Response to draft changes to the Somerville Zoning Ordinance brought before the public by the Mayor, to allow developers to come in and create small units with greater density in commercial and certain residential districts of this condensed city- and call that "Senior/Disabled Housing.". the Ordinance was not passed.

1. ARTS REACHING THROUGH SOCIETY/ COMMUNITY ACCESS & INCLUSION PROJECT
December 3, 2009 via Email to City Clerk John Long
Attention: BOA Land Use Committee and the Somerville Planning Board
cc: Office of Strategic Planning and Community Development
Re: AN ORDINANCE AMENDING THE SOMERVILLE ZONING ORDINANCE TO
INCLUDE A SENIOR HOUSING USE CITYWIDE 10/22/09 DRAFT.
These written comments are submitted to be incorporated and considered without
edit or omission as part and portion of the joint public hearing December 3, 2009 at
the VNA Community Room, 259 Lowell Street.
A.R.T.S./Community Access & Inclusion Project advocates for the equitable
inclusion of all members of our communities and for the maximum useability of all
programs, services, activities, events, information, and opportunities.
We appreciate this opportunity to place comments on record regarding the proposed
amendments to the Somerville Zoning Ordinance relevant to Senior Housing. Five
recommendations follow.
1. We recommend conducting a Housing Needs Assessment Review, per SZO,
Section 13.8. The market demand for age-restricted housing with reduced floor
space, reduced parking space, and increased density in the named commercial
districts plus Residence C district is not sufficiently demonstrated. As with the
proposed revisions to the Condo Ordinance, which were tabled in March, more
outreach appears necessary.
2. We recommend consolidating this Housing Needs Assessment with the updating
of the City's Analysis of Impediments to Fair Housing (AI), as required by HUD at
24 CFR 91. This proposed housing use defines eligibility as one member being 62
or over, and/or disabled. The market demand for age-restricted housing with
reduced floor space and reduced parking space for households with at least one
disabled member is not demonstrated by the current AI or Housing Needs
Assessment reports used to develop the HUD Five-year Consolidated Plan,
referenced in para. 2 of this proposed Ordinance. Somerville's AI is currently
substantially incomplete because it omits discussion of the availability of appropriate
housing choices for the disabled community, who have poverty concentrations in
the 2 NRSAs as well as other census block tracts in Somerville. By consolidating an
RESPONSE TO PROPOSED AMENDMENT TO SZO FOR SENIOR HOUSING SOMERVILLE, MA 12/03/09 1

2. ARTS REACHING THROUGH SOCIETY/ COMMUNITY ACCESS & INCLUSION PROJECT
updated and inclusive AI with the Housing Needs Assessment, the City can
determine if this use is an appropriate and necessary strategy to overcome
impediments in fair housing for residents with disabilities.
3. We recommend that any Somerville Zoning Ordinance utilize the Fair Housing
Accessibility Guidelines as the statutory authority for new housing of any kind, and
encourage the use of the Principles of Universal Design. We applaud your idea of
using the Seven Principles of Universal Design guidelines to ensure use by the
widest variety of users. However, the Design Guidelines specified in this draft are
commonly used recipes that will not, of themselves, ensure accessibility of the
development as a whole. Nor are they Universal Design Principles, as is stated in
the Ordinance draft.
4. Any local Design Guidelines should be checked against the Universal Federal
Accessibility Guidelines (UFAS) if the affordable housing units are subsidized by
HUD program funding. We assume that you made a typographical error by
suggesting that Front Door widths begin at 26".
5. We recommend the promotion of a wider range of housing types, including for
intergenerational and non-traditional households, in order to accommodate the
projected increase of Seniors as well as smaller household sizes by 2030. While it
is clear that the continued production of single-family homes is not a sustainable
strategy, the development of age-restricted housing developments is not proven to
eliminate problems of isolation and limited access to quality markets and
community choices. However, it is increasingly shown that Seniors have a healthier
quality of life when they have access to intergenerational community activities and
choices. Therefore, expanded diverse housing development appears indicated,
rather than age-restricted housing, in meeting the challenges of the future.
Thank you very much for your continued good work.
Sincerely,
Eileen Feldman for A.R.T.S./CAIP
RESPONSE TO PROPOSED AMENDMENT TO SZO FOR SENIOR HOUSING SOMERVILLE, MA 12/03/09 2