To read SAND's earlier comment letter on the Fan Pier Project Notification Form (PNF), click here.

SAND has filed the following letter with the Boston Redevelopment Authority, responding to a public comment period for a recently released Draft Municipal Harbor Plan. The BRA is preparing a final Municipal Harbor Plan for submission and approval by the Massachusetts Office of Environmental Affairs.

SAND has been attending recent meetings held at Boston City Hall regarding the Municipal Harbor Plan.


Ms. Linda Haar
The Boston Redevelopment Authority
City Hall, 9th Fl
Boston, MA 02201

Dear Linda:

Members of the Seaport Alliance for a Neighborhood Design (SAND) support many of the stated intentions of the Draft Municipal Harbor Plan - especially those which will activate the watersheet and open space, making the waterfront vibrant and accessible. We also support concepts which will enable the western portion of the South Boston waterfront to flourish as a 24/7 mixed-use neighborhood as opposed to a commercial district with office towers dominating the waterfront.

We have a number of issues regarding the Draft MHP that have not been addressed. The majority of these concerns regard inconsistancies between the South Boston Waterfront Public Realm Plan (PRP), Chapter 91, and the MHP Draft. A number of items proposed by the MHP draft, including height, density, setbacks and open space are significantly different than the language suggested by Chapter 91 and throughout the PRP - yet remain unjustified.

With the allowances for development made in the MHP, a number of the objectives put forth in the PRP are threatened. By encouraging massive development projects to move quickly, for example a three million square foot project on the 20-acres of Fan Pier, the MHP may preclude the ability for other land uses to be distributed as originally projected. As parking and traffic become apparent issues, developers may have to scramble to get approvals before conditions become intolerable.

The impact of overdevelopment, allowable as a result of the MHP, may impede other goals stated in the PRP. For example, an objective stated in the PRP is to protect the industrial port. This objective, supported by SAND, may be negatively impacted by significant traffic congestion caused by development allowances made by the MHP that would have been restricted under Chapter 91. Similarly, if office towers and commercial projects are allowed to dominate the waterfront without proper consideration of housing and other community uses, the ability of the area to emerge as an urban neighborhood is eroded. By not adequately stating how the BRA intends to address these issues, the MHP Draft does not fulfill the promise of the PRP.

Open space remains a signficant concern. We do not believe the MHP should envision the best public spaces as those owned and maintained by private property owners. Public spaces should be owned and maintained by the City and State, not construed as a right granted by one private party to another. Much of the area discussed by the MHP is private property, but publicly owned spaces should be reclaimed as a function of the MHP to offset negative impacts on the environment (i.e. air quality, traffic, noise, etc). The fact that much of this property is tideland should make this argument even stronger. A reluctance on the part of the City to afford the maintainance open space should not be stamped as policy into a document designed to protect the public trust.

Due to the accelerated timetable of the BRA, the concerns of the South Boston community may not have been registered or considered as required by the MHP charter legislation. The BRA has not held a single community meeting (typically noticed in a South Boston newspaper) regarding the MHP Draft, or the written comment period typically held subsequent to a reasonable series of community meetings. To the best of our knowledge, the BRA held a community meeting at the beginning of the MHP process last year and one meeting in February, prior to the release of the Draft, but none since. These meetings and comments should be part of the process and thoughtfully considered in the Final MHP. In our view, an open and public process made the final BRA Public Realm Plan (PRP) significantly better than its initial draft.

Lastly, we would encourage members of the BRA Municipal Harbor Plan Advisory Committee to have ample opportunity to discuss issues and comments. Additional MHP meetings should be scheduled for discussion and concensus building. Assimilating the advice of the CAC members and public comments, we encourage the BRA to more clearly align the Municipal Harbor Plan with the Public Realm Plan before submitting a final draft to the EOEA.

We will continue to weigh in as this process moves forward.

Best regards,

Steve Hollinger
on behalf of
The Seaport Alliance for a Neighborhood Design (SAND)

Your comments as a visitor to the SAND website would be appreciated and forwarded for discussion.