The following letter was filed by SAND with the Boston Redevelopment Authority in response to a Project Notification Form (PNF) filed by the Boston Wharf Company. The Boston Wharf Company PNF proposes renovating a building currently occupied by cultural non-profits and Fort Point artist studios into class A office space.
May 7, 2001
Mr. David Hanifin
Senior Project Manager
Boston Redevelopment Authority
One City Hall Square
Boston, Massachusetts 02201
Dear Mr. Hanifin:
Thank you for providing SAND with an opportunity to comment on the 288 A Street proposal submitted by the Boston Wharf Company. Our membership has a number of concerns related to this proposal and we welcome the opportunity to work with the BRA to ensure that this project enhances the Fort Point neighborhood and the City of Boston.
Absence of a Master Plan
We have grave concerns over the reviewing of individual projects without a Master Plan for the neighborhood. The City's Public Realm Plan and the current residents of Fort Point envision this neighborhood as a lively 24 hour district. As buildings such as 343 Congress Street, 327 Summer Street and buildings on Melcher and Stillings Streets are renovated into office space, we relinquish the ability to achieve, through planning, the goals desired to create a living neighborhood.
We would like to see a description of this project in relation to other developments the Boston Wharf Company has completed or commenced in this district over the past several years. Splitting up the projects and approving them individually makes it difficult to comprehend their full impacts. In looking at the entirety of Boston Wharf's redevelopment over the years, we are concerned that there has been no housing component. As on Midway Street, we should look at the past projects combined with the present to get an accurate picture. We will then be better able to determine if the BWC should be held to the same 1/3 of new development being residential as other developers in the district.
SAND respectfully asks the BRA to withhold approval for any further projects in this district until the Working Group has had an opportunity to create a plan. With a unified comprehensive plan in place that the community has been able to participate in, proposals will be able to move forward with full support of neighborhood groups.
In a master planning context, it may be appropriate to consider whether or not complete conversions to office space are allowable uses of buildings zoned for manufacturing. Secondly, the applicability of an artist live/work overlay on current industrial zoning may be considered.
There are several specifics of the PNF that we would like to see addressed:
On p. 3 of the PNF the developer claims the public benefits of this project are:
- create numerous jobs
- pay substantial real estate taxes to the City of Boston
- provided needed Class A office space during a period with severe office space shortage
- improve the South Boston area by changing an underutilized structure into a rehabilitated structure
- providing technologically advanced and environmentally sound amenities
SAND challenges that these stated public benefits are greatly outweighed by the negative impacts this renovation will have. The public benefits that the 50 artists and 3 non-profits currently occupying the building provide greatly outweigh any public benefits cited by the proponent. The need for viable space for artists is much more critical to the City of Boston than the addition of Class A office space. 10 million square feet of office space is already projected to develop on the South Boston Waterfront.
Non-profits like the Revolving Museum have activated the neighborhood with their "round the clock attraction value". They have provided activities that are educational, free and open to the public and attracted a wide audience to their exhibitions. The artists add to the allure of open studios, visited by thousands of people each year and add character to a neighborhood that is quickly becoming overrun with 9 to 5 office workers. Losing the Revolving Museum, Artists for Humanity and the Massachusetts Coalition for the Homeless is hardly a public benefit. These groups have been doing just what the City is looking for in this neighborhood. They provide a cultural attraction, they enliven and activate the neighborhood, and they provide programs accessible to a wide range of people.
The impacts of traffic need to be studied based on a full buildout of the district. Individual projects may not appear to pose a threat. If developers are permitted to create parking and transportation studies in a vacuum, the cumulative effects will plague the area in the future.
The proponent states that "Because the proposed rehabilitation does not represent an increase in space over the existing Building, traffic impacts are expected to be negligible."(PNF p.5) Changing from an underutilized building to a fully occupied office/warehouse seems to be a significant change that will have significant impacts. We would like to see these impacts in context with other development in the neighborhood.
Additionally, we would like to see a report on usage of the Boston Wharf garage that currently exists next to the site. Is it at capacity? What is the actual usage in daily trips for that garage? How will the additional amount of office workers effect the current usage?
The activation of A Street is an important component to the overall improvement of the district. By creating an entrance to the building on Garage Access Road, the project does not conform to the ideal of activating A Street. We would like more information on whether there will be ground floor retail and improvements to the streetscaping on A Street. In the area of Fort Point owned by the Boston Wharf Company and occupied by Thompson Financial (Pittsburgh, Stillings, Farnsworth), the streets are dark and deserted every weekend. Because of the number of office lobbies created out of entire building floorplates in that area, BWC renovations have entirely stagnated that area. We do not want that approach to planning in this section of Fort Point.
SAND requests that the developer include operable windows. Pedestrians have a better sense of a living, vibrant neighborhood when they are able to look up and see the occasional face or potted plant. A walk down Melcher Street demonstrates how Boston Wharf Company has sterilized its pedestrian walkway by sealing a number of office buildings for air-conditioning. 343 Congress Street agreed to include operable windows in their development but they did not fulfill that promise. The BRA should indicate how they will enforce their determinations.
288 A Street falls within Chapter 91 tidelands. Infill area of this project on Chapter 91 tidelands should be considered as a loss of aggregate open space.
In its Scoping Determination the BRA should require documentation for increased water usage, waste water, and solid waste generation and determine whether the project is in compliance with Ch. 91 licensing requirements.
Establishing a Master Plan for the Fort Point Neighborhood is imperative. Without the BRA taking the lead, a neighborhood as envisioned in the Public Realm Plan will never develop. It is the BRA's role to determine that the benefits of a Proposed Project outweigh the negative impacts of said project. We would like to see a plan and a project that this neighborhood can fully support. This can be achieved by letting the community actively participate in the planning process.
The building program should be modified to reflect the needs of the neighborhood. If the BRA is intent on permitting the project to move forward as proposed, it should state when and what it will do to retain the artists and non-profit businesses within the neighborhood, and provide sureties that this will occur.
BWC should demonstrate some of the vision and civic mindedness which led them initially to created this fine district. There is active harm being done in reducing the arts, services and industrial nature of the district, and replacing them with commercial offices. Without an overall plan and an understanding of how each building fits to it, we will lose the vitality and uniqueness of the neighborhood, and thus most of its value to its occupants and to the City. Renovating the Boston Wharf buildings one at a time is a quick fix, not a solution.
Thank you for your consideration.
Seaport Alliance for a Neighborhood Design (SAND)
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