As is our custom, we provide the full text of our support and/or comment letters and this one is both. The letter fairly well explains our thinking at this point in this program, but it is worth pointing out that “this point in the program” is really just about table-setting. Our support and comment letter relate to the set of proposed zoning text amendments soon to be considered by the Boston Zoning Commission that will, most critically, add a series of floating zones that are not yet mapped anywhere in the city. Instead, those zones will float, available in the Zoning Code, until they are brought down to the ground through specifically focused small area planning processes. While the floating zone concept is relatively new to Boston, it is not by any means a recent innovation in land use regulation. The concept has been around for a long time and has been used elsewhere even here in Massachusetts.
As we are all well aware, Roslindale Square has recently been identified among the first group of places where such small area planning processes leading to new zoning and an accompanying action plan will be undertaken, we understand commencing at some point in late winter/early spring. We look forward eagerly to engaging with the city and our neighbors in that process and adopting effective zoning changes that will make the principal center of our neighborhood a better, more active, and more welcoming place where more people can live, work, shop, and just connect with each other.
We urge everyone reading our letter to take a look at the initiative in more depth and we’d be delighted if you concluded that you wanted to weigh in with your support through the BPDA’s online comment submission portal here.
January 24, 2024
BY ELECTRONIC MAIL ONLY
James Arthur Jemison II
Chief of Planning and Director of the Boston Planning & Development Agency (BPDA)
City of Boston
Re: Squares + Streets Planning and Zoning Initiative
Dear Chief Jemison:
Please accept this comment and support letter on behalf of WalkUP Roslindale with respect to the Squares + Streets planning and zoning initiative currently underway by the BPDA. Squares + Streets is a new planning and zoning initiative furthering key updates to the city’s current zoning to focus on more housing, public space, arts and culture, and transit in our neighborhood centers like Roslindale Square and along main streets.
WalkUP Roslindale strongly supports this initiative and appreciates the BPDA undertaking this ambitious and exciting endeavor to enhance Roslindale Square and other neighborhood centers around our city. We especially extend our gratitude to the BPDA staff who have already held numerous community meetings, drop-in sessions, and opportunities for feedback throughout the first phase of this process as the floating zones are first adopted into the zoning code, to be mapped later upon the conclusion of subsequent small area planning processes.
We are excited by the intent of the Squares + Streets initiative to facilitate critically needed new housing growth and to strategically increase population density which will help support our small businesses and improve walkability in key neighborhood centers. For nearly a decade now, WalkUP Roslindale has supported new housing in our neighborhood, organized for better public transit, and advocated for enhanced street safety and walkability to support our neighborhood’s small businesses and community residents. We believe the Squares + Streets initiative is very much in line with this mission and these actions of WalkUP Roslindale and are excited to support its progress. In particular, we applaud the removal of unnecessary and counterproductive parking minimums through the proposed zoning and the capacity for enhanced building heights adopted through to-be-undertaken small area plans – two specific elements that will facilitate new housing growth and improved walkability.
While broadly supportive of the Squares + Streets initiative, WalkUP Roslindale strongly encourages the BPDA to further consider the following recommendations:
- Utilize Objective Criteria. BPDA staff must use objective criteria to map out the small area plans for Roslindale Square and other neighborhood centers. These criteria should include, but not necessarily be limited to: proximity to transit (both rail and bus), walkability, existing conditions, and anticipation of growth. It is crucial that easily understandable and transparent criteria are utilized to plan and zone these small plan areas to create the conditions for future growth and enhanced density and walkability.
- Limit Conditional Uses. We recommend that the BPDA reduce the number of conditional uses imposed throughout the new, proposed zoning. While conditional uses have a place in some situations, the proposed zoning can and should go further to make many of these conditional uses allowed by right. We know from experience in Roslindale that conditional uses can bog down applicants and small business owners in unnecessary bureaucracy that delay new housing and new businesses and raise the associated costs.
- Use Existing Conditions as the Floor. In Roslindale, the vast majority of lots are existing non-comforming. That is to say, the lots were initially developed with small lot sizes, minimal setbacks, and similar characteristics, but made retroactively nonconforming by later downzoning. This situation means almost any development, whether new construction or simple exterior renovations, will require zoning variances. At a minimum, the new zoning should restore existing lots to legal status and remove the requirement of variances to do basic work and simple additions to them.
- Keep S-5 Placemaker Squares. We understand and applaud the BPDA for returning the S-5 (Placemaker Squares) districts to the Squares + Streets options for small area plans after they were previously removed. The S-5 districts enable the greatest density of housing and uses where appropriate to create vibrant, active neighborhood centers. We wish to reiterate that the S-5 districts are a crucial tool for planning and should be included in the final set of floating zones adopted.
- Address Displacement. Displacement is inevitably most prevalent when the status quo is maintained. If no new residential or commercial space is built, steadily increasing demand for both guarantees that residents (renters, aspiring homeowners, and business owners) will be priced out. That said, changes that increase permissible commercial and residential density will result in new construction and potentially higher rents if anti-displacement measures are not considered from the outset. We encourage the BPDA to proactively plan for this in small plan areas under the new zoning and create incentives for existing property owners to keep rents reasonable through property tax abatements and other measures, such as providing current commercial tenants the right of first refusal to return to the space at issue.
- Engage All Stakeholders. As an organization of neighborhood residents and local business owners, we firmly believe in public feedback and input into planning and zoning decision-making. At the same time, we know that no one group, including our own, can speak for an entire neighborhood, never mind an entire city. We have been impressed by the outreach conducted by BPDA staff to date and urge its continuation as the process moves forward from adopting the proposed set of floating zones to undertaking the small area plans. It is crucial that staff continue to actively reach out to stakeholders where they are. It is well documented that evening meetings are difficult for individuals with small children, evening jobs, and other life commitments to attend, for example. We hope to continue to see opportunities for feedback at pop up events, the Roslindale Farmers’ Markets, on transit platforms and bus stops, and at community activities where people naturally congregate and deserve an opportunity to be heard.
In closing, we wish to reiterate our deep support and appreciation for the Squares + Streets initiative. We believe a thoughtful neighborhood and citywide rezoning is long overdue in Roslindale and Boston, respectively. Starting with the Squares + Streets planning and zoning, we hope that the city can finally and fully enable the density, walkability, and investment we need in our neighborhood centers to enhance the vibrancy of our communities, to provide intrinsic support for local businesses, and to tackle the critical need for more housing so evident in our Roslindale neighborhood and across our entire city.
WalkUP Roslindale Board of Directors
Cc: Michelle Wu, Mayor
Enrique Pepén, City Councilor District 5
Ben Weber, City Councilor, District 6
Ruthzee Louijeune, City Council President
Julia Mejia, City Councilor At-Large
Erin Murphy, City Councilor At-Large
Henry Santana, City Councilor At-Large
Bill MacGregor, State Representative
Rob Consalvo, State Representative
Michael Rush, State Senator