January 15, 2002
Bob Durand, Secretary
Executive Office of Environmental Affairs
MEPA Analyst: William Gage
251 Causeway Street, Suite 900
Boston MA 02114
FAX (617) 626-1181
Via e-mail
Re: The Residences at Kensington Place #12657
Dear Mr. Gage:
The Kensington project triggers MEPA review for resource impacts and land transfer. We submit the following comments on these issues.
Historic resource impacts:
The project is in the Midtown Cultural District of Boston, an area rich in both architectural and cultural historic legacies. This project threatens both. It would not only demolish the Gaiety/Publix Theater, itself a Category IV building, but would accelerate the speculative demolition of small historic buildings that is, as the BRA has itself often said, promoted by development grossly beyond zoning limits. This demolition would deprive Boston's cultural heart of yet another mid-sized theater, of which there is a recognized shortage. This is the officially zoned Midtown Cultural District; to demolish a theater to build an "enlivening" residential tower is counterproductive, and perverse, and does not conform with the City's "general plan for the city as a whole," or the patchwork of zoning and district plans that passes in Boston as such. I urge you to require a careful and contextual analysis of this project's historic impacts, both physical and economic.
The MEPA office should be aware that the City of Boston is embarking on a systematic up-zoning of a huge portion of the downtown, called the "Financial District Special Study Area." The Kensington project is a forerunner of this re-scaling of the historic core of the city, together with the Liberty Place tower proposed immediately across the street on the site of the historic Pilgrim Theater, which was demolished in l997 and left in speculation as a parking lot. Boston's historic landscape is about to undergo wholesale transformation, and I request your help in examining a project illustrative of a trend that can is likely to result in a forest of towers dotted with a few isolated landmarks.
Land transfer:
The BRA will, according to the Project Notification Form, be making Urban Renewal Plan modifications, including changes in acquisition status of land parcels for disposition. In the past, the BRA has made a total of about 280 modifications to Urban Renewal Plans, all of which are by law required to be submitted to the State Department of Housing and Community Development for review. The BRA has submitted only four for such review. This means that we, the citizens, have been deprived of State oversight of the Urban Renewal Program in Boston. Further, because DHCD has the power to determine which proposed modifications are "major" and therefore subject also to City Council review, we have been deprived of Council oversight as well. Indeed, with 280 changes to 13 UR Plans over 40 years, it is possible that the original purposes of these Plans, created in very different economic and political times, have been changed beyond the mission and mandate of the Redevelopment Authority. Since the extraordinary Chapter 121A and 121B powers of the BRA rely specifically on these Plans, the almost total absence of oversight by either State or City Council has left the BRA to operate as an unaccountable body, implementing urban renewal, dealing in real estate, and, uniquely in Boston, occupying the position of the city planning agency. It is essential that State agencies coordinate their review process to assure comprehensive project oversight.
We urge you to condition any BRA land transfer on the proper submittal, review and approval of this project's Urban Renewal Plan modifications by the State DCHD. Thank you for your attention our comments.
Daniel Cushing, President
Shirley Kressel, Vice President
Alliance of Boston Neighborhoods