I know that town employees cannot respond via Lincoln Talk.  But this needs
a response somehow from the town.  If true, this would be extremely
concerning about the process and procedures.



> *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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