15 Suggestions for the Affordable Housing Overlay (8/1/19)

I sent these comments to the City Clerk to submit for the 8/1 Ordinance Committee hearing on the 100% Affordable Housing Overlay zoning:

1. Amend the Tree Protection Ordinance immediately so that affordable housing developments are no longer exempt from the Tree Protection Ordinance.
2. Add a sunset provision and require annual progress reports to the Planning Board and the Council. Most of the Planning Board members supported a sunset provision. A thousand units by 2030 is the goal that set this in motion; make that the target number to reach and don’t move the goalpost until it is reached. Then sunset the AHO and re-evaluate.
3. Restore some control on density (FAR) so that AHO projects, especially those on large lots or on combined parcels, are not dramatically out of scale with their context. This sensitivity to context is critical on smaller side streets in low-scale residential areas. AHO FAR should be a multiple (eg up to 2x) in proportion to the base FAR, not an across-the-board maximum (3.0 is too great).
4. Require separate structures for AHO developments over a certain size to break up massing, consistent with the neighborhood context.
5. Increase the transitional buffers and step-down heights between taller AHO projects and small residential buildings. Follow Councillor Carlone’s recommendations.
6. Clarify the requirements for units created below grade (especially if the first story starts at 4’ above grade, a measure that many have found confusing) and do not allow below-grade units to extend under the setbacks.
7. Add protections for tenants earning up to 110% AMI who are displaced by AHO developments.
8. Set a goal for producing a percentage of units for home ownership.
9. Require minimum side and rear setbacks from existing abutting residential structures, not only from the property lines.
10. Establish priorities in AHO lotteries for current Cambridge residents to the full legal extent permitted by funders. Seek Council input over how tenanting priorities are set and how the wait lists are managed.
11. Require all AHO developers to submit a pro-forma for public review and limit profit to no more than the return allowed under 40B.
12. If parking is to be reduced or even eliminated for proximity to transit, then measure the distance to transit (a subway entrance) by the walking route’s distance, not as the crow flies, and be cautious in considering bus lines as reliable transit, since bus frequency and stops are not under our direct control.
13. Do not allow shared roof decks and balconies to meet the open space requirement.
14. Existing neighborhood-serving retail must be preserved in the small neighborhood business districts. Services for AHO tenants should not replace existing active use retail in residential areas.
15. The draft design guidelines, as currently written, are weak tea and will be too easy to ignore when directions are phrased as “consider” and “where possible”. This is a form-based code and there still is far too little consideration given to how these larger, denser forms will impact the existing context and abutters.