February 10, 2015
Dear Members of the Board of Aldermen,
Over the past few weeks, a Union Square Neighbors (USN) work group has been meeting to review the proposed Somerville Zoning Ordinance. Revisions to zoning have been an important priority for USN and many Union Square residents for some time. With much of the City's future development set to happen in Union Square, it is particularly important to us to understand the impact of zoning as this will in many ways shape the future of our neighborhood. In general, the USN group is impressed by the overall vision, and is supportive of the zoning overhaul and its aspirations. There are clearly many significant improvements in the new zoning. However the complexity of replacing a traditional zoning ordinance with a form-based code, which is a very different approach, cannot be overstated. Our group includes architects, planners and other knowledgeable residents; we have collectively spent hundreds of hours reviewing this, and none of us feels as though we have a grasp of the full implications of what is being proposed. A complete zoning overhaul could easily have unintended consequences, and we believe there are risks to premature implementation. We are concerned about the overall time provided for review, comment and revision and are concerned about sufficient education and outreach to residents to understand the code, now that it is published. Accordingly, we ask that the Board of Aldermen consider agreeing at the outset to have this renoticed. While we have identified many areas of improvement in the new zoning ordinance, we have also outlined a few issues of concern below to demonstrate the need for a careful and rigorous review. Please note these are preliminary observations and we have not yet had a chance to review this with OSPCD.
- Mechanisms to generate commercial development are insufficient - while all mixed use (MU) districts allow commercial buildings, there does not appear to be a way of achieving an appropriate mix in Union Square. Currently the market favors residential development, but for the future of Union Square it is critical that commercial development also occur. The incentives and requirements for commercial development in the draft zoning appear insufficient to achieve SomerVision’s jobs goals and Somerville’s fiscal stability. This is also a problem with current zoning.
- Open space requirements are insufficient. Only 15% open space would be required in large mixed use developments, and none would be required in 3-5 story developments (which is most of Union Square). The amount required seems inadequate even to meet the basics of a high quality public realm. There are no mechanisms for acquiring and creating larger open spaces. City officials have said that additional open space must be built by developers, since Somerville does not have the financial strength to pay for it. But our quantitative analysis seems to show that creating the minimum amount of open space required in every possible project would achieve only a fraction of the 125 acre SomerVision goal.
- Standard, prescriptive building standards may inhibit creativity and not be able to account of uniqueness of Somerville - The zoning contains building standards which set out a series of guidelines which prescribe building mass, form and many design elements. The goal is to create sufficient guidelines that any building which complies with them will be acceptable. Nearly every property in Somerville is unique in some way though, and it is not clear if it is possible to create prescriptive standards that account for the variety of different conditions on each property and building variation in the City. We are also concerned about potentially reducing or discouraging creativity in building design by creating over-prescriptive requirements.
- Less community input. Special Permits are proposed to be replaced in large part with 'Site Development Reviews'. This is an administrative review, and appears to allow for less public input, less consideration of that input when a development is reviewed, and less discretion for the Planning Board or ZBA in deciding whether or not a project should be approved. In light of the numerous questions about development outcomes, it is all the more concerning to see that there will be lower or non-existent hurdles for review from either the public or boards.
- The new approval process relies on the zoning requirements being able to anticipate and codify in advance every factor that the Planning Board/ZBA would otherwise need to consider in granting a Special Permit. Because of this, the neighborhood meeting and public hearing could be empty exercises without any chance of influencing the project being proposed or the decision of whether to approve it. This underscores how it is more important than ever before to scrutinize the zoning requirements being proposed to make sure they will result in the outcomes people desire and expect - because there will no longer be discretion to influence a compliant proposal during the approvals process.
- Setbacks are reduced between existing residential neighborhoods and new buildings
- Allowable building heights are increased
- Requirements for landscaped (green) space are reduced
- There is still no 'open space' requirement
- Allowable density appears to be increased, sometimes significantly, though this varies by lot
- The number of residential units permitted on a lot is increased significantly, potentially creating an incentive for large residential developments that take up as much of a property as possible and are made up primarily of small unit types (studio and 1 bedrooms).
- Currently, CCD-55 does not allow residential use on the ground floor and requires commercial space. 5MU would permit 'apartment building' types which have residential units on the ground floor and no commercial space (unless along a designated 'pedestrian street'). This is a big change, and would result in existing buildings with small retail spaces on the ground floor being replaced with buildings that have none. While much of Union Square is designated as 'pedestrian streets', all of Somerville Ave east of Prospect Street and all of Washington Street from Columbus all the way through East Somerville to Charlestown would now be able to have 100% residential apartment buildings built along them.
Union Square Neighbors (USN) - Zoning Work Group
Rob Buchanan, Stuart Dash, Jim McGinnis, Philip Parsons, Bill Shelton, Maya Tal-Baker, Brien Tal-Baker, Tim Talun
Mayor Joseph Curtatone
George Proakis, Director of Planning