I am going to attach the email I sent to the Director of Planning, Jennifer Glass and Utile a few days ago at the bottom. I don't think there is any ambiguity in the wording of the guidelines and believe option E as sent would be compliant. However, we do not want to get bogged down on this issue. There is one simple fix to ensure contiguity, which we have offered repeatedly to the HCAWG, both in public meetings and via email. As per the email Sarah Postlethwait sent to LincolnTalk and Jennifer Glass last night in response to Jennifer's email, we are adding 2 Lewis St to Option E. It would have been more reasonable for Jennifer and Paula to contact us before posting that public notice and it would have been in keeping with Jim Hutchinson's public request that technical non-compliance issues for resident's proposals would be parsimoniously fixed.
I disagree with the characterization that option E is minimally compliant. Option E would allow for 113 units built (this excludes Battle Road Farm) an amount that is equivalent as a % of our existing units to Brookline's approved HCA proposal. Brookline's proposal was widely celebrated as a successful compromise between opposing groups. This doesn't even take into consideration the fact that the Village Center District rezoning would be presented separately at Town Meeting if Option E is chosen. There are options we could have presented which would have led to zero units developed as of right, but we decided not to do that because we want to put forward a compromise option that can satisfy as many residents as possible. I want to make clear that excluding N Lewis was not part of our original mission. It was actually a request from the Historical Society. A lot of us would have been comfortable including it, but we also realized that there is a good deal of fungibility in designing options. There are clearly folks in town who care deeply about our history, so we saw no particular harm in rezoning other properties instead. We could have dropped all of Lewis St, but that would have meant that Option E would have tilted perhaps too far for some in the no development by right direction. As to your point regarding development encroaching Codman Farm. I think there is a big difference between what we propose and options C-D. The biggest difference is that no re-development would occur at Doherty's, which is obviously the closest parcel to Codman Farm. Under the by-laws discussed for options C-D, a 48' 4-story building could be placed on that site. The same could occur at the Mall. The other difference is that for the Lincoln Rd/ Lewis St district we are a) limiting the height at 36' rather than 42' as per the by-laws discussed, and b) increasing the setback to 25' from 15'. On Thu, Nov 30, 2023 at 8:12 AM Carl Angiolillo <carlangioli...@gmail.com> wrote: > I appreciate Karla's clarifications, and her interpretation of the act > seems reasonable, however the wording is indeed ambiguous so I think there > is a possibility that the EOHLC could choose to interpret it differently. > (As evidenced by the recent email from Jennifer Glass) > > However, this part of the explanation particularly stuck out to me: > > > The only impact of having a discontiguous piece of Lincoln Rd that is > less than 5 acres is that those 2.7 acres do not count towards our minimum > requirement of 42. This is not an issue as option E adds up to 56.9 acres > not including the 2.7. > > In that case I am unsure why those four non-contributing lots were > included in Option E. It seems like it would have been simpler to exclude > all of Lewis street and then pick up another fifty or so units of modeled > multi-family capacity by adding a couple units per acre at Battle Road > Farm, especially if these are unlikely to be built anyway as per the > Lincoln Residents for Housing Alternative website. > > First, objections levied against Options C and D (including from LRHA > supporters) included the specter of multi-story buildings overlooking > Codman Farm and the sensitive environment in and around the Codman Corner > area. Including North Lewis seems to subject option E to the same > objections. > > Second, even if one is reasonably confident that the EOHLC will permit > discontinuous subdistricts, that still leaves a small chance they will not, > potentially forcing the inclusion of the historic Lewis Street lots. > > Third, the LRHA group seems to have given thoughtful consideration to each > area included or excluded, and my sense is that otherwise Option E has been > intelligently designed to be minimally compliant in order to retain as much > town control as possible. In that light, including additional acreage seems > out of place. > > Note that I'm not arguing against including these lots; on balance I > personally lean towards including them as well as the rest of Lewis Street. > I'm just working my way through all the compliance options and trying to > better understand the factors behind the decisions. > > Carl > > > On Fri, Nov 24, 2023, 10:02 AM Karla Gravis <karlagra...@gmail.com> wrote: > >> *Question 1* >> >> The guidelines allow for the setup in Option E. There is no need for the >> Lincoln Rd/Lewis St parcels to be contiguous. The Compliance Model User >> Guide shows an example that deals directly with the same contiguity point >> we are discussing. >> >> https://www.mass.gov/doc/compliance-model-user-guide/download >> >> >> District 1 is comparable to our Lincoln Rd in that the (sub)district is >> made up of non-contiguous pieces, yet when calculating contiguity district >> 1a is added to district 2. In our example, Lincoln Rd east of the tracks is >> added to Ryan Estate and to Lincoln Woods, which gives us a total of 32.7 >> acres of contiguous land in the multi-family district, well over 50% of the >> total. >> >> Part of the confusion comes from the loose use of the words district and >> subdistrict found in the User Guide, which has also permeated the WG’s >> exposition. It is important to note that when the guidelines talk of >> “multi-family zoning district”, it is the entire HCA district. The >> guidelines only provide a definition of district as “multi-family zoning >> district”: >> >> *“Multi-family zoning district” means a zoning district, including a base >> district or an overlay district, in which multi-family housing is allowed >> as of right; provided that the district shall be in a fixed location or >> locations, and shown on a map that is part of the zoning ordinance or >> by-law.* >> >> While there are more than a hundred uses of the word district as in >> “multi-family zoning district”, there is only mention of “subdistrict” in >> the entire guidelines, which is found in 5.c, and deals with an unrelated >> issue: >> >> *(i) the unit capacity of residential dwelling units in the mixed-use >> development district or subdistrict (as calculated by EOHLC using a >> methodology similar to that in section 5(d) which takes into account the >> impact of non-residential uses),* >> >> It is a bit unfortunate that the EOHLC did not define what they meant by >> subdistrict, but it does not really matter to our purposes. >> >> Armed with the proper definition of the word district as used in the >> guidelines, we can now check the only contiguity requirement, found in >> 5.a.(ii): >> >> *In all cases, at least half of the multi-family zoning district land >> areas must comprise contiguous lots of land. No portion of the district >> that is less than 5 contiguous acres land will count toward the minimum >> size requirement. If the multi-family unit capacity and gross density >> requirements can be achieved in a district of fewer than 5 acres, then the >> district must consist entirely of contiguous lots.* >> >> Option E’s multi-family zoning district is more than half contiguous. The >> only impact of having a discontiguous piece of Lincoln Rd that is less than >> 5 acres is that those 2.7 acres do not count towards our minimum >> requirement of 42. This is not an issue as option E adds up to 56.9 acres >> not including the 2.7. >> >> *Question 2* >> >> When an area is included in HCA there is a probability of redevelopment. >> Once a district is rezoned, in this case to 18 units/acre, the value of >> tearing down the buildings and redeveloping increases. By including this >> historic district as part of HCA rezoning, there is an enhanced risk that >> those historic buildings will be lost to redevelopment. >> >> It would be useful for the Chair of the Historical Commission, who is >> also a member of the WG to clarify the WG's stance. Are the buildings worth >> protecting or not? If they are worth protecting, they should not be >> included as the risk of tear down and redevelopment increases. The only >> reasonable explanation seems to be that the WG considers the redevelopment >> of these parcels to be of greater utility than the historical value of said >> buildings. >> >> >> >>> From: Carl Angiolillo <carlangioli...@gmail.com> >>> Date: Fri, Nov 24, 2023 at 08:21 >>> Subject: Re: [LincolnTalk] Mass. Investment in Communities that Build >>> Around Commuter Rail Stations >>> To: ٍSarah Postlethwait <sa...@bayhas.com> >>> CC: Lincoln Talk <lincoln@lincolntalk.org> >>> >>> >>> I love learning new things about town and appreciate Sarah's attachment >>> with the history of Lewis St. But it also raises a few questions. >>> >>> > North Lewis was excluded [from Option E] at the request of the Lincoln >>> Historical Society since every property on the North side of Lewis is >>> considered Historical >>> >>> First, omitting the historic lots (e.g. the building with the Clark >>> Gallery, the Food Project building, 14 Lewis, and the Pickle Factory >>> buildings) seems to make the lots across the street on the south/west side >>> of Lewis St discontinuous with the rest of the subdistrict. Does that >>> present a compliance issue for Option E? (I recall the Housing Choice Act >>> Working Group including a few lots in Options C and D primarily for >>> continuity reasons.) >>> >>> Second, does rezoning a historic building under the HCA reduce it's >>> protection and if so to what degree? >>> >>> Third, did the Lincoln Historical Society (Sara Mattes et al) or anyone >>> else make a similar request to the Housing Choice Act Working Group to omit >>> these lots from options C and D and if so what was the reason for including >>> them anyway? >>> >>> Carl >>> Codman Rd >>> >>> P.S. Apologies if these questions have already been answered, I am not >>> confident I have read all of the emails flying back and forth. >>> >>> >>> >>> On Wed, Nov 22, 2023, 9:05 PM ٍSarah Postlethwait <sa...@bayhas.com> >>> wrote: >>> >>>> My parcel is included in every single proposal from the HCAWG and >>>> option E. I am affected if every single option gets passed. And if I >>>> fought to exclude my land you would call me a NIMBY (as many already have). >>>> >>>> I do not look forward to the implications of being rezoned and having >>>> properties being sold around me affecting my property value and raising my >>>> taxes, but I am willing to do so to avoid having something as drastic as >>>> option C to be passed, which allows over 1100 units to be built in south >>>> Lincoln. >>>> >>>> Both North and South Lewis Street were included in option E originally >>>> since Lewis Street has been discussed to be rezoned for decades AND it’s >>>> included in every other proposal from the town. However North Lewis was >>>> excluded at the request of the Lincoln Historical Society since every >>>> property on the North side of Lewis is considered Historical. >>>> >>>> If you would like to learn more about the historical significance of >>>> North Lewis Street, I would highly recommend the attached article. >>>> >>>> Sarah Postlethwait >>>> >>>> Lewis Street >>>> >>>> Proponent of option E >>>> >>>> >>>> >>>> On Wed, Nov 22, 2023 at 7:30 PM Lis Herbert <lisherb...@gmail.com> >>>> wrote: >>>> >>>>> It would likewise be much more transparent for proponents of E to >>>>> identify themselves and their respective properties within the boundaries >>>>> that have been drawn on Lewis Street, which appear to comprise just a >>>>> handful of lots. >>>>> >>>>> Sent from my iPhone >>>>> >>>>> On Nov 22, 2023, at 6:32 PM, ٍSarah Postlethwait <sa...@bayhas.com> >>>>> wrote: >>>>> >>>>> >>>>> >>>>> Are you also speaking as a member of Fin comm? >>>>> >>>>> It would be much more transparent if members of town boards would >>>>> include their respective board in their email signature when commenting on >>>>> town matters in LincolnTalk (especially when voicing your own biased >>>>> opinion). >>>>> >>>>> It’s also worth noting that we are currently in compliance, and will >>>>> be for all of 2024 and qualify for all the funds being discussed. >>>>> If our water mains can’t last a couple more months after December 2024 >>>>> until the town is able to make an informed decision, then why haven’t we >>>>> applied for these funds now while we are still in compliance? >>>>> >>>>> This rush towards December 2024 is unnecessary. Especially when 4 >>>>> story 48’ buildings with no lot limits (besides 25’ setbacks) at the mall >>>>> are being discussed in planning board meetings… >>>>> >>>>> Sarah Postlethwait >>>>> >>>>> >>>>> >>>>> On Wed, Nov 22, 2023 at 5:47 PM Rich Rosenbaum <s...@bcdef.com> wrote: >>>>> >>>>>> >>>>>> *It’s a little like asking us to make a YUGE leap of faith.* >>>>>> >>>>>> An alternative would be to take a different leap of faith that none >>>>>> of the following happen: >>>>>> >>>>>> - we end up delaying so much that we miss the deadline for complying >>>>>> - we no longer qualify for state funding for needed repairs and >>>>>> replacement of our past-the-expiration-date water mains >>>>>> - we end up with a bond to pay for a very, very large bill to keep >>>>>> clean water flowing to our faucets >>>>>> >>>>>> Rich >>>>>> (speaking as a citizen of Lincoln) >>>>>> >>>>>> >>>>>> On Wed, Nov 22, 2023 at 5:01 PM Sara Mattes <samat...@gmail.com> >>>>>> wrote: >>>>>> >>>>>>> Amen. >>>>>>> It’s a little like asking us to make a YUGE leap of faith. >>>>>>> It makes the argument that we should proceed with extreme caution >>>>>>> and not make any changes where these questions might come into play, >>>>>>> esp. a >>>>>>> challenge to our wetlands bylaw. >>>>>>> >>>>>>> >>>>>>> ------ >>>>>>> Sara Mattes >>>>>>> >>>>>>> >>>>>>> -- >>>>>> The LincolnTalk mailing list. >>>>>> To post, send mail to Lincoln@lincolntalk.org. >>>>>> Browse the archives at >>>>>> https://pairlist9.pair.net/mailman/private/lincoln/. >>>>>> Change your subscription settings at >>>>>> https://pairlist9.pair.net/mailman/listinfo/lincoln. >>>>>> >>>>>> -- >>>>> The LincolnTalk mailing list. >>>>> To post, send mail to Lincoln@lincolntalk.org. >>>>> Browse the archives at >>>>> https://pairlist9.pair.net/mailman/private/lincoln/. >>>>> Change your subscription settings at >>>>> https://pairlist9.pair.net/mailman/listinfo/lincoln. >>>>> >>>>> >>>>> >>>>> -- >>>> The LincolnTalk mailing list. >>>> To post, send mail to Lincoln@lincolntalk.org. >>>> Browse the archives at >>>> https://pairlist9.pair.net/mailman/private/lincoln/. >>>> Change your subscription settings at >>>> https://pairlist9.pair.net/mailman/listinfo/lincoln. >>>> >>>> -- >>> The LincolnTalk mailing list. >>> To post, send mail to Lincoln@lincolntalk.org. >>> Browse the archives at >>> https://pairlist9.pair.net/mailman/private/lincoln/. >>> Change your subscription settings at >>> https://pairlist9.pair.net/mailman/listinfo/lincoln. >>> >>> -- >> The LincolnTalk mailing list. >> To post, send mail to Lincoln@lincolntalk.org. >> Browse the archives at >> https://pairlist9.pair.net/mailman/private/lincoln/. >> Change your subscription settings at >> https://pairlist9.pair.net/mailman/listinfo/lincoln. >> >> -- > The LincolnTalk mailing list. > To post, send mail to Lincoln@lincolntalk.org. > Browse the archives at https://pairlist9.pair.net/mailman/private/lincoln/ > . > Change your subscription settings at > https://pairlist9.pair.net/mailman/listinfo/lincoln. > >
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