SAND has filed the following comments during the public comment period now underway regarding the siting and construction of Harborlights Pavilion on Wharf 8.

As required, SAND has addressed these comments to:

Executive Office of Environmental Affairs
100 Cambridge Street
Boston MA, 02202
Attention: MEPA Unit
Mr. Robert Baldwin
Deputy Director of Industrial Development
Boston Redevelopment Authority
One City Hall Square 9th Floor
Boston, MA 02201
Mr. Greg Carrafiello
Acting Program Chief
Waterways Regulation Program
One Winter Street
Boston, MA 02108

December 17, 1998

Executive Office of Environmental Affairs
100 Cambridge Street
Boston MA, 02202
Attention: MEPA Unit

Re: ENF/PNF/WRDA for Harborlights Pavilion

Dear Secretary:

The Seaport Alliance for a Neighborhood Design is a community group based in the Fort Point Channel neighborhood of South Boston. 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 commercial district. We have also advocated for protection of the Marine Industrial Park (MIP) from encroachment by Seaport District development. A chronicle of our work on behalf of our constituents is well documented on our website at www.seaportalliance.org.

SAND has informed the proponent of our concerns regarding the conversion of irreplaceable maritime resources within the MIP for hotel, office and retail projects. The proponent is also aware of other concerns, notably the press announcement of Harborlights's relocation to Wharf 8 by Mayor Menino and the BRA without notice or benefit of a hearing by the site's occupants and neighboring communities.

Because we view the occupancy of Harborlights on Wharf 8 as temporary and because we understand that the proponent is working to preserve and improve the maritime capabilities on the site, SAND would support a 5-year siting of Harborlights on Wharf 8 if the reasonable requests outlined in this document were addressed.

Regarding the use of Public Resources

Harborlights has become an important and valuable Boston destination. It should not, however, be construed as a "public" venue on City-owned property. Ticket prices ($25 - $50) do not enable the general public to regularly attend events. Any improvements to the property or public amenities provided by the proponent are of significant importance to neighboring communities.

Regarding Siting on Wharf 8

Discrepancies exist between statements made regarding the short-term and longer-term or potential permanent occupancy of Harborlights. Terms of the lease agreement negotiated between the proponent and Boston Redevelopment Authority have not been publicly disclosed upon repeated request. Whereas the ENF states that "the facility will be removed after 5 years" (ENF Schedules P 2) and returned with improvements, it has been disclosed that the lease agreement includes a renewal option.


Regarding Public Amenities

A number of "public" amenities are proposed in conjunction with this private venture, yet the proponent unreasonably regulates the public access to all of these amenities. For example, public restrooms are available to pedestrians along the Harborwalk, yet the proponent restricts access to the Harborwalk (and access to the restrooms) during event hours.

We would ask that each public amenity as listed on the following page - having already been announced to the community and dedicated by the Harborlights organization for public benefit - must accommodate the public during the entire term of the operating season, during event hours and off-hours.

Regarding Transportation

To its credit, the proponent indicates an interest in providing shuttle service to and from South Station. Furthermore, by offering free parking to ticketholders, the proponent avoids potential problems caused by the use of South Boston residential parking by eventgoers.

Considering the proximity of Wharf 8 to residential South Boston and to the MIP, the proponent has not provided adequate support of public transportation. Whereas the proponent embeds parking costs in the ticket price as a marketing tool, no similar accommodation is made to provide and encourage free shuttle service between South Station and the venue.

Changing conditions within the Seaport District, especially considering construction schedules for completion of the Convention Center, MBTA Silver Line and Massport parcels will affect traffic on a 24-hour basis. For example, starting January 14, 1999, the MBTA construction will require New Northern Avenue to be a one-way from East Service to Sleeper, requiring a signaled right turn from Sleeper (near the Barking Crab) onto New Northern Avenue for all traffic attempting to approach the Moakley bridge. The proponent has not, and can not accurately predict traffic patterns in this district based on existing conditions.

The number of idling passenger vehicles must be minimized because South Boston residents continue to experience a well-documented, serious decline in health conditions due to traffic exhaust.

Although the proponent states that the EDIC garage is "a convenient 1500' walk" (Transportation Sec. 4 II-D P14), this is actually a fairly long walk (over 1/4 mile) to the facility entrance. Eventgoers in private vehicles will likely use the passenger drop-off at the foot of the facility.

Regarding Sound Mitigation

Harborlights, as it existed on Fan Pier, was a welcome neighbor of many SAND members. The noise level from Fan Pier to the residential community of the Fort Point Channel was tolerable and often an enjoyable addition to our eclectic neighborhood. With the Federal Courthouse completed as the last season of Harborlights began, the sound level increased within the residential district due to the amplification or redirection of sound waves off the new courthouse side-wall. Even so, the sound was still tolerable in this community - one familiar with urban noise, bagpipers at the Fire Museum, horses and occasional airplanes.

That said, the proponent has not adequately prepared for effects of amplified music on the neighboring South Boston residential community. Based on our experience with music from Fan Pier traveling through the Fort Point Channel neighborhood, it is likely that music will be audible within South Boston. A level of planning, mitigation and enforcement should be provided.

We appreciate you consideration of this matter and look forward to working with your office as we move forward with this project.

Best regards,

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
cc: SAND Membership

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