Myths vs Facts
Lincoln’s best future deserves a cohesive plan.
Article 3 (aka Option C) gives developers the power to determine how our town’s housing, commercial center, and character will evolve. It is not a cohesive plan. It’s a speculative, piece meal approach that does not support Lincoln's goals.
Vote NO so Lincoln Can Do Better.
Lincoln can comply with the Housing Choice Act (HCA) in a way that gives our town maximum flexibility to develop a cohesive plan for development, commercial viability, and growth that will enhance—not cripple—our town. HCA compliance through Article 3 (aka Option C) is a risky and rushed substitute for thorough and strategic planning.
Vote NO on Article 3 at the March 23 Town Meeting.
Lincoln has until December to draft a better HCA compliance solution. Together we can:
Protect our commercial center
Increase our percentage of inclusive, equitable housing
Develop a vibrant, livable commercial center that knits together housing, retail and greenspace at the Mall to make it Lincoln's de facto commons
Be fiscally responsible to taxpayers
Provide new housing options throughout Lincoln instead of segregating impact in the Lincoln Station area (650-800 units shoehorned into a 1/2 mile radius)
Maintain self-determination instead of ceding these important decisions to speculative developers
And first, let's get the facts straight:
Myth:
A "No" vote on HCA in March means we do not comply with the state HCA law. Voting No will put us at risk of being sued by the state like Milton.
Fact:
A "No" vote in March means you vote down the max-build of Option C. The town can and will submit an alternative option.
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First: don't vote to zone for something that you don't actually want to see built.
Article 3 (modeled for 648 units) at its maximum build out would zone for 800 units within less than 1/2 mile of Lincoln Station. This would increase Lincoln’s housing stock by 30% on only .4% of Lincoln’s land. As a point of comparison, consider Cronin's Landing in Waltham on Moody Street. It contains only 281 units and benefits from underground parking. Envision three Cronin's Landing Complexes plus above-ground parking for each unit all within less than a 1/2 mile of Lincoln Station. It's ok to vote this down and then come up with a more moderate, practical HCA Compliance Option.
Lincoln's HCA Compliance Submission is not due until December 31, 2024.
That leaves almost ten months after the upcoming Annual Town Meeting on March 2 to devise a more fitting solution.
A revised HCA compliance submission is totally doable within the time frame that we have.
As of Spring last year, there had not been even one Option pulled together and very few people in town were even aware of the HCA Mandate. The HCAWG relied entirely upon the services of Utile to navigate the state's compliance model and didn't technically understand it themselves.
We are in a better position than ever as a community to tackle HCA compliance together
Since October, the LRHA has demystified the modeling of these Options—even generating eleven compliant versions on their own and proposing one to the town at the December 2 Special Town Meeting (Option E). Since then, (and largely through the LRHA's efforts) public literacy about The HCA and its application to Lincoln has grown considerably. Better-informed Lincoln residents will result in a better-crafted HCA compliance submission.
Myth:
The Lincoln Residents for Housing Alternatives want no additional housing in Lincoln.
Fact:
We all want additional housing in Lincoln, but are united in the idea that it needs to be thoughtfully planned out. In addition to rezoning sub-districts throughout Lincoln to increase the Town’s housing stock, many of us are also supportive of rezoning 40-50 units of housing at the Mall if the retail presence there is protected. The HCA mandate was not designed to be an urban planning tool. We can do better! We welcome different points of view, and invite you to join us.
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Send us your thoughts. Find out how you can get more involved. Click here to contact us!
Myth:
The State wants us to build 635 units.
Fact:
The State has said there is no mandate to build housing.
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The state’s regulations allow Lincoln to include in its compliance solution the many areas that already have high-density housing. We can comply with a small or moderate change in the town. The law was intentionally written to reward towns that already have a good percentage of multi-family housing--which Lincoln does. In fact Lincoln surpasses all its peer towns because of the town's history of proactive planning for inclusive housing. Lincoln is an outlier in this regard.
A more rational, honest approach to the HCA would have us comply without doing major surgery to the town, freeing us to continue Lincoln's enviable record of housing inclusivity in our own way. The HCAWG has co-opted this legislation to push an agenda which is outside the scope of the law. This explains the rushed schedule (trying to finalize in March what is due in December), the resistance to resident input (such as misrepresenting Option E to the town and forbidding residents who proposed it to present it to the town at December's Special Town Meeting), and lack of transparency in the crafting of Bylaws that show undue favor for a private nonprofit that will benefit from Article 3 at the expense of the town. (Click here to read more about those costs to the town).
Myth:
The best way to revitalize the Mall is through the HCA.
Fact:
The HCA is a housing density law. It is not about commercial revitalization. For developers, housing is more profitable than commercial real estate. Redeveloping the Mall through the HCA will result in less commercial presence there.
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The HCA gives developers now and in the future the right to develop without town input. Developers’ preferences are going to be for higher priced housing, not retail.
We can see the HCAWG's preferences clearly through the process of creating the new Zoning Bylaws. Potential developers have had an outsized voice in the making of the Bylaws, and they were pushing for lower percentage requirements for commercial space and unusual definitions of “commercial.” In crafting Article 3's Bylaws, “commercial space” was being used synonymously with “street activating” uses, which included gyms, lobbies, and common spaces only for residential unit use. This is not a typical definition of commercial space. Members of the LRHA (and others) pushed back against these definitions and the resulting bylaw no longer uses “street activating uses” as the same as “commercial uses” Thank goodness!
Myth:
Nowhere near the maximum build-out will happen in the HCA rezoned Option C sub-district.
Fact:
The purpose of the Housing Choice Act is to take control away from local towns and to give developers the option to build in the rezoned area by right. Zoning land under the HCA takes away decision-making from future Lincoln residents and gives power to future developers and they have financial incentive to maximize land use for their own profit.
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Lincoln has a history of zoning with intention. There is no reason to rezone parcels that there is no intention to ever develop. Furthermore, if the purpose of the HCA is to address a regional housing crisis—if that is "the spirit of the law" as was promoted in the marketing of Article 3 (aka Option C)—the stance that "it will never get built" reflects a hollow commitment to these stated values. Meanwhile, the LRHA has sought transparency in our approach to HCA compliance: practical reasoning without any quasi-moral overtones. Only zone and write Bylaws for what realistically you would be willing to allow to happen. Then go through the longterm work of strategic planning for Lincoln's growth and development--without the restrictions that the HCA imposes on the town. Maintain Lincoln's agency in its own future. Don't cede it to outside developers.
Myth:
Going through Town Meeting is overly burdensome to developers, so we should not make the RLF and its chosen developer go through Town Meeting for developing the Mall.
Fact:
Lincoln has a long history of approving multifamily housing developments. Recently, the Commons expansion and Civico's Oriole Landing development were easily passed at Town Meeting. We believe Town Meeting will pass a reasonable plan for development at the Mall that includes housing but also has protections for retail. Most Article 3 (aka Option C) and many Option E supporters would support reasonable development at the Mall.
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The Mall is a townwide resource upon which we all rely. As such, it is also a focal point within the town which should reflect our small town character. It is reasonable for the town as a whole to take an interest in its revitalization and usher it through the channels of Town Meeting, as has happened with past major developments in Lincoln. It is not enough for the RLF to say, "trust us." There is reciprocity in trust. We ask the RLF, likewise, to trust the town.
Myth:
Article 3 (aka Option C) is the best way to address the state's affordable housing shortage. Addressing the housing crisis is the most important value that must be considered.
Fact:
Make no mistake: Article 3 is not going to create tons of affordable housing in Lincoln. If you have been told this, you have been misinformed. According to the State Guidelines, No More than 10% can be required to be affordable, and the Bylaws allow for less. We can do better and continue being a regional leader in percentage of affordable units--but first we have to vote No, so we can make a more equitable plan.
Due to the high cost of land acquisition in the Lincoln Station area, the type of housing that is most likely to be built is high end housing, and the state does not have a high-end housing shortage. Increasing affordable housing, reducing environmental impacts, supporting local businesses, and maintaining Lincoln’s rural character are also important values.
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The biggest winners with the proposed option's max build-out are developers now and in the future. Article 3 is a recipe for gentrification around Lincoln Station.
Myth:
The Lincoln Residents for Housing Alternatives is working against the town.
Fact:
The Lincoln Residents for Housing Alternatives is working with and for the town.
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LRHA members analyzed the state model and recognized an extreme overzoning that would occur on wetland parcels once combined with neighboring dry parcels. They even created an educational YouTube video on the topic. The state corrected the flaw in the model the week before our special town meeting. This allowed the HCAWG to greatly decrease the units per acre in most subdistricts of Option C (now Article 3) just 3 days before town meeting.
LRHA's persistence on this issue resulted in a reduction in density in all of the subdistricts for Option C.
Here are the changes in units per acre (UPA):
• Lincoln Woods: from 20 UPA to 8 UPA
• Lincoln Rd/Lewis St: from 18 UPA to 11 UPA
• Codman Rd went: 18 UPA to 10 UPA
This resulted in Option C’s decrease in maximum units from over 1400 (as presented in September) to 801 maximum units in the current Option C. That’s almost 600 extra units that could have potentially been built within this small area. A 67% increase in Lincoln’s housing stock would have been disastrous on our little town.
Members of the LRHA (and others) have advocated for the Planning Board to drop 4 story buildings from their bylaws, capping buildings at no more than 3-stories–more in scale with our small town. (and we are thankful they agreed!)
The LRHA have advocated for the Planning Board to drop the clause that states more height, density and stories could be added without town meeting approval (and we are thankful they agreed!)
The LRHA also advocated for removing “street activating” uses such as lobbies and common spaces for a residential building in the definition of “commercial space,” protecting our local businesses.
The LRHA pointed out and corrected multiple calculation errors done by Utile and notified and submitted these corrections to the HCAWG.
The LRHA pointed out 18 extra acres in the HCAWG’s model that didn’t need to be there and were subsequently removed from their model. The HCAWG was unaware of this problem.
The LRHA has built an informational website about the HCA in Lincoln as a service to the town as a whole. Most people have been in the dark on the consequential impact that the HCA could have on Lincoln and have left it to a small committee with an agenda to make these decisions for them. The website seeks to bring these issues to light and make them accessible for Lincoln residents. It includes researched topics of interest, calendars of important meetings with zoom links, recordings, minutes, and attendee-written summaries, comparisons with peer towns, and clear explanations of what the HCA is–and what it isn’t. The Town website is cumbersome and difficult to navigate. Minutes of meetings on the town website are slow to be posted and often leave out details that add to understanding of the issues being discussed—whereas timely attendee-written summaries on the LRHA website include these details.
The LRHA got the HCA Options to be a warrant article at the Special Town Meeting in December. Prior to the LRHA’s organizing of the letter-writing campaign it was not on the agenda. There would have been no discussion of and no vote on the HCA at the Special Town Meeting–only a casual “survey” would have been offered with no explanations or public discussion. Now we have an engage community that is more literate on these issues than they would have been otherwise--primarily because of LRHA's involvement.
The LRHA got the adoption of Electronic Voting Clickers during Town Meeting to be a warrant article at the upcoming Annual Town Meeting through another letter writing campaign, instead of having it be just another survey with no discussion–kicking the issue down the road. It should be easier for Lincoln residents to vote on consequential topics (like the HCA) at Town Meeting—not encumbered by antiquated procedures and disorganization. The democratic process should not have pointless barriers to participation. All of our peers town use clickers--why make voting difficult? We even offered to fund the rental of these clickers to improve the efficiency, accuracy, privacy, and security of voting at this March's Annual Town Meeting, but the offer was turned down by the Selects.
Myth:
Article 3 (Option C)–the maximum build– will not cripple the town financially.
Fact:
We do not fully know the financial implications of highly concentrated development at this extreme of a scale in Lincoln. The HCAWG showed little curiosity about the topic until late February—less than a month prior to March's Annual Town Meeting—when in haste they published a draft of a financial study without the approval of its author and which has been shown to be flawed in its basic assumptions. Why the rush? The devil is in the details. Let's get the number right. Meanwhile, we know that the town will have increased infrastructure costs (traffic lights, wear and tear on roads, water) and public service costs like Police, Fire, and transfer station considerations. The greatest cost of all, however, will be the schools, with Lincoln having one of the highest costs per pupil in the state.
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Read an analysis about how a fully implemented Option C would impact our taxes through increased school costs.
Myth:
Housing near train stations will decrease the need for cars.
Fact:
The commuter rail is infrequent and unreliable, and this is unlikely to change anytime soon. Only a select few have work situations that make using the commuter rail feasible. Even with a reliable train, residents would need a car for basic necessities like medications and clothing, and if Donelan’s is not protected (as it is currently vulnerable) residents would need a car for food. Overbuilding at Lincoln station can lead to even worse stop-and-go traffic down Lincoln road, decreasing local air quality and increasing carbon emissions. Someday, we hope the commuter rail will improve, but until then we should not allow the maximum build.
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Unfortunately, it is going to take time for train service to improve. According to the Boston Globe: "The MBTA needs a gobsmacking $24.5 billion to repair and replace its decrepit track, stations, trains, signals, and other assets…. $8 billion is needed to repair the commuter rail system alone.” Only when train service improves does it make environmental sense to do anything close to Article 3's max build around Lincoln Station.
Furthermore, it is noteworthy that the Housing Choice Act guidelines originally required 100% of rezoning to be within .5 miles of an MBTA station, bus station or ferry terminal. After widespread feedback, however, the guidelines were reduced to 20% due to the fact that it was deemed unrealistic and "over burdensome" for towns to consolidate so much rezoning in such a small area. Yet: Lincoln's current rezoning proposal flies in the face of this wisdom and puts 100% of that burden on existing South Lincoln residents and its infrastructure anyway. It defies even the rationality of the state guidelines. Vote No and send the this project back to the drawing board to devise a more reasonable, equitable plan.
Myth:
“The max build” of Article 3 (aka Option C) is the best way to make Lincoln socioeconomically diverse.
Fact:
The HCA requires 0% affordable housing. The HCA guidelines permit towns to add up to 10% in their zoning bylaws without a feasibility study, and as much as 20% with a feasibility study. Lincoln did a perfunctory study that showed only 10% was feasible to be required (despite our existing standard of 15%). As a result, Lincoln can only require 10% affordable housing in our HCA zoning bylaws (meanwhile, Lexington, for example, can require 15% based on their feasibility study and Concord can require 20%). Having pushed back for many months on LRHA requests to submit a better feasibility study to the State and appeal the 10% limit, suddenly starting in late February, the Planning Board mentioned changing Article 3's Bylaws to 15%—and they ultimately put a reference to this in the bylaws. But this increase amounts to little more than hollow campaign promises. The only entity that can change this percentage is the State--and so until the State approves a change, Lincoln HCA affordability is limited to 10%.
Despite this 10% cap, there are ways to get around it. Rezoning land under the HCA locks in this 10% maximum cap, and puts the power to negotiate for additional affordability in the developers' hands.
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Meanwhile the remaining 90% of the units offered at Lincoln's market rate would be out of reach for middle and low income households. Find out more about "market rate" in Lincoln here.
The 10% affordable rule only applies to developments with 6+ units. And it’s rounded up to the whole unit. So a 6 unit development will have 1 affordable unit at 80% AMI and 5 market rate units—Unless a developer uses the "fees in lieu of housing" clause, then it can be 0 affordable units (read more about that below).
The HCAWG has claimed that 10% is the minimum percentage of affordable units that a developer can build. But that's not the complete picture. Here are two points to understand how achieving and maintaining percentages of affordable housing are slippery topics:
A developer might build more than 10% affordable housing under HCA, but there are costs to the town involved in achieving this. The Town would need to incentivize a developer to increase the 10% cap set by the HCA and pay them with funds from the Affordable Housing Trust in return for more than 10% affordable units.
Something similar happened at Oriole Landing under our Bylaw that requires 15% affordable housing: the town paid $1 million to Civico for including 6 additional affordable units in order to raise the affordable percentage of the development from 15% to 25%. At a 25% threshold, the whole development can count toward our Affordable Housing Inventory (in this case, 60 units)--but in reality, 75% of the units (45) are still market rate and don't add socioeconomic diversity to Lincoln. They are thought to "subsidize" the affordability of the other 25% for a developer—in addition to the $1 million payoff from the Affordable Housing Trust. It's a lucrative maneuver for a developer.
The bylaws also allow a developer to build less than 10% by paying into the Affordable Housing Trust the money that it would cost to develop those units. This approach obviously is going to save a developer money because the cost of building "40 market rate units" -or- "a combo of 36 market rate units w/ 4 affordable units" is going to be nominally the same (the cost of 4 units is peanuts in the scope of the project). Also, the cost of operating after development will be more profitable because the developer will earn more on the market rate units than they would have on affordable ones. Furthermore, if they sell the development it will be worth more because there also will be no affordable units for the next owner to lose money on.
The developer just has to decide if they would rather have the lump sum cash payoff to build the units… or save money in the long run by not building any affordable units. Meanwhile, this has little to do with increasing socioeconomic diversity in Lincoln.
Myth:
“Local control” means exclusionary policy.
Fact:
Local control in the Lincoln way is far from exclusionary. It means more affordable housing than allowed by the HCA. It means protecting commerce in the mall. We have a long history of multifamily housing projects passing town meeting, with good results.
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Unlike peer towns, Lincoln has been proactive in contributing to the Greater Boston housing stock for many years.
Lincoln far surpasses nearby peers, with 40.4% of its housing being multi-unit (excluding Hanscom)—and this comparison holds strongly to towns further afield. Natick is only 33% multi-unit. Dedham is only 31% multi-unit. Acton is only 30% multi-unit. Andover is only 26% multi-unit. Reading and Milton are only 24% multi-unit. Winchester is only 23% multi-unit. Plymouth is only 21% multi-unit. Needham only is 19% multi-unit. Duxbury is only 12% multi-unit. Dover is only 6% multi-unit.
For a town that is lacking urban infrastructure and that must deal with wetlands, septic fields, conservation land which is a resource to all of Greater Boston, an independent water supply, and hosting large educational and cultural nonprofits on sizeable pieces of prime acreage, Lincoln has been punching well above its weight in prioritizing inclusionary housing for years. The HCA guidelines are written to give credit for this achievement that many peer communities can't as readily claim.
Myth:
The town of Lincoln has many guardrails to control specifics in development.
Fact:
The HCA is designed to take power away from towns and to give developers the ability to build by right. The guardrails are overstated.
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Once rezoned, the land can be developed "by right" and requires only Planning Board Review (and no input through Town Meeting on what is built).
Site Planning Review deals with basically 5 issues: lighting, topography, drainage, screening, traffic circulation. There's also a requirement of architectural harmony with the neighborhood that is subjective and is not used by the Planning Board. Site Planning Review cannot stop a project, it can only dictate mitigation.
In an historic district, the Historic District Commission may impose a Demolition Delay of up to 1 year, but this doesn't ultimately prohibit demolition.
Myth:
Only .4% of Lincoln land is being rezoned through Artcile 3 (aka Option C). It's negligible compared to Lincoln's total acreage of 9600 acres. In the scale of things, it's nothing.
Fact:
Here's another way to look at it: increasing Lincoln’s housing stock by 30% on only .4% of Lincoln’s land is irresponsible and over-burdensome for South Lincoln.
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30% is based on:
801 (max units)
(minus)
185 Current units in rezoned area
= 616 total new units
(divided by)
2078 (current housing stock without Hanscom)
= 29.6% increase in housing concentrated in .4% of Lincoln.
How is that "negligible" or fair to South Lincoln Residents? Vote "No" and demand a more equitable solution.