This is actually a very important clarification because it directly affects how we will need to calculate density. The guidelines are very expansive in what land is included in the denominator for density calculations. It includes things like roads and public land. The point is that the "15 units per acre" is never going to be the "density of the buildings" because some of the land will always need to be set aside.
We, as citizens, are trying to understand what the proposed rezoning would look like for Lincoln. The Sudbury project has 12 units per acre as per the guidelines, which is what we should consider for comparability purposes. The minimum for HCA is 15 units/acre, which is not even the highest value we're proposing in some districts for Lincoln. Like Sarah P pointed out, the working group is proposing much denser housing at 18-25 units per acre in some parts of Lincoln, which translated into the "density of buildings" could be even higher. Guidelines are not regulations, and state agencies' interpretations do not carry the force of law. Again, what we are asking for is a proper due diligence of the risks and rewards, which hasn't been completed yet, and a truly democratic process with proper debate, opening the floor to residents' opinions. On Mon, Oct 9, 2023 at 6:08 PM Margaret Olson <[email protected]> wrote: > Just to be clear - when describing the density of the Sudbury project I > was trying to answer the question: "what is the density of the buildings". > I was not making any statement about the lot density or any HCA > calculations. > > I can not speak for the HCWG, but they are concerned I believe with the > regulations because the state agencies are empowered to define what it > means to comply with the law. > > On Mon, Oct 9, 2023 at 4:33 PM Karla Gravis <[email protected]> wrote: > >> Waterlands and septics can be taken out for "gross density" >> <https://www.mass.gov/info-details/section-3a-guidelines#6.-minimum-gross-density-> >> calculations per 3A guidelines, BUT publicly owned land CANNOT. >> >> >> >> The 9.9 acres in the Sudbury parcel that are owned by the town cannot be >> excluded from the denominator in the density calculation. The calculation >> shared by Margaret of 21 units per acre is not accurate, since it removes >> publicly owned land. According to the guidelines, the Sudbury project has a >> density of 274 units in 26-3.1=22.9 acres or 12 units per acre, below the >> 15 units per acre needed for HCA compliance. *Any zoning approved in >> Lincoln that pertains to follow the guidelines would have to be DENSER than >> what is being built in Sudbury. *Rob is right - I encourage folks to >> take a look at the Subdury project here >> <https://sudbury.ma.us/pcd/2020/05/07/cold-brook-crossing-residential-development-planning-board-permitting-application-materials/> >> . >> >> >> >> I would also point out that the RLF proposed a plan to build at a density >> of 25 units per acre (slide 48 >> <https://www.lincolntown.org/DocumentCenter/View/79138/2023-06-16-HCA-Public-Forum-Slide-Deck?bidId=>). >> That is almost twice as dense as the project in Sudbury. >> >> >> >> The model Rob is building will help people understand the enormity of the >> changes being floated. >> >> >> >> The working group has not explained why it is solely concerned with >> following the guidelines, which keep changing and could continue to change >> even after we vote for any hypothetical rezoning. Guidelines are not law >> nor regulation. We should be more concerned with what the law states than >> with attempting to follow guidelines that are merely interpretations of the >> law by government agencies and are constantly changing. >> >> >> ———————- >> >> >> >> Section 3A guidelines – 6. Minimum Gross Density >> >> >> >> a. District-wide gross density >> >> >> >> To meet the district-wide gross density requirement, the dimensional >> restrictions and parking requirements for the multi-family zoning district >> must allow for a gross density of 15 units per acre of land within the >> district. By way of example, to meet that requirement for a 40-acre >> multi-family zoning district, the zoning must allow for at least 15 >> multi-family units per acre, or a total of at least 600 multi-family units. >> >> >> >> For purposes of determining compliance with Section 3A’s gross density >> requirement, the EOHLC compliance model will not count in the denominator >> any excluded land located within the multi-family zoning district, except >> public rights-of-way, private rights-of-way, and publicly-owned land used >> for recreational, civic, commercial, and other nonresidential uses. This >> method of calculating minimum gross density respects the Zoning Act’s >> definition of gross density—“a units-per-acre density measurement that >> includes land occupied by public rights-of-way and any recreational, civic, >> commercial and other nonresidential uses”—while making it unnecessary to >> draw patchwork multi-family zoning districts that carve out wetlands and >> other types of excluded land that are not developed or developable. >> >> >> >> c. Wetland and septic considerations relating to density >> >> Section 3A provides that a district of reasonable size shall have a >> minimum gross density of 15 units per acre, “subject to any further >> limitations imposed by section 40 of chapter 131 and title 5 of the state >> environmental code established pursuant to section 13 of chapter 21A.” >> This directive means that even though the zoning district must permit 15 >> units per acre as of right, any multi-family housing produced within the >> district is subject to, and must comply with, the state wetlands protection >> act and title 5 of the state environmental code—even if such compliance >> means a proposed project will be less dense than 15 units per acre. >> >> >> >>> ---------- Forwarded message --------- >>> From: Margaret Olson <[email protected]> >>> Date: Mon, Oct 9, 2023 at 2:59 PM >>> Subject: Re: [LincolnTalk] 15 Units per Acre - Part 2: Cold Brook >>> Crossing - Sudbury/Concord on 117 >>> To: Robert Ahlert <[email protected]> >>> Cc: Lincoln Talk <[email protected]> >>> >>> >>> From the project narrative ( >>> https://s3-us-west-2.amazonaws.com/cdn.sudbury.ma.us/wp-content/uploads/sites/326/2020/05/Cold-Brook-Crossing-Site-Plan-Narrative-March-11-2020.pdf?version=dd2e49a8d33cbe913460c6b7d51236c4 >>> ): >>> >>> Of the 26 acres: >>> 9.9 acres are in conservation >>> 3.1 acres are part of the Sudbury Water District and will remain so >>> >>> That leaves 13 acres. 274 units/13 acres = 21 units per acre. >>> >>> >>> -- >>> The LincolnTalk mailing list. >>> To post, send mail to [email protected]. >>> Browse the archives at >>> https://pairlist9.pair.net/mailman/private/lincoln/. >>> Change your subscription settings at >>> https://pairlist9.pair.net/mailman/listinfo/lincoln. >>> >>> -- >> The LincolnTalk mailing list. >> To post, send mail to [email protected]. >> Browse the archives at >> https://pairlist9.pair.net/mailman/private/lincoln/. >> Change your subscription settings at >> https://pairlist9.pair.net/mailman/listinfo/lincoln. >> >>
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