*Executive Summary:*
- I identified a series of mistakes in the Option C proposal submitted to the State for compliance check. Option C as presented in the SOTT and approved by the Boards for submission rezoned 70 acres of land. The model that was sent to the State rezoned 88 acres, 18 acres more. After reviewing with our consultant Utile, the mistakes were confirmed by our Director of Planning. For reference, the State is asking us to rezone 42 acres. - The model sent to the State states the maximum number of units that can be built in Lincoln as a result of the rezoning is 1,679. The State is asking for 635 units. - The HCAWG’s decision to include so many parcels near wetlands is the main reason for this very high number of units. - Public land, for example the DPW, is unnecessarily included in our option C proposal. This has the impact of lowering our gross density, which is one of the State's requirements. - Options C and D1-D3 create an incentive for massive redevelopment of Lincoln Woods. This could be avoided with no impact to compliance. It seems that the density denominator used for Lincoln Woods is wrong as well. - Options D1-D3 presented last night rezone 60-75 acres and could also lead to >1,000 units built. - More foresight has been applied to the proposals our resident group has prepared: the maximum number of units built is exactly the same as the compliance requirement (~635). 7 of these proposals have more than 20% units near Lincoln Station. *Findings* Following multiple requests by residents over the past week, the HCAWG finally released the Option C submission to the public yesterday. The details of the model were surprising: *about 18 more acres of land were included in what was sent to the State than what was presented to the public and approved by the Boards. A number of parcels along Lincoln Rd that were never part of any district presented to the public were added to our submitted proposal*. While the parcels do not provide credit towards compliance, their inclusion would lead to up to ~325 incremental units given the unit per acre cap. I alerted the Director of Planning of the discrepancy. After she checked with our consultant, Utile, I was informed that the inclusion of those parcels had been a mistake. This revelation raises a few questions: - *Are we submitting rezoning proposals to the State prepared by a third party without reviewing them?* - *Is there someone in the Administration or the HCAWG who has studied the model and understands how it works?* - *Who is driving the decisions about our district design? Utile or appointed officials?* The State uses a very basic model to calculate the maximum building footprint of any parcel. First, any wetlands are excluded. Then, 20% of the gross acreage is also taken out as “open land”. Finally, 45% of the remainder is considered parking spaces – note the irony that we are fantasizing about a car-free neighborhood and the State is assuming parking space will take almost as much land as the buildings*. It is extremely punitive to include parcels with a big wetland presence. Either Utile did not communicate the message or our WG/staff did not digest it, as we could not have come up with a more wetland-heavy district.* Option C includes *over 40 acres of parcels for which we get no credit from the State*, which we could drop from our proposal with no repercussions. We are *unnecessarily including 6 acres of public land, even conservation land, most of which is the DPW, which could have been left out altogether.* Including all that unnecessary public land lowers our gross density. It is important to note that just because the State does not give us credit in modeling does not mean that those parcels could not be developed at some future date to the maximum number of units per acre they have been rezoned to, perhaps in combination with other parcels. There are more surprises. Option C would allow TCB, the owner of Lincoln Woods, to build up to 403 units in that parcel. It is important to understand that the maximum number of units per acre applies to all the land in a parcel, not just the developable land. *TCB could in time evict all tenants, tear down all of the 125 two-story semi-detached housing units, and build one or more massive three-story buildings in their parcel with a lot more units.* The fact that the affordability restriction for Lincoln Woods ends in 2032 makes that possibility all the more real. This threat can be avoided if the WG puts a cap of 7 or 8 units per acre rather than 20. The Town gets absolutely no compliance benefit from having that higher cap since it is only modeling 159 units. *Why are we rezoning Lincoln Woods at 20 units per acre if we get no additional credit from it?* It is worth noting that the developable land in Lincoln Woods had been presented as 7.0, last night it jumped to 7.6, but if we look at the model submitted it only adds up to 6.2. It looks like either the number of units calculated for Lincoln Wood or the gross density are wrong. Putting it all together, we get an alarming vision of the potentialities of the rezoning exercise. The table below is a screenshot from the model submitted. *Up to 1,679 units could be built within 0.5 miles of Lincoln Station*. That is 80% of the existing total number of units in Lincoln (ex. Hanscom). I realize this is a worst-case scenario, by *why are we even talking about this risk?* All of this can be avoided if a little bit more thought is applied to the proposals. [image: image.png] *Proposals D1-D3 presented last night suffer from the same deficiencies. All of them would enable up to well over 1,000 units built in Lincoln.* *The proposals our group of concerned residents put together and have presented to the WG, PB and SB do not have any of these problems. The modeled capacity of our proposals, 7 of which have more than 20% of units and land in Lincoln Station, exactly matches the maximum number of units that could be built.* David Cuetos Weston Rd
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