September 17, 2012

Mr. John Fernandez
Chief Executive Officer
Massachusetts Eye & Ear Infirmary
243 Charles Street
Boston, MA 02114

Dear Mr. Fernandez,

We write on behalf of the community and advocacy organizations listed below regarding the proposal of Massachusetts Eye and Ear Infirmary (MEEI) to build a 1065-car parking garage beneath the Esplanade, to extend its existing 243 Charles Street building over Charles Street and into the park, and to return to park use the Massachusetts Department of Conservation and Recreation’s (DCR) land used currently by MEEI for parking.

Our organizations are a diverse group, some with broad interests and constituencies and others more specifically focused. One or more of us:

• Advocates for improved multimodal transportation, meeting the needs of walkers, drivers, riders (on bicycles and mass transit), businesses and residents;
•  Focuses on the Charles River, its cleanliness, its success as a natural habitat, its recreational opportunities and its accessibility;
• Focuses on the parklands along the Charles River, preserving and reclaiming parkland, improving the horticultural and physical plant, protecting the parks’ historic features,enabling all manner of recreational activities;
• Addresses public policy issues such as privatization of parkland and ensuring public benefit from government action; and
• Represents the interests of area residents.

We all respect the excellence of MEEI, support the continuation of its clinical and research activities, and value its importance to the greater Boston area by treating patients from around the world, burnishing Boston’s reputation as the seat of one of the great medical communities in the world, and providing thousands of jobs to area residents. We understand your interest in expanding your facilities and would like to provide input as you develop more detailed plans.

We know that you are developing an understanding of how your project could impact the diverse interests represented by our organizations. We appreciate that you dropped your plan to press for approval of the proposed land transfer during the current legislative session so that these impacts can be evaluated and addressed further. We also appreciate your acknowledgement and commitment that this project will not go forward without community support.

Our organizations are committed to exploring in good faith how our interests and yours can both be satisfied, and it is in that spirit that we have joined together to identify what we see at this time as our major concerns. Because your proposals are at this point very early stage and few, if any, studies have been completed, we can speak now only in the most general terms, but each of us is available to meet with you to discuss our concerns and identify what information and studies would enable us to explore ways to meet your needs and our concerns.

We are not a monolithic group insisting that all of the concerns of all of the participating organizations be met to the complete satisfaction of each. We are intent, though, on ensuring that all the concerns are clearly communicated to MEEI, are taken seriously, that adequate information about the concerns is provided, and that good faith attempts at resolution are made. We have committed to each other that we will operate in a transparent fashion, alerting each other about upcoming meetings with MEEI and government officials, inviting our representatives to attend such meetings as observers, and summarizing the proceedings. We ask that you similarly commit to a transparent, open process.

As we consider your proposals, we have two over-arching needs:

•  We need to understand your objectives, your needs, why you see these as a solution, and what alternatives have been considered and discarded. For example, the capacity of the parking garage would seem to be the primary driver behind many of the issues that concern us. Why 1065 spaces? What has changed since you submitted your draft IMP in early 2011?
• We need a shared understanding of the likely benefits and deficits of your proposals. Some of this will come from studies commissioned by you (such as a traffic study, which we understand is already underway), and some will come from informed judgments made by all of as to likely effects.

With this in hand, we will all be in a better position to look for solutions. Below we outline in broad terms the concerns we have, recognizing that over time some will vanish, others will grow in importance, and new ones may arise.

Transportation. Adding more than700 additional parking spaces will inevitably increase vehicular traffic in a highly congested area. Storrow Drive is already over capacity, and Charles Circle and Leverett Circle consistently resist all attempts to either reduce traffic counts or improve flow.

• While we support the goal of making it easier for infirm patients to visit MEEI, we want MEEI to explore different ways of meeting that need without constructing such a large facility. Perhaps special drop-off or parking programs can be targeted specifically at patients and visitors needing special assistance. Perhaps MEEI can reduce employee-parking needs by adopting additional programs that encourage employees to use alternative transportation. Perhaps the involvement of state and city leaders can encourage area institutions, businesses and garage operators to increase MEEI’s access to existing parking facilities or even partner with MEEI to facilitate convenient multimodal transportation in the area.
• Charles Circle and Leverett Circle appear to be particularly vulnerable to increased traffic generated by the garage. These impacts must be studied and solutions proposed to ameliorate new impacts and perhaps existing problems.
• The potential of the garage to interfere with the proposed Blue Line/Red Line connector should be explored.
• There are a variety of suggestions of how to make Storrow Drive work better for the benefit of all concerned (not just car drivers), such as reconfiguring ramps, realigning lanes, installing traffic signals and adopting traffic calming measures. Your proposal could benefit from them, enable them or render them impractical. We should all look at all the options.
• Traffic caused by the garage during evenings and weekends, when MEEI usage is presumably reduced, should also be studied. The availability of parking could be a benefit if concert-goers and charity-walkers stop parking illegally on area streets, but it could also exacerbate the situation if the incentive to use other means of transportation is reduced.

Parkland. It seems that the Commonwealth’s parks are always at risk. They are underfunded; what used to be true parkways through and adjacent to parks often morph into highways; open, undeveloped land too often gets converted to non-park uses, sometimes to private uses; and parks don’t vote. The history of Storrow Drive and the Esplanade illustrates all too many of these risks. The MEEI proposal comes to the fore during a hard-fought battle over the privatization of Daly Field, alongside the Longfellow Bridge rehabilitation project, and on top of the a long-term “2020” planning effort led by The Esplanade Association which among other things calls for significant changes in MEEI’s neighborhood.

• MEEI currently uses for parking parkland leased from DCR. The Esplanade Association’s Esplanade 2020 Vision calls for the conversion of this parkland back into park uses. MEEI’s plan does the same, but at the expense of the other issues raised by this letter. Clearly this is something we will have to explore.
• The 2020 plan proposes to return to park uses land adjacent to the Charles River through a significant realignment of Storrow Drive that is also projected to make Storrow safer. At first blush, MEEI’s plan appeared incompatible with the 2020 plan, but you have indicated that design changes could fix that. We look forward to having that discussion.
• The Longfellow Bridge rehabilitation project will affect the Esplanade and area business and residents adversely during construction but positively up its completion. We want MEEI to make every effort to ensure that its project not delay the Longfellow rehabilitation and to manage its own construction as much as possible so as not to make it seem like the Longfellow rehabilitation will never end.
• The proposed garage is largely underground, out of sight from the parkland, but we will all have to look closely at how the entrances, exits and ramps would affect access to the Esplanade, safety of bicyclists and pedestrians, and enjoyment by all.

243 Charles Street Expansion. This part of the proposal raises classic “parkland” issues, such as dedication of public land to private purposes, and many of the other issues described above. It also raises the issues typically posed by any development in an urban area such as wind, shadow, massing and design, some of which are especially sensitive because the project is close to residential areas.

Environmental and Construction Impacts. You are no doubt cognizant of the environmental issues that must be studied such as air pollution, stormwater run-off, water quality in the Charles River, and the water table impacts, many of which receive heightened attention because of the proximity of the project to the river. These will, of course, be addressed in reviews under MEPA and the BRA’s Article 80, and we suggest that earlier consideration, in consultation with our organizations, would be beneficial to all concerned.

Public Benefit. Privatization of parkland has become increasingly controversial as governments seek to off-load maintenance expense and find low-cash means of advancing private interests that are compatible with government goals. Some work well. Some don’t. Calculating the public benefit is hardly an exact science but, in the case of the proposed dedication of state parkland to underground parking and to landing the extension of 243 Charles Street primarily to support a private activity, it will be important to be able to answer questions such as the following:

• Are measurable economic benefits likely to flow to the state, the city and local businesses and residents?
• Will use and enjoyment of adjacent public land be significantly enhanced by the project
• How significant are the projected adverse impacts of the project?
• How can the $30 million state investment requested by MEEI be justified? Does it come at the expense of other priorities?

These are serious issues that may prove very difficult—even impossible—to solve. For instance, the amount of increased traffic may be insurmountable; the environmental issues may be insoluble; the privatization of parkland may fail on its merits for this project or as an unacceptable precedent for other state parks; and the final financials may not prove attractive. But the fact that these hurdles exist should not discourage any of us from looking for solutions to the challenges MEEI faces now and will in the future.

We will do our part, you will, no doubt, do your part, and we expect the myriad of public players—MassDOT, DCR, EEA, the City of Boston and the BRA—to do their part as well.

We look forward to working with you.

With kind regards,

Margo Newman, Chair of The Esplanade Association
on behalf of the organizations identified below

CC: Richard A. Davey, Secretary, MA Dept. of Transportation
Richard K. Sullivan, Secretary, MA Dept. of Energy and Environmental Affairs
Edward M. Lambert, Jr., Commissioner, Dept. of Conservation and Recreation
Mayor Thomas M. Menino
Peter Meade, Director, Boston Redevelopment Authority
Senator Anthony Petrucelli
Senator Sal DiDomenico Senator William Brownsberger
Representative Marty Walz
Councilor Michael Ross

Cooperating Organizations and Contact Information