March 28, 2000
Bob Durand, Secretary
Executive Office of Environmental Affairs
Att: MEPA Office
100 Cambridge Street - 20th Floor
Boston, MA 02202
RE: EOEA #12171, Two Financial Center (Laura Rome, Analyst)
The Alliance of Boston Neighborhoods protests the Rose Associates proposal for this 205' tower on a site zoned for 80' (as-of-right) to 100' (with additional review) height. The proposal violates explicit zoning regulations intended to protect the historic fabric of our city.
The project site, a parking lot, is surrounded by a Historic District registered by the National Trust for Historic Preservation. The site was not included within the registered District because no one intended to protect the character of the parking lot (or the 1950s parking garage nearby). However, both are in the Leather District zoning district and therefore subject to Article 44. This zoning was deliberately established, with both the parking lot and parking garage included, to protect the character of the neighborhood and to prevent high-density development which would put pressure on existing small historic buildings.
Article 44, Section 44-1 of the Zoning Code states, "The goals and objectives of this Article and the Leather District Plan are to preserve the historic and architectural character of the Leather District; to promote the mixed residential, office, studio, retail, and service uses of the Leather District, and to ensure that new development is compatible with existing buildings in scale, design, and choice of building and decorative materials." The intent of the Code is clear, and the Rose tower defeats that intent.
The BRA, together with the community, set these zoning limits to avoid development pressures on historic buildings. Experience shows that large developments in historic areas, aside from destroying the historic character, create incentives for demolition (often, by neglect) of small old buildings and replacement by more lucrative towers. Further, the proponent's rationalization that the project is on an "edge" or "transition" site between the historic scale and nearby towers sets a dangerous precedent, since seven of the eight Leather District blocks are perimeter sites that could be classified as "transition sites," in a neighborhood about to be surrounded by tall buildings.
The domino effect is well understood by the BRA, and is starkly illustrated by the Pilgrim Theater, which was demolished in l996 and replaced by a parking lot, and whose site is now the nucleus of site assembly for a new tower which will destroy most of the remaining buildings in the historic Liberty Tree block.
The developer's strategy for evading the zoning seems to
have changed from filing as a Planned Development Area (for
which the site did not qualify, despite the paper
gerrymandering) to requesting a Chapter 121A agreement. For
this purpose, the owner proposes to declare the site's
surface parking lot (a lucrative, low-tax land-bank on a
prime redevelopment parcel) a "blighted, decadent and
substandard" area . The owner, having kept the site an
unsightly parking lot for 30 years, now asks for public
indulgence to violate the law as a reward. With the 121A,
the developer would receive the additional reward of a tax
abatement. The City/BRA is abetting this destructive
strategy, and reinforcing several very
dangerous incentives to future developers.
We ask for State assistance in preserving Boston's historic heritage, which will otherwise fall prey to private developers supported by the BRA and its narrowly defined economic agenda.
Sincerely,
Shirley Kressel,
President, ABN
cc: Mayor Thomas Menino, City of Boston
Mark Maloney, Direct, Boston Redevelopment Authority
Linda Haar, Director, Planning and Zoning, BRA
Lawrence Rosenblum, Leather District Neighborhood
Association
Joan Goody, Boston Civic Design Commission
Judy McDonough, Elaine Finbury, National Trust for Historic
Preservation
Albert Rex, Boston Preservation Alliance
Richard Kindleberger, The Boston Globe
Laura Siegel, The Boston Phoenix