October 23, 2002
Richard Shaklik, Deputy Director of Zoning
Boston Redevelopment Authority
One City Hall Square
Boston, MA 02201
Re: Proposed Downtown Interim Planning Overlay District
(IPOD)
Residential Development Area (RDA)
Dear Mr. Shaklik:
The BRA is again proposing the Residential Development Area (RDA) zoning amendment for the long-unzoned Financial District IPOD. Like Planned Development Areas (PDA), RDAs would be exempted from underlying zoning, and allowed to create their own zoning through codification of their project uses and dimensions. RDAs would receive this self-zoning privilege for sites of one-half acre (which could include existing adjacent buildings by agreement with their owners), half the size of Planned Development Areas, and would be allowed to build 350' to 400' towers in 155'-height zones, in return for making half of the building housing.
We are concerned, as before, that the RDA zoning proposal is being implemented without proper public process, and without a comprehensive planning study. Despite concerns expressed earlier about these deficiencies by the public, the press, and the Boston Civic Design Commission, Boston Landmarks Commission, and Boston Zoning Commission, the BRA is proceeding to get this amendment passed with no improvement in either the public review process or the planning process. To our knowledge, the public process will consist of presentations to the Boston Civic Design Commission, Boston Landmarks Commission, Boston Redevelopment Authority, and Boston Zoning Commission. This is not an adequate public process for a proposal of this importance. A meaningful public process requires provision of detailed substantive information about the proposal and its implications, presented at one or more open, broadly noticed public meetings, with opportunity for public comment and BRA response to comments.
The ABN requests the following:
- The BRA should prepare comprehensive zoning for the
entire IPOD, rather than contriving a narrow
development-incentive provision for particular kinds of
buildings. The zoning should be based on an in-depth
planning study for the downtown in the larger city/metro
context. The planning study should include a full
build-out analysis, and an examination of the related
environmental impacts (traffic, shadows, etc.), real
estate economics (land speculation, increased housing
costs, relevance to workforce housing shortage), historic
preservation effects (incentives for demolition or
modification of small historic buildings),
neighborhood-building (availability of schools, shopping,
etc.) and urban design. Such a planning study should be
the basis for any zoning regulation, the authority for
which is given to the government to protect public
health, safety and welfare.
- The BRA should conduct an open information meeting for the public -- for all the voters, taxpayers and citizens of Boston -- with opportunity for comment and BRA response. The BRA should prepare written and graphic materials, make them available in advance and distribute copies at the meeting. These materials should describe in detail the planning goals, all the zoning proposed, and projections of the build-out and impacts.
All Boston residents have an interest in this proposal. It would set important precedents for incentive up-zoning in the city. Moreover, it would add another self-zoning category to the five already in the Boston Zoning Code (PDA, U-District, Chapter 121A, Institutional Master Plan, Special Study Area), which in total exempt a substantial portion of Boston's large-scale development from zoning control. All residents have a stake in sound planning-based zoning, which both protects the public welfare and creates a stable residential and business environment. And all residents have a stake in the future of Boston's downtown; the commercial, cultural and historic center of Boston belongs to everyone.
We look forward to your response.
Daniel Cushing, President
Shirley Kressel, Vice President
Cc:
Mark Maloney, Director, BRA
Rebecca Barnes, Chief Planner, BRA
Ellen Lipsey, Boston Landmarks Commission
David Carlson, Joan Goody, Boston Civic Design Commission
Robert Marr, c/o Jeffrey Hampton, Boston Zoning Commission
Stephanie Pollack, Conservation Law Foundation
Steve Bailey, Tom Palmer, Scott Greenberger, The Boston
Globe
Paul Restuccia, The Boston Herald