To: Members of the Concord Community Preservation Committee
From: Winthrop St. – Commonwealth Ave. Neighborhood Association (wincom.neighbors@gmail.com)
cc: Concord Housing Development Corporation Members
Board of Selectmen
Planning Board Members
West Concord Advisory Committee Members
Subject: Concord Housing Development Corporation (CHDC) CPA Funding Request
The Concord Housing Development Corporation (CHDC) has applied for $250,000 of Concord Community Preservation Act funds to continue development of an affordable housing project on former state prison land in West Concord. The Junction Village project as it was initially conceived (20 units plus open space) had neighborhood support. However, on November 13, 2013, the community learned that the CHDC is now pursuing a project that would be five times as large – 90-110 rental units.
The Winthrop St. – Commonwealth Ave. Neighborhood Association strongly opposes this expansion in scope, which:
- does not fit within the guidelines of Concord's Housing Production Plan
- increases the demands on town services by nearly $500,000 per year
- doubles the traffic on Winthrop St and (together with the Beharrell St project already under construction) increases traffic by 9% on the already congested Commonwealth Ave
- adds an average of one child to each classroom at Thoreau or Alcott Elementary Schools, depending upon whether the students are bused
- overwhelms the scale of an existing neighborhood of one- and two-family houses
- further concentrates moderately affordable housing in one of the few areas of Concord that already has it, rather than distributing it throughout the town
- does not support "Smart Growth" development principles
- subsidizes the development of housing for people with higher incomes than the majority of Concord residents, and
- presents long-term risks of unit marketability, with additional potential costs to the Town
The Junction Village project should serve the comprehensive interests of the Town, rather than CHDC's narrower objective of maximizing affordable housing stocks. Yet the CHDC does not operate in a public process, so there is little opportunity to influence its plans, other than through funding decisions. The WinComm Association urges the Community Preservation Committee to condition its Junction Village funding upon maintaining the project at its original 20-unit scope, consistent with Town documents such as the 2010 Housing Production Plan and the 2013 Analysis of Impediments to Fair Housing Choice. Otherwise, there's the growing risk that the CPA funds could be wasted, as opposition continues to grow from neighbors, taxpayers throughout the town, drivers and pedestrians in West Concord as well as Concord Public School parents.
WinComm Neighborhood Association
Attachment: Supporting details for each of the concerns listed above.
1) Housing Production Plan – Recommended Scope of Affordable Housing Projects
The Housing Production Plan adopted by the Board of Selectmen and Planning Board in August 2010 provides guidance for future residential development in Concord. Section 2.3 details how projects should be defined once the 10% affordable housing threshold is met. The document states: "Even after reaching the 10% threshold, the Town plans to continue creating affordable housing, though at a smaller scale." It goes on to say that "These units will be created incrementally with smaller projects (5 units) moving forward regularly every year and three or four larger projects (15-20 units) making greater gains in the years they are approved."
At the bottom of Page 53, the Housing Production Plan includes a table of potential projects, where the project that has now become Junction Village is listed as having 20 units.
2) Lifetime Project Cost
Each incremental unit of housing at Junction Village would consume approximately $9,600 in town services each year. Of this amount, approximately $4,300 would be recovered through property taxes, resulting in a burden to the town of approximately $5,300 per unit each year. By taking a "big bang" approach to building 110 units of affordable housing inventory in advance of the actual amount required to maintain the 10% affordable housing threshold, the project will create a negative impact on the Town budget of nearly $500,000 per year for the first 5 years after it is built. Over the total planning horizon presented by CHDC, the aggregate incremental cost of CHDC's "big bang" project over the multiple-small-project approach proposed in the Housing Production Plan would be approximately $7 million, with a net present value of approximately $5.4 million. Any cost estimates for a "big bang" affordable housing project should consider these extra Town costs.
3) Traffic Impact
By CHDC's own estimates, 110 units of housing would more than double the traffic on Winthrop St., which is so narrow that visitors often park on the sidewalk. The limitations of Winthrop St. as an access point to the site were previously documented in a letter to the Planning Department on December 4, 2010. When combined with the traffic from the new Beharrell St housing project, it would also increase the traffic on the already congested Commonwealth Ave. by 9%. That reduces its level of service grade from "C" (stable flow) to "D" (approaching unstable flow).
4) Impact on Class Sizes at Thoreau or Alcott Elementary School
If CHDC's preferred 110 rental unit proposal goes forward, the CHDC estimates that 4.23 students per grade will be added to the public school system. At the elementary school level, there are currently four classes per grade at both Thoreau and Alcott. The Junction Village property is currently in the Thoreau school district, but according to School Superintendent Diana Rigby, the Junction Village students are anticipated to be bused to Alcott School, in the same manner as the children in the Concord Mews development have been. The result would be an average of one additional student in each classroom at Alcott Elementary School.
5) Project Character and Scale Relative to the Surrounding Community
The Community Preservation Committee encourages mixed-income developments that are harmonious in design and scale with the surrounding community. Winthrop Street and Commonwealth Avenue have a total of 53 one- and two-family units. CHDC's preferred proposal would build 90-110 units – approximately twice as many units as in the surrounding neighborhood. This is clearly out of scale. The proposed project also disregards the Town-sponsoredVillage Centers Study of 2010, which recommended that the Town "Consider a mix of uses that includes commercial, industrial and residential, which also takes into account the impact of increased traffic and change in intensity of use on the existing residential neighborhood on Winthrop Street."
6) Distribution of Affordable Housing Units in Concord
According to the Concord Long Range Plan and the Housing Production Plan, affordable housing should be distributed throughout the town. The Winthrop St. – Commonwealth Ave. neighborhood is one of the few in Concord that already meets the "moderately affordable" criteria that the CHDC intends to use for most of the units in its project. Over 75% of the existing units on Commonwealth Ave. and Winthrop St. are assessed at below the 150% threshold that will be used for the "moderately affordable" units in Junction Village project, and all residential properties in the area are below Concord's median assessed value. The project, as conceived, would further concentrate rather than distribute moderate affordable housing in Concord.
7) Junction Village vs. Smart Growth Development
Smart Growth concentrates development near city centers and transportation corridors to reduce the impact of commuters and enable shopping and other daily activities within walking distance. However, Junction Village is not intended for users of the commuter rail, but for people who already reside in, work in or are employed by the Town. The only significant local workplace within walking distance is the prison, so virtually all of the residents will commute to work by car. There is also no grocery store nearby, so residents will do most of their food shopping by car as well. Finally, due to capacity problems at Thoreau Elementary School, elementary school students in the complex will likely be bused across town to Alcott Elementary School. The Junction Village design routes all of this vehicular traffic through a residential area, rather than directly onto the Route 2 transportation corridor, compromising the walkable nature of the neighborhood that Smart Growth is supposed to promote.
8) Implications of "broadening" affordable housing to people with above-average incomes
The CHDC has defined 150% of the state median income as the threshold it would apply to the 75% of units that would become "moderately affordable" housing at Junction Village. That would include families of four making up to $141,600 per year. As CHDC points out, 52% of Concord's families would qualify for this "moderately affordable" housing. Put another way, the threshold is above most Concord families' median income, so even families with above average incomes could live in rentals whose design and construction was subsidized by many less-well-off taxpayers through CPA funds.
9) Long-term Marketability of "Moderately Affordable" Rental Units
As of June 2013, Concord had 1,157 rental housing units, with a median monthly rent of $1,572. The "moderately affordable" units at Junction Village would be more expensive: maximum rents could range up to $2,471 for a 1-bedroom, and up to $3,088 for a 3-bedroom, according to the CHDC's presentation. Rents in the surrounding area are substantially below these levels. While there are attractive attributes to the site (rail trail, river and proximity to West Concord Center) that might enhance demand, there are negative aspects as well (clear field of view from the prison required by deed, former brownfield site, more transient nature of a 100% rental property) that could hurt marketability, particularly as the units age. The CHDC has not presented any plan to contain this potential long term liability to the Town.
