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Home My WebLink AboutNorthAndover Comments to MassHousing_7.25 - Town Manager - Correspondence - 0 Prescott Street 7/17/2025 Town of North.� iud;ov r Office e �)f ih r old: ou o,%tid jvc 1'o&n Hti11 y� 1r1 GEC C i '� �I <<" North Ar:u�:llaaFeu°°,�q�1A 018�4 l �w� � t ��ur°��d W°'lg�� '�a;;a�.��tn�r d�.��r�u•��w a g��° Meh,5,5a Murphy-Rodrigues, Esq. Yelephone (978)688-9510 lawn Manager Tax (978)688-9556 July 17, 2025 Via Electronic Mail Ms. Kat Miller Senior Planning and Programs Analyst MassHousing One Beacon Street Boston, MA 02108 RE: Project Eligibility Application—0 Prescott Street&67 High Street,North Andover,MA MassHousing Project No. 1281 Developer: East Mill Housing LLC Dear Ms. Miller, On behalf of the Town of North Andover, I respectfully submit this letter of comment in response to the Project Eligibility(PEL) application submitted by East Mill Housing LLC for a proposed 296-unit mixed-income rental development at 0 Prescott Street and 67 High Street under M.G.L. Chapter 40B. These comments reflect preliminary input from the Select Board and Planning Board, informed by internal staff review and a site visit that was held on June 26, 2025. Please note that the Planning Board felt it important to provide its own letter with detailed commentary;therefore,that letter is attached and reflects a detailed expansion of comments that are covered in this letter. The Town of North Andover supports the Commonwealth's goal of expanding access to affordable housing and recognizes the role of Chapter 40B in helping communities achieve that goal. North Andover is a Housing Choice Community as designated by the Commonwealth's Executive Office of Housing and Livable Communities and has taken meaningful steps to address housing needs, including efforts to expand multifamily zoning, encourage redevelopment, and preserve existing affordability. Recent actions include the adoption of an Inclusionary Zoning Bylaw(2022), an MBTA Communities Multifamily Overlay District(2024), and an Accessory Dwelling Unit Bylaw(2025). This is in addition to having a previously approved 40R District, land use boards that have for several years regularly approved multi-family housing developments, and consistent support for the development and preservation of affordable housing through the use of Community Preservation Act funding and the Town's Affordable Housing Trust. With that said,the Town believes that the below comments and concerns warrant careful consideration before a Project Eligibility Letter is granted. Project Context and Site Suitability The project proposes 296 rental units on approximately 6.13 acres—an intensity of development that significantly exceeds what is typical or permitted in this area under local zoning. The site is located within the Industrial S and Residential 4 underlying zoning districts, as well as the Subdistrict A: Historic Mill Area overlay district. Town of North.� iiud;ov r Office �)f ihe 1r1 GEC Ci i '� �I <<" North Ar�u�:llaaFeu°°,�q�1A 01 �4 l �w� � t �r�ur°��d W°'lg�� '�a;;a�.��tn�r d�.��r�u•��w a g��° Melissa Murphy-Rodrigues, Esq. Yelephane (978)688-9510 town Manager Fax (978)688-9556 Although the surrounding area includes recently developed multi-family housing, it is also flanked by low-density, single-family homes and a heavily trafficked commercial corridor(Route 125). The proposed building height of approximately 53 feet in the Residential 4 portion of the site significantly exceeds the 35-foot height limit permitted by right and would ordinarily require a special permit under the Subdistrict A overlay. Similarly,the proposed floor area ratio (FAR) of 1.70 exceeds the 1.0 maximum allowed by right and would also normally require special permit relief. These figures compound concerns about massing and scale,particularly adjacent to existing residential homes. In addition,the proposed 16.5-foot side setback along 39 Prescott Street is noncompliant with the 35-foot setback requirement outlined in the Subdistrict A zoning where abutting residential districts. The first 15 feet of this setback is typically required to remain open and landscaped,which the current plan does not reflect. The Town is also concerned about the removal of mature trees adjacent to existing homes,which would reduce natural screening. Retention of existing vegetation and commitment to a robust tree-planting program are strongly recommended. Summary of Key Concerns 1. Traffic,Access, and Circulation • The project could potentially introduce substantial additional traffic to Prescott Street,High Street, and the Route 125 corridor. • The Town recommends a comprehensive, independent traffic impact study that addresses: o Intersection operations and sight lines o Trip generation o Queuing at key access points o Emergency vehicle circulation 2. Emergency Access and Public Safety • The proposed private way serving the site is only approximately 20 feet wide due to 90-degree parking along both sides,which poses potential obstructions for emergency access. 3. Stormwater,Floodplain, and Environmental Conditions A recent study commissioned by the Town and supported with a Municipal Vulnerability Preparedness (MVP) Action Grant,the Cochichewick Brook Floodplain Management Report(June 2025),presents detailed hydraulic modeling of the watershed from Lake Cochichewick to the Merrimack River. This report identifies flood risks throughout the Machine Shop Village District(this is the neighborhood in which the project is proposed), including High Street and the area directly adjacent to the proposed Zero Prescott project site. This area experienced a 100-year flooding event in 2023 that contributed to over$30 million in damage reported by the Town. It is important to note that Mill Pond in the Machine Shop Village is less than 300 feet away from the Town of North.� iul;ov r Office �)f ihe 1 o% il 1r�1 ii GEC Ci i '� <<" ort1� Ar�u�:llaaFeu!-, N1A 01 �45 �Il �w� � t �r�ur°��d W°'lg�� '�a;;a�.��tn�r d�.��r�u•��w a g��° Melissa Murphy-Rodrigues, Esq. Telephone (978)688-9510 Town Manager Fax (978)688-9556 project site at its closest point, although it is downhill from the site. Among the Report's findings are: • In a present-day 50-year storm, a model shows that the bank ofMachine Shop Pond[Mill Pond]is overtopped by about 1.9"of water The flooding footprint wraps around the buildings between Machine Shop Pond and High Street, including 9 through 43 High Street. The flooding footprint extends through High Street to the parking lot west ofHigh Street, and abuts the buildings for 14 through 50 High Street. • In a projected 2070 100-year storm, the bank of Machine Shop Pond is overtopped by about]-feet 3.2-inches of water The flooding footprint wraps around the buildings between Machine Shop Pond and High Street, including 9 through 57 High Street. The flooding footprint extends through High Street to the parking lot west ofHigh Street and abuts the buildings for 14 through 50 High Street. Nearly the entire building for 30 to 50 High Street is inundated with flood waters. Plood limits abut the foundation of the building for 65 High Street. • Current FEMA maps do not capture the full extent of flooding risks, and the modeling supports an expansion of regulated flood zones. Any large-scale development at this location should take the Floodplain Management Report's hydraulic modeling and broader findings into consideration. 4. Compatibility with Surrounding Neighborhood and Zoning Context • The building height, FAR, and minimal setbacks exceed the standards of the underlying and overlay zoning districts. • The scale and massing could potentially be considered out of character with the surrounding neighborhood and adjacent one-family homes. 5. Municipal Services • The introduction of nearly 300 units may lead to burdens on municipal water, sewer, emergency and solid waste services. • The Town recommends a thorough load capacity analysis of water and sewer systems, as well as an analysis of how emergency response -police, fire, ems - may be affected by the proposed project. Regulatory Framework Context The Town submits these comments in the context of the required findings outlined in 760 CMR 56.04(4). While we recognize that the proposed project may meet certain threshold criteria for eligibility under the housing subsidy program,we urge MassHousing to consider the site's functional limitations, zoning inconsistencies, and significant contextual challenges in determining whether it is "generally appropriate for residential development" under subsection (b), and whether the conceptual design aligns with the site and surrounding neighborhood under subsection (c). Housing and Planning Context Town of North.� iul;ov r Office �)f ihe 1 o% il 1r1 it GEC Ci i '� <<" rrtl� r�A dlaa Feu!-, NIA 018�4 �Il �w� � t �r�ur°�� W°'lg�� '�a;;a�.��tn�r d�.��t��r�u•��w a g��° Melissa Murphy-Rodrigues, Esq. Telephone (978)688-9510 Town Manager Fax (978)688-9556 North Andover has proactively addressed housing needs, as demonstrated by the recent adoption of several zoning tools and the permitting of other high-density housing developments. However,the scale and density of this proposal far exceed recent approvals: Property/Developer Site Area (AC) Units Lot Coverage Floor Area Units per Acre Ratio Avalon NA 9.57 170 13% 0.47 18 Princeton Properties 9.3 192 16% 0.60 21 (residential only) Minco (505 Sutton St) 3.24 136 34% 1.1 42 Berry Farms (40B) 26.09 196 7% ? 8 Zero Prescott(proposed) 6.13 296 34% 1.7* 48 *FAR calculation without parking garage: 0.99 The Town has a comprehensive Master Plan that was accepted by the Town's Select Board in 2018. Among the document's strategies that could be construed as being inconsistent with this project, or requiring further action are: • Land Use, Strategy 3: Focus new development and zoning changes along key commercial corridors that may be more appropriate for higher-density mixed-use development at key nodes or intersections. o Although the proposed development sits within what could be considered a"key node"given the area's function as a commercial and residential center with other higher density uses, it is also not located on what would be considered a key"commercial corridor"like Route 125 or Route 114 that are better positioned to absorb potential impacts of the project. • Housing, Strategy 15: Continue to review the impact of new housing development on the Town's public infrastructure and services. o The Town would like to fully understand the impact(s)that this project will have on public infrastructure and services. • Economic Development, Strategy 21: Ensure existing commercial and industrial land is not converted to support only multi family uses, but instead a mix of uses promoting vibrant commercial centers and corridors. o Although the Mill Area itself has a mix of uses that could be perceived as promoting a vibrant commercial center,this site and the surrounding recently redeveloped parcels owned by AvalonBay Communities will have been redeveloped exclusively as multi-family housing. As expressed earlier in this letter,the Town very much values and supports the development of Town of North.� iiud;ov r Office �)f ihe S20 1r�1 yid GEC Ci i '� <<" ort1� Ar�u�:llaaFeu!-, N1A 01 �4 �Il �w� � t �,,. �r�ur°��d W°'1 �� '�a;;a�.��tn�r d�.��r�u•��w a ��° Melissa Murphy-Rodrigues, Esq. Yelephane (978)688-9510 town Manager Fax (978)688-9556 housing, especially affordable housing,but it also wants to ensure that it provides a healthy counter balance of commercial/industrial development. • Economic Development, Strategy 25: Encourage the development of mixed-use buildings which support both residential and commercial uses. • Economic Development, Strategy 29: Work with large landowners of economically-important properties in town to identify and attract a mix of uses for the redevelopment of those properties. Technical Assistance and Next Steps The Town intends to apply for a Chapter 40B Technical Assistance Grant through MHP to support the Zoning Board of Appeals' future review of this project, should it proceed. We appreciate MassHousing's continued partnership in helping communities evaluate complex proposals fairly and thoroughly. Conclusion In summary,while North Andover supports the production of affordable housing in appropriate locations,we have concerns about the scale, zoning and Master Plan inconsistencies, and potential infrastructural and service-based impacts of this particular proposal. We respectfully request that MassHousing take these comments under advisement before issuing a Project Eligibility Letter and encourage further dialogue with the Town as this process continues. Sincerely, Melissa Murphy-Rodrigues, Esq. Town Manager Cc: Janice Phillips - Chair, Select Board Andrew Shapiro,AICP -Assistant Town Manager/Director of Community and Economic Development Eitan Goldberg -Chair, Planning Board Jean Enright-Planning Director Michael Lis - Chair,Zoning Board of Appeals Paul Hutchins -Building Commissioner/Zoning Enforcement Officer Attachment