December 30, 2002
Rebecca Barnes, Chief Planner
BRA
Boston City Hall
Boston 02201
Re: LMA Interim Guidelines
Dear Ms. Barnes:
I am submitting the following comments based on the BRA's public presentation of the Draft Interim Guidelines on December 16 at Harvard Medical School. As several speakers mentioned, there was a serious disconnect between the distributed material and the presentation, specifically regarding the mechanisms that would leverage funds for the City and also act as incentives for projects desiring additional height. The public review process has been unnecessarily compromised because the written material accompanying the presentation did not include descriptions of the "bonus point system" or the color coded diagram of the parcels nominated for "bonus height," certain to be one of the areas of greatest concern. The handouts should have described exactly what was being proposed.
The city's goal of managing growth in the LMA must be connected to wider metropolitan area planning efforts. The opportunity exists for Boston to be a regional leader because of the economic value of the medical and educational institutions in the LMA. The future LMA Master Plan should reference both city and regional plans, for example, the Metropolitan Planning Organization's 5-year. Transportation Plan, the city's own ACCESSBOSTON plan and the Boston Parks Department's 5-year. Open Space Plan. Master plans for individual neighborhoods and districts are deficient and parochial if they are not connected to an overall citywide plan for managing growth. Air quality standards are an example that involves City, State and Federal guidelines.
The first statement in the Urban Design paragraph severely limits the purview of the guidelines with the phrase, "to enhance and protect physical assets of the LMA." Haven't we already agreed on the regional impacts of the LMA? Landmarks and important view corridors are located both within and out of the LMA district. Obviously the adjacent communities (including Roxbury and Brookline as well as Mission Hill and the Fenway) are affected by the development in the Longwood area.
Balancing between the common interest of the adjacent neighborhoods and the internal needs of the institutions has always been difficult and is exponentially more complicated because new development is being proposed that is not institutional; but in fact is speculative and not subject to institutional zoning; (Merck Pharmaceutical, for example, or the proposed Joslin residential tower). This change, including partnerships between real estate developers and institutions, is not acknowledged in the BRA's Interim Guidelines because the statements only refer to "institutional projects".
This is an example of the reactive, project-driven planning mode that the City is engaged in; for example, air quality standards should be applied to all development, not just the institutional campuses. Providing employee parking anywhere in the LMA should be restricted. If the Air Pollution Control Commission mandates a maximum of .4 parking spaces per 1000 sq ft in the downtown area then why is the LMA exempt? Environmental concerns should be the basis for the interim guidelines and those concerns clearly don't have boundaries.
Workforce development is obviously a mayoral priority, and the BRA's Office of Jobs and Community Services should certainly be involved with the Longwood area. However, once again only institutions are mentioned. If the medical industry R&D employment is not involved city residents will lose out.
What was not clear from the Dec. 16 presentation was the relationship between financial contributions and the "bonus point system." Will the funds "mitigate" the pollution from the idling vehicles that line up waiting to enter the parking garages? In other words: what does the developer earn with their contributions? Is this negotiation process "the limit on growth" that the guidelines refer to?
On Dec. 16, a diagram was shown of the parcels where additional height, according to the BRA, could be allowed if an institution achieved certain goals that the city agency agreed to. These goals would be negotiated during the review process. There would be points awarded if housing was included in the proposed project: a "residential bonus" that would then allow projects to be taller and would specifically encourage high rise residential development. And if an institution develops property in other neighborhoods, then apparently additional bonus points will be earned, potentially counting toward an increase in allowable height on LMA parcels. These types of trade-offs are extremely disturbing and antagonistic to community based planning. Potentially neighborhoods will be divided against one another and the residents who are directly impacted by the specific parcels will be voiceless. The diagram showed potential areas for development up to 300 ft in height on the block of Huntington Avenue between Longwood Avenue and Francis Street and on portions of both Francis and Fenwood in addition to the corner of Brookline Ave. and Longwood. These parcels directly abut residential neighbors; 300 ft can hardly be labeled a "buffer zone."
Granting bonus zones for height on the very parcels where smaller historic buildings currently exist is not just an incentive but an actual mandate for demolition. In contrast, preservation and renewal (re-use) of historic buildings affirms the continuity and evolution of urban society. The cornerstone of "green construction" is to build as a last resort. The BRA as a responsible planning agency must be an advocate not for reckless demolition but for re-use and stewardship of the older buildings in the LMA.
New development should enhance the existing Fenway and Mission Hill residential areas as well as the commercial, open space, recreation and other facilities which support the existing quality of life and attractiveness of those communities. These guidelines are a flawed response to the crisis in "over-development" in the LMA and are inherently reactive.
I look forward to the BRA's response to my comments.
Sincerely,
Alison Pultinas