December 12, 2000
Bob Durand, Secretary
Executive Office of Environmental Affairs
Richard Mertens
Boston Redevelopment Authority
To the reviewers:
The Alliance of Boston Neighborhoods is an association of neighborhood civic organizations, concerned with planning and development issues of citywide importance, and with meaningful public process.We have the following comments on this project.
REGULATION
Zoning:
The City of Boston has a voluminous and detailed zoning
ordinance.However, the agency that establishes the zoning
law, the BRA, is a developer. The BRA is the City's zoning
staff, Urban Renewal agency, Economic Development agency
and in this case, the property owner. There is an inherent
conflict of interest as the Boston Globe has pointed out in
several editorials (4/6,4/15,4/20/99). It is not realistic
to expect that the BRA can objectively perform scoping and
permitting for its own project. This site was zoned only a
decade ago as an Economic Development Area with a maximum
PDA building height of 400'. The proposed tower of 700'+
(the true total height is not specified) almost doubles
that height. The desirability of density at a transit hub
was presumably considered when the zoning was done; this
doubling simply reflects market opportunism by the
proponent, and by the BRA as landlord and development
advocate.The FEIR should be required to examine an "as of
right" zoning alternative.
Chapter 91:
Chapter 91 would reduce the height considerably, even lower
than the BRA's zoning. However, this project was exempted
from Chapter 91 through a last-minute attachment to the
transportation bond bill passed by the state legislature in
August of this year. The collaboration of the City and the
State in legislatively exempting individual projects from
Commonwealth tidelands regulations sets an unfortunate
precedent for overriding State laws that protect public
interests. Changes in Chapter 91 limits should have been
the subject of a Municipal Harbor Plan process, where
"substitutions" must be justified as means to protect
public rights, and "offsets" required for mitigation.
FAA:
The FAA has expressed concern with the proposed tower
height in terms of flight safety. The proponents must show
how this issue will be resolved. The FEIR should examine an
alternative that would be built in full compliance with FAA
regulations. There must be no rerouting of planes over
residential areas due to hazardous conditions that this
tower would create.
Boston Civic Design Commission:
The Boston Civic Design Commission declares in its PNF/NPC
comment letter that this project remedies a "blighted
condition. "We are concerned with the invocation of the
"blight" description; the site can hardly be considered
blighted by the legal definition, which involves the
inhibition of healthy growth and development in the area.
We ask what is the basis and purpose of this declaration,
which is not explained by any substantiated findings.
INTERMODAL CONNECTIONS AND ENHANCEMENT OF TRANSIT ACCESSIBILITY AND UTILITY
In 1998, DEP reviewer Gregory A. Carrafiello, in his comments on the Notice of Project Change and the criteria for granting variances from 310 CMR, stated: "A demonstration of an overriding public interest must be based in the project to be constructed rather than on underlying or subsidiary project component.While the existing South Station site is dominated by public transportation, often seen as a qualifying overriding public interest, the proposed air rights project does not share that interest."
Water Transit:
Under Chapter 91, significant water related public benefits
would be called for. There is very little detail provided
in the South Station Air Rights DEIR about intermodal
transportation from the point of view of South Station
connections to water transit, which is a significant
omission. With the increasing daily volume of commuters who
pass through the bus and rail terminals and the Red Line
subway, clean, nonpolluting transit connections to other
parts of the city are critically important.
According to the BRA's Municipal Harbor Plan released in July 2000, the CA/T project mitigation commitments include the requirement to build a new water transportation facility in the Fort Point Channel (section 6.4). "This facility originally was sited at the Russia Wharf, but was relocated to the Boston Edison (BECO) site due to issues related to construction of the Silver Line/Transitway Tunnel and relocation of the M.V. Chelsea.Design of the terminal has not been finalized, and the location may change again. "The new terminal is labeled South Station/Russia Wharf in the MHP's Table 5.1, leading one to suspect that it might be located within a walkable distance of the train station. Is the MHP overly optimistic? In the South Station Air Rights DEIR the site location, project vicinity and study area maps offer no information about this new water terminal, labeling neither Russia Wharf nor the BECO site.A year ago, the BRA released their Boston Inner Harbor Passenger Water Transportation Plan, which concluded, "intermodal passenger connections need to be re-established for the inner harbor ferry network." What is the pedestrian route to the new terminal? The DEIR offers no clues. According to the Public Realm Plan for the South Boston Waterfront, "Basin D" between the Summer St. Bridge and the Dorchester Avenue Bridge is suitable for water transportation but only under "no wake conditions." Does that absolutely preclude a ferry facility? (A boathouse is being suggested for the Wormwood St. area.)
If the USPS site were redeveloped, which is now a likely possibility, Dorchester Avenue would appear be the best location for a new terminal, which would truly make South Station intermodal. The relocation of the Postal Service from the adjacent site opens new possibilities for large scale planning that could maximize public interests.The lack of coordination between the Federal government, the MBTA and the BRA puts the public at a significant disadvantage and potentially limits the most ideal intermodal connections.
Rail Expansion:
South Station's potential as a rail hub must be realized in
order to alleviate air-flight congestion as well as
regional and local roadway congestion. The impact of the
project on South Station's rail capacity for several
purposes must be very clearly understood before it goes
forward; the need for future additional tracks is very
real. This is an important time for the high speed Acela
system.
The use of shuttle trains for visitors to the South Boston Convention Center and the hotels of the Back Bay has been discussed in accessBoston and other community meetings with the City. Shuttle trains could alleviate potential traffic problems. In addition, this project very clearly must not preclude or compromise the North-South Rail Link.
Just as every opportunity for track expansion must be respected by the project, the TUDC development should not affect the customer base.Four years of construction will be disruptive and could discourage new riders from using the Acela train just as it begins its service. As to the public benefit of concourse improvements, South Station is already a "great space. The public amenities mentioned in the DEIR (ticket counters, restrooms, food courts, and connection from Atlantic to Summer) already successfully exist. The train platforms will lose both their access to fresh air and to natural light after the tower is constructed.The FEIR should discuss in detail the ventilation plan that will keep the platform air clean. Passengers at Back Bay Station are familiar with the pollution that seeps even into the upper lobby.Environmental health concerns should be fully addressed in the MEPA review. The train platform area should be designed as a high-quality extension of the "great space."
Bus Terminal:
The South Station air rights are jointly owned by public
entities, the BRA and the MBTA. Although the earlier phases
of South Station improvements were undertaken by the
agencies themselves; this phase is a private development
project. The Hines Co. bears the burden of proving the
public benefit of a high rise office tower, parking garage
and hotel over the tracks when the transit infrastructure
improvements were never completed, e.g., the MBTA's design
for a "moving sidewalk" between the head house and the bus
terminal.Will the private developers provide the public
services/spaces that should be built by the government
agencies? The DEIR is vague on this point; "there will be
provisions for the expansion of the bus terminal" but it is
not actually being expanded at this time; "there will be
room for additional tracks," but they are not part of this
project.Instead of a moving sidewalk there will be an
interior arcade/hallway between the head house and the bus
terminal accessed from a 37'-tall escalator inside South
Station. The environmental review of this project must be
mindful of any negative impacts to the public nature and
use of the entire South Station site and to the Intermodal
Transportation Center (the bus terminal's official name).
Is it in fact too late to discuss what is the best plan for
expanding the bus terminal? For this project to get
approved it must unequivocally improve intermodal
connections.
Bus passengers can not be an afterthought in what has become a private development on public property. When the new bus terminal was completed in 1995, Robert Campbell, the Boston Globe critic lavishly praised the domed skylight, more than 50' in diameter, at the top of the central rotunda. What does the TUDC project do to this light?
The MBTA never finished phase 2 of their South Station improvements.The bus terminal was supposed to be bigger; original plans were for 36 docks not 25.According to an executive with Peter Pan Bus Lines quoted in a Boston Globe story, (1/18/00), "there's a bus heading to NYC every 15 minutes; that's unheard of in any other place in America." The volume of bus passengers now exceeds 12,000 a day. Will access to the elevator at the existing parking garage (level 5) that serves both the baggage and package deliveries counter and drop-off/pickup parking for bus customers be compromised with this project? Key characteristics of a great bus/train station include adequate and well-defined taxi waiting areas and drop off/pick up zones. With this project what happens to the existing spaces on Atlantic Avenue; will there be a reduction in number?
PEDESTRIAN CONNECTIONS
Currently there is an at-grade access to the USPS building from the train platforms.Apparently that vanishes with this project and the new plan for access to Dorchester Avenue is for elevator or escalator rides up to the skystreet, elevation 102', in order to cross over the train platforms. The City's Public Realm Plan for the South Boston Waterfront included a new pedestrian bridge spanning the Channel from Dorchester Avenue to the Wormwood Street/Fort Point Historic District. How will pedestrians from Atlantic Avenue access this bridge?This is potentially an important connecting route between the new Convention Center and South Station, a connection which would facilitate conventioneers' use of the South Station-Back Bay shuttle train and reduce shuttle bus and automobile use.
Instead of the promised moving sidewalk connecting the bus and train facilities, (Boston Globe, Aug.9, 2000, "Audit identifies $20M in cost overruns at South Station complex") the TUDC plan gives the public a walkway of unknown length under the tower, hotel and garage complex. Primary consideration should be for bus or rail passengers arriving with luggage, strollers etc. How easily can they move from one mode to another? Elevators and escalators are options but as MBTA passengers know - machines can and do break down (it took over 40 days last spring to fix the elevators at the bus terminal). The Atlantic Avenue sidewalk is critically important and should be a viable option for pedestrians. Walking across garage entry and exit curb cuts is not safe and shouldn't be allowed at this location. In this very busy pedestrian realm, thousands of people are walking from the South Station area into the financial district and Chinatown at peak hours, and pedestrian/vehicular conflicts must be minimized. Existing conditions at South Station are not depicted accurately in the DEIR. Today there are 3 options for walking between the bus terminal and the head house; the actual sidewalk, the plywood walkway and along platform 1. Several options are necessary because of the pedestrian volumes.
Intermodal connections should be visually accessible and not contrived.In other words, it should not be necessary to go up and then down or north to get south. People are not vehicles that can be ramped and looped back and forth. Human scale is important, as well as orientation to the natural world. Train passengers destined for the bus terminal shouldn't have to walk hundreds of feet in the opposite direction.
The skystreet and hotel lobby are at 102', the office lobby is at 61', the walkway to the buses is at 37'- an arrangement with a segregated feeling. Ideally, all pedestrians should have the maximum number of choices -- and equal choices in terms of amenity and convenience. Ideally also, the pedestrian realm is in the public ways of the city, and not in internalized privately maintained complexes.
PARKING GARAGE and TRAFFIC IMPACTS
The project is promoted as a transit-oriented development; however the 1,150 car garage contradicts that claim. With 1,250,000 square feet of office, this is a parking ratio of .92 spaces per 1,000 SF (hotel and R&D need very few of these "shared" spaces"). BTD recommends a ratio of .4 for downtown; this is the center of the transit hub, and should have even less. An alternative plan at the legally zoned height should be presented, with a .4/1000 SF garage calculated for a 400' tower, to compare the impacts ofa building that complies with the BRA's own zoning. The garage also takes up 500,000 SF of the development space; the alternative plan should show how much lower the tower can be with the elimination of much of this parking as the tower is reduced in square footage.
Proponents should include in their traffic impact analysis:
- the number of vehicle miles traveled (VMT) that the proposed parking will generate, based on expected origins of vehicle trips, and
- the congestion and air pollution impacts in all anticipated origin/destination corridors.
It is not enough to study the intersections and pollution impacts only in the immediate development area for a project that will draw traffic from a wide metropolitan catchment area. Estimating VMT conservatively, if the projection of 6,000 vehicle trips per day is accurate, estimating an average 50-mile round trip, once a day, on only the 260 week-day work days, 78 million additional vehicle miles will be traveled annually to and from this project on a limited number of approach corridors, with enormous regional impacts which should be of concern to MEPA, even if the BRA disclaims jurisdiction.
Allowing this garage in the most transit-concentrated spot in Boston is a vote of no-confidence in the MBTA, and will further postpone the inevitable necessary capital re-investment in transit infrastructure, which is at or beyond capacity. As MBTA planning staff constantly emphasize, there is no point in providing T-pass subsidies to employees when there is no capacity available for users. Office workers who want to drive will not be persuaded to leave their cars for shabby, infrequent, unreliable, and over-loaded transit vehicles, in a system neglected as the mode of last resort.The proponents are planning on the Transitway (Silver Line) and other transit lines that will not meet the total demand projected for them, and rather than looking for more parking in the area, the proponents should make it clear to the State and the City that economic development in Boston will very soon be stifled by the lack of high-quality, state-of-the-art public transit. Obviously, this transit-oriented project must not itself reduce the opportunities for public transit improvements.
The 1998, BRA comment letter on the NPR praises the project for "removing traffic from surface streets"; how is that possible when the parking garage will have entrances and exits on Atlantic Avenue? In 1998, BT requested that the existing commercial parking facility for 250 spaces be fully described (page VIII 2-7); this would include occupation of spaces by facility, user type, turnover rate, rates charged, description of valet operations, car pool spaces etc.
The DEIR fails to answer any of these questions. Instead, the project only refers to the eventual replacement of these 250 spaces which would be in addition to the 1, 150 spaces requested with this proposal.There is no mention of the stackers currently in use at the site or how many spaces are allocated for the USPS, Equity Office Properties etc. The new garage that will be constructed will violate the City's Downtown Parking Freeze because it is impossible to distinguish between "the general public" and customers and visitors to a public facility, i.e. South Station. The FEIR should describe how the number of parking spaces needed was determined, particularly since all previous air rights plans (goingback almost 30 years) have included very similar size garages. Recent transit improvements; commuter rail expansion, the Red Line extension, new intercity bus service, water transportation, and more enlightened notions of city planning evidently have made no impact on the developers' intentions for a large parking facility.
There is no mention in the DEIR of the 1 Lincoln Tower currently under construction 2-3 blocks away. The 920-car garage that was permitted for that project includes 265 commercial spaces (non- employee). The parking survey, Table VI 2-1, should have counted these spaces.
The existing SSTC ramps from Kneeland St. were built for the commercial bus carriers. Will adding in the vehicle traffic for the new garage compromise their operations?The DEIR fails to address this.
PUBLIC REALM
Shadow Impacts:
Shadows on public open space seriously detract from its
value.The public space of Dewey Square, a focal point of
the new Central Artery surface restoration, will experience
increased mid-day shadow. There is no specific analysis of
the shadow impacts on the planned new Cabot Cove Park at
Dorchester Avenue. The DEIR shadow studies were done
"during the time periods chosen," but none were done for
6:00 pm, spring, summer and fall, important impact times.
(The 1 Lincoln Tower development was asked by the City's
Environment Dept. to analyze shadows for the 6:00 pm time
period.) These impacts should be shown.
HISTORIC RESOURCES:
The most important impact on historic resources is the placement of a 700+ tower into the center of the South Station head house, dwarfing it and essentially redefining the building as a decorative base-course for the second-highest tower in New England.This visual impact cannot be measured, as a shadow impact can, but it must be judged. The Mayorally appointed Boston Landmarks Commission has expressed approval of this tower, in the belief that "the proposed project may be recognized as a Boston Landmark in the future. "This sets a precedent for anticipatory landmarking that every tower developer would use as an argument, and indeed would encourage ever higher towers to assure unique claim to such advance historic status. As the Boston Globe has said, density near South Station is good, but must it be right on top?
The impact of siting this tower in the center of the South Station head house must be analyzed from multiple viewpoints. The large escalators and the additional support columns necessary for the excessive height of the tower should not be glossed over; there will be impacts on the waiting area and the platforms. The opportunity for planning a high quality transportation center that maximizes intermodal connections should be the focus of development at South Station. Projects over the air rights of the tracks should only be permitted if the public realm is enhanced and not diminished.
COORDINATION WITH POST OFFICE DEVELOPMENT:
The relocation of the Postal Service from the adjacent site opens new possibilities for large-scale master planning. The project should be reconsidered in this larger context to maximize public interests and optimize private development. Since the BRA is also the City's planning agency, the same conflict of interest may prevent such reconsideration. We look to the State to restrain development aimed at short-term financial gains over long-term regional benefits.
HOUSING IMPACTS:
BRA Director Mark Maloney has announced a public policy aimed at increasing housing in Boston to alleviate a critical shortage. Indeed, the city has gained 113,000 jobs in the last decade, and only about 3300 housing units.It is imperative that the City promote a jobs/housing balance. Director Maloney stated at a recent meeting of Move Massachusetts that when a proponent comes forth with an economic development proposal, he asks, "Where is the housing?" We ask the same question of this proponent, the BRA.
ALTERNATIVES:
If the project review is to move forward, at least three alternatives should be evaluated, meeting:
- Current zoning limits
- Chapter 91 limits
- FAA height limits
However, our recommendation is to step back and reconsider on a much broader basis, as follows.
AREA-WIDE CAC:
This project needs to be reconsidered, with
participation by all stakeholders. A Civic Advisory
Committee, working with representatives of the community
(neighboring and beyond), Amtrak, the Postal Service, MBTA,
the North-South Rail Link CAC, Massachusetts Convention
Center Authority, etc., should be convened to review a
coordinated plan for the area from Atlantic Avenue to the
Convention Center. A hasty decision that overlooks
significant changes in recent conditions will result in
critically important lost opportunities for transportation
and development that will affect the city for
generations.
We ask that the current review process be suspended, so that a more comprehensive review of this critically important site can be taken by all stakeholders, and a variety of alternatives can be evaluated. Thank you for considering our comments.
Sincerely,
Shirley Kressel
Alison Pultinas
Alliance of Boston Neighborhoods
Cc: Andrea Damato, Boston Transportation Department
Maura Zlody, Boston Environment Department
Bennett Heart, Conservation Law Foundation
Vivien Li, Boston Harbor Association
Albert Rex, Boston Preservation Alliance