Today was the final day of public comment on recent changes to the South Boston Marine Industrial Park zoning, submitted by the Boston Redevelopment Authority for approval by the Executive Office of Environmental Affairs.
The major change proposed to MIP zoning would change zoning of select parcels from "maritime industrial" to allow for "retail" and "commercial" uses including restaurant, cultural and office projects.
SAND has submitted the following comments for consideration.
November 9, 1998Ms Trudy Coxe, Secretary Executive Office of Environmental Affairs 100 Cambridge Street Boston MA, 02202 Attention: MEPA Unit
Re: EOEA #8161 - Master Plan Update - Boston Marine Industrial Park
Dear Secretary Coxe:
The Seaport Alliance for a Neighborhood Design is a community group based in the Fort Point Channel neighborhood. Our members, including many Boston-area residents and business owners, have facilitated the planning of a "neighborhood" in the Seaport District, rather than strictly a hotel/office/retail district.
Although SAND has been focused on the planning of a new Seaport District community, we included as part of our charter a mandate to recognize and include the concerns of existing Seaport District constituents. We have advocated for the protection of the Marine Industrial Park and have opposed conversion of this area for uses that might compromise future expansion of shipping, seafood processing and other maritime businesses. To use a shopworn metaphor, we drew a line in the SAND at the Marine Industrial Park.
Unfortunately, as the market value for waterfront property has escalated, the Marine Industrial Port has become endangered. Massport and the BRA have proven a case for office towers and retail complexes to exist in the MIP, as these types of projects promise better jobs, profits and revenue for the City. Many of these decisions are responsive to immediate demands (i.e. Convention Center, Seaport District facelift), but have not adequately considered the long-term effect of the shrinking Marine Industrial Park.
SAND opposes zoning changes in the MIP from "maritime industrial" to "maritime retail" for the following reasons:
- Zoning changes from maritime industrial to "waterfront retail" on Wharf 8 will eliminate the possibility of future use or expansion of the deep water berth on the working port. A zoning change on Wharf 8, justified by the promise of increased short-term revenue (10-20 years), may have absolute consequences on the vitality of Boston's ability to compete long-term (50-100 years) with other Eastern seaboard ports.
- Zoning changes within the MIP from maritime industrial to "waterfront retail" will negatively impact blue-collar jobs that are vital to the health of many Boston communities. The maritime/industrial jobs currently available in the MIP would be displaced by office/retail sector jobs. Of the 30,000 - 50,000 jobs already projected to develop in the Seaport District, most are white collar (office) and service (retail/hotel) jobs with little or no room for Boston's blue-collar base.
- All of the uses planned for the "waterfront retail district" including bank/restaurant/bar are already being planned in the Seaport District, sited within one to three blocks of the MIP. A number of property owners, including Anthony Athanas (with mall developer Stephen Karp), the Pritzker family (with Urban Strategies) and Massport (with private developers) are moving forward with retail projects. None of the retail proposals on Wharf 8 would be vital to the success of the MIP, the Convention Center, or of the Seaport District.
- Protections for truck traffic from the MIP to greater Boston are weakened by the change on Wharf 8 to "waterfront retail". A BRA/EDIC parking garage at the edge of the MIP has become an invitation for passenger vehicles into the MIP area, and a waterfront/retail complex on Wharf 8 would invite pedestrians into an area that already has truck congestion concerns.
- Adequate mitigation has not been provided by the proponent. Linkage funds may be an important component of mitigation, but current linkage legislation will not mandate re-development of projects that are dependant on maritime property and, therefore, will not serve the port appropriately. The classification of "water dependent" uses for linkage is vague and may arbitrarily catalyse projects that conflict with the industrial use of the port system.
- Harborlights, relocated by Mayor Menino and the BRA on Wharf 8, was sited on this public land (owned by the BRA/EDIC) without the benefit of a single public hearing. Although SAND has not opposed the relocation of Harborlights on Wharf 8, many Seaport District constituents have not been able to register their concerns, ranging from year round plans for activation of the site, relocation of existing businesses, etc. We also have questioned the BRA/EDIC on its decision to embed a hidden BRA/EDIC parking fee in the Harborlights ticket price instead of requiring a shuttle service - certainly an unreasonable invitation for car traffic at the edge of the MIP.
If Harborlights is permitted to move forward on Wharf 8, we request that your office consider issuing a temporary zoning change of up to five years, rather than a permanent zoning change. We would also ask your office to monitor the relocation effort of existing businesses on Wharf 8.
One would expect Massport - a quasi-public agency with a charter to strengthen and expand the Massachusetts port system, to support our effort regarding EOEA #8161 in order to preserve the MIP's zoning protections as a marine industrial park.
Unfortunately, protection of the industrial port system and property has largely been left to community activists and harbor advocacy groups. Massport, in its determination to enter the lucrative real-estate business, has continued to convert its irreplaceable resources on the waterfront into hotel, office and retail projects - projects that we have argued could be sited in many other areas of the Seaport District. And maritime business tenants on Massport property, beholden to their landlord, may now be unable to present arguments in support of their own maritime-industrial future.
Because Massport has its own near-term gains at stake, we do not believe this Authority is in a position to adequately address the long-term impact of real-estate speculation on Boston's future, vis-a-vis the social and economic consequences of a transition from a City once dependant on maritime economy to one that serves as a retail mecca. The problem is that once this valuable Marine Industrial Park is parceled off to address immediate market demands, it will be difficult or impossible to return it from retail with a water view to manufacturing with a water dependency.
Massport, ready to embark on a hotel project on its own Parcel F, is not likely to defend the use of the MIP for strict maritime-industrial use. And so, we must look to your office for zoned protection of this public trust.
Thank you,Steve Hollinger On behalf of: The Seaport Alliance for a Neighborhood Design (SAND) c/o FPAC, 300 Summer Street, Boston, MA, 02210, 617-423-4299 www.seaportalliance.org
cc: SAND Membership
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