As required by MA state law, our Housing Plan Implementation Committee (HPIC) is in the process of updating our 2016 Housing Production Plan, and has hired two consultants, Barrett Planning Group and Horsley Witten Group, for this work. However, despite frequent references to community outreach, the draft Plan has not been made available to the public, so that feedback from residents has been completely avoided. Even Committee members had barely enough time to read this Plan – sent out only one day prior to the September 2, 2021 presentation by Barrett Planning Group at the HPIC’s regularly scheduled meeting.
See the Draft Plan here
The draft Plan contains many errors, and omits what should be a significant part of all planning, which is any suggestions for addressing the grave climate crisis facing us, and the loss of our tree canopy and creation of heat islands due to the clear cutting of lots that accompanies residential construction. But the major flaw in the report is that it scarcely addresses affordability issues and completely avoids the needs of very low-income residents most in danger of homelessness, and the role of Arlington Housing Authority in combatting these problems.
Partial List Of Errors and Omissions In The Draft Plan
Under the heading of KEY FINDINGS
⧫ p. 2-3, third bullet point
The statement that the “overall picture of Arlington is that of White, middle- and upper-income homeowners” belies the fact that Arlington, although gradually falling victim to gentrification under current leadership, is still predominantly middle class. Also, as some of Barrett Planning Group consultants’ own economic data demonstrates, the chief obstacle to diversity in Arlington (economic and racial) is the cost of housing that is being constructed or rebuilt after teardown. Arlington’s median household income is $108K per year. The duplex homes being built to replace single-family teardowns sell for over $950K, and new single family homes near $1.5M. These prices require households to make at least $200K per year. Those residences will not increase diversity—either racial or socio-economic. Arlington’s leadership has opposed efforts to decrease these teardowns and preserve affordability and diversity.
⧫ p. 2-3, fourth bullet point
This statement is completely wrong. There is no evidence for the existence of historically discriminatory policies of the past in Arlington’s government.
⧫ p. 2-10, fig. 2.4.1
This slide tries to show the degree of racial diversity in different neighborhoods. Barrett Planning Group claims that several large tracts are 100% white. It shows a large segment of precinct 10 as having zero minorities, whereas it is actually 15% minority. The draft Plan also claims that a large land area around the Stratton School is 100% white, despite the fact that Stratton School has a 38% minority student enrollment. This information is not accurate and must be corrected in accordance with the 2020 census.
Under the heading of MIXED USE
⧫ p. 2-21
The Housing Plan should elaborate on the failed implementation of Mixed Use in Arlington, due largely to incomplete safeguards in the bylaw as designed by Department of Planning and Community Development (DPCD) and promoted by them and the Arlington Redevelopment Board (ARB). The faulty bylaw has resulted in apartment buildings masquerading as mixed-use buildings, which allows developers to drastically reduce open space. The Plan should suggest improvements in this failed Mixed Use Bylaw instead of ignoring its failings. There is usually only a token business use in some tiny area of the new mixed-use buildings. Existing cherished businesses serving our residents are being destroyed to create these false “mixed-use” buildings. They are not mixed-use: See 483 Summer Street, where the ‘business” is an office for the owner—nothing to contribute to the hyped “vibrancy” of mixed-use for the streetscape. They do not allow for sufficient open space for trees and plantings that make authentic apartment residences attractive and provide environmental and climate-control benefits and at least some play space for children. Developers can game the Inclusionary Zoning Bylaw in various ways so that very few “mixed use” apartments will be affordable. Residential multi-unit developers can build 4- or 5-unit buildings to bypass the bylaw requiring the provision of affordable units if six units are being constructed. The ARB has allowed a permit for a forbidden use in a “mixed use” building, and has awarded permits for some of these “mixed use” buildings resulting in much developer speculation; in holes in the ground (see 1500 Massachusetts Avenue where a handsome house formerly stood); in allowed violations of the zoning bylaw (see, for example, illegal permitting of open space/internal area and floor/area ratio violations granted by the ARB in the case of the former Toraya restaurant block, at 882-892 Massachusetts Avenue opposite the high school, for a hopelessly cramped “mixed-use” apartment building). This is not what was promised when DPCD persuaded Town Meeting to approve their “mixed-use” bylaw. It needs to be corrected. The Housing Plan should spell out a remedy.
Under the heading of DEMOLITIONS & REPLACEMENT HOMES
⧫ p. 2-27
Town Meeting established the Residential Study Group (RSG) to investigate the teardown/mansionization problem. RSG studied this along with DPCD. Before the study was completed DPCD wrote its own flawed report (“Report on Demolition and Replacement Homes, 2019”). During the same period the RSG attempted for many reasons to have a role in the Accessory Dwelling Unit (ADU) warrant article being planned by DPCD. The RSG was immediately disbanded. They were never allowed to meet again to complete the investigation authorized by Town Meeting and produce their own report.
Under the heading of HOUSING SALE PRICES
⧫ p. 2-29
The draft Plan states the obvious: “There are remarkably few opportunities for young wage earners to choose Arlington or anywhere nearby.” It further points out that the same is true for communities comparable to Arlington. It fails, however, to point out that Arlington’s comparable neighboring towns all have significantly lower residential density.
Under the Heading of HOUSING AFFORDABILITY
⧫ p. 2-31
This section correctly observes that affordable “units that have offered a pathway to owning a home in the past have been a key target of demolition/rebuild projects in Arlington’s older neighborhoods.” However, there is no mention of the fact that RSG (see above) was authorized by Town Meeting to investigate this problem but was ghosted before it could complete its study.
Under the heading of POTENTIAL BARRIERS TO AFFORDABLE HOUSING DEVELOPMENT
⧫ p. 2-37
This heading is extremely misleading. The barriers discussed pertain to barriers for very dense and very expensive residential construction favored by DPCD. They have little or nothing to do with affordability. For example, there is no interest in the provision of affordable housing by purchase and renovation of existing residences, which has been a wonderful approach for affordability.
The Plan should include a statement that DPCD and leadership of the Town opposed initiatives to increase affordable housing at the 2021Annual Town Meeting. This included insistence that Arlington would have no requirement for affordability of ADUs (except for non-profits). The DPCD/ARB never even offered any amendments or substitute motions for promising citizen warrant articles to render them suitable for their approval and recommendation for a positive vote at ATM. The interest of Arlington’s leadership in housing affordability is apparently zero except insofar as it can enrich 40B developers.
Under the heading of OPEN SPACE
Arlington has very limited Open Space about which residents are very concerned. The final sentence of this section should be changed to:
“It is recommended that no designated open space, and conservation lands, will be made available for housing development.”
Under the heading of CHAPTER 40B SUBSDIZED HOUSING INVENTORY
This is a remarkably obfuscatory section of the draft Plan. Suffice to say that the section chooses to ignore the fact that Arlington is very close to the statutory “safe harbor” requirement of 1.5% land area devoted to affordable units, and instead expounds at length upon the alternative safe harbor yardstick of 10% of total housing units required to be affordable. The latter yardstick is essentially unattainable for communities as land-poor as Arlington and would necessitate Arlington being on an everlasting construction treadmill gobbling up parks and open space. Depending on whether Arlington were to use 40B construction or construction of apartments observing our Inclusionary Zoning bylaw, the additional 859 affordable units required to meet the 10% affordability yardstick would require Arlington to build between 5,000 and 15,000 additional units as is explained in this October 2020 blog post. It is inappropriate for the consultants to suggest that we should do so. It would overwhelm schools, and create an intolerable traffic situation. Instead, the consultants should present a blueprint for finalizing our attainment of the 1.5% land area statutory requirement by such methods as redefining the cemetery districts as non-residential, and purchase and renovation of existing residences for use as affordable units, which has been successful in the past for both Arlington Housing Authority and Housing Corporation of Arlington.
Under the heading of REGULATORY CONSTRAINTS
The second paragraph misleadingly states that in 2021 the Town successfully adopted an ADU policy in the bylaw… “so long as the ADU or primary residence is occupied by the property owner or a family member of the property owner” (family member undefined). This is not true if the owner or owner-developer, after initial ownership, then sells the property—there is no requirement that the new owner or family member resides there. It can simply be an investment property and could exacerbate teardowns. There are almost no safeguards for the community in the ADU bylaw as promoted by DPCD, and now that it has been approved by the Attorney General it will be the most lenient ADU bylaw in Massachusetts. The specter of short term rentals is not adequately dealt with. The draft Housing Plan should be providing improved ADU concepts instead of endorsing flawed legislation.
In the third paragraph the draft Plan states that focus groups “suggested that local zoning does not allow for enough diversity of housing types.” Who were these focus groups? How were they chosen? This information has not been made public. It is not wise to ignore the opposite conclusion of the Master Plan approved by Town Meeting—after the documented input of hundreds of residents. The Master Plan emphasized the outstanding nature of the diversity of housing in Arlington, which is much superior to that of other local towns. It also said that the housing that Arlington needs is affordable housing and senior housing, both of which are given short shrift in the draft Plan.
⧫ p. 2-44
The final paragraph is an unsubstantiated statement for which there is no evidence: “regulatory barriers like those documented in Arlington … act as an impediment to creating affordable and equitable housing opportunities.” What regulatory barriers? Where is the evidence for this statement? Arlington’s leadership opposed every attempt at Town Meeting in 2021 to create affordable units. They are the major impediment – not imaginary “regulatory barriers.”
“The legacy of Arlington’s past exclusionary practices is embedded in the town’s urban form and in laws that remain on the books.” What laws are the authors talking about? There is no substantiation for this statement.
“Addressing that legacy will require ongoing community conversation and openness to disagreement, and reforming laws on the basis of inclusion.” Actually, housing policy and affordable housing policy and related conversations require honesty, not distortions to increase profits for developers. Arlington’s zoning bylaw was reformed years ago to include an exemplary Inclusionary Zoning Bylaw. Recent attempts to expand the affordability provisions of that bylaw were opposed by DPCD and town leadership. The Housing Plan should present a pathway for improved leadership in housing and affordable housing policy.
One of the ongoing allegations of DPCD relative to the false narrative of racism in Arlington’s housing history is their repeated accusations of redlining. This is simply wrong and the draft Plan should make that clear. The following communication from a precinct 10 constituent should bring accuracy to redlining history:
If these and other mistakes in the draft Housing Plan are corrected we can have a good Arlington Housing Plan.
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