The following comment letter was submitted to the Boston Redevelopment Authority by Mayor Menino's appointed Midway Impact Advisory Group (IAG) in response to Beacon Capital Partner's proposed Midway project. The Impact Advisory Group's role is to evaluate and advise the Boston Redevelopment Authority on the Midway project.

Eight of nine IAG members drafted and signed the comment letter. The ninth member, representing Gillette Corporation, will be submitting comments under separate cover.

SAND member Jon Seward has a seat on the Midway IAG, nominated for the seat by State Representative Jack Hart.

Mark Maloney, Director
Boston Redevelopment Authority

From: Midway Impact Advisory Group (Midway IAG)

Re: Midway PNF Public Comments

The Midway IAG has the responsibility, as well as the opportunity, to advise the BRA on community impact mitigation once the BRA has accepted a project proposal. The IAG process is not intended to replace the community input necessary in the shaping of a project. It is particularly important that a proposed project of the size and scope of Midway have a design and function that relates well to the existing neighborhood which has established the area as a viable community. In the case of Midway, we feel that it is critical that the project relates well to both the traditional South Boston residential and business community and the Fort Point Channel artist and small business community.

Although it may not be within the described scope of the Impact Advisory Group (IAG) process, the undersigned members of the Midway IAG feel compelled to submit the following comments to the BRA in response to the Midway PNF published on January 24, 2001. After attending several public meetings and listening to the issues and concerns of the various constituents the IAG members represent, we urge the BRA to consider the following points in your response to the Midway Proposal represented by the Midway PNF dated January 24, 2001.

The issues outlined below are in the order in which they appear in the Midway PNF, and not in order of priority. In fact, each of the issues noted below has equal import and should be implemented as a whole in order to make this proposed project acceptable. As you will note, we have incorporated suggestions for areas of mitigation where appropriate to help shape this project more in accordance to its location within the existing neighborhoods of South Boston. It is our understanding that the Midway IAG will have the opportunity to more fully address the issue of mitigation once an "acceptable " development proposal has been established by the BRA.

Note on IAG Process

There exists considerable confusion regarding the role and purpose of the IAG in the approval process. This confusion is present among the members of the Midway IAG as well as the general community and is of great concern. It has been our experience that conflicting and contradictory messages and instructions have been given to us from various staff and administration within the BRA. Firstly, we understand that the IAG concept is a "work in progress", but we believe that to be credible, a clear and consistent process be established and communicated both to the IAG members and to the general community. Secondly, it must be made clear to the developers involved in the IAG process and to the general community that the IAG process is not to replace the traditional public process required of any effort to obtain zoning relief. Developers must be encouraged to appear before neighborhood and community groups to make the case for their project and to must be demonstratively responsive to the issues raised in these meeting. Such meetings can and should be in addition to the formal "scoping sessions" required by the Article 80 process. The BRA should hold developers accountable for responding to community concerns voiced in such meetings.


Development of 1.7 million square feet of space on a 6.8 acre (296,208+/- sq. ft.) site is excessive, given the location of the site at the immediate edge of the South Boston residential community. In addition, the site offers access/egress only on one side (A Street), concentrating the traffic impact (pedestrian and vehicular) onto one city street that is already overburdened.

Massing & Height

Building Rehabilitation - We commend the developer for proposing to rehabilitate and preserve the character of eleven (11) of the existing buildings on the site.

Infill Construction - The BRA should insist that any infill construction be consistent and complimentary with the existing structures, particularly regarding its massing.

Height - The proposal to construct a 150 foot building on A Street and a 250-300 foot office tower on New Street is excessive. Both of these buildings are located on the south end of the site, closest to the residential neighborhood of South Boston. The IPOD for this area allows a height not to exceed 80 feet. Additionally, the Public Realm Plan discussed height limits "south of Summer Street" to be restricted to a maximum of 150 feet. We see no compelling reason to violate these principles. We propose two principles with respect to the height issue:

1. Any infill or new construction on A Street shall be limited to the heights of the existing buildings along A Street, generally 70 -80 feet. This restriction would emphasize the character of the original buildings and enhance the project's identity.

2. The heights of any infill or new construction on the New Street side of the project shall be limited to a height not to exceed 150 feet. However, the developer should be required to make a compelling case for any building higher than 80 feet.

Massing-Open Space ­ The proposed project offers little genuine open space. Nonetheless, open space remains a critical component of any urban project of this scale. We understand that much of this site consists of existing buildings that will be rehabilitated. We, therefore, believe that some relief should be granted from the 50% open space requirement proposed by the Large Project Review process.

Although Midway Street is depicted as primarily pedestrian, it will also function as vehicle and truck access to the surround buildings, limiting its use as open space. Additionally, Midway Street is interior to the project, there is no open space proposed that might open the project to A Street. The result is a very "inward facing" project. We urge the BRA to require that at least one of the vacant lots proposed for infill construction along A Street be designated as open space, designed to invite the public to enter the site from A Street and lending a more open feeling to Midway Street. This space could be bordered with retail space, further enlivening the street and inviting pedestrians into the site.

On-Site Parking

The proposed total of 1,200 parking spaces on-site is considered excessive. No amount of mitigation can offset the volume of vehicular traffic generated by such a parking scheme. The developer states that the site is currently assigned 400 spaces under the South Boston Parking Freeze. However, current daily usage is well under that amount, so that even a project which would activate all 400 spaces represents increased vehicular traffic on an already overburdened A Street and surrounding intersections. The suggestion that the vehicular traffic generated by an additional 800 parking spaces on the site can be accommodated on the site cannot be accepted. In reviewing the project, the BRA needs to acknowledge that any additional vehicular traffic generated by this project will exacerbate already overburdened traffic infrastructure.

In light of this, we advise the BRA, and the developer, to dramatically reduce the number of proposed parking spaces allowed on the site. The BRA should also require that any on-site parking, other than on-street, be constructed underground.

We recognize that available on-site parking spaces are important to the viability of a commercial project, that project scale and available parking are directly related. The BRA should use this direct relationship between project scale and available parking to both reduce the vehicular impact of the project while at the same time reducing the scale of the overall project. The developer has no incentive to build commercial space that cannot be leased due to the unavailability of on-site parking.

Off-Site Parking

This project will have a pronounced impact on the parking situation in the neighboring residential areas of South Boston. Because of the nature of the streetscapes, most South Boston residents do not have the luxury of off-street parking, relying mainly on street parking. Daily workers to the site will seek free parking along the residential streets in the surrounding blocks. This will force the neighborhoods to seek relief through a resident parking program, a program strongly resisted by the community. The developer should be directed to address mitigation for this impact.


Project Phasing

Phasing of the project approval process is not acceptable. The community must know the character and impacts of the entire project before any approvals are given. Phasing of the construction process would be a decision left to the developer in consultation with the BRA and the project's neighbors.

Mix of Uses

We encourage the BRA to work with the developer on the mix of uses to spread the impact of traffic throughout the course of the day and to activate the site as a genuine 24 hour/7 day a week community.

Housing Component

The guideline for residential development outlined in the City of Boston's Municipal Harbor Plan and in Mayor Menino's directive on South Boston Waterfront development should be followed by this project. The BRA should require that one-third (33%) of the project be dedicated to residential use. The Midway PNF recognized this obligation (although they consider 30% as the criterion) but then seeks to circumvent it by including the Fort Point Place Project within this ratio. Fort Point Place, located on Wormwood Street, is an entirely separate project that has been separately permitted and completed. The BRA should reject this position outright and insist that no less than 33% of the Midway Project are developed for residential use.

At the same time, we recognize the differing housing needs of the two neighborhoods of the South Boston community most directly impacted by this development. In this spirit, the BRA should insist that no less than 50% of the residential component of the Midway Project be built on-site, with the preponderance of this space to be artist's live/work in character and function. The remaining residential requirement not built on-site would be developed off-site within South Boston, in character and function acceptable to that neighborhood. A significant percentage of such housing, both on- and off-site, should be affordable.

This requirement will bring the Midway Project into compliance with the Public Realm Plan, bring the on-site residential component to a level sufficient to activate the site as a 24-hour community, and provide a contribution to the housing needs of the two impacted neighborhoods of South Boston.


Parking - As noted earlier, the development of 1,200 parking spaces on-site is excessive and will impose an insurmountable burden to the existing traffic infrastructure. The BRA should require a dramatic reduction in allowable on-site parking.

Traffic Study - The study submitted with the Midway PNF is simply inadequate. The BRA should require that a traffic impact study be performed for the entire project, including quantified documentation of specific improvements, prior to any project approval. The BRA should not accept any study of a proposed Phase I and should not consider phasing the approval process. A traffic impact study of the entire project should include, but not be limited to, the following elements:

1. Study area - The study should extend the study area to include all intersections to the south bounded by Dorchester Ave at West Broadway, D Street and Dorchester Ave, D Street at West 1st Street. The intersection at both ends of the Broadway Bridge and the 4th Street Bridge should also be included. The study should also extend north to include the intersections along Summer St., Congress St. and New Northern Ave as far eastward as D Street, as well as the access ramps to the Ted Williams Tunnel and the I-90 extension.

2. South Boston Traffic Study - The Midway study should incorporate the conclusions of the South Boston Traffic Study, including the 2010 "full buildout" forecasted traffic levels.

3. Failed Intersections - The study should clearly indicate intersections which are considered "failed" at present usage, at project buildout, and at area "full buildout" levels.

4. Mode Split - The assumptions contained in the 65/35 mode split outlined in the original traffic study need to be re-examined.

5. The study should be conducted at times that are representative of typical traffic volumes. Those times should include specific peak traffic days in the fall and spring.

6. Court Square Press Building - The traffic study should take into consideration the development of this building.

7. Other development buildings, indicated in the graphic materials or in the text of the PNF, on the properties of other landowners in the South Boston Waterfront District should be evaluated for their impacts on available roadway and transportation resources.

8. The traffic study should include calculations of pedestrian levels of service (LOS), from South Station and Broadway Station to the furthest extent of the site, with estimated trip times.

Traffic Mitigation - No amount of "traffic mitigation" can lead to the absorption of the traffic levels generated by a 1.7 million square foot, 1,200 parking space development as proposed in the Midway PNF. The roadway infrastructure in the area simply cannot carry that volume of traffic. The BRA should direct the developers to scale down the project to a more manageable size and then present a detailed plan for traffic mitigation based on that smaller project. Particular emphasis should be placed on pedestrian mitigation.

Haul Road - The BRA should require that no traffic forecasts be considered which include increased or expanded use of the South Boston Haul Road, or any further signalization or entries/exits to or from the South Boston ByPass Road. This road is a critical component of the area-wide traffic mitigation plan negotiated with the South Boston community to take trucking off local neighborhood streets. It is also the vital link between the regional and national road infrastructure and the EDIC. This project must not threaten its integrity. Additionally, with respect to the design of the project along Richards Street, the developers should be directed to take into account any potential future westerly access to the Haul Road.

Site Access/Egress - Gillette Co.

The BRA needs to ensure that the project does not impede the operations of Gillette Company. In this regard, particular attention needs to be directed to the vehicular activity on Richards Street, which is proposed to concentrate the main access/egress to the site and is directly opposite the Gillette facility.

Displacement Issues

Considerable displacement of current business and artist tenants will occur as a result of the project. The developer has been unspecific as to any plan to provide relocation assistance to these tenants. The BRA should require the developer to provide an acceptable relocation plan prior to any approvals.


A more fully developed plan for the treatment of sidewalks and open space must be presented for review. Particular attention should be directed to the A Street face of the project. The designation of one of the infill lots for open space would considerably improve the project, opening it to the rest of the community. Retail space should be considered for the border of this open space, as well as along A Street.


Wind & Shadow Impacts

A more fully developed study must be forthcoming. Particular attention needs to be directed towards the effects of wind and shadow on the abutters and public realm.

Air and Noise Quality

Further study is required. Air quality will be affected by increased automobile & truck activity to the area, as well as venting of an underground garage. Increased noise levels will result from delivery and trash removal trucks, and air conditioning units.


Water & Sewage Impacts

The development of the South Boston Waterfront area is putting enormous stress on the water and sewage system in the area. The South Boston community has long been involved in discussions regarding sewage and drainage capacity, as well as CSO (waste) discharges into the Reserve channel and/or Boston Harbor. A more detailed analysis of this project in the larger context of continued development in the area needs to be made, such as complete storm water separation, on-site groundwater recharge, and greywater recycling.

Neighborhood Business District

Broadway has long been the focal point of the business district of South Boston. In addition, there are a large number of small businesses located in South Boston that would be negatively impacted by clogged streets and intersections. West Broadway is currently undergoing a number of changes, including the new Broadway Bridge, the development of the Court Square Press Building, redevelopment of public housing, and the conversion of St. Peter and Paul Church to residential use. These changes have placed the lower end of West Broadway and the surrounding intersections under considerable stress. The same is true for the Congress Street area. Traffic is clogged here for a good part of the day. The Midway project will simply add to this stress by funneling all traffic from the north and south through these areas. As proposed, the Midway project offers no clear benefits to the South Boston and Fort Point Channel Business District.

As noted earlier, the Midway project, as proposed, is "inward looking" in its design and function. The commercial and retail spaces are focused along Midway Street. These business and retail services will provide for the needs of the workers who will populate the office buildings during the weekdays. There is no inherent benefit to the small businesses and retail establishments throughout South Boston and the Fort Point Channel area. For the most part, Midway dollars will stay in Midway. It is not enough to theorize that the lines of commuting office workers streaming through Broadway or Congress Street during rush hour will spend their money along the way. The developers should be directed to submit a plan that would specifically provide business opportunities to the established South Boston and Fort Point Channel businesses.

Thank you for the opportunity to comment.

_____________________________ ___________________________

Valerie Burns .....................................Becky Dwyer

_____________________________ ___________________________

Mike Casey .....................................Mike Foley

_____________________________ ___________________________

Bob Costello .....................................Jon Seward

_____________________________ ___________________________

Richard P. Devoe .....................................Burns Stanfield

Jharry Breed (Gillette Co.) will be submitting a separate comment statement representing the issues and concerns of the Gillette Company.

Cc: List
James M. Kelly, Boston City Council
Stephen F. Lynch, Massachusetts State Senate
Jack Hart, Massachusetts State Representative
Anthony Gilardi, Mayor's Office of Neighborhood Services
Peggy Davis-Mullen, Boston City Council, At-Large
Michael Flaherty, Boston City Council, At-Large
Francis "Mickey" Roache, Boston City Council, At-Large
Susan Hannon, Project Manager, Boston Redevelopment Authority


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