September 2, 2005
Doug Lloyd
Massachusetts Housing Finance Agency
RE: Comprehensive
Permit Site Approval Application of James Lefebvre entitled 7 Roads Station
“B”,
Dear Mr. Lloyd,
The East Longmeadow Board of Selectmen recently responded to you in a letter dated July 27, 2005 with comments pertaining to the Comprehensive Permit Site Approval Application submitted to MHFA for eligibility determination of the above mentioned project. Now that we have had an opportunity to review these plans, we feel compelled to update our original comments. However, before addressing the specifics of the plan, it should be noted that no low or moderate income housing project proposal has ever been submitted by Mr. Lefebvre or any entity under his control to the Board of Selectmen for this site and, to the best of our knowledge, he has never presented such a plan to any other municipal board or agency seeking to create low or moderate income housing at this site.
In addition, a review of the
application shows that the applicant is an individual, James Lefebvre. It is our understanding that pursuant to 760
CMR 3.01 (1) in order to be eligible to submit an application for a
comprehensive permit the applicant and the project must meet the jurisdictional
requirements (a) the applicant be a public agency, a non-profit organization,
or a limited dividend organization, (b) the project shall be fundable by a
subsidizing agency under a low or moderate income subsidy program, and (c) the
applicant shall control the site. No
specific information with respect to funding is provided in the materials
submitted to the Board, however, shows that the applicant is an individual, not
an entity as required by the regulation, and that the applicant is not in
control of the site. A significant area
designated as parking on the plan is owned by the Town and would required the
Town of
The plans submitted are not “official” site plans; however, they do give an understanding of building size, appearance, access/egress, and parking, (as noted above the parking is not fully contained on the site but would requires the acquisition of property from the town of East Longmeadow to construct the parking area as shown). No landscape enhancements or open space is currently identified on these plans.
Building #1 is a 4,793 square foot, single-story building designated for retail use. The minimum required parking per town bylaw is twenty-eight (28) spaces. Building #2 is 21,712 square foot, two-story structure designated for commercial use. The minimum required parking per town bylaw is one hundred nine (109) spaces. Building #3 is 68,542 square foot, four-story structure which is designated for retail and residential uses. The retail use is at grade level and is 15,168 square feet. This would require minimum parking of ninety-one (91) spaces. The residential use for levels two, three and four is 53,374 square feet and would require, per town bylaw, a minimum of forty (40) parking spaces.
The total
parking required pursuant to the Town of
According to the plan, parking is provided via adjacent parking areas or a two story parking garage. As previously stated by both the Board of Selectmen and the Planning Board, a parking garage is not an allowed use according to the town’s bylaws. The town does allow for a private parking garage but has a limit of no more than five (5) vehicles for such a garage. A denial of the second level of the proposed parking garage would reduce the offered parking by another forty (40) spaces.
Mr. Lefebvre’s plan also contemplates the relocation of the historic railway depot building from the applicant’s property to abutting town property. This land has been dedicated for a future bike path. While this action would require approval from the Board of Selectmen, such approval has never been requested nor granted by this board. In addition, the plan shows forty-seven (47) parking spaces along the westerly boundary, each of which exceeds the property boundary line and encroaches onto town property by approximately 50% of the area required for each space. Private parking on Town property again requires approval from the Board of Selectmen subject to a Town Meeting vote. Again, such approval has not been requested nor has it been granted by the Board of Selectmen or Town Meeting at the present time.
The plan shows the maximum height for the residential/retail establishment to be 57 feet, 10 inches. The maximum height requirement for a residential use is 35 feet, a business use is 40 feet, and an industrial use is 50 feet, according to the Town’s bylaws. This project contemplates exceeding even the least restrictive height requirement now imposed by town bylaw.
In summary, the proposed plan lacks the ability to correct serious deficiencies in parking should the project be developed, as the entire parcel is over-utilized. The plans demonstrate no room to add additional spaces and there is no option for any on-street parking within a close proximity to this location. Even with some “creative” planning, the total number of parking spaces provided is significantly less than the minimum requirements. If this proposal moves forward as a “mixed use” project, the retail tenants will come and go determined by market factors, each new tenant with potentially different parking needs dictated by the specific use or type of business. Again, there is no opportunity to mitigate the existing deficiencies. Although the plan does provide for one space per residential unit, experience indicates that most two-member households will have two vehicles. Additional parking should have been planned to reflect this. The expectation is that the overflow vehicles will utilize space in the adjacent commercial and municipal lots. This would further perpetuate the already existing parking deficiencies.
Of great concern is the viability of the forty-seven (47) parking spaces encroaching on Town property, the approval of which rests with the Board of Selectmen subject to Town Meeting approval. The same requirement applies to the re-location of the Railway Depot on town property. Since no approval for these actions has been requested or given, the Board suggests that this plan, as presented, is defective, and does not represent a reasonable proposal.
Finally, the Town of
Thank you in advance, for your thoughtful consideration to these matters.
SINCERELY,
John Claffey
James Driscoll