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Fred Berman submitting comments re: #200102, the proposed inclusionary housing ordinance.
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Dear Members of the BOA:
I was hoping to be there this evening when proposed legislation to increase the inclusionary zoning rate is briefly processed and referred to committee, but I have a meeting conflict.
I am writing from a new computer and do not have access to my files yet, but wanted to briefly summarize the legislation and explain why we filed it, given our anticipation that inclusionary zoning will be addressed in the zoning overhaul that the BOA will be considering in the new year.
What the Proposed Legislation Would Do:
(a) Increase the inclusionary rate to 20% citywide. If it isn’t citywide, developers will always have a financial incentive to build just outside the 20% zone.
(b) Reduce the threshold size of development from 8 units to 6 units. Given the profits that developers are making, and given the propensity of developers to build one fewer unit than the threshold size, lowering the threshold to 6 seemed absolutely reasonable, while still protecting small property owners.
(c) Define “affordability” in terms of all costs. If heat and rent are affordable, but someone can’t afford the unit because of the added cost of parking and water, then we haven’t created an affordable unit.
(d) Afford tenants in inclusionary units the same protections as tenants in tax credit units. Inclusionary zoning is an anti-displacement strategy; if tenants can be evicted without case, that undermines the purpose of the unit.
(e) Create a unified wait list for inclusionary units. It will be increasingly impractical to require applicants for an inclusionary unit to get on all of the lists for all of the units that will be developed across the city.
Why It’s Needed:
The Sustainable Neighborhoods Working Group heard a number of presentations by the Metropolitan Area Planning Council (MAPC) about the housing that would need to be developed in Somerville over the next 15 years. One of their presentations broke it down into income an household size. I’ll send you that breakdown in a few days, when files are restored to my computer, but the gist of their message was that 40% of the 8-9,000 new units needed have to be affordable to households with incomes at or below 80% of Family Median Income (FMI). A 12.5% inclusionary zoning rate doesn’t even begin to get us there. In the context of the need for 40% deep affordability - because I can’t remember how many additional units need to be affordable to households within income between 80 and 110% of FMI -- the 20% inclusionary rate looks pretty darned modest.
Why Not Wait Until the Zoning Overhaul?
In today’s hot real estate market, we can expect the City to receive lots of requests for permits between now and when the overhaul zoning is approved, sometime next year (assuming it makes it through the full process on the second try). We’re filing this legislation as an interim tool for ensuring that development proposed before the full citywide re-zone is adopted and goes into place results in as much affordable housing as possible. We liked a number of the innovations that George Proakis and Co. wrote into the inclusionary zoning in the first iteration of the overhaul legislation, and we hope that some of those same innovations appear again. We also think that the requirements need to be stiffer, and in line with the language we are proposing. Hopefully, the comprehensive rezoning will incorporate the best of both our proposals. In the meantime, we can’t afford to wait and lose out on leveraging as many inclusionary units as possible from development that is permitted between now and when the overhaul is finally adopted.
As elected officials, you probably hear more about displacement and escalating rents than many of us. People are being forced out of the city left and right. Parents whose support the Somerville Schools have worked so hard to earn are having to move their children out of those Somerville schools, because they can’t afford to stay in our community. The residents of Somerville who constituted the environmental justice population that leveraged the Green Line Extension will -- unless we act definitively and quickly -- be displaced by the speculation and real estate inflation precipitated by the promise of Green Line Extension they fought so hard for. In the time it takes for the City to pass a comprehensive zoning overhaul, a lot more people will be displaced. Creating inclusionary units is one small step to provide alternative housing for people who would be forced out of the City; and we need all the units we can leverage.
Thanks for your consideration.
Fred Berman