Our new Greenway parks are at risk of being “rented-out”. As discussed in a previous post, the Greenway Leadership Council (GLC) is reviewing draft guidelines for the Greenway’s Public Programming, Special Events and General Use. Approving these “rules & regulations” is one of the most important functions of the GLC as assigned per State legislation. Chapter 306 of the Acts of 2008 created the GLC as a governing body over the private, non-profit Rose Fitzgerald Kennedy Greenway Conservancy. A list of current GLC members can be accessed here.
My comment letter strongly opposes the “renting out” of the Greenway parks for large, semi-private events that could destroy the parks and the hurt the character of the North End/Waterfront neighborhood. Turning the Greenway into an outdoor convention center goes against the desired public use nature of these long-awaited parks. Click here for a PDF version of my comments.
The GLC is accepting public comments through July 15, 2009 before considering the final version of the guidelines at their next private meeting. I hope you will take a minute and submit your own comments via email to: comments@rosekennedygreenway.org.
It is a good idea to cc/copy your comments to public officials. Their emails can be found on our Resources/Links page.
Anyone is welcome to copy/paste parts of my letter at the link below.
July 8, 2009
Ms. Ann M. Thornburg, Chair
Greenway Leadership Council
c/o Rose Fitzgerald Kennedy Greenway Conservancy
One International Place, 14th Floor
Boston, MA 02110
Via Email: comments@rosekennedygreenway.org
Re: Park Use Guidelines for Public Programming, Special Events and General Use
Dear Ms. Thornburg:
I appreciate the opportunity to comment on the Rose Fitzgerald Kennedy Greenway Conservancy Park Use Guidelines for Public Programming, Special Events and General Use ( “Guidelines”).
As a resident of the North End/Waterfront neighborhood, I oppose the use of the new Greenway parks for large paid events, such as conferences, conventions and private/corporate sponsored festivals. I believe it is important to have appropriate programming in the North End and Wharf District Parks that will benefit the community, of a small-scale, public use nature. But the “renting” of the Greenway for private and sponsored events will compromise the public use character of the parks.
It would be an insult to the Boston neighborhoods that suffered over a decade of Central Artery construction to now be subjugated to a Greenway that is used as an outdoor convention center. After the years of Big Dig construction and public expense, the North End/Waterfront remains on the front lines of the Central Artery/Greenway evolution. Parcels adjacent to residential streets should be infrequently used for events requiring stages, sound amplification, portable potties and equipment that could negatively impact surrounding residents and businesses.
In its current form, the draft Guidelines allow and encourage unlimited, large-scale events with thousands of attendees that will bring disorderly crowds and adversely impact the character of the North End/Waterfront neighborhood. Protections must be put into place during this review process to prevent abuse of the Greenway parks.
Large scale events as currently designated in the Guidelines will:
- damage the fragile park infrastructure and vegetation,
- create excessive trash and filth in our streets,
- result in traffic and parking congestion,
- create security and safety challenges,
- increase noise levels on residential streets,
- disrupt regularly scheduled public use programming
- increase public and private costs to mitigate the above factors.
The Guidelines should restrict the frequency and scale of events to lessen the harmful effects of large scale, convention and festival activities. In particular, the Guidelines should discourage events over 200 attendees, especially those of a corporate-sponsored and for-profit nature. While it may be desirable to “show-off” the Greenway with 1 or 2 big events per year, opening up the parks to events every weekend will take a horrible toll on the Greenway and the neighborhoods.
The following revisions to the draft Guidelines are strongly advised. (These comments refer to the Working Draft, dated July 1, 2009, as posted on your website www.rosekennedygreenway.org/docs.)
Section III – Guiding Principles for Use of the Rose Fitzgerald Kennedy Greenway
- Add bullet point: “Programming that could obstruct pubic use is discouraged. Priority will be given to events that are educational/community-based and non-profit in nature.”
Section V – Rules and Regulations; Special Event Permits
- Add new paragraph, “Restrictions on Large Events with Over 200 Attendees”
“The Conservancy restricts the frequency of large scale events with more than 200 attendees with a limit of two such events per parcel per year. Such use is intended for special, one-of-a-kind and historic events. Applicants for large scale events should indicate the benefits to the community-at-large and provide mitigating resources for security, crowd control and clean-up. “
- Add new paragraph, “Charging Fees for Events”
The Conservancy discourages applicants from charging participants for events. Exceptions would include fees to cover costs for educational programs, community events and charities.
Section VII – Event Policies; Clean up, Trash Removal & Recycling
- Add sentence: “Applicants are also required to clean the pavement and surfaces on the sidewalks and gutters on both sides of the streets adjacent to the Greenway parcel, immediately following the event.”
Section VII – Event Policies; Decoration & Event Signage
- Add bullet point: “No area of the Greenway park property is to be roped off or designated as private in any way. All event areas must be open and accessible to the public.”
Section VII – Parking & Traffic
- Add sentence: “No parking of event vehicles is allowed on or adjacent to the Greenway. Existing parking restrictions will apply before, during and after any event.”
Appendix A – Rose Fitzgerald Kennedy Greenway Parks; North End Parks & Wharf District Parks
- To discourage dense and unruly crowding, the maximum occupancy should be 10 square feet per person. References to 6 and 7 sq. ft. per person should be eliminated in Appendix A text and diagrams.
- The parcel diagrams adjacent to residential streets should be noted and designated to be free of stages, sound amplification, portable potties and equipment that could negatively impact surrounding residents and businesses.
In closing, I wish to thank the Greenway Leadership Council and the Rose Fitzgerald Kennedy Greenway Conservancy for holding public meetings during this review process. Because of the importance of the Greenway to the public-at-large and because these Guidelines will be felt by many, I ask that open public meetings be held and noticed during future reviews.
Sincerely yours,
Matthew J. Conti
Member, North End/Waterfront Residents’ Association
Council Member, North End/Waterfront Neighborhood Council
Founder, NorthEndWaterfront.com
cc: Governor Deval Patrick
Mayor Thomas M. Menino
State Senator Anthony Petruccelli
State Representative Aaron Michlewitz
Councilor Salvatore LaMattina
Council President Michael Ross
At-Large Councilors John R. Connolly, Michael Flaherty, Stephen J. Murphy and
Sam Yoon
Jeffrey B. Mullan, Executive Director, Massachusetts Turnpike Authority
Karl Haglund, Department of Conservation and Recreation
Antonia Pollak, Commissioner, Boston Parks and Recreation Department
John F. Palmieri, Director, Boston Redevelopment Authority
Nancy Brennan, Executive Director, Rose Fitzgerald Kennedy Greenway Conservancy
Mark Paul, President, North End/Waterfront Residents’ Association
Stephen Passacantilli, President, North End/Waterfront Neighborhood Council
A few comments and corrections:
1. The Conservancy was formed on its promise to take care of all park expenses with private money. But after it was created, the Conservancy obtained, in the four years before it began maintenance of the park, $9 million from the state and $1 million from the City of Boston.
2. The public cannot know where all this money has gone, since the Conservancy is a private corporation, exempt from the Open Meeting Law and Public Record Law. Its non-profit reporting documents do not detail the uses of this money.
3. The Conservancy certainly DOES rely on tax dollars. Its enabling legislation provides that half of its annual budget will be paid by taxpayers.
4. The park will be made a venue for private events for which the Conservancy will charge large fees, and will be occupied much of the time by such events. Since private for-profits groups will be charged much higher fees than non-profits, the Conservancy’s incentive will be to favor them, in order to maximize its revenues.
5. Our citizens will come to assume that this space is brought to them as a gift of generous private business interests, when in fact it is we who created and will be paying for their advertising and event space.
6. The park is a public space, and should be open and free for all to use. The only commercial uses that are appropriate are small, movable licensed vendors of refreshments and similar items, selected, sited, permitted and regulated for the enjoyment of park visitors and not for the funding of the Conservancy.
7. The decision regarding event size and frequency is separate from that of charging fee payments for event use. The former is a permitting issue, and should depend on environmental and social criteria. The latter is a political issue, restraining park use and privatizing our open space.
8. I object to the Conservancy’s designation of “Free Speech Areas,” indicated with yellow dots on their maps in the Park Use Guidelines. The Conservancy has no right to tell us where we can express our opinions and where we can hold our rallies. This is our public park, not the Conservancy’s rental venue.
9. The Conservancy is not operating transparently. A certain limited number of public board meetings are required by their legislation; but they can meet privately any time they want. The same is true for the so-called Leadership Council. This means that the public sessions will be for-show meetings to rubber stamp decisions worked out in private, out of our sight. Their records, as I said above, are not available to the public except as required by IRS laws regulating tax-exempt organization, and otherwise only as the Conservancy board members wish to provide voluntarily. This leaves a lot of information secret. The legislation requires annual reporting of “all revenues and expenditures of funds for the prior year, regardless of source.” However, the Conservancy has stated that it interprets this to mean simply the IRS reports as required of any tax-exempt organization.
10. The posting of the Guidelines for comment is inadequate in a crucial way; the fee schedule is not posted for comment, so the public is not being informed of this privatization.
11. The Conservancy lease violates the legislative intent, and possibly the constitutional Article 97 requirement for a 2/3 legislative approval. It should be terminated, and the park should be managed as an ordinary state park, with public funds, using competitive bidding for management contracts. It will be far less costly to the public, and we will get back our public space.