The BRA has submitted a first draft of its Boston Harbor Municipal Plan, a proposal which -- once approved by the Executive Office of Environmental Affairs -- will overide state development regulations for coastal property. The plan attempts to identify Boston's coastal properties as an "urban" waterfront and thus capable of being developed beyond the restrictions set forth under existing state Chapter 91 legislation.

Chapter 91 regulates the Massachusetts coastline, protecting the waterfront from privatized uses --including specifications for maximum building heights and setbacks. The BRA is intent on loosening Chapter 91 regulations for the City of Boston, as City Hall moves to create a new standard for waterfront projects -- from the commercial project selected by the BRA to replace the Old Northern Avenue Bridge (a retail mall over the Fort Point Channel) to the hotel/office towers being projected for development on Fan Pier.

Within days of its expiration, SAND was made aware of a public comment period regarding the first draft of the Boston Municipal Harbor Plan. The BRA did not announce or send notice to inform Boston's waterfront communities of the document's submission or the associated public comment period.

July 30, 1999
Secretary Robert Durand
Executive Office of Environmental Affairs
100 Cambridge Street
Boston MA, 02202
Attention: MEPA Unit, Tom Skinner, Elizabeth Grob, Coastal Zone Management
Regarding: BRA Municipal Harbor Plan

Dear Mr. Durand:

Our community group, the Seaport Alliance for a Neighborhood Design (SAND) has been very active in improving public awareness and advocating for neighborhood ideals in the South Boston waterfront dialog. We were not aware that the BRA submitted a first draft of the Municipal Harbor Plan until a SAND member discovered news of its publication earlier this week and secured a copy of the draft. We have not reviewed the draft, nor are we able to respond to it for today's deadline.

We have been informed that the BRA has proposed a Fort Point Mitigation Trust to oversee development in the Fort Point area, and that this committee does not specifically include community members as it does landowners and the BRA. Given that much of the Fort Point historic subdistrict is owned by absentee landlords most prominently including the UK-based Boston Wharf Company, one would have expected long-time residents and community members to have input into the planning process.

Although SAND members have extremely supportive of the BRA Seaport District Public Realm Plan, our members have been critical of the City's management of the public realm (i.e. the proposed privatization of the Harborwalk), the exploitation of priceless public resources for revenue generation (i.e. the proposed mallification of the Old Northern Avenue Bridge), and the use of tax dollars to fund infrastructure improvements to the waterfront with seemingly inadequate public return on investment. It is not surprising that we have been excluded from the planning process and from the BRA's proposed advisory committee for the waterfront.

While the Municipal Harbor Plan will correctly address issues pertaining to an "urban" waterfront, we feel it may erode valued protections on the public realm and may weaken the ability of the EOEA to oversee proper access and use of the waterways and the water's edge. We hereby ask you to consider SAND as a commenter, putting our group on the list for further notification.

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

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