Hot off the Press! New Design Guidelines
The new design guidelines draft is now available (afternoon of July 29) for the August 1 Ordinance Committee meeting. The document boils down to a short, 14 page single spaced word file without the photos. But the small size of the document belies how truly massive these structures are assumed to become. Remember this is the 3rd or 4th or 5th most dense city is the country for a population above 100K AND we are one of the oldest cities, founded in 1630 so a lot of historic buildings will have to be bulldozed to make this happen and a lot of current tenants will have to be forced out - and onto the massive affordable housing lists to do this. It is all very stunning (and not in a good way).
Text (language) evokes lots of flexibility and wishful thinking. Basically the developers are asked to "consider" thisor that, with very few specific requirements. The whole document comes in at a staggeringly low 5.811 words -the equivalent of a short term paper. Compare this to the 100 plus page documents posted by other cities for form-based design criteria guidelines in communities elsewhere. Detailed design requirements are necessary if this is to be as-of-right with no real checks and balances.
Photos, renderings, and plans show that these affordable housing developments are intended to be massive. It is hard to imagine how these would fit in to the various residential neighborhoods west of Mass. Avenue where 78% of them are intended to be built as indicated in the City Manager's report. The massiveness of the scale of these also makes one think that the west of Maaa. Ave push may indeed be partly a lost leader, that the bulk of these new units are intended to be built on those sites where the four companies who have the support of the Cambridge Affordable Housing Trust to undertake AH projects here (Just A Start, Homeowner’s Rehab, the Cambridge Housing Authority, and Capstone/Hope already have properties and own the land.
This would greatly diminish the non-profit and for-profit developers costs to build (or in this case rebuild much taller, bigger and denser structures, as of right. Trolley Square north of Porter, where CDD held its last meeting now is only two stories, but because it is adjacent to Ma. Ave could easily be rebuilt as a 7-story development extending to near the property lines. Since it already is beginning to show a lot of wear maybe this is part of the plan. This is not to say that ares west of Mass. Ave are out of the city manager's eyesight for massive AH developments, but as one developer revealed recently, if the AHO passes the city is expecting a "s...storm" of lawsuits and given both the property values and the pocketbooks, this is far more likely to come from West Cambridge residents and in some other parts of the city.
Specific Design Criteria
(Organized thematically in the Document)
On Green: Lots of pretty pictures of nice new green spaces, but where in a city this dense will these green spaces be added: Affordable Housing Developers focused on the bottom line are clearly not going to care about this, nor is the city going to buy properties from citizens simply to have more green spaces.
On Context: Developers are asked (2.9 to "Consider the location" but there are no requirements specifically to do so.
On Traffic: The AHO PLAN will significantly add to traffic because, as noted in (3) their intent is to "Promote non-motorized mobility by prioritizing pedestrian-friendly and bike-accessible site design" and in (4) "Minimize the detrimental impact of parking aND driveways on residents, neighbors, and the general public." Good luck in Dec-Mar when snow impedes, or those who work at night, or in places outside the city, or have multiple jobs, or children, or have disabilities.
On Unsightly Utilities (5) Many will be on the roof tops, adding an additional level of height intruding on the neighbors; if not on the roof, "where possible" not at the front of the building (no specific placement requirements.
On Outdoor Lighting (6): Please be ready for bright lighting surrounding these developments, regardless of neighborhood. They will be VERY visible "for safety and functionality" - and for better "allowing open spaces to be usable in the evening, illuminating signage, or subtly accentuating key architectural elements." And this lighting will also add to the roof scale in the encouraged use of "photovoltaic panels to power lighting."
On Public Art (7) -encouraged. But nothing on selection criteria, competitions, judges - which would be important for a first class program.
On Building Design
(1) Massing: Be ready for change "massing should be compatible with the prevailing or desired pattern of neighboring buildings." This basically allows anything, as also in "Consider reducing the visual impact of taller buildings by using stepbacks...." These are just suggestions, nothing is required. Similarly the developers are requested to "Adjust building configuration and massing to maximize access to sunlight, air, and sky views from neighboring buildings and sites, and to maintain privacy." Yet nothing here stops them from interrupting sunlight or removing sky or other views. In another example: (1.9 )Where a neighboring residential building is located very close to the lot line, consider adjusting building’s footprint...." Nothing required.
(2) Facades: "Building facades should enhance and enliven the public realm." (pretty mushy). And, "2.1 Consider Cambridge’s architectural history, heritage, culture and regional significance...." Again, no requirements. 2/9 "2.9 Avoid incorporating extravagant or exaggerated building elements or features..." This keeps down costs. " 2.22 "Wherever possible, screen parking with programed spaces with functions that enliven the street facades." Nothing is required. 2.26 In renovating or adding to an existing architecturally or historically significant building, or where original materials... use traditional building elements with the same architectural features, material quality and craftsmanship. If not feasible, substitute with style-neutral high-quality...." Again, not required.
On Sustainable Design: To design projects with energy efficiency, health and wellness in mind. The removal of mature trees is fine. " 1.4 While trees are preferred, where they are not feasible consider the use of shading devices such as canopies, awnings, or pergolas...." So much for protecting the tree canopy and addressing global warming.
In short: as with many documents what we see in the CDD's new Design Guidelines reveals quite a lot about how this process is intended to unfold, even (and especially) if it is short of specific requirements.
Who Qualifies for AHO Housing?
[UPDATED: to reflect new June 28, 2019 HUD AMI Data] The housing in the proposed Affordable Housing Overlay (AHO) is intended primarily for low income residents, those earning c.$54,800 ($63,450) annual salary for one person, or 80% of the Area Median Income (AMI) according to June 20, 2019 CDD documents for the AHO.* For initial occupancy at least 80% of the occupants must be at or below 80% of AMI (1-person earning $54,800 or less). All the remainder must be less than 100% AMI (1-person: $68,500).** Most of these tenants will be near this 80% AMI target, since Section 8 housing is in place for lower income thresholds (e.g. 30% AMI identifies as being “extremely low income” or 50% AMI identified as being “very low income.”
Housing financial numbers published by HUD June 28, 2019 after the CDD report was published on June 20, raises the city's 80% AMI salary to $63,450.*** This same document identifies the City's 50% AMI (for inclusionary) as $39,650; HUD 50% AMI (for CHA Housing Choice Voucher) as $41,500 and the City's 100% of AMI (Homeownership resale Pool and Homebridge ) number as $79.300. These new salaries are indicated in parentheses in the examples below.
What do these salary numbers really indicate? Like the term "affordable housing," median salaries resemble pizza dough, they can be stretched or contracted to meet pretty much any set of desires or needs. And like pizza everyone likes affordable housing. The same kind of malleability also is true with terms such as middle Income. An Article in the November14, 2018 Business Insider identifies Boston as having a "Middle-Class" salary range of $57,127 to $171,382. The Boston median income is listed in this source as $85,691, considerably higher than the HUD or CDD AMI salary of $54,800 ($64,450) on which the City's Affordable Housing salary determinations will be made.
Who will find housing here in the new AHO units? Some of these people will be individuals in need who do NOT live in Cambridge or even Massachusetts because as a recipient of Federal Funding, these projects must advertise nationally for residents. The current list is some 19,000 people long. Those Cambridge residents who make too little money also will not qualify for this funding, e.g. those between 0 and 50% AMI. In short Very VERY few current residents will qualify and benefit from this very expensive and deeply flawed proposal.
LET’S PLAY A GAME …
to see which professions in the city will do OK by the radical city-wide up-zoning and massive expenditure of tax-payer money.
Go to Salary.Com to explore other average Cambridge salaries (as of June 27, 2019). Who would qualify for this - and for how long?
HOW DO YOU FARE?
HOW DO OTHER PEOPLE YOU KNOW FARE?
IS THIS PLAN WORTH THE CITY PAYING $500,000 OF YOUR TAX DOLLARS
There are many far better, smarter, and more effective ways to add more affordable housing here, and as you know, Cambridge is already way ahead of state mandates for this.
*The city of Cambridge will calculate income level eligibility for these proposed AHO Dwelling Units:
(i) The gross household income of an AHO Eligible Household upon initial occupancy shall be no more than one-hundred percent (100%) of AMI.
(ii) At least eighty percent (80%) of AHO Dwelling Units shall be occupied by AHO Eligible Households whose gross household income upon initial occupancy is no more than eighty percent (80%) of AMI.
**What the city’s AMI percentages mean in terms of actual salaries:
HUD 80% AMI 1-person: $45,500; 2-person: $52,000; 3-persons: $58,500; 4-persons $65,000
Income limit for most affordable housing programs
City 80% AMI 1-person: $54,800; 2-persons: $62,640. Ami; 3-persons: $70,480 AMI, 4-
persons $78,240. Income limit for City Inclusionary Housing program
100% AMI 1-person: $68,500; 2-persons $78,300; 3-persons $88,100; 4-persons $97,800
Income limit for FTHB Financial Assistance program
120%AMI 1-person: $82,200; 2-persons: $93,960; 3-persons: $105,720; 4-persons: $117,360
Income limit for existing City middle-income homeownership units.
***2019 HUD Income Limits, Cambridge MA. CDD and HUD Average Median Income (AMI) Numbers June 28, 2019
City 50% AMI (for inclusionary) $39,650
HUD 50% AMI (for CHA Housing Choice Voucher) $41,500
HUD 80% of Median (most private and non-profit affordable housing) $62,450
City 80% AMI (Middle Income and inclusionary rental housing program) $63,450
100% of AMI (Homeownership resale Pool and Homebridge ) $79.300
City 120% of Median (Home Improvement program; Middle income rental program) $95,150
Above are HUD and City AMI data from June 28 Report. Below are HUD AMI data from CDD's June 20 report
The Citywide Up-zoning Plan for more Affordable Housing
How did we end up here?
What are the core concerns?
Cambridge citizens lobbied for a Master Plan – we still don’t have one! The Affordable Housing Overlay (AHO) is not what we asked or paid for. Instead this was taken over by Cambridge's Community Development Department (CDD) and this section of the Envision process was largely written by affordable housing developers; CDD and the City have not listened to alternative approaches that would do far more to address affordable housing and root causes of the current problem.
The AHO is a radical plan that was rushed ahead of all the other Envision concerns (some of which contradict key elements in the AHO). The people of Cambridge feel very let down. At neighborhood meetings citizens have opposed the Overlay 4 to 1; many others remained confused. The large majority of Cambridge neighborhood groups who have written to council on this issue OPPOSE the AHO as written, yet we all strongly SUPPORT affordable housing. We want it done in a way we can be proud of.
We all believe we must create more affordable housing. But this plan is far too risky. Why take this risk?! It does not address root causes (and impacts). Current gentrification impacts. Some 17% loss of African American In the Port. We need a sure plan that will address both causes AND specific context-based plans going forward.
Cambridge has met and surpassed our affordable housing and other development needs effectively through this means & citizens effectively advocate for design & other issues. The AHO represents a major shift in both policy and precedent and it moves us in a direction that no other city has gone!.
The Affordable Housing Overlay
The AHO removes key Planning Board design oversight (review only); Limits checks & balances. The AHO rushes the design review process. The AHO removes both citizens right to both legal appeal & meaningful input in design issues. The AHO Design Oversight (final decisions) are given to CDD, the Affordable Housing Trust, and Developers. AHO does not address the real problem (influx of new businesses & higher paid employees; gentrification & luxury housing glut); 14% vacancy in E. Cambridge units attests to this).
AHO Developers will receive differential treatment from other developers – as well as from citizens seeking changes. Only one type of builder/owner will be allowed to own/construct. And the only type of unit allowed is not currently allowed in A-1. (Note Palo Alto’s plan was to only build in places where there were no houses). There is a major danger here that buildings that should NOT be built will be, and these will end up in court. There is a real risk of mistake. Allowing 3-4 (or greater) times the density allowed in some places currently envisioned is just wrong. Low low- income earners and middle income earners are left out; one cannot take a better job and stay in this housing. Economically segregated housing is not equity, especially when housing form & materials are visually distinct from others. We URGE the Planning Board (and City Council) to send this Overlay Proposal back to be rethought and then resubmitted in a format we can all proudly get behind.
Disproportional AHO neighborhood impacts
*The Same zoning code likely will have radically different impacts in city neighborhoods (based on manager’s report).
Some 77.83% of all city properties tagged in manager's report for likely AHO projects are west of Mass Ave. (based on sales in Table II)
40.68% West Cambridge
17.37% from North Cambridge
15.68% from Neighborhood 9 (Avon Hill, Porter Sq etc.)
4.10%. Strawberry Hill –Grove St
77.83% is a stunning figure and many of these areas are far from public transportation hubs.
According to the Manager's report's Table 1 Competitiveness Data: the most likely areas where properties for these massive 4-5 story housing developments will be in
-Strawberry Hill - 100% competitive
-Professors Row (Agassiz – nr. the Divinity School) – 100% competitive
-Coolidge Hill - 80% competitive
-Brattle Street area – 57% competitive (NOTE: Brattle St. itself is in an Historic District so facades cannot be changed
-Concord Ave area – 33%
-Huron Ave area– 25%
-Riverside - 17% competitive
-Cambridgeport - 20% competitive
The areas west of Mass. Ave are often large properties, with many mature trees, historic homes, and l green spaces. To build large AHO projects here, there will be significant citywide environment losses (green spaces, mature trees, historic residences)
Questions around the Manager’s Report
-In the Manager’s Report, West Cambridge is reported in 4 distinct areas –Brattle, Huron, Concord, Coolidge Hill. Why?
-The manager’s report co-joins Wellington-Harrington (W-H) AND The Port – Why? What is the actual count for each??
-MIT and Cambridge Highlands have no data in the report. Why?
SITE RENDERINGS: GENERAL CONCERNS
All 4 the CDD models are on empty lots (no trees, houses): most are on corridors and 1/2 are on corners. There are no examples for current A-1 zoning These are well drawn but are not representative examples Nearly all of the units have no parking, yet they may be outside ¼ mile of the subway entry. Many people will be circling for parking so they can get to work in outside areas or at odd hours. Major environmental & livability impacts. There is no requirement for green spaces in the AHO (instead all are simply “open” spaces – concrete or asphalt) There is no requirement to preserve of mature trees. In manager’s report: resident displacement is not a concern. Yet many displaced cannot move back based on income. The AHO does not address displaced businesses. Many will go under or be forced to leave, leaving neighborhoods without key amenities.
Site 1: Now an Empty Lot. To be 4 stories plus rooftop mechanicals. No Parking. Front 10’ setback does not
include covered entry. Side 7.5’ setback does not include bump-out. No room for green spaces.
Site 2: Now an empty lot. On a major corridor. 80 feet tall plus mechanicals. For 37 (or 34) units. No Parking Spaces. No front or side setback. 20 feet rear setback. 1 version has 16 below-ground parking spaces
(1 for every 2 units). Who would get them? Possible cause of conflict.
Site 3: Now an Empty Lot. Corner property. 88 units. No Parking. 4 stories plus roof mechanicals. Front bump outs likely not included In setback at front. One version has less open space.
Site 4: Now Empty Lot. Corner property. Likely on a major avenue. 4 stories. 9 or 10 units. No parking.
No setback on either of front sides. 7.5’ setback on 2 other sides. Bump outs not included in setbacks.
Dwarfs adjacent houses
We URGE the City Council and Planning Board to send this Overlay Proposal back to be rethought. We can and must do better, and once we get a progressive and smart proposal with the kind of cross-neighborhood citizen impact we should expect here. We will come back and proudly and strongly support it!
Several days ago the City of Cambridge sent out these postcards to city residents. These cards seem to have gone out in several batches, but this one was received on July 23. On this side of the card we read the core arguments the city is using to support the up-zoning proposal that is being rushed through towards a September vote.
Cambridge citizens have yet to be provided with any information on the Affordable Housing Overlay's core design guidelines. This will presumably come at the August 1 City Council Ordinance meeting. Unfortunately Cambridge citizens likely will not have had enough time between their formal submission and the Ordinance Committee meeting to critically evaluate these guidelines before our allotted 3 (or more likely 2) minutes of time to voice any lingering concerns we have at this meeting. Hardly a well thought through community and democratic process
The city's decision to send this postcard also seems to many of us as yet one more example of their continuing propaganda campaign, at the tax payer's expense, to promote this deeply flawed proposal.
Missing on this postcard advertisement is any mention of how tall these units would be - 4-5 stories - allowable as of right in every neighborhood citywide, or 7 stories if the building is already 4 stories. No where on the card does it say that potentially a significant number of mature trees and green spaces will be removed so that these housing projects can be as large (dense) as possible by maxing out square footage within the property.
Missing on this postcard is any mention of what many of us are learning, through other sources, that the City is seriously LOW-BALLING the number of these units that will be built in the new stream-lined (greatly relaxed) process, or that the unelected City Manager (in part in his role as Chair of the Cambridge Affordable Housing Trust) will control this whole endeavor, funneling taxpayer resources to the four or so favored developers, presumably excluding most everyone else.
Why the stark lavender design of empty tall buildings at the lower right? For some, this recalls the shells of buildings constructed by global real estate investors and developers in places like Vietnam that sit there, empty of local inhabitants, while the pockets of the builders and investors fill to capacity.
Above is the front of the card, with various resident groups and areas being coded differently. We learn some of the key upcoming dates, August 1 especially.
Missing here is September 9 when the City Council likely will first vote on this up-zoning plan.
Missing here is September 23, the likely date of the Council's second and final vote on this up-zoning plan.
Missing here is September 28 when this mess of a politically charged and deeply flawed petition will either have been enacted by the Council OR will have died.
Missing here is November 5, the date of the next City Council Election, when the memories of how Councillors voted on this terrible proposal will be still fresh in voters' minds.
Missing here is the period between September 23 and November 2, when CCC will be active in getting out the word on who voted how.
Fortunately we have a number of great City Council Candidates who are on our side on this and are opposed to this petition's passage in its current state, and are already making their views clear. There also are a number of Candidates running to replace current sitting Councillors so we will have a number of new candidates for Council to chose from as well.
Cambridge has long been proactive in adding more affordable housing. The 2019 Concord Highlands development is a case in point. The photo at the top is of Concord Highlands a 2019 rental development for 98 low-income and middle-income households expected to be completed in 2020.We also have great regional data and Cambridge is very near the top regionally.
More Good News...
8.15.19 CONCERNING BUSINESS: Susan Labandibar, Board Chair of Cambridge Local First, Foresees Negative AHO Impacts .https://www.cccoalition.org/blog/concerning-business-susan-labandibar-board-chair-of-cambridge-local-first-foresees-negative-aho-impacts
8.13.19. POLITICS BY DESIGN and Why it Matters. https://www.cccoalition.org/blog/politics-by-design-form-vs-farand-why-it-matters
8.12.19. WHY TREES MATTER TO EVERYONE: One More Reason why the AHO is Deeply Flawed
8.8.19. GRAPPLING WITH GRAPHICS: Misrepresenting the Complexities of Visualizing the AHO https://www.cccoalition.org/blog/grappling-with-graphics-misrepresenting-the-complexities-of-visualizing-the-aho
8.8.19 REALITY CHECK: Peter Kroon responds to Disinformation promoted on the AHO Reality website https://www.cccoalition.org/blog/reality-check-peter-kroon-responds-to-disinformation-promoted-on-the-new-affordable-housing-overlay-reality-website
8.7.19. REBOOT: Kelly Dolan's letter: Withdraw Affordable Housing Overlay Petition https://www.cccoalition.org/blog/withdraw-affordable-housing-overlay-petition-for-a-rewrite-to-be-simply-voted-by-city-council-by-kelly-dolan
8.6.19. NOT READY: Patty Nolan on the Affordable Housing Overlay Proposal Not Ready for Prime Time in Cambridge https://www.cccoalition.org/blog/affordable-housing-overlay-proposal-not-ready-for-prime-time-in-cambridge
8.3.19. CAMBRIDGE HOUSING CONCERNS: A Short History. https://www.cccoalition.org/blog/the-housing-crisis-a-short-history
7.31.19 YES to Affordable; No to this Plan. https://www.cccoalition.org/blog/yes-to-affordable-housing-and-no-to-the-overlay
7.29.19 HOT OFF THE PRESS: New Design Guidelines. https://www.cccoalition.org/blog/hot-off-the-press-new-design-guidelines
7.29.19 WHO QUALIFIES for AHO Housing. https://www.cccoalition.org/blog/july-29th-2019
7.28.19 HOW DID WE END UP HERE? What are the Core Concerns?