the project may exceed MEPA limits and be required to file a environmental notification form.
General PNF Comments on Traffic and Transportation
There is no discussion in the PNF of public transportation walking, bicycling, ferries, etc. and the mode split between all of the transportation options as they affect this project. There is no discussion of parking demand in the area in general and how it will change as other developments proceed. There is no discussion of why all of the parking must be above ground, why that number of parking spaces was required, much less office area.
Why can none of the parking spaces be provided below ground? No discussion of the projects economics has been advanced.
According to the PNF, the parking garage will be open to the public and therefore will have to fall under the parking freeze regulations. No evidence that this will be accomplished has been mentioned, or how it can be accomplished. SAND was informed that all spaces, not just those reserved for the public, would have to be withdrawn from the freeze bank.
55,300sf @200 gsf/employee = 276 occupants x 68% public transit & walking usage = 88 parking spaces required for the building. 495 parking spaces are for other persons than the development in question.
General PNF Comments on Street Edges
Stillings and West Service Road
Stillings Street is being called the front in the PNF while the pedestrian entry is on West Service Road. On three occasions in the PNF, the proponent mentions the future emergence of West Service Road as a major pedestrian thoroughfare, yet as recent as last week the Boston Wharf Company was installing permanently mounted HVAC units on the West Service Street face of the adjacent building at 316 Congress Street. And the proposed garage extends 25 feet towards West Service Road, beyond the adjacent structure of 316 Congress Street, creating a poorly uneven street edge.
Sidewalk widths are far less than those called for in the Public Realm plan and BTD's roadway design guidelines. West Service Road should have the full sidewalk width of approx. 16 - 18 feet.
Stillings Street to New Northern Avenue
Future extension of this edge is not addressed by the PNF.
How will that intersection be designed by whom and when? What will it look like and what will it be able to accomplish? Mitigation to traffic impacts should be made, designed in this filing, and done by the proponent.
Specific comments on PNF Specifications
Page 7 It is a mistake not to base transportation modeling firstly on the 2010 CA/T numbers with the BCEC addendum as a starting point. 2003 is an arbitrary and meaningless point in time which will misrepresent the impacts of the facility.
Page 9 How were the peak hours to be studied determined?
Rush hours peak between 7-9 am, and 5:15 - 6:15 PM. Often, severe congestion begins about at 4:15 and extending to 7 pm on weekdays.
The intersection of A Street and Congress presently fails severely, at a volume to capacity (V/C) ratio of approximately 1.5. This intersection and its behavior will continue to govern the flow of traffic in the future and its performance is most critical and should not be further degraded.
Page 12 Current traffic volume on Stillings Street is so small as to be statistically insignificant, its vehicles per hour would generally be measured in single digits.
Page 14 How was the traffic growth figure of 1.5%/yr arrived at? What are the implications if traffic grows at a higher rate? Does the rate hold for the block, the district, the city?
Was any consideration of the traffic impacts of the Haul Road permitting passenger cars to use it during the week considered, and what effect would that have on all of the projections?
Page 17 What is the mode split expected? How many occupants per vehicle at what time and what sort of users?
Page 18 Trip generation based on one other garage is inadequate for this purpose. There is no rationale advanced to explain why this the Farnsworth Street Garage is the ideal model, or what might be learned from the operational characteristics of other garages.
What are the operational characteristics and restrictions for the Farnsworth Street Garage?
If this garage is needed to serve other existing or future developments in the area that needs to be stated explicitly. As a facility open to the public it must withdraw those spaces from the bank established by the parking freeze. That has not been stated. The employees of the proposed buildings (200gsf/person is a standard for cubicle offices) would occupy it at a rate of 2.2 cars/person. Obviously many people working outside the development project will be using the garage.
What was the rationale used to select June 3 - 18 as the study period? Why wasn't a time between Labor Day and Memorial Day used? Weekends are not explicitly excluded from the analysis period.
What are the other operational characteristics of the garage? hours, personnel, users. Will auto related activities like detailing or concierge be envisioned or excluded?
Page 20 Typically, 50% of a garage spaces can be expected to turn over during a peak hour, up to 190 more than is being use for the analysis, or 125% more volume, which is probably enough to overload the capacity of Stillings Street and the nearby intersections. The change in volume on Stillings Street has not been calculated and should be noted.
The postcard survey, methodology and results are not detailed. The population cannot be assumed to be the same as that for this project.
The garage will generate trips on its own. Currently this area parks thousands of cars, primarily for people who work in the financial district. Those people come first to the Waterfront to find parking and then go to their final destination. They have not been first to State Street to try to find parking and wind up on West Service road somehow. By placing a new facility on Stillings Street, usable by the public, it will attract vehicles on its own.
Page 20 If 76% of users will be making a left turn from Congress onto Stillings, that can be up to 341 cars/hr, enough to justify a dedicated turning lane. No provision of such has been suggested. Either way that should provide enough additional conflict to cause catastrophic failure of both the Haul Road and A Street intersections.
Page 25 It is unlikely that the shift of 42 cars from a left turn to a right turn from A Street is sufficient to generate a full step of LOS improvement. If so, it would mean a degrading of six steps further on Congress Street due to the additional vehicles introduced.
Page 26 The cascade nature of queue backups indicates that vehicles which do not clear during light cycle cause more vehicles to fail to clear the intersection in the next cycle, increasing until the rate that vehicles enter the queue falls below the rate at which they can clear. This description suggests that vehicles leave one congested intersection to join a more congested intersection. By adding vehicle which would otherwise not be present the proposed project simply worsens an difficult condition.
There is approximately one full light cycle each minute to 1 1/2 minutes. This indicates that back ups will proceed for 15 to 60 light cycles. At worst case, even one additional car each cycle would extend the queue by 60 cars, or 1,200 feet.
Page 27 The design and operation(s) of Pittsburgh and Stillings Street in the various scenarios has not be presented. No suggestions are made of actions that might mitigate their failing conditions, or that of other intersections that this project will impact.
Page 29 Of 17 intersections and traffic moves studied 11, or 65%, fail in the morning, 7, or 41%, in the evening, 5, or 29%, fail both morning and evening.
Page 30 The modeling requires that there be no stopping of vehicle flow on Congress Street flowing West from the Haul Road to A Street or the model will fail. No discussion has been made of how cars will turn left onto Stillings without requiring a yielding by oncoming traffic.
LOS E on Stillings Street is effectively a failure, and should be mitigated to a level D or better.
Causing a LOS F for the drive on the opposite side of Congress is an unacceptable imposition onto those users. This projects should not create unacceptable burdens on realistic expectations of others to the unencumbered use of their property. Would the proponent object if another project was to impose similar burdens?
To assert that with most intersections in 2010 operating at LOS F, without anticipating this development, that this additional burden is somehow acceptable is disingenuous. Even at a LOS F there is a calculable volume to capacity ratio (V/C) that will give an indication of the relative impedance, and this projects additional contribution. The BRA should not be permitting projects which cause a further deterioration in the service of the roadway network.
Page 31 The description of the project does not justify the use of the modifier 'negligible'. A more correct term would be 'significant to severe'.
3.1.2 No description of a methodology, time frame management, or prior experience with a metering of traffic has been advanced. Without support it cannot be considered a credible alternative or mitigation measure.
3.2.9 The users of the facility are not submitting the PNF. There are no guarantees that low production of waste will be attained.
3.3 Urban Design
This project will occupy a prominent location, possibly without a neighbor on West Service Road for many years. This building will attract attention by its location and by projecting above and beyond the existing building on Congress Street that it will adjoin.
The setback and continuity of the urban streewall should be maintained and continued.
All future development should be governed by the existing building typologies, setbacks and other forms of the existing district.
A timeframe and set of conditions that must be satisfied prior to retail being introduced must be described. No blank walls or parking spaces should adjoin the sidewalk of any building.
Why does a garage elevator deserve particular prominence?
Accent element should be specified as stone or concrete. The possibility exists that all will be concrete, leading to a degrading of the visible language.
Metal screening elements are not acceptable on window openings.
No rationale has been advanced for the particular dimensions of any portion of this building. All assertions are argumentative and without value.
Page 37 Street design guidelines should be seen as minimal criteria. Additional amenities should be provided and explicitly detailed.
3.5 State of the art is not an explicit or enforceable term. Details should be provided.
Other Comments
No description of how valet parking will be managed, what uses it will serve, and under what circumstance or when it will be converted to retail.
The TSIS traffic modeling software appears to be new and not in general use in this area. We are not able to understand the methodologies or algorithms used, its strengths and weaknesses, and it is therefore hard to compare to the performance of other software that is well understood. Why was it chosen?
SAND's traffic delegate was told that TSIS is relatively new and is likely somewhat buggy or not able to accurately model behavior. It has two major features - the ability to model the behavior of several intersections and their impacts on each other; and the ability to model the behavior of individual drivers, such as calm, road rage etc. While this is a good idea, there is no agreement on its accuracy.
In conclusion, we again must stress our disappointment with the lack of public process demonstrated by this PNF, amplified by the BRA's continual approval of market-driven projects which do not foster the emergence of a vibrant Fort Point neighborhood. We have appreciated your genuine willingness to improve our community's relationship with the BRA and look forward to working with you.
Steve Hollinger and Jon Seward
on behalf of
The Seaport Alliance for a Neighborhood Design (SAND)
300 Summer Street, South Boston, MA 02210
SAND Office 617-423-4299 (answering machine)
cc: City Council President Jim Kelly
State Senator Stephen F. Lynch
Representative Jack Hart
Mr. Anthony Gilardi, Mayor's Office Neighborhood Coordinator
Ms. Becky Dwyer (FPAC)

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