Dear George, other Planning Staff, and consultants,   

Thank you for your hard work on the Plan and for your outreach and inclusion of the public in so many meetings to develop it.   

I wanted to share some high-level comments on these two documents.  I have read both documents twice, although it has been almost a month since I did so.   

I will be assuming in these comments that the Union Sq GLX station will be built as envisioned or something close to it.  If not, or if there is bus or commuter rail service instead of a subway stop, the entire plan may need to be redone as I don't think poor transit service will support anything close to this level of development.

There is much that is good in the Plan, such as the street changes, some of the building and streetscape designs, and the rough ideas for some of the seven development blocs.  But I am going to focus on what I see as some of the larger problems in these documents.  I think they both need a lot of work.  

I would first refer you to the Union Square Neighbors' analysis, which I hope they have submitted, which I saw in a presentation in late November and have reviewed subsequently.  This analysis highlighted some of the good things and also pointed to some major problems in the Plan.  I have attached the slides from this analysis in case you have not received them.

I also believe that Bill Shelton's two articles in the Somerville Times, one about the Plan and one about the Fiscal Impact Analysis, made many good points.  While I don't agree with his tone in places, and I think he got a few things wrong, he raises many good questions and I agree with his major points.

I am worried about some of the directions in which the Plan seems headed. I am concerned about the sheer huge scale of development envisioned, and I don't understand why the scale is so much larger than what was envisioned in Somervision.  The large number of housing units proposed (about 3,000, 3-4 times what was envisioned in Somervision) seems disproportionate for just one area of the City.  I don't believe a 20-story apartment building fits in Union Square on the D-2 bloc.  The amount of open space included in the plan is way too little, and clearly at odds with what the community has repeatedly asked for. The lack of any concrete plans for parking is puzzling leaves out a critical item in terms of space and finance.

My greatest concern is that the plan does not require enough commercial development on the D-2 and D-3 parcels right next to the Green Line station.  Each of these blocs is divided into three. According to the Plan, it seems that one third would be commercial office, one third housing, and the other could be either one.  I do not think we should allow any developer to put such a large proportion of housing on those two blocs.  They should at the very least conform to the 60-40 commercial/residential guideline, and probably be significantly more commercial as they are the prime locations for commercial development.  I think two of the three sub-blocs in both D-2 and D-3 should be commercial office, lab, R&D etc. and they should be reserved for those uses, even if they can't be developed for those uses in the near term.

I am extremely concerned that residential development will precede and crowd out commercial development. Will the real estate development cycle crash before commercial space gets built? The City needs commercial development, particularly office and R&D and lab space, because they create good jobs and bring in far more tax revenue than does housing. Right now the market for housing is white hot, so most developers want to build housing first because it is so lucrative.  We can't let them do that.  Commercial and housing need to be phased in together; we must not allow developers to cream off their profits through development of luxury housing first, before significant commercial space is built.

Our job as City leaders is to get the kind of development we want and need from private developers.  I have heard lots of opinions on both sides about whether Union Sq is ready for the commercial office development we want.  But since the benefits from large-scale luxury small-unir apartment housing development for the City are modest or non-existent, we should not allow any developer to use the best parcels in Union Square for apartment buildings.

In terms of housing, I disagree with giving developers the option for a payout or to build inclusionary units off-site.  The inclusionary housing program has worked well, and I don't think Somerville should have towers of exclusively wealthy residents in one place and low-income housing in another.   Also, the zoning for Union Square and the rest of the City should require a mix of sizes in apartments.  We have heard from many people that families are moving out of the City not just because of the cost of housing, but because there are not enough 3 BR apartments available.  Developers should be required by zoning to build some family-sized apartments in addition to 1 and 2 BRs.

I am puzzled by the proposal for Allen Street, which seems to have come out of nowhere, and would also be difficult to implement given that the City does not control almost all of the properties on Allen Street. 

Some of the assumptions in the Fiscal Impact Study seem extremely problematical.  There are no costs included for the City for civic space or civic buildings, for green and open space, and for parking.  The assumption seems to be that developers will pay for all these.  That would be lovely!!  Believe me, I want to soak the developers as much as we can and get every last penny possible out of them.  But while I hope and expect we will get a lot out of them, I don't see getting all the green space, all the civic space, all the parking, most of the maintenance, and so many other things we want as well (e.g. community benefits such as job training, artist space, affordable housing, etc).  Of course, with the GLX negotiations, we may end up getting a lot less than we expected or deserve from US2 and other large developers if they have to contribute big money to GLX.  

Those are my main points.  I look forward to the next draft of both documents.

Thank you again for your work on this and for keeping the public comment period open through the end of the year.

Yours,

Mark