10/4/99

SAND has filed the following comments regarding the proposed development of a 650-unit residential condominium on D Street. The proposal was filed for comment by owner Cathartes Investments.


9/28/99

Mr. Bob Durand, Secretary
Executive Office of Environmental Affairs
100 Cambridge Street
Boston, MA 02202
attn.: Ms Laura Rome, MEPA Unit Analyst
EOEA # 12022, D Street Residences

Dear Secretary Durand,

The Seaport Alliance for a Neighborhood Design is pleased to be able to support this proposal, with certain specific reservations that we will detail below. SAND has long advocated that a significant number of new housing units of all levels of affordability be provided throughout the South Boston Waterfront area, to create new communities and bolster those existing, to relieve gentrification pressure on South Boston, and to provide dwellings nearby for those who will work in the Waterfront District.

This project will make a substantial contribution in an area that we think should be a natural extension of the St. Vincent's neighborhood, and will provide additional context which should assist in further design and development efforts for the new Convention Center. We hope that this project will provide some guidance as to size, scale and density for other development in the area, and look forward to being able to greet our new neighbors upon completion of the project.

There are, however, some significant elements of the design and conceptualization of the project that we find to be at odds towards the creation of a new neighborhood. We hope that the Secretary will concur and require that sufficient, specific changes be made to improve this project. Our concerns center on the issues of excessive provision of parking, the way in which the project meets the street and activates its ground story, and the effects of creating an insular enclave.

Due to the urban location and the availability of ample multi-modal transit, the parking ratio for the complex should be reduced to no more than 1 structured space per unit from the current ratio of 1.25 : 1. On street parking should be maximized with provisions for servicing, curb cuts, handicapped parking and bus stops, as appropriate on the perimeter and interior roadways. Too much of the indicated surface parking is provided in lots. Most should be parallel parking along the curb of city streets. None should be provided in double loaded lots.

The co-location of grade and garage parking exits will produce conflicts of turning moves at D Street. They should be separated entirely or brought to join well away from D Street. The potential conflicts of these exits with the Convention Center events exits should be investigated to prevent congestion, or the inadvertent routing of traffic through South Boston. The proposal indicates that fire trucks and emergency services will have difficulty accessing the inner portions of the site with the current site circulation, which can be eliminated with a site configured into city blocks. All of the project roadways and circulation corridors should be part of the public realm and not internalized. These roads should readily and seamlessly connect with the existing and proposed roadway network in this area.

The current proposal creates a super block which has been proven not to work in the best interests of urban development. It does not respect the block layout and development pattern or orientation of traditional South Boston, which is ample enough to provide adequate development opportunity in this location. Attached town home style buildings primarily facing onto the street with alley development through the mid-block behind would be more appropriate here. The repetitive, U-shaped residential blocks are not appropriate as they create private zones at odds with the larger neighborhood. Future development to the East of this site will be made problematic if this scheme is approved. We appreciate, however, the gradual stepping down to meet the residential community and find the higher, denser scale of the structures as they meet the converted buildings along Summer Street to be appropriate.

Potential for ground level activation with shops and offices immediately abutting the sidewalk is encouraged. D Street, in this area, has the ability to become the sort of local shopping street that Broadway serves in the rest of South Boston. Access to apartments should beat grade, from public streets. The raised plinth with fencing mediating between the sidewalk and building entries should be eliminated. This provides an unacceptable level of separation, more suited to residential sections of Commonwealth Avenue than to South Boston, and will lessen vitality, compromising the success of the street edge. All of the buildings should have occupied facades which are built to the rear of the sidewalk line.

Sidewalks, particularly along D Street, should have an unobstructed walkway width of at least eight feet. Consideration should be made for planting a double row of street trees against the curb line, taking advantage of D Street and Convention Center opportunities. Street furniture and amenities for the public should be provided along D Street.

SAND encourages the provision of large, suitably programmed and maintained areas of open space, available for public use. What is described in the ENF appears to be highly privatized and uninviting to the general public. We hope that the ground plane can be made as vegetated and porous as possible, enabling a minimum level of contribution to stormwater drains.

SAND is interested in assisting this project to resolve these difficulties and move forward. We remain available to discuss this project and its particulars with yourself, your staff, and the project proponent.


Sincerely,
Jon Seward

on behalf of SAND


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