Reality Check: Peter Kroon responds to disinformation promoted on the new Affordable Housing Overlay Reality website
A new website has emerged on the 100% Affordable Housing Overlay (AHO) proposal, created by Christopher Schmidt, and under the name of "Affordable Housing Overlay Reality." Schmidt has frequently spoken out in favor of the AHO at City Council, Planning Board, and other meetings. How does his new site rate in terms of its core facts? Cambridge resident, Peter Kroon, who is well versed in issues of both zoning and finance, has forwarded the following letter to the City Council Ordinance Committee today. In his text offers a reality check to the new "AHO Reality"site. CCC is pleased to publish this letter with permission of the author.
Dear Ordinance Committee members -
I write to rebut a website that purports to tell the "Affordable Housing Overlay Reality".
Contrary to what is stated on that site:
1. The AHO has no limit to the funding that could be applied and there are many ways such funding could be raised and thus there is no guarantee that "the overlay will [only] impact a handful of developments each year ... not enough to drastically change the character of our neighborhoods or the City as a whole". In fact, the opposite is true. If approved it would create a financial incentive (density boost) and a mechanism (by right) to transform the City.
2. The Design Guidelines are lovely suggestions but they are aspirational (e.g. "will consider") and toothless (no enforcement mechanism) and thus do not guarantee "buildings in the style of the neighborhood". The buildings shown on the site were produced under the current rules. We are now being asked to allow By Right development with no firm assurances of anything other than the right to speak for 3 minutes before the Planning Board which in turn will issue a non-binding recommendation. That is unreasonable.
3. Suggesting that "the AHO will only increase height slightly in residential districts" is wildly misleading. A half-acre lot that has a large single or two-family home today could turn into an apartment containing 45 two-bedroom units. The economics will strongly encourage assemblages of super sites.
4. "Taller development" "only along the commercial corridors" is also misleading. Parts of those commercial corridors are residential. They could now have by-right seven story buildings facing the corridor, stepping down to 50' tall just 20' away from existing two-story home sites directly behind. Our historic neighborhoods are not going away. Seven stories is too tall. Even six stories is too tall. Five stories is the most we should offer.
5. "Thoughtful building re-use" is also misleading. The elimination of FAR and the city-wide multi-family zoning will allow older buildings including in Neighborhood Conservation Districts to be torn down and replaced with apartment buildings. That is not true under current zoning.
6. Cambridge has essentially achieved the State mandate of 10% affordable units whereas our neighboring cities are at between 5% and 10%. This is where increased development needs to happen. Cambridge exceeds that minimum but nevertheless this allows Affordable Housing developers to sidestep local zoning restrictions and other requirements by means of comprehensive permits. Cambridge may choose to produce more affordable dwellings, but it does not "need" to in any legal sense. We need to demand that our sister cities do their fair share.
7. Despite what it says in the Design Guidelines, any mature tree in the way of an AHO development can be chopped down without penalty. That is not true for regular non-AHO development.
8. AHO developments could have a little as zero off-street parking if located within half mile of a T stop despite opaque City studies that claim to show that the existing 100% affordable buildings generate 0.4 actual cars per unit. Be honest as you consider the impact on our street parking and the people that depend on it.
9. Despite being untested policy, the AHO has no cap on development and no sunset clause. To my knowledge, no impact analysis has been performed on the potential creation of thousands of new dwelling units. Is that a good idea? Not in the business world.
I submit to you that the foregoing is a more accurate "reality of the proposed Affordable Housing Overlay".
There are some good ideas in the AHO, but the AHO as it stands is not good policy. Please fix it or kill it.