SAND has filed the following comments regarding a Notice of Project Change (NPC) for the Midway Project proposed by Beacon Capital Partners.
June 6, 2001
Mr. Mark Maloney, Director
Boston Redevelopment Authority
One City Hall Square
Boston, Massachusetts 02201
Dear Mr. Maloney:
Please accept our comment letter to address the recent Notice of Project Change (NPC) for the Midway Project. These comments are supplemental to SAND's recent PNF comment letter (copy attached).
We ask that you continue to employ the scoping originally issued for this project. We also ask that any deviations from current IPOD zoning and/or existing ratios of housing and commercial usage as issued as City policy in this district, be fully itemized and justified on the grounds of necessity.
Our issues regarding the NPC have mainly focused on the following issues:
- · Midway in context to a Fort Point Master Plan
- · Housing and live/work
- · Traffic circulation
- · Open space
- · Public Access
A zoning and planning process for Fort Point is underway with the Fort Point Working Group at City Hall, with a broad vision based on the comprehensive public dialog that culminated with publication of the BRA Seaport Public Realm Plan. We support much of that vision, one that expects the Fort Point area to evolve as an urban neighborhood. In planning this area, we also sensitive to the needs of existing constituents including the Gillette Company, the Boston Wharf Company and Beacon Capital.
As dictated by the Seaport Public Realm Plan, a Seaport Zoning Amendment must be codified for the Plan to be effective. Other legislative resolutions, including a requirement for housing and a limit on office space development were enacted by an executive order of Mayor Menino. We believe that the Beacon project must abide by existing planning guidelines, and must anticipate the Seaport Zoning Amendment.
At the present time, the Midway project proposes building heights and densities that are well in excess of the existing zoning (the Seaport IPOD limit is 80', with M-4 use and density). This type of excessive variance from existing zoning should only be considered once the area has a comprehensive re-zoning plan established through a public process, regardless of current area uses.
Housing and Live/Work
New development in Fort Point on the scale of the Midway project will have a direct impact on the Fort Point artists neighborhood and traditional South Boston communities. These impacts include traffic and rising rents in the area anticipated as a result of upscaling.
Onsite, in its proposed conversion of dozens of existing affordable artist live/work studios to class-A office space, the Midway Project directly represents a loss of creative live/work space in a neighborhood which for two decades has been the home of New England's largest and most highly concentrated arts community.
To mitigate for these impacts, the Midway project presents valuable opportunities which have not been sufficiently addressed in the PNF or NPC. SAND's support for the Midway project is contingent on the proponent more clearly addressing mitigation obligations.
In Fort Point public meetings and in ongoing dialogs with representatives of the Fort Point arts community, the proponent indicated an intent to work with the Fort Point Cultural Coalition (FPCC) to develop the artist live/work component. In turn, the FPCC engaged Keen Development Corporation as its co-developer.
The FPCC, the Fort Point Arts Community Inc. (FPAC) and Keen Development Corp. have an unsurpassed track record of development of artist live/work and rental space in the region. FPAC, in consultation with Keen Development Corp., developed the 300 Summer Street artists co-operative. FPAC developed the 249 A Street co-operative and was instrumental during the early stages of development of Sommerville's Brickbottom studios. These developments have served as models of artist live/work developments nationwide.
We at SAND support the nomination of FPCC as the developer of the live/work component.
Shifting course, the proponent recently signaled an intent to pursue market rate housing opportunities (i.e. Fort Point Place condos) for the "live/work" component rather than truly addressing impacts on the arts community. As a model for housing, the Fort Point Place condominium (and it's linkage component) are entirely unsuitable for artists, and do not present a viable alternative.
Prior to being granted further approvals, the proponent must clarify that the developer of the housing component is the Fort Point Cultural Coalition. Sufficient clarity is also required in the financial terms of such a development agreement to ensure viability.
Within the 175,000 square foot artist live/work component currently proposed, we expect that a portion may be required to meet the City of Boston's affordable housing requirement. If required, this portion should be subject to development, access and affordability guidelines required of similar publicly subsidized housing.
SAND supports Mayor Menino's executive order requiring that 1/3rd of new development be reserved for housing. Because the South Boston community is similarly impacted by the wholesale upscaling of the area, we support the creation of new housing that is suitable for the South Boston community.
We support the creation of significant housing in South Boston according to the community's needs, including the nomination of a development corporation to ensure access and affordability for residents who otherwise would have limited options.
Transportation and Traffic Circulation
The proponent has reduced parking spaces from 1200 to 900 in the NPC. We contend that a 900-car parking garage is still likely to introduce circulation problems that have not been adequately addressed, not only into the site but also for area concerns including Gillette.
We recommend that the 900-car garage be further reduced in size. A project of this scale, in such a short walk from two MBTA stations, should not require 900 parking spaces. The project should propose less than the City's downtown ratio of .4 spaces per thousand square feet of office, and less than the historic districts' .6 space per dwelling unit.
The proponent has stated that this project will be a transit-oriented development; therefore the project should meet all of the criteria of that designation.
Transportation and Traffic Circulation (continued)
We adamantly oppose any consideration of access for the Midway project onto the South Boston Bypass Road. SAND remains especially concerned that the viability of the shipping and trucking industries in the South Boston Marine Industrial Park (SBMIP) will be impeded by the continued pressures on access for non-truck traffic on the Bypass Road.
We recommend that the developer include provisions for use of office-parking spaces by area residents during evenings and weekends, helping to reduce further parking needs in Fort Point.
We further recommend that the proponent reserve at least (3) parking spaces for Zipcars or an equivalent alternate for low-cost hourly passenger vehicle rental. The Zipcar concept offers progressive ride-sharing alternatives over the use of private vehicles.
Note that once this project is approved without Zipcar spaces (or a similar alternative), it will be less likely that the property owner will support the inclusion of Zipcar spaces. Parking revenue potential from private owners in the Fort Point area has proven to be price-prohibitive for this type of shared transit service.
Binford Street has been identified as a major access point for this project. We would recommend that more focus be placed on some of the mid-point access roads to alleviate strain on Binford. Also, the proponent has not clarified whether or not vehicular access will be allowed to move from Binford onto Midway. All diagrams show an unidentified structure on Midway at the Binford intersection.
SAND recommends the creation of a small park at the corner of Binford and A Street, complementing the curved Sporto building façade, the abutting artist live/work building and adjacent Fort Point Place condominium.
In the NPC, the proponent has changed Midway from a pedestrian route to a vehicular route. More attention must be given to the creation of greenspace, perhaps on Midway Street on the block north of Richards Street.
No area serving as a roadway, a vehicle accessway, or as vehicle storage should be considered as open space.
All faces of existing and new buildings should be considered and activated for access and activity. Existing buildings on A Street should continue to have entrances and an orientation towards the street. The project should present an opening of facades onto 'New Street' and at the extension of Richards Street.
SAND does not support demolition of Fort Point's historic warehouses. We have supported the recent landmarking of Fort Point as a Historic Landmark District, and also appreciate the proponent's stated support for historic preservation.
Demolition of existing buildings, and of significant portions of building facades and fabric, should be minimized or avoided altogether. All renovation work should be accomplished with utmost sensitivity to the existing, historic structures.
Infill construction should not replicate historic structures, seaming together buildings with additional brick-and-beam construction for example. We support complimentary architecture to juxtapose modern ideas with respect for the historic buildings.
In its fulfillment of a truly public realm plan, SAND requests that the proponent offer a full and public easement on Midway's streets, sidewalks and open spaces. Public access should at no time be a private, revocable right relegated to owners or tenants. In exchange for such public access, the City of Boston should meet its own obligations in providing necessary public maintenance and ancillary City services.
Thank you for your consideration of our comments.
Seaport Alliance for a Neighborhood Design (SAND)
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