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September 26, 2023
On behalf of the Greater Boston Chamber of Commerce and our 1,200 members, I write to oppose Docket #1293, the administration’s text amendment to the Boston zoning code codifying Boston’s Inclusionary Development Policy (IDP). The Chamber is deeply concerned that the City is advancing a policy that has no clear goals and makes housing development infeasible in Boston. In March, the Chamber submitted testimony raising these concerns. We remain concerned over this policy development because the text amendment addresses neither of these concerns.
Despite the opportunity to clarify the goals of the administration in updating the IDP, the zoning amendment makes no reference to an end-goal from this policy change. We do not know how many new units of housing will be built because of this change, why the administration is choosing now to pursue this update, and how this policy change will meet housing production and affordability goals. Without these guide points, it is nearly impossible to measure progress and to consider alternative policy developments.
One thing is clear from the data on IDP: even modest changes to the IDP requirements negatively impact project feasibility. The higher the standards, the more difficult it becomes to build more housing. The amendment advances policies that would make some housing projects infeasible. For large housing developments, the City’s own research concludes that at a 20% IDP unit set aside standard for rental units, projects may have to seek cost relief to be financially viable.[1] The Chamber raised this feasibility issue previously, but this option remains in place for large projects. The amendment provides a new option “B” for large rental developments to meet their IDP standard, but the City’s own research indicates that this option is just as nonviable as the original option. [2] Increasing the supply of housing is paramount to solving the region’s housing shortage. The City must pursue policies that make it easier to develop more housing in the City. This policy does the opposite by making housing developments less financially possible.
In the text amendment, the City is also largely ignoring the IDP zone designations that were originally put in place to ensure that neighborhoods with lower property values have less stringent IDP standards. This is an important caveat in the policy to ensure housing projects remain feasible across the City. The administration’s original proposal echoed this consideration by requiring less stringent IDP ownership standards for developments on the outer core of the City. [3] The zoning amendment makes no such distinction. These additional IDP standards will compound the difficulty of building housing in the outer core of the City.
The zoning amendment does not address the feasibility concerns raised by the Chamber, and in some ways, this amendment doubles down on standards that will disincentivize investment in housing production. Data indicate that building permits in the Boston metro area are down 50% from last year.[4] The Chamber urges the Council to reject this proposed zoning amendment and instead pursue policies with clear goals that will make building more housing easier in Boston.
Sincerely,
James E. Rooney
President & CEO
[1] Boston’s Inclusionary Development Policy (IDP) Analysis, RKG Associates, Inc. Page 61-62
[2] City of Boston Inclusionary Development Policy: Financial Feasibility Analysis Technical Report, Page 6
[3] Boston’s Inclusionary Development Policy: Background and Zoning Proposal December 2022 Side Deck, Page 17
[4] U.S. Census Bureau Building Permits Survey (BPS)
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