September 15, 2006

Secretary Robert Golledge
Executive Office of Environmental Affairs, MEPA Office
Boston, MA 02114

Mark Maloney, Director
Boston Redevelopment Authority
1 City Hall Plaza
Boston, MA 02201

Re: Congress Street Hotel project

Dear Commissioner Golledge and Director Maloney,

SAND, the Seaport Alliance for a Neighborhood Design, is generally supportive of this innovative project, located on a challenging site. This enthusiasm is somewhat tempered by our review of the ENF/PNF document and realizing that it does not contain any description of the underlying zoning regulations, and this projects conformance to them. As this must be a PDA project to justify its exceedance of the base one hundred twenty-five foot height limit (125’) by more than one hundred feet, and that its FAR approaches 18, rather than the underlying FAR 3, we find this omission to be of some concern.

Due to limited time and staffing, our review of the permitting documents has been less than thoroughgoing. We must therefore ask our public agencies to be particularly diligent in ensuring that this project application is fully in conformance to current regulatory standards, and that the proposed or required mitigations fully reflect the substantial increment of value which the granting of additional height and massing represents to the proponent, and the potential of this project to make insufficient improvements to the public realm.

SAND finds the total height of 24 stories is appropriate at 256 feet high, at this distance from the historic resources of the Fort Point Channel landmark district. As the filing documents specifically state that the maximum building height, inclusive of non-occupiable elements, will not be above 257 feet above grade, we ask for future vigilance to ensure that this limitation continues to be respected.

The reliance on transit, bus and pedestrian access to the building is strongly supported, as are the curb cut limitations, internalizing of loading docks, and minimization of parking provisions. Our understanding of the efforts being made to reduce transportation demand below MEPA thresholds is such that a thoughtful and effective approach has been identified. We support their joining with the Seaport TMA, rideshare, public transit, and pedestrian oriented approach to traffic management. We ask that there be ongoing monitoring of traffic generation following completion of construction and subsequent to the opening of the hotels, and that penalties or further mitigation steps be identified, should such limits and thresholds be exceeded.

However, SAND does have a number of concerns that should be fully reviewed and addressed as the project proceeds, incorporated into the design and publicly reviewed prior to initiation of construction. These items are as follows:Pedestrian Issues

The pedestrian environment presented to the project is daunting. The hotel and its site should be thoroughly evaluated to ensure that it is providing the maximum possible improvement to the streetscape, public realm, and pedestrian amenities possible. The proponent should demonstrate in future public for a how it making the fullest progress towards mitigating these challenges to pedestrian circulation.

Efforts should be made, in concert with Massport, MHD and MTA, and BTD to improve intersections and pedestrian crossings in this area.

The sidewalk and landscape fronting the hotel parcel should be upgraded to provide improved pedestrian amenities with elements such as benches, visible bicycle racks, sheltering canopies, and other features that will encourage increased pedestrian use.

The ground floor spaces of the hotel and associated retail areas should provide their main access points directly facing the sidewalk. The interiors of these spaces should be designed so that they present an active, populated face to the street, both visible and attractive.

The proponent should evaluate and commit to their previously offered provision of pedestrian access between Congress Street and Summer Street. We believe that it is fully possible to replace previously existing stairways from the Summer Street viaduct to the Congress Street grade with an ample, permanent and handsome stair. This connection may require the use of public lands to site a stair tower and bridge, and to span the distance needed to make the connection. The appropriate public agencies should be directed and encouraged to make every effort to facilitate the reintroduction of this needed, historic connection.


The façade of the building should be further considered and refined, so that there is a human scale and level of interest to low speed and adjacent passersby. The overall massing and design of the building should be further refined to provide a greater recognition and relationship to the historic Fort Point Channel district, perhaps with elements such as cornices or stringlines that reference the height, massing and organization of those loft buildings. Materials and detailing of the hotel should not be historicist. Window tinting and reflectivity should be minimized.

Natural Resources and Sustainability

The project needs to monitor groundwater levels during construction phases, when dewatering of the site may be necessary. If necessary, provisions should be made to recharge the water table, if dewatering does lower water levels. Historic buildings nearby have already suffered from piling deterioration, and no further impacts should be introduced. Recharge of stormwater directly to the ground should be evaluated, both from roof drainage and from the site. Should further design or engineering reveal the need for site drainage following construction, plans should be established for ongoing monitoring of groundwater levels and making ample provision for their maintenance.

The proponent has stated that they will incorporate sustainability principles, recycled materials and other elements into the project, following LEED guidelines. This commitment should be clarified and enhanced, so that the public can reasonably expect that these laudable goals will be fully attained. The proponent should state what level of LEED certification they are designing to, and report on their success in meeting those criteria. The proponent should consider making an application for LEED certification, as this would improve the marketability of the project and the hotels. Consideration should be given towards using locally and regionally sourced goods and products. The hotels should consider programs developed by other sustainable hoteliers, notably the Lenox Hotel, to reduce costs, conserve resources, and best serve their patrons.

Wind and shadow impacts should be carefully considered, and design refinements made, to ensure that the experience of the pedestrian at grade is pleasant, and improved to the greatest degree possible. We have found that BRA protocol for wind comfort to be overly optimistic, and so diligent efforts should be made to minimize ground level winds, particularly during the colder and more inclement months. A cold, dark and windy location will discourage pedestrians, and is not conducive to retail trade, nor towards delivering a pleasant stay for hotel guests. Conclusion

SAND supports this project and wishes the developer and hotel operators the greatest success, conditioned on the premise of addressing and implanting responses to the concerns detailed above. We eagerly anticipate the services and amenities that this innovative new neighbor can bring to our neighborhood, adding to the life, vitality and diversity of the district. We are certain that the hotel can greatly improve what is today a very difficult and discouraging location, and set a high bar for later developments to strive to match. We appreciate the clarity and openness of the developer, and look forward to working together to expedite this project, improving and ensuring its success.Please be in touch on any issue related to this project, at your convenience, for clarification or additional comment.

Best regards,

Jon Seward, for SAND

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