The following letter was submitted to The Sun from the Secretary of the Commonwealth’s office
Dear Chairman Moore,
I want to express my appreciation for your Committee allowing me the opportunity to have the professional staff of the Massachusetts Historical Commission evaluate the impacts of the high-rise construction, which would be authorized by this legislation.
As the Chairman of the Massachusetts Historical Commission I have a responsibility and obligation to protect historic sites throughout Massachusetts, however the affected sites of this proposed construction are among the most important and significant, including the State House itself.
I must report to you that after a careful review of the submitted Millennium shadow study and the shadow study commissioned by the Friends of the Public Garden, as well as other recent studies commissioned in conjunction with other construction projects, it is the conclusion of the Massachusetts Historical Commission that the construction of this building at its proposed height would do great damage to historic buildings included on the National and State Registers of Historic Places including the State House, public parks and private residences.
It is important to note that the shadow study presented by Millennium
Partners is incomplete and therefore flawed.
This shadow study presented by Millennium Partners only depicts 6 individual days of the year with a disclaimer that the study is only “approximate” and that “further studies will be conducted.” Because of the few dates it shows, it under-represents the full extent of the added new shadow. It also only shows new shadow on the Boston Common and Public Garden, omitting the reach of the new shadow on the State House and Beacon Hill.
Millennium Partners conceded that if built, the Tower would add 282 days/year of new shadow on the Boston Common and 112 days of new shadow on the Public Garden.
The Friends of the Public Garden conducted a separate shadow study for each month of the year and showed the following dramatic results.
If built, Winthrop Square Tower would cast a morning shadow stretching from Winthrop Square in the financial district, down the middle of Boston Common, through the heart of the Public Garden (including the Swan Boats) and onto the Commonwealth Avenue Mall in the historic Back Bay- a distance of roughly one mile. Additional new shadow on the Common would occur every month from February through October.
If built, the Tower would also cast new shadow on the State House and historic buildings on Beacon Street and in the Beacon Hill Historic District in the months of January, February, October and November (about 120 days/year) making the short days even darker for the occupants of the State House.
The month of March would see the greatest extent of new shadow across the Common, which would negatively impact the winter thaw and beginning of spring growth.
New shadows would continue through the spring, summer and fall, which will impact the growth and health of trees and other vegetation.
The Boston Common and Public Garden are not only beloved by the city, but are national treasures and focal points for tourism. They are listed in the State and National Registers of Historic Places, and are both City and National Historic Landmarks.
More significantly, in light of the millions being spent on historic rehabilitation, new shadows on the State House and other historic buildings on Beacon Hill would create permanent moist conditions on the exterior walls and interiors of the buildings – problems that would need additional funding to rectify (e.g., repairing spalling plaster on interior walls and ceilings, repairing lost mortar on exterior walls).
Consideration of this bill is premature since the full extent of all of the environment impacts of the Tower have not yet been studied or publicly disclosed. The project has not completed the MEPA review process. MEPA scoped an EIR, but the EIR has not yet been completed.
In addition, there are many unanswered questions about the full impact of the Tower- such as will it create more wind along the surrounding city streets?
For the protection of these valuable public assets I urge you to at least postpone further consideration of this legislation until these critical questions are asked and thoughtfully answered.
My staff will be available to answer any specific questions you might have.
Sincerely,
William Francis Galvin
Secretary of the Commonwealth