Two expert organizations on climate change and sea level rise have raised concerns regarding the proposed Lewis Wharf hotel project. The Boston Harbor Association (TBHA) and the Conservation Law Foundation believe the project would set a poor precedent for climate change preparedness on Boston’s waterfront.
The hotel buildings could be vulnerable to damage from extreme storms, according to TBHA who calls the plan an “unwanted precendent” on Boston’s waterfront. TBHA explains its position in a 6-page letter (pdf), including the following excerpts:
“The core issue at hand is one of “building in harm’s way.” … “In light of the speed and uncertainty of increases in climate change-related storms and sea level rise, we believe that the City’s granting a variance would set an unwanted precedent especially since the City is actively working to become better prepared for coastal flooding.” … “From a climate change perspective, it would be better practice to build any new buildings away from the water’s edge with an open space buffer to decrease storm energy.”
Regarding the 1991 Harborpark Plan used by the developer as the regulatory framework for its proposal, TBHA notes the dramatic increase in climate change awareness by the scientific community since the zoning plan was generated.
“First, in 1991 there was essentially no acknowledgement of the risk of coastal flooding due to climate change and corresponding related extreme weather and sea level rise. More significantly, there were no regulatory or permitting requirements reflecting sea level rise and climate change.”
“Second, the socio-economic context surrounding Lewis Wharf has changed, with much more residential development, leading to substantially more neighborhood opposition to this project than to the 1991 Gunwyn proposal of a similar size.”
The harbor association expands its thinking to the broader waterfront and favors public open space for the Lewis Wharf extension and for the parking lot on Sargent’s Wharf.
“Finally, since much of Boston’s downtown waterfront has been redeveloped since 1991, Lewis and adjacent Sargent’s Wharves represent two rare opportunities for high quality public open space that visually connect the street and the harbor.”
“For these reasons, we believe that the Lewis Wharf Project needs to go well beyond the 1991 standards.”
Lastly, TBHA addresses Chapter 91 requirements, highlighting the “limited opportunities for public waterfront uses” in the North End and raises the lack of water dependent use in the proposed hotel project.
A hotel is, by Chapter 91 definition, a non-water dependent use. As such, it is required to promote public use and enjoyment of the land to a degree that is fully commensurate with the proprietary rights and ensure that private advantages of use are not primary but merely incidental to the achievement of public purposes [emphasis added].
For this project to conform with the spirit and intent of Chapter 91 to keep the waterfront as a public benefit, it will need to be significantly scaled down and reconfigured.
[button link=”http://northendwaterfront.com/wp-content/uploads/2015/10/TBHA-Comment-Letter-PNF-to-BRA_Lewis-Wharf-Project-1.pdf” color=”aqua”]Read the full TBHA letter here (PDF)[/button]
In a separate intereview on BNN TV, Peter Shelley of the Conservation Law Foundation speaks out against the hotel proposal. The hotel proposal is ill-suited for its waterfront location, according to the CLF. Watch video of the TV segment shown below.
The Lewis Wharf project proposal remains under review at the Boston Redevelopment Authority. See this previous post for a status update.