July 22, 2016 Matthew A. Beaton, Secretary !Massachusetts Executive Office of Energy & Environmental Affairs c/o Office of Coastal Zone Management !251 Causeway Street, Suite 800! Boston, MA 02114! ATTN: Lisa Engler Re: South Boston Waterfront MHP Amendment / 150 Seaport Blvd Dear Secretary Beaton: I am writing you today to register my concerns with respect to the SBW MHP Amendment: • impacts onsite at 150 Seaport Blvd; • flawed public process drafting the SBW MHP Amendment • detrimental precedents set by the SBW MHP Amendment • low bar for offsets and benefits under Chapter 91 districtwide • routine undervaluation of privately owned tideland parcels with respect to projects undergoing approval South Boston Waterfront landowners have been graced with billions of dollars in state and federal investment: Boston Harbor Cleanup CA/Tunnel Ramps in Seaport MBTA Tunnel and Silver Line BCEC Moakley Courthouse Moakley Bridge Value capture was and remains a primary responsibility of the Boston Redevelopment Authority. As evidenced in the following pages, public access and civic/cultural accommodation objectives of the Seaport Public Realm Plan and South Boston Municipal Harbor Plan are not being met, largely as a result of a systemic failure in the BRA’s planning, enforcement, zoning and public approval process. Best regards, Steve Hollinger 26-Year Resident 21 Wormwood St. #215 South Boston, MA 02210 Cc: Ms. Lisa Engler, CZM Mr. Ben Lynch, DEP Senator Linda Dorcena Forry Representative Nick Collins Mayor Marty Walsh City Councillors Michelle Wu, Ayanna Pressley and Bill Linehan Mssrs. Rich McGuinness, Chris Busch, Erikk Hokenson, BRA Mr. Jim Canales, Barr Foundation Ms. Sara McCammond, FPNA Community Representative Ms. Julie Wormser, Boston Harbor Now Ms. Deanna Moran, CLF Ms. Emily O’Neill, FPAC ONSITE INTERIOR CIVIC SPACE UNDER SBW MHP AMENDMENT ISSUE: ECONOMIC CLASS SEGREGATION IN BOSTON’S SEAPORT DISTRICT I attended two (2) SBW MHP Amendment Advisory Committee meetings and I wrote two (2) comment letters. In both oral testimony and written comments, I asked the Boston Redevelopment Authority to consider carving a 2,500 square foot interior public civic/cultural space from the 10,700 square foot restaurant planned at 150 Seaport Blvd. Proposed by BRA/Proponent at 150 Seaport: 10,700 SF commercial FPA, ground floor and 2nd floor My proposal onsite at 150 Seaport: 8,200 sf commercial FPA, ground floor and 2nd floor 2,500 sf public civic/cultural FPA, ground floor No action was taken by the BRA in response to my oral and written requests. More details are provided in the “Process” section of this letter. Background and rationale for a 2,500 sf Civic Space at 150 Seaport Blvd The Boston Redevelopment Authority’s inattention to fundamental civic needs in Fort Point and larger Seaport District has fostered an environment that is increasingly unwelcoming to visitors of all economic classes incapable of patronizing commercial establishments. This failure to recognize the needs of citizens of limited means to afford commercial establishments has been compounded by the BRA’s support for the off-siting of affordable housing – including affordable housing proposed by 150 Seaport Blvd. The Boston Redevelopment Authority seems to have adopted a view that waterfront visitors of lower and middle economic classes will enjoy scheduled invitations to private spaces such as a by-invitation-only Vertex classroom or a cavernous “family boat building workshop” operated by a tenant handpicked by a project’s developer. Lower income residents have to be explicitly invited the district for special events at privately owned facilities such as the Childrens Museum or ICA. The South Boston Waterfront has seen over fifty large commercial projects built and approved in the 21st century. To date, not one significant civic facility (school, library, community center, etc) has been planned or built as a year-round destination for those who can’t afford to patronize commercial establishments. 2 FAILURE TO PROVIDE A PUBLIC REALM SUITED FOR PEDESTRIANS The Boston Redevelopment Authority has ceded the entire ground floor design to suit the needs of a 10,700 sf restaurant enclave situated at the rear of the project (facing the Harbor). The front façade of the project along Seaport Boulevard — the primary way for pedestrians walking between Liberty Wharf and Fan Pier — is devoid of active, attractive uses. Two garage bays and a loading dock front Seaport Boulevard, with truck cabs parking over public sidewalks. 3 FAILURE TO DELINEATE PUBLIC VS. PRIVATIZED AREAS OF HARBORWALK The BRA is touting a 26-foot wide Harborwalk adjacent to the restaurant space as a significant public benefit onsite. At two SBW MHP Advisory Committee meetings that I attended, I asked the BRA to differentiate between public space on the Harborwalk and space on the Harborwalk that could be permitted for exclusive use as a commercial patio by the ground floor restaurant. No action was taken by the BRA in response to this request for delineation of public vs. private Harborwalk areas. It is my belief that while refusing to delineate permanent public portions of the Harborwalk from potential private portions of the Harborwalk, the BRA was fully aware that a commercial patio adjacent to the restaurant would be sought at a later date for permitting by the proponent. 4 FAILURE TO REASONABLY ASSESS VALUE OF PUBLIC RESOURCES Value of air rights over publicly owned sidewalks were not contemplated in BRA’s proposed SBW MHP Amendment. Rights to public parcels on land and within Boston Harbor are being amassed and contributed to the project by the City of Boston, Massport et. al. The public interest in these properties and/or rights were not assessed in the MHP or compensated for in the Chapter 91 project benefit package. 5 FAILURE TO ASSESS OFFSITE OPEN SPACE BENEFITS COMMENSURATE WITH PROJECT In my view, the park to honor Martin Richard at Childrens Wharf is an extraordinary initiative, and wholeheartedly supported. As I understand, an estimate of the park’s cost is $7.5 million. A $1.5 million contribution to the park as proposed as a project benefit in the SBW MHP is arbitrary and insignificant relative to the scope of the luxury 150 Seaport condo project made possible under the MHP. For context with respect to a project of the scale of 150 Seaport and a $1.5M contribution, consider: Seaport lots acquired at $9 million per acre, once BRA-approved for Class A office space or a luxury tower, have routinely flipped to developers for $23 to $26 million per acre. The recently completed PwC office tower sold for over $400 million. For the BRA to negotiate a payment of $1.5 million towards Martin Richard Park during approval of a project of this scale is an abrogation of responsibility to the public trust. This is the type of disappointing BRA horsetrading (outside of public process) that has left the Seaport with commercial buildings shaped like boxes hulking over an array of inordinately bland and anemic public accommodations ranging from plain, manicured lawns to cobwebbed and desolated interior spaces. 6 FAILURE TO REASONABLY ASSESS PROPOSED OFFSITE CIVIC/CULTURAL BENEFITS COMMENSURATE WITH PROJECT Following my testimony and written request for a 2,500 sf civic/cultural space at 150 Seaport Blvd, the BRA returned to the next Advisory Committee meeting with a presentation suggesting that the BRA had been working with the Fort Point Arts Community (FPAC) to secure funds from 150 Seaport Blvd benefit package necessary to complete a fit-out of FPAC’s 1,200 sf space at the Envoy Hotel. As I understand, the estimated value of the stated benefit arriving from 150 Seaport is $100k - $200K. This amount is arbitrary and insignificant relative to the scope of the 150 Seaport condo project made possible under the MHP. More importantly, the anticipated contribution to FPAC is insignificant relative to the benefit of a useful civic/cultural space onsite at 150 Seaport. A slide presented by the BRA to MHP Advisory Committee members announcing FPAC’s Envoy fit-out as a key benefit of the 150 Seaport project inferred that FPAC had already been on board with the BRA, fully engaged and supportive of the 150 Seaport process. There is no public letter or attendance record indicating engagement of FPAC in SBW MHP Amendment process or 150 Seaport approvals. Few citizens including this commenter understand the pathetic reality of how the BRA approaches its responsibility to offsite benefits. I have too much respect for FPAC to be critical of this organization, and I am aware of pressing needs at the Envoy. But suffice it to say that no FPAC members attended the MHP Advisory Committee hearing when FPAC was announced as a beneficiary. Perhaps EEA/DEP can ask the BRA for an accounting of the process leading up to and Advisory Committee hearing presenting FPAC as a collaborator in the SBW MHP process and approvals 150 Seaport Blvd. NON-COMPLIANCE WITH EXISTING MUNICIPAL HARBOR PLAN The BRA’s mismanagement of civic/cultural accommodations Seaport-wide continues to violate EOEA Secretary Robert Durand’s demand in the Municipal Harbor Plan decision (p. 31) calling on the BRA to form an advisory body representing cultural interests “citywide.” To the BRA, everything is simply a matter of internal horsetrading sufficient to either win support of a necessary constituency or to maximize public support through some type of inflated announcement. Nearly every civic/cultural accommodation made under Chapter 91 since the ICA has been subpar. Even the most recent high bar, in which Society of Arts will take space at 100 Pier 4, provides a remnant space with low ceilings and columns. See the final page herein for an instructive list of how the BRA manages FPAs.