May 9, 2022

Megan Riccardi, Chair
Ordinances, Licenses and Legal Affairs (OLLA) Committee
City of Salem
93 Washington Street
Salem, MA 01970

Re:  Bridge Street Neck Overlay District Proposal
 
Dear Chair Riccardi and Members of the City Council,

Bridge Street Neck is a significant historic neighborhood that includes 382 contributing buildings in the Bridge Street Neighborhood National Register District. Historic Salem and neighborhood residents have been involved in the current planning process for the proposed Bridge Street Neck (BSN) Overlay District for nearly three years, specifically as a member of the City’s working group for this project, as well as attending meetings, reviewing draft schematics, and commenting on the drafts of the Ordinance as they were developed.

This Overlay process began with a desire to create a zoning designation that brought the desirable but non-conforming existing uses along Bridge Street into compliance and specifically to allow new mixed-use development. As the community process unfolded maintaining and improving the physical character, both the appearance and the walkability, of the corridor was also highlighted as a concern.   The resulting Bridge Street Neighborhood Vision Plan Update directly informed the elements of the Bridge Street Neck Overlay District proposal.

As a participant in the zoning working group, we strongly disagree with most of the Planning Board recommendations for changes to the proposed Overlay District because they weaken the ability of the zoning proposal to support the Vision Plan. We look forward to participating in the discussions at the OLLA sub-committee meetings and in advance of the May 9, 2022 meeting provide the following input:

Administrative Review
We understand, based on the Planning Board conversation April 21 that the Planning Board would like small changes reviewed by the Board, rather than by staff who would use the Design Standards as a criteria. For context, the working group felt that Administrative Review would provide oversight on small changes in the district without burdening homeowners and small business owners with the requirements of a full Site Plan Review. If the administrative review is removed, consideration should be paid to a process for waiving the requirements of the site plan review application as appropriate. Placing the undue burden of a full site plan review on homeowners and small businesses could result in those owners avoiding improvements to their properties, selling to another entity with more resources, or undertaking changes without a permit.

Design Standards
As a consistent participant in public project review processes, HSI has often seen design guidelines not followed in other parts of our city and supports the original intent of Design Standards rather than Guidelines. We are not concerned about Standards needing to be changed via amendment to allow for flexibility because the ordinance allows for waivers after further Design Review Board (DRB) review.

Density
Until now we have not taken a position on density, but we cannot support higher density than the maximum proposed by the draft. The Planning Board calls for higher density without any suggested ceiling. The BSN Overlay dimensional requirements were developed based on the existing dimensional characteristics of the neighborhood, which is currently highly walkable and price diverse.  The density of 1700sf lot area per unit is in line with the current density of the neighborhood, which was heavily developed prior to the age of automobiles. The draft proposes a density that is significantly higher than what was proposed in 2012 or what was proposed at the beginning of this current overlay planning process. The proposed density is the highest in the city outside the downtown core.  An increase in the allowed density of the overlay, as suggested by the Planning Board, will quickly come into conflict with the required setbacks, open space and maximum heights.

Increasing allowable density would also make it difficult for projects to comply with the design standards. Increasing the density above 1700 sf of lot area per dwelling unit could result in development proposals requesting dimensional variances so that they could achieve an increased density. It is important that the density allowances be aligned with what could be built under the companion dimensional standards, which were derived through the important collaborative efforts of the working group and the neighborhood.

Planned Unit Development
We do not support the inclusion of Planned Unit Developments (PUD). The Vision Plan of the Bridge Street Neck applies equally to the 3-4 large parcels along the corridor as well as to any smaller parcel. The overlay was drafted to support that Vision Plan and a major goal of this initiative was to find a way to allow mixed-use projects, which the overlay does. As a result, the use flexibility of a PUD is not needed.

The dimensional standards were also a key part of the BSN Zoning Overlay, standards which PUDs are not subject to.  An allowance for PUDs would directly undercut the ability for the corridor’s community-developed vision to be met. If PUDs were allowed under this ordinance, it would negate much of the work on and intention of this overlay that was created with broad based neighborhood, stakeholder, and city administration participation.

Design Review Board (DRB) Recommendations
We support the need for a positive recommendation from the DRB to the Planning Board. In any review by the DRB the work of the DRB should be equal to the peer-review undertaken by other professionals (for example, traffic or wastewater engineers).


As the City Council considers this ordinance and the Planning Board recommendations, we feel it is important to respect the substantive neighborhood input and support that has been cultivated through a robust community engagement and input process and that is reflected in the ordinance as originally submitted.

We strongly urge the retention of the key elements of the Ordinance as originally submitted by the Planning Department to the City Council.

Thank you for considering our comments on this zoning overlay. We are available for further discussion and are ready to help the Council and Planning Department address issues and concerns to ensure that zoning changes in the city are respectful of our existing resources and workable as our community moves into the future.
 
Sincerely,
Emily Udy
​Preservation Manager