The following comments were filed with the Executive Office of Environmental Affairs (EOEA) to register SAND's opposition to Massport's proposed expansion of Logan Runway. The deadline for public comment was April 23, 1999.

Update 6/15/99: The estimated cost of the Fan Pier buildout, a project in the planning stage at the time of filing, has since been published at $1 Billion and has been corrected below, with the redacted version appearing in brackets ([ ]).

To read additional SAND history about the Massport runway proposal, click here.
To visit, the Citizens Against Runway Expansion (CARE) click here.

April 22, 1999

Secretary of Environmental Affairs
Attention MEPA Office
Mr. Arthur Pugsley - EOEA No. 10458
100 Cambridge St. 20th Floor
Boston, MA 02202

Re: EIS/EIR #10458 - Logan Airside Improvements

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 advocated for the planning of a "neighborhood" in the South Boston Seaport District. A chronicle of this effort is documented on our website at

We are addressing the Massport EIR for Logan Airside Improvements (#10458) by discussing the long-term impacts of Logan expansion on the South Boston waterfront - an area slated to emerge as a wonderfully vibrant neighborhood over the next 30 years. The South Boston waterfront is geographically the most severely impacted area - a future pedestrian friendly environment now imperiled by the proposed tripling in capacity of Logan Runway 27.

South Boston Seaport District - A Gem in the path of Runway 27

Surprisingly, economic and environmental impacts on the South Boston Seaport District have not been presented by Massport. This tract of land, roughly 4-5 times larger than Boston's North End, is projected by the Boston Redevelopment Authority's recently published Public Realm Plan to emerge as a dense urban residential and commercial neighborhood over the next 30 years. Outdoor elements of the waterfront plan already under way include harborwalk, harbortrail (bike path), a Fan Pier outdoor skating rink, tidal pool and many harbor-based leisure activities. The Fan Pier buildout alone is projected at [$1] billion - much of it made possible by public investment in infrastructure.

Taxpayers have invested $4 billion into Seaport District infrastructure and $4 billion into harbor cleanup, and should expect a long-term return on these investments. A large number of these taxpayers, including all of our members, have dedicated a personal effort in attending hundreds of various meetings with the City of Boston, the BRA, City Council, community leaders, the MBTA, the BTD, landowners, developers, towards achieving a successful master plan for the South Boston waterfront. At none of the hundreds of planning meetings attended by SAND core members - even with Massport, was a mention or consideration of an increase in flights departing from Runway 27.

Most unfortunately, the South Boston Seaport District is not yet inhabited by the tens of thousands of residents, workers and pedestrians projected in the BRA Master Plan, those most adversely affected by the tripling of capacity of runway 27 to 56,000 departures per year. We at SAND remain vigilant on behalf of our future neighbors.

The Massachusetts Visitors' Bureau and the Massachusetts Convention Center Authority contend that the proposed changes to the airport will aid the South Boston Seaport District by bringing in conventioneers. These cheerleaders for tourists and conventioneers are well-meaning, yet indefensible - the Boston Convention Center occupies a 60 acre parcel out of 800 acres of developable area. The Seaport District of South Boston has never been dedicated to the import and management of tourists, but rather to the service and livelihood of all denizens of the City. Furthermore, the impact of plane flights on the pedestrian environment evolving around the Convention Center (much to the benefit of conventioneers) has not been studied by the MCCA, nor do we expect pedestrian impacts to be provided your office in their comments on this EIS/EIR.

SAND continues to stress that the success of the South Boston Seaport District will be in its ability to evolve as a mixed-use district for living and working - not as a pedestrian-unfriendly environment with planes roaring 500 - 600 feet overhead. Massport - an agency that has squandered land-banking opportunities within its own Seaport District-based Marine Industrial Park for the sake of short-term revenue generation, is seemingly incognizant of the economic opportunities to benefit Massachusetts over decades to come.

Massport's systematic expansion of Logan Airport

Massport asserts that this proposal will reduce delays caused by wind patterns. Logically, one must ask why delays have been worsening over the past 10-15 years. Here, Massport does not contend that delays have increased as a result of wind patterns. Delays increase because Massport has systematically overburdened its runways. Massport's modus operandi for expansion has been to seek approval at a stated capacity, continue to exceed the capacity to a breaking point and then to state a new objective to alleviate its problems.

In fact, delays have worsened due to Massport's unwillingness to balance supply and demand for air travel. If passengers were able to fly for free, would Massport be expecting its airports to continue to meet demand?

We would suggest that delays would be reduced, now and in the future, by regulating supply and demand for air travel. Business and leisure travel has increased during the current economic boon and will certainly decrease as the economy stabilizes or if ticket prices are raised during peak periods.

Massport has not met reasonable Community Obligations

Although Massport is well aware of our community group (based in South Boston's historic Fort Point Channel neighorbood) Massport has not held a single meeting in this area for the benefit of property owners, residents, businesses. The Fort Point Channel neighborhood, home to the Childrens' Museum and New England's highest density population of artists and creative professionals, is the starting point and most significantly impacted neighborhood affected by Runway 27.

Flights pass over the Fort Point Channel neighborhood along A Street at altitudes of approximately 500-800 feet, yet no decibel or emissions testing has been performed in the Fort Point Channel area.

Massport's Concerted Campaign of Obfuscation

Massport's EIR and public relations campaign have been devoid of relevant information for the layperson to assess impact.

Massport has portrayed this EIR as

1) a delay reduction program

2) a plan to move air traffic over the harbor with a unidirectional runway

3) an economic necessity for Massachusetts

None of these portrayals are entirely truthful or substantiated by the EIR/EIS. Considering the potential for increased capacity at Logan with an additional runway (backed by precedent), this plan is much more than a delay reduction program. And considering the major land-based shifts in traffic on runways 22L, 22R and 27, the proposal is not a harbor move.

Although we accept that expansion at Logan would have a positive impact on the Massachusetts economy, we do not believe the positive benefit of this particular proposal outweighs its tangible burdens. Despite the vocal chorus of business leaders supporting the runway plan, none have embarked on providing an assessment of the long-term impacts to substantiate their position.

We at SAND expect a thorough economic assessment before we accept claims regarding substantial benefit.

As further evidence of Massport's attempt to obfuscate, the agency accepted and used the skewed results of a poll conducted by a business group to demonstrate an "invisible army" of support. In fact, questions offered by the telemarketing firm regarding the Logan proposal were misleading and directed towards supporting the plan.

We ask the EOEA to either consider the actual questions asked by these telemarketers, or to discard Massport's use of biased polls and studies.

Finally, it is important to note that Massport worked with Governor Paul Cellucci during the EIS/EIR comment period, to secure Worcester Airport for future expansion. This type of knee-jerk planning is emblematic of Massport's roughshod approach to solving regional transportation issues.

In conclusion, SAND would suggest that Massport EIS/EIR 10458 is short-sighted, permanently retarding the progress of one of Boston's most notable long-term planning accomplishments - the South Boston Seaport District. This urban waterfront will evolve over many decades rather than in one or two business cycles, and the EOEA should join with SAND in appreciation of it - protecting an environment today that generations will enjoy tomorrow.

Best regards,

Steve Hollinger
on behalf of:
The Seaport Alliance for a Neighborhood Design (SAND)

Also sent to:

Mr. John C. Silva
Manager, Environmental Programs
Airports Division ANE 600
New England Region
12 New England Executive Park
Burlington, MA 01803

Your comments as a visitor to the SAND website would be appreciated and forwarded for discussion.