Robert Durand, Secretary, EOEA
MEPA Unit: Attention: Janet Hutchins
EOEA # 12083
100 Cambridge Street
Boston, MA 02202
Paul McCann, Acting Director
John O'Brien, Project Manager
Boston Redevelopment Authority
One City Hall Square
Boston, MA 02201
January 7, l999
Re: Fan Pier Development PNF/ENF Combined Comments
The Alliance of Boston Neighborhoods is an umbrella organization of neighborhood associations promoting community participation in city development issues. We appreciate this opportunity to comment on the Fan Pier Development ENF and PNF, since this project will have important impacts on the public realm, and set precedents for the entire South Boston waterfront. It will also benefit from enormous public investment in natural resources and infrastructure around the site, and must honor the public trust as it pursues its private enterprises.
Comment standards
Our comments are informed by the Commonwealth's Chapter 91 and 310 CMR 9.00 Waterways Regulations, the EOEA Scope (October 20, l999) for the South Boston Waterfront District Municipal Harbor Plan, the City's Boston 400 planning principles, and the Seaport Public Realm Plan.
We understand that the Commonwealth provides for a Municipal Harbor Plan so that municipalities can meet, or exceed, the intentions of the Waterways Regulations in physical designs most appropriate to their specific circumstances. MHPs are not intended to be vehicles for exemption from Chapter 91 regulations, but should seek to optimize protective regulations and policies governing stewardship of trust lands. As mentioned in the Scope, the BRA's Request for Scope focuses on substitutions that will facilitate implementation of the Public Realm Plan. The PRP includes numerous laudable goals, but it is widely understood that the BRA's mandate to promote economic development in the city may conflict with its planning mission, resulting in compromise of the public realm. Therefore, we ask the Commonwealth to hold the proponents to the highest standards of fulfillment of these stewardship policies.
The proponents have begun the BRA and MEPA review processes before an approved Municipal Harbor Plan is in place. The proponents emphasize the proposal's consistency with anticipated regulatory requirements in the MHP that will be developed by the BRA. However, judging from the discussions at the MHP Advisory Committee meetings, the BRA's forthcoming MHP draft will require lengthy work to be acceptable to the Committee. Further, the Secretary's Scope differs significantly, in ways the Alliance very much supports, from the Scope requested by the BRA. Therefore, the Alliance members feel strongly that the existing regulations should be the review standards, until the MHP is fully approved by the Commonwealth.
Plan comments
Neighborhood-makingThe BRA's PRP has emphasized the goal of creating in the seaport district a genuine neighborhood -- an extension of Boston's much-valued mixed-use, livable urban fabric -- rather than an office/hotel complex in a waterfront theme park. This goal is strongly endorsed by the Alliance, and is a widely accepted principle of enlightened urban planning nationally. The proponents state their agreement with the goal of creating a new neighborhood, citing as one of their principles, "Provide a diverse and critical mass of housing (including live-work opportunities) to ensure that the site is alive 24 hours a day."
However, the proposal includes only about 450-525 units, which might house about 1000 residents. Further, because of the project's anticipated high housing prices, the desired diversity is unlikely to be achieved without particular efforts.
The proponents should be directed to model the number and demographic composition of a resident population that would constitute an authentic, functioning neighborhood, which would support local businesses, schools, churches, playgrounds, libraries, etc. Data should be presented for one or more existing vibrant, successful Boston neighborhoods that could serve as models, for example, Back Bay, South End, North End, South Boston. The analysis should include dwelling units and number of residents per acre, and proportion of built square footage occupied by residential units (excluding hotel/lodging uses). (The project proposes twice as many hotel units as housing units, and 50% more office space than residential space.) The analysis should also describe and quantify commercial, office, and cultural and educational uses.
The model(s) should be compared to the proposed plan. The proponents should indicate how they will produce their proper share of housing units and other neighborhood elements for such a population, so that this project does not simply target the luxury housing market and leave the community-creating task to subsequent developers.
It is important, for various reasons acknowledged by the proponents and the City, that developers in the district create diverse neighborhoods, where all kinds of people can share in the benefits of the massive public investments that give the site value, and can enjoy the unique qualities of the tidelands. It is not sufficient to spin off funding to build "affordable housing" elsewhere; this will intensify socioeconomic segregation in the city and unfairly distribute public benefits.
Public realmPublic access: The overarching principle governing development in the project area is the Commonwealth's commitment to responsible stewardship of public rights in the tidelands. This policy requires that any project seeking a Chapter 91 license serve a proper public purpose that provides greater benefit than detriment to the rights of the public in tidelands. This benefit is in unfettered access, accommodation through amenity, and maximum dedication to water-dependent uses.
The proponent's promise to provide unimpeded public access "in contrast to the limited, passive pedestrian access to the edge of Boston Harbor that now exists at this site" merely rectifies a condition the property owners themselves have created. It does not imply a public service that can be used in trade for development excesses.
Further, any project claim to fulfilling public purpose by "attracting" people to the waterfront by developing commercial "destinations" has limited legitimacy, and is not a basis for trading public land value for development value. The underlying premise of the regulations is that the water itself is the attraction. The developer is committed to public purpose and public access to the waterfront when building on these tidelands a priori, even for building strictly within the Chapter 91 constraints. Any deviations from Chapter 91 proposed as "substitutions" in the MHP should be considered only if the whole ensemble, together with the "offsets," fully complies with or exceeds the regulatory intent.
The proponents should clarify explicitly their assumptions about what public access and accommodation provisions are required, or "baseline," and which they consider eligible for consideration as "offsets" for requested "substitutions."
Setback: The 100' setback zone is a critical component of the Chapter 91 regulations, intended to devote sufficient space along the water's edge to water-dependent activity and public access. The proponents ask to re-draw the setback line to accommodate their building preferences, in a way that, on the average, produces the same measurement from building-face to seawall, and totals the same (or greater) number of unbuilt square feet. But this manipulation of the numbers results in a far inferior quality of the space left in the setback zone. Most of the water's edge is roadway, with meaningless slivers along most of the cove, which could be a very special waterside space. If anything, the development should "amplify" the requirements, and exceed the 100' minimum setback in this unique and potentially extraordinary place in the harbor, providing more than the minimum of completely accessible, usable, truly public space. As shown, the setback area quality is entirely inadequate to justify any width modifications, and even if the strip were the full 100', the use of the entire edge for road is not an acceptable interpretation of the regulations. This zone is not only to be open, but to be water-related. An alternative design should be required removing roads from this zone. An alternative should be shown without roads between buildings and water, using another method for separating and "de-privatizing" the public open space along the private building areas. The setback zone should not be compromised by manipulating the letter of the law.
Quantity of community open space: The proponents currently calculate their open space per the letter of the Chapter 91 requirements. However, most of this space on the site is, in fact, roadway, sidewalk, and other space that is technically "unbuilt space" rather than functional "open space." "Parks, Gardens, Plazas" of any size, i.e., the skating rink and tidal pool, amount to about 1.5 acres. If the proponents truly wish to create a living community, they must provide usable passive and active open space, available for various ages and interests, as defined by the Boston Parks and Recreation Department: parks, playgrounds, plazas, and squares. The DPR has a target acre/population ratio of 5.5 acres/1000 residents in the neighborhoods; the proposal falls far short.
Once the demographic model described above produces the "critical mass" numbers for building neighborhood fabric, the population numbers should be used to prescribe the amount of truly usable public open space to be included in the development, or, by pre-development agreement with other property owners, aggregated elsewhere as acceptable under Chapter 91 requirements. Criteria for open space planning should include quantified carrying capacity and water-related character.
Quality of open spaces: The Tidal Park is an interesting concept, but in the over-all context of the open space plan presents some serious problems. First and foremost, the tidal-pool area is not usable as public open space. Its carrying capacity is extremely limited; it appears, from the drawings, barely accessible and much of the time wet or flooded. Even if the Tidal Park were viable (and this is questionable) as an artificially constructed tide-pool habitat, it is inappropriate to use a major stretch of the inner harbor's water's-edge land, and the only significant water's-edge area in the project, to create an uninhabitable space.
The "Café and Gardens" to the east of Tidal Park is described as a place for a wide range of leisure activities. From the drawing, one can barely locate this "smaller-scale park," and the only apparent space is a commercial snack bar with tables and a vendor area near the "look-out point." This space is not a park by any common definition.
Evidently, the residential use of the adjacent buildings C and D prompted this design, to protect the privacy and security of unit owners. However, the creation of what is effectively a moat, precluding public gathering under the windows from which these residents will enjoy their water views, is not an acceptable solution in the context of protected public tidelands. The Tidal Park is functionally a suburban mulch berm, with inverted topography and wetter: landscaping to look at but not to be on. Since real tidal areas tend to be "messy" by landscaping criteria, this one is likely to become such a mulch mound after a few residents complain to the maintenance manager.
The skating rink is to office building F what the tidal pool is to buildings C and D. According to the aerial perspective, it is, for most of the year, a fountain on a corporate lobby forecourt, serving primarily to enhance real estate values and occupants' views. Although it does leave an open view corridor from Old Northern Avenue to the water, it is more closely connected to the building, in its design and layout, than to the public realm. If the project intends to provide a public space in Chapter 91 lands, that space should be where the law requires and common sense suggests: along the waterfront. A simple, unprogrammed piece of terra firma would be the most useful addition to the public realm; indeed, a half-acre water fountain seems redundant when the whole harbor is a few feet away. The rink/fountain functions as another visually decorative moat, to provide views while preventing gathering.
A pattern of privatization of the public realm emerges, as the proponents fill what little public space they provide, creating visual accessories and spatial buffers rather than common ground. This is typical for private developers (and their tenants and buyers), who are generally uncomfortable with the notion of uncontrolled public milling on their property. Experience shows that it is virtually impossible to force private developers and owners into the role of guardians of the public realm, regardless of easements, designs, and regulations; eventually, privatization will set in. The solution is, here as always, unencumbered, publicly owned and managed open space, carefully planned and unambiguously given by the City of Boston to its taxpayers. City planners should keep this in mind before bestowing upon any property owner enormous "substitution" development rights that drive up the value of land they may want to take for public use.
Continuity with Courthouse: One of the principles
espoused by the proponents is that the water's-edge open
space should "create a relationship to the Court House
plaza, providing for seamless continuation of the public
space." Instead, the block pattern forms a sharp corner
that creates an unwelcoming space between the two projects,
and the Tidal Park is an abrupt shift in style and pathway
that turns the public realm into a quilt of formal and
"naturalistic" patches, discrediting both as arbitrary and
out of place.
Harborwalk: The Tidal Park diverts the harborwalk and bike
trail from the water's edge for its entire length. This is
an important additional flaw in the tidepool's design.
Pedestrians end up on a narrow sidewalk along the road for
several hundred feet of this special curved sweep of
waterfront.
The proposal states that the harborwalk must be 10' wide. We understand that the requirement is 12' wide, clear of any obstacles such as trees and street furniture. However, we feel that the proponent should be generous here, and exceed the minimum requirements.
Roadways: Roads proposed along all building perimeters may be intended to provide on-street parking for casual visits to the waterfront, and create a "public" belt to "de-privatize" the water's-edge open space that might otherwise feel like the front yard for private buildings. However, vehicle access to the building faces along the water is not really required, and the roads may simply impede pedestrian access to the water. Any water's-edge access-ways should be designed to denote their transitional character; paving materials, traffic-calming devices, limited vehicular uses, and other features could allow them to accomplish their purposes without impeding pedestrian crossing and without encircling the setback zone in asphalt. The foot route from the new MBTA station, and the bicycle Harbortrail, should be shown in the plan, and be appropriately designed for these users.
Seawall: The Tidal Park seems to contradict a principle claimed by both the City and the proponent, which is to rehabilitate the historic granite seawall. This goal should be clarified.
Minor public spaces: The proponents refer to the amenity provided by small public spaces, but these in fact add little to the usable open space of the project. The "Public Square" at Building E is merely a planter in a circular driveway. The open corner at Building C provides a more open vista from the street, but is not usable space. The planted edge ("Urban Arbor") along the south cove edge is a widened sidewalk along a road. None of these qualifies as passive or active recreational space, by any definition, and nones enhance the experience of the water.
Commercialization: To avoid commercial privatization of the waterfront, the development of water-vessel access and docking facilities should not become a business opportunity in public tidelands. Transit vessels, if this is an appropriate place for them in the transportation plan, should not have their fares inflated by project fees. Public use of the water in and outside the cove should remain free or virtually so. WaterSkate Place should not be a money-making facility, as the Frog Pond in the Common has become despite its official non-profit status. Ideally, the City should have permanent control over any docking and concession facilities, and prices, if any, should be nominal. The City should look to its burgeoning tax base to support public services, and maintain control over the public realm. The proponents should be asked to describe in detail how privatization will be avoided by permanent contracts and deeds in Chapter 91 licensed areas.
Interior Spaces: During the MHP Advisory Committee meetings, there was some indication that high-amenity ground-floor interior spaces might be considered as offsets for limitations on public open space. It is true that regulations require of interior facilities of public accommodation that "the private advantages of use are not primary but merely incidental to the achievement of public purposes." But while some visitors might enjoy lobby amenities, or wish to cut through the large full-block buildings rather than going around, past experience with interior private "public spaces" teaches that these are not public, regardless of amenities, or easements, or agreements to provide all-hours access. Private doors, and private doormen, define very clearly who belongs there and who does not (with or without signage about public rights), open hours change, and there is no enforcement of access privileges once the project is built. Therefore, although Facilities of Public Accommodation are required and serve a useful purpose, they should not in any way be assumed to substitute for truly open, public spaces.
Civic site: The proponents' use a 2/3 acre site within the critical water's-edge setback zone for a cultural venue. Building J, although it may support a worthy public activity, is not a water-dependent use, and therefore does not justify its occupation of a large and significantly located stretch of water's edge land. Waterfront land is unique, it is finite, and it is protected by law for entirely unfettered public access. It is far from clear that an art museum, which could be anywhere, and which has limited open hours, various attendance constraints, and admission charges, should occupy space within the water-dependent use zone.
Moreover, the building area, counted in the proponents' setback calculations, is used to justify the significant narrowing of the rest of the setback zone, as tight as 50', and even that narrow ribbon is filled primarily with roadway. The only area wider than the required 100' is along the Tidal Park, and the extra width is, again, roadway. None of the proposed spatial configurations of the proposed setback, despite its total size, compensate for this disposition of a large corner, with much potential as a wonderful, unprogrammed, flexible, truly open space for 24-hour, no-fee, unconstrained use by all.
If the proponents want to provide space for an "attraction" that will enhance their development at least as much as it will our waterfront, they can do so on the non-water-dependent-uses building footprint. It seems that any "public benefits" trading for such use belongs in the Article 80 PDA process, as long as no trades compromise the requirements of Chapter 91.
Water sheet uses: We question the appropriateness of the acre of boardwalks, piers and docks covering the cove water sheet. These elements fill and constrain the cove, and may have impacts on the underwater ecosystem by affecting sunlight and water motion, as described in the Department of Environment comments on the MHP Request for Scope. The proponents should show alternate plans for providing useful access to the water's edge, without imposing substantial new coverage. Privatization of water uses is discussed elsewhere in this letter.
A full spectrum of water-based uses should be analyzed, for the cove and the curved edge west of it, to be sure all alternatives have been considered, and that no future needs will be precluded. The needed carrying capacity and amenities of the water-dependent uses zone should be planned from this analysis, so that the design starts from the water and moves inward. It is likely that very desirable water uses might depend on large gathering spaces along the edge. The current plan leaves no flexibility for various kinds of water-associated needs.
Microclimate: Unless Chapter 91 is used as the project standard, performance criteria for wind and shadow, related to the pedestrian experience of the public realm, should be established by the BRA, as per the Secretary's Scope for the MHP. EOEA-approved criteria should be used to evaluate the project's design impacts.
The Scope should require that any analysis of massing take into account proposed off-site projects. Wind and shadow obviously cannot be studied without context assumptions.
Studies should look at shadows at important seasonal times and hours on the ground-level public realm, especially on the waterfront open spaces and on major active and passive recreational spaces. The studies should also look at shadows on vertical building surfaces, to study impacts on day-lighting for interiors.
Urban designScale and grain: The proponents claim to accept several urban design principles relating to building and street-grid scale: "Create small footprints which provide for a fine-grained scale of development." "Develop building typologies with bases compatible to the Boston Wharf buildings and a progressive stepback of higher elements." "Build on the tradition of local building types while also ensuring a variety of styles." The Seaport Public Realm Plan speaks of bringing "the smaller, irregular block sizes and shapes of Boston into the Seaport." The Plan says, "By controlling the size of the block, the scale of any one building or development can be controlled."
It appears, however, that the planning rhetoric is inconsistent with the development proposal. The referenced historic Boston street grid is a plaid of streets and alleys, which allow for building "fronts" presenting a welcoming public face, and "backs," where utility and private functions take place. This pattern creates relatively small building footprints, with scale, fenestration and articulation that create a comfortable human scale. The proposed plan, however, is a checkerboard of elephant footprints, a series of full-block one-acre giants, with no service alleys so that major street walls are marred by garage ramps and loading docks. Photos of the Back Bay's Newbury Street as a retail model are misplaced in this proposal.
We do not seek to recreate the architecture of the 19th century, but the proponents and the BRA should observe their promises of human scale and articulation of buildings and streets, even in a contemporary architecture. Changes in technology and economics have not changed human scale -- nor negated the difference between front and rear. The proponents should overlay the street grids of Boston neighborhoods, to show how their grid compares.
Height and density: The proponents assume (and well they might, based on current City practice) that the PDA will be the mechanism by which deviation from all standards will be excused. The PDA -- "to allow for averaging of height" -- will provide the creative calculus by which buildings 300' tall can be proven to meet the 150' IPOD limit. Perhaps the BRA has found a way to fit 300' buildings under a 150' overlay, but the sun will not be fooled, and the public realm and water sheet will be heavily shadowed, PDA or not. Chapter 91 does not incorporate the principle of averaging inter- or intra-builidng height.
The MHP Scope specifies that, pursuant to 301 CMR 23.05, for substitutions governing the location of FPT's, the MHP must ensure that private uses next to the setback zone must not conflict with or discourage water-dependent activity or public use and enjoyment of the water-dependent use zone. Microclimatic and other experiential impacts on the pedestrian realm imposed by height and density should be analyzed by explicit criteria.
PDAs, per the Boston Zoning Code, must be consistent with overall plans for the city as a whole or for the general area. The proponent should be required to demonstrate conformity with the Seaport Public Realm Plan and the Boston 400 principles, now finalized, as well as an EOEA- approved MHP (or in the absence of such, the Chapter 91 regulations).
TransportationAside from Chapter 91 issues, transportation is the most important constraining factor for this and every project on this limited-access peninsula. Transportation is a subject that will be addressed competently and comprehensively by other organizations, notably the Conservation Law Foundation, and we offer here only a few brief comments.
Full build-out assumptions: All transportation analysis must be done with explicit assumptions for the full build-out by other contemplated developments, in South Boston and its origin/destination corridors, as the "no-build" condition.
Mode-split assumptions: Mode-split assumptions for this and "no-build" development must be validated by comparison with experience in other comparable areas of the city. TMA efforts to date have not adequately reduced automobile dependency in Boston, so promises of "mitigations" and TMA measures are not acceptable reassurances of traffic reduction. Only two measures are effective: curtailed parking capacity, and excellent public transit. The first is not incorporated by this proposal, and the second is not on the horizon; the proponents must either build to transit capacity limits or advocate for public improvements.
Transit availability: The project as described depends heavily on mass transit. However, the transit systems in the pipeline, the controversial Silver Line, will not, even if it is constructed as publicized (and this is widely doubted), have the capacity to transport Fan Pier users and all the others to be generated by all the planned developments it is to serve (as indicated in the draft Louis Berger transportation study for South Boston).
It is not the responsibility of individual developers to build public transit to accommodate their projects; but it is their responsibility to build only as much program as funded public transit commitments will support. A verified analysis of future transit capacity, confirmed by the agencies of jurisdiction, must be required in the Scope.
Shuttle buses: In the absence of State and City planning for a modern, efficient public transit system, this developer, like many others, is planning a private transit system of shuttle bus lines: a hotel shuttle to Logan, an employee shuttle to South Boston, and a resident/employee shuttle to downtown. This will enable the developer to opt out of the lagging MBTA system, and add to the fleets of private buses increasingly occupying our city streets. These shuttle systems constitute a privatized tier of transportation, and strip the public system of essential political constituencies. The unaffiliated masses of transit-dependent citizens are being left with a constantly shrinking public transit network. The shuttle solution to urban transportation is neither efficient nor equitable.
To help in understanding the impacts of such shuttle systems, the proponents should be required to estimate, for their proposal, the number of shuttle vehicle trips and vehicle mile traveled; projected ridership numbers indicating number of individuals expected to avail themselves of shuttles, and number of trips; and costs of shuttle transportation and how they will be paid, impacts on prices of the development's housing and services, etc. We need to use these projections to document the unmet transit demand the MBTA should accommodate. We should also understand the hidden costs to project users through increased costs of goods/services, and to taxpayers through tax-deductions of shuttle costs and extra uncompensated public infrastructure wear.
New Parking: The proponents are building a huge garage, and they must analyze traffic movement for an assumed full build-out of other projects, which will undoubtedly also build huge garages. The proponents can grandfather in another 300 spaces of their own, and Pier 4 PDA, for example, is already approved for 2,650 spaces. The proposed 2200-car Fan Pier garage is too small to hold all the vehicles that are likely to want parking, yet too large in terms of the proportion of the district's total vehicle traffic capacity its users will occupy. The net result may be tremendous pressure on subsequent developers to build garages, which will generate unsustainable traffic volumes. Given the jobs-housing balance promised here, whom is this garage meant to serve?
Existing parking: The proponents currently operate 1650 parking spaces on the site; unless these drivers will all soon occupy the new development, the proponents must be required to consider the disposition of this existing "demand."
Trip Generation: The Scope should require more detailed explanations of Trip Generation Estimates. For example, how can 450 dwelling units generate 6000 round trips per day? How do 825 hotel rooms generate 7,200 round trips per day?
Alternatives
Chapter 91 compliance:Since the current Fan Pier proposal is premised on significant substitutions and offsets varying from Chapter 91, the proponents should be required to present and analyze both the proposed plan and an alternative plan that fully complies with all Chapter 91 regulations.
If an approved MHP is available in time, an alternative complying with it should also be presented.
"Critical mass" neighborhood:The proponents should present and analyze a Chapter 91-compliant physical design that provides the "critical mass" of diverse housing necessary to create a functional neighborhood, as discussed above, in addition to a compliant design incorporating a land-use program similar to the one proposed.
Shadow criteria:In addition, because the massing of the proposed development will have significant shadow impacts on the protected waterfront areas, an alternative proposing a concept similar to the "shadow bank" used on the Boston Common, should be presented, which sets explicit criteria for times and seasons when sunshine is to be protected in the Chapter 91 setback zone and other important areas. For this alternative, the proponents should work backwards to find the building massing that will meet these criteria, just as developments affecting the common computer-build their massing by removing mass to suit the shadow constraints. Such a criteria-based alternative would be consistent with the Secretary's Scope directive.
The resulting massing should then be tested for wind impacts, for which explicit standards should be used based on pedestrian comfort. Reasonable assumptions about future construction by others that would affect wind impacts should be included for this analysis.
Public process for MHP
Public comment:The public comment period for the Request for Scope was August 10-September 9, l999, and the official public hearing for the Request for Scope was held on August 25. These were improbable dates for focusing public attention on regulatory matters; even relatively active citizens were unaware of the process at that time. The BRA-appointed Advisory Committee has held many meetings since then. The meetings have included discussions on Waterways and Municipal Harbor Plan Regulations, substitutions in the submitted Request for Scope, and presentations of proposals by developers. However, very few members of the public were able to attend these afternoon meetings. Although the official State requirements for public comment may have been met, we recommend strongly that the BRA provide further opportunity for broad community input before the draft MHP is submitted to EOEA, including a series of evening meetings as recommended in the Scope.
MHPAC meetings:Requests from MHPAC members and myself to audio-record and transcribe the meetings, which involved important regulatory issues, were refused by the BRA on the grounds that statements could then be taken "out of context" by the press and publicized inappropriately. The risks of media abuse (which are actually less using recordings than reporters' attendance notes) may be less important than the loss of information to the public regarding materials presented and member comments and questions. Minutes are provided, but they are not as complete as a recording or transcription.
It is important to note that the MHPAC has not fully discussed the Secretary's Scope, issued October 20, l999. The BRA is preparing a draft MHP, which it plans to provide to the AC in mid-January for comment. The timetables for the proposed project and the MHP finalization seem quite different, and yet the BRA and proponent seem to have linked them, perhaps assuming acceptance of both. However, in view of the significant differences between the requested Scope and the Secretary's issued Scope, we ask that the MHP process proceed with due public participation and deliberation. The proponents should adjust their submission schedule to wait for the final approved MHP, or else comply with the laws currently in effect.
Conclusion
We look to the City and the State to pursue on our behalf a project design that meets the spirit as well as the letter of the Waterways Regulations. A project must serve a proper public purpose that provides greater benefit than detriment to the rights of the public in tidelands and must be consistent with the policies of the Massachusetts Coastal Zone Management Program. Where projects are located on Commonwealth tidelands, they must promote public use and enjoyment of these tidelands to a degree that is fully commensurate with the proprietary rights of the Commonwealth. Plans must ensure that private advantages of use are not primary but merely incidental to the achievement of public purpose. No significant privatization is allowed of waterfront-dependent use area. These are the overarching principles for the effort.
We also look to the City to take responsibility for guiding the development of a diverse and authentic neighborhood, in a humanly scaled urban fabric, with a generous and truly "public" public realm. We believe that ultimately, this is the kind of development that creates the most lasting, most genuine, and most equitably shared economic, environmental, and civic value.
The proposed plan leaves considerable room for improvement toward these standards, both in land use program and in physical design. The proponents are apparently guided more by the principles of conventional real estate marketing and maximization of private property values. We encourage them to put more trust into community-building principles as a way to create value; this has worked well in Boston before, and given us an urban fabric that is a national model. We look forward to a good-faith cooperative effort by the public and private parties in resolving the outstanding issues, so that the citizens of the city and the region can soon come to enjoy the wonderful waterfront of South Boston.
The Alliance of Boston Neighborhoods thanks you for this opportunity to comment. We look forward to the BRA and MEPA response.
Sincerely,
Shirley Kressel, MLA
President
Alliance of Boston Neighborhoods