{"id":3422,"date":"2024-11-19T17:30:30","date_gmt":"2024-11-19T22:30:30","guid":{"rendered":"https:\/\/walkuproslindale.org\/weblog\/?p=3422"},"modified":"2024-11-20T18:32:22","modified_gmt":"2024-11-20T23:32:22","slug":"comment-letter-on-squares-streets-zoning-amendments","status":"publish","type":"post","link":"https:\/\/walkuproslindale.org\/weblog\/2024\/11\/19\/comment-letter-on-squares-streets-zoning-amendments\/","title":{"rendered":"Comment Letter on Squares + Streets Zoning Amendments"},"content":{"rendered":"

Today, we sent in our comment letter<\/a> on the proposed zoning amendments from the Squares + Streets initiative<\/a>. Given the significant impact on our core issue of housing, we collaborated with Rozzidents for More Rozzidents and Abundant Housing Massachusetts<\/a> <\/span>on the comment letter. The full letter is reproduced below.<\/p>\n

<\/p>\n

Nov 19, 2024<\/span><\/p>\n

BY ELECTRONIC MAIL ONLY<\/span>
\n<\/span>Planner II Abdul-Razak Zachariah (abdul-razak.zachariah@boston.gov)<\/span>
\n<\/span>Boston Planning Department<\/span>
\n<\/span>One City Hall Plaza, 9th Floor<\/span>
\n<\/span>Boston, Massachusetts 02201<\/span>
\n<\/span>Attention: Abdul-Razak Zachariah, Maya Kattler-Gold and Kathleen Onufer<\/span>
\n<\/span>
\n<\/span>RE: Comments on the Planning Department\u2019s Squares + Streets Text Amendments<\/b><\/p>\n

 <\/p>\n

Dear Abdul-Razak Zachariah, Maya Kattler-Gold, and Kathleen Onufer,<\/span><\/p>\n

Please accept the following joint comment letter on behalf of WalkUP Roslindale, Rozzidents for More Rozzidents, and Abundant Housing Massachusetts with respect to the Planning Department\u2019s Squares + Streets Text Amendments.<\/span><\/p>\n\n\n\n
Reference materials<\/b><\/p>\n

Planning Department Text Updates to S+S Zoning.pdf<\/span><\/a><\/td>\n<\/tr>\n<\/tbody>\n<\/table>\n

Allowing more uses on upper floors would be an improvement<\/span><\/h1>\n

The current use requirements under Article 8 are quite restrictive. Greater flexibility in the mix of uses on a building\u2019s upper floors can lead to a more interesting and diverse mix of establishments.\u00a0<\/span><\/p>\n

However, our support for added flexibility ends at the point where it effectively creates lower density substitutes for the S2-S5 districts. We are concerned that this approach could be used to scale back an area\u2019s rezoning in order to limit building heights and densities for other reasons.<\/span><\/p>\n

The S2 amendment would hurt commercial area redevelopment and make fully residential buildings more expensive and less likely to happen<\/span><\/h1>\n

We oppose restricting ground floor residential use under S2 on two grounds:<\/span><\/p>\n

    \n
  1. It would limit redevelopment potential in commercial areas by inviting the mapping of S2 to areas where S3 or above would be more appropriate. In Roslindale Square, this raises the worrisome possibility that we won\u2019t see anything higher than S2 mapped here.<\/span><\/li>\n
  2. It would make fully residential development more expensive and less likely by adding yet another hoop to jump through, and dilutes the principle of allowing 5-story residential buildings by right on our main streets.<\/span><\/li>\n<\/ol>\n

    Preserve the S3, S4, and S5 for commercial areas<\/b>
    \n<\/b>It is important to maintain the S3 and above as the most appropriate\u00a0 districts for mapping to commercial areas, where we want to maintain a continuous stretch of active ground floors. In <\/span>    Roslindale Square<\/span><\/a>, for instance, this includes those areas currently zoned for Community Commercial and Neighborhood Shopping (see below).<\/span><\/p>\n

    We believe S3 would be the best district for the job, because the trade-offs make sense to us. In exchange for requiring redevelopments to subsidize ground floor commercial, make 20% of the units affordable, and sustain the costs of enhanced anti-displacement measures under the City\u2019s forthcoming ordinance, developers are granted greater lot coverage, an additional two floors of height, and greater use flexibility. These increase the chances that redevelopment will make financial sense. Also, spreading the cost over a greater number of housing units relative to building under S2 can lessen the price burden on future tenants.<\/span><\/p>\n

    \"\"<\/p>\n

     <\/p>\n

    Don\u2019t make residential projects even more expensive<\/b>
    \n<\/span>This amendment would make fully residential developments under S2 more expensive by requiring a conditional use permit from the Zoning Board of Appeal, and all the added time, cost, and risk that their process entails. These costs will inevitably be passed on to future owners or tenants, and reduce housing.\u00a0<\/span><\/p>\n

    This would not be worth the tradeoff when you consider that the S2 was designed for current or future mixed-use streets, where you\u2019ll see triple deckers and small apartments on one side, and a strip of ground floor retail on the other. This description fits the areas marked blue on the map above, as well as places<\/span> already mapped S2 in Mattapan<\/span><\/a>. In these locations, we think it would be a mistake to prioritize ground-floor commercial over residential, because adding more homes is the bigger benefit to the community.<\/span><\/p>\n

    There is value in the principle of allowing 5-story residential buildings by right on our main streets. It is a signal of the City\u2019s seriousness about addressing our dire housing shortage. Please don\u2019t dilute that.<\/span><\/p>\n

    A better way to address displacement concerns<\/b>
    \n<\/span>The Planning Department noted the amendment was inspired by concerns over small store displacement and the loss of commercial activity. These are reasonable concerns and we share them, but we think there are better ways to address them without scaling back the redevelopment potential in our core commercial areas and weakening the S2\u2019s capacity for housing production:<\/span><\/p>\n