Mr. Kairos Shen
Chief of Planning
City of Boston Planning Department
1 City Hall Square #9
Boston, MA 02201

Re: PLAN: Downtown – Protect and Preserve Sunlight for Boston’s Downtown Parks

Dear Chief Shen,

As the PLAN: Downtown zoning approaches a Board vote, the Friends of the Public Garden urges the City to codify stronger sunshine protections for Boston’s parks alongside the proposed zoning amendment to ensure our city’s built and natural environments can grow and thrive together. Without endurable safeguards for sunshine, the City risks casting a long shadow over the Common, the Public Garden, and the Commonwealth Avenue Mall, thus jeopardizing the health and vibrancy of our parks and people for future generations.

Approving new as-of-right building heights that jump from 155 feet to 500–700 feet disrupts the balance established by the State Shadow Laws, which were enacted 35 years ago in alignment with the lower building heights allowed at that time. With 500–700 foot heights, we believe as-of-right projects are far more likely to consume the maximum shadow allowances afforded for the former Midtown Cultural District. Each project’s impact will have a compounding effect on Boston’s iconic parks even while remaining technically in compliance with the State laws.

Local sunlight protections, on top of the State laws, are essential to address this imbalance. New regulations can incorporate updated shadow modeling technology and respond to current evidence-based understanding of the sunlight needs of urban landscapes and the people who use them throughout the year.  But timing and sequencing matter and passing this maximum build-out zoning first will make it much harder to introduce thoughtful limitations later. Furthermore, allowing Planned Development Areas to proceed without codified protections invites a piecemeal erosion of sunlight through incremental, parcel-by-parcel approvals. The Winthrop Square precedent demonstrates the willingness of the City to make exceptions, and once sunlight is lost, it cannot be regained.

While we support the City’s efforts to revitalize and activate our downtown, favoring near-term development benefits with little understanding of the permanent impacts is shortsighted. Our charge as a membership organization is to ensure that development is matched by equal care for our parks. We believe Boston can and must achieve downtown growth and development alongside healthy, sunlit public green spaces.

Boston is known for bold leadership, from creating America’s first public park and public botanical garden to shaping decisions that reflect our democratic and civic values. As we approach the 250th anniversary of the nation’s founding, the City faces a defining choice: honor our legacy by safeguarding the sunlight that sustains our downtown parks, or lose it for future generations?

The Friends share the City’s vision for a vibrant, growing downtown, but true progress requires equal commitment to our treasured green spaces. Boston can both grow and uphold healthy, sunlit parks. The current zoning amendment does not achieve that essential balance.


Liza Meyer
President


Leslie Singleton Adam
Board Chair

CC: Mayor Michelle Wu
Brian Swett, Chief Climate Officer, City of Boston
Ruthzee Louijeune, City Council President
Julia Mejia, City Councilor At-Large
Erin J. Murphy, City Councilor, At-Large
Henry Santana, City Councilor, At-Large
Gabriela Coletta Zapata, City Councilor, District 1
Ed Flynn, City Councilor, District 2
John Fitzgerald, City Councilor, District 3
Brian J. Worrell, City Councilor, District 4
Enrique J. Pepén, City Councilor, District 5
Benjamin J. Weber, City Councilor, District 6
Sharon Durkan, City Councilor, District 8
Liz Breadon, City Councilor, District 9
Aaron Michlewitz, Massachusetts State Representative
Jay Livingstone, Massachusetts State Representative
Lydia Edwards, Massachusetts State Senator