[Massplanners] Starter Homes M.G.L c40Y Draft Regulations Public Comment Period

Fri Jun 20 12:07:00 EDT 2025

The 2007 study I was citing is *The Fiscal Impact of Mixed-Income Housing
Developments on Massachusetts Municipalities
<https://donahue.umass.edu/documents/UMDI_FiscalImpact.pdf>*.

More recently MGL 40S has put some of this to the test. 40R projects have
the right for reimbursement of school costs, the primary driver that Jeff's
studies focus on, under some circumstances. Certainly there have been
significant 40S payments, but they have been far less than planners and
municipal officials originally thought since those impacts have been less.
I have not seen a detailed study on this, but no doubt it's out there.

*Wayne Feiden FAICP*

On Fri, Jun 20, 2025 at 12:00 PM Jeff Lacy <
ruralplanningassociates at crocker.com> wrote:

> This was the 90s when these studies came out. After the AFT study was
> publicized, concluding that residential didn’t pay for itself, follow-up
> studies established the assessed value cutoff between which covered their
> costs and which didn’t.  I then recall developers making representations to
> planning boards about how “high end” their homes were, thus riding above
> the threshold, so not to worry.
>
>
>
> Land uses that require a subsidy from other land uses to break even can
> only persevere until the cumulative subsidy is exhausted. I would say to
> Wayne and Judy that if there is an assessment tool out there that
> individual communities can use to debunk this notion, let’s put it out
> there so we misinformed planners may see the light.
>
>
>
> Jeff Lacy
>
> Rural Planning Associates
>
> 896 Graves Road
>
> Conway, MA 01341
>
> (413) 230-9693 (cell)
>
> ruralplanningassociates at crocker.com
>
>
>
>
>
>
>
> *From:* Judi Barrett <judi at barrettplanningllc.com>
> *Sent:* Friday, June 20, 2025 11:16 AM
> *To:* Wayne Feiden <wayne at feiden.org>; Jeff Lacy <
> ruralplanningassociates at crocker.com>
> *Cc:* Harry LaCortiglia <hlacortiglia at comcast.net>;
> massplanners at masscptc.org
> *Subject:* Re: [Massplanners] Starter Homes M.G.L c40Y Draft Regulations
> Public Comment Period
>
>
>
> I agree completely, Wayne. People don’t understand how to evaluate the
> fiscal impact of new housing or any other land use. If planners have
> trouble figuring this out, I don’t know how we can expect local officials
> to understand, let alone the general public.
>
>
>
> Judi Barrett
>
> BARRETT PLANNING GROUP LLC
>
> 350 Lincoln Street, Ste. 2503
>
> Hingham, MA 02043
>
> Office: (781) 934-0073, x7
>
> Cell: (781) 206-6045
>
>
>
>
>
> *From: *Wayne Feiden <wayne at feiden.org>
> *Date: *Friday, June 20, 2025 at 10:43
> *To: *Jeff Lacy <ruralplanningassociates at crocker.com>
> *Cc: *Harry LaCortiglia <hlacortiglia at comcast.net>, "
> judi at barrettplanningllc.com" <judi at barrettplanningllc.com>, MassPLanners
> MassPLanners CPTC <massplanners at masscptc.org>
> *Subject: *Re: [Massplanners] Starter Homes M.G.L c40Y Draft Regulations
> Public Comment Period
>
>
>
> Jeff identifies where a lot of opposition to affordable and attainable
> housing comes from, even in spite of the overwhelming social and economic
> need for such housing.
>
>
>
> I will point out, however, that while the American Farmland Trust (AFT)
> identified the high cost of residential development, they used a *average
> cost approach.* When the Citizens Housing and Planning Association
> (CHAPA) did a similar analysis, specifically of multi-family housing, they
> used a *marginal cost approach*, which resulted in very different
> outcomes. New housing rarely creates the need for a new city hall, fire
> station, police station, etc, so the marginal cost from new housing is much
> lower.
>
>
> *Wayne Feiden FAICP*
>
>
>
>
>
> On Fri, Jun 20, 2025 at 10:27 AM Jeff Lacy via MassPlanners <
> massplanners at masscptc.org> wrote:
>
> Fundamental rub with lower-priced housing, technically “affordable” or
> not, is fiscal. Cities and towns are principally concerned with making
> their budgets work without overrides and revolts. Their principal
> obligations are to provide essential services and infrastructure that
> residents expect and retaining an experienced high-quality workforce.
>
>
>
> The American Farmland Trust some decades back did a “Costs of Community
> Services” study in New England that looked at various land uses, what local
> government services they demanded, and how much they contributed in
> property taxes toward those services. Commercial, industrial, and open
> space all demanded less than they contributed. Residential, as a category,
> demanded more than contributed. But the residential results were a mixed
> bag, with an assessed value cutoff between the homes that covered their
> costs (higher assessed values) and those that did not (lower assessed
> values).
>
>
>
> For the AFT the takeaway was that, as a category, open farmland not only
> exerted fewer demands upon municipal services, but actually subsidized
> residential. So keeping those lands from being residentially subdivided
> made dollars and sense. For municipalities, the takeaway was that,
> fiscally, if there’s a given family of four in a house, it’s better for the
> town that the house have a higher assessed value (to better pay for the
> same service demands, education in particular).
>
>
>
> This tension between a societal need and a fiscal reality is the point I
> think Harry is making.
>
>
>
> Jeff Lacy
>
> Rural Planning Associates
>
> 896 Graves Road
>
> Conway, MA 01341
>
> (413) 230-9693 (cell)
>
> ruralplanningassociates at crocker.com
>
>
>
>
>
> *From:* MassPlanners <massplanners-bounces at masscptc.org> *On Behalf Of *Harry
> LaCortiglia via MassPlanners
> *Sent:* Friday, June 20, 2025 6:34 AM
> *To:* Judi Barrett <judi at barrettplanningllc.com>
> *Cc:* massplanners at masscptc.org
> *Subject:* Re: [Massplanners] Starter Homes M.G.L c40Y Draft Regulations
> Public Comment Period
>
>
>
> Since we're currently at 11.4 % Affordable on the SHI it's a safe bet that
> the Town recognizes the inherent value in affordability, Judi.
>
> The challenge to adopting new districts at town meeting in this community
> can often come down to framing the argument in beneficial monetary terms.
>
> Years ago our attempt at a 40R adoption failed by only 2 votes at Town
> Meeting. By the time we were ready to try adoption again at a subsequent
> Town Meeting, the State's incentive funding had dried up.
>
> We lost the carrot.
>
> Not surprisingly, we do not have a 40R District.
>
> In the aftermath of a contentious MBTA 3A adoption, until the bruises
> fade, the passing of new Zoning Amendments will now entail getting the
> citizens to forget the stick EOHLC used to achieve MBTA 3A adoption, and
> focusing more on the potential carrots that the town may receive.
>
> We just went through a Prop 2&1/2 override, so carrot$ could be very
> helpful.
>
> Best,
> H. LaCortiglia
> Georgetown P.B.
>
>
>
> It seems to me the best incentive is getting some affordably priced
> housing!
>
> [image: Image removed by sender.]
>
> Judi Barrett
>
> (she, her, hers)
>
> Barrett Planning Group LLC
>
> 350 Lincoln Street, Ste 2503
>
> Hingham, MA 02043
>
> (p) 781-934-0073
>
> (c) 781-206-6045
>
>
>
>
>
> On Thu, Jun 19, 2025 at 6:37 AM Harry LaCortiglia via MassPlanners <
> massplanners at masscptc.org> wrote:
>
> Thank you Filipe,
>
> The link you provided states that "Massachusetts offers incentives and
> technical assistance for towns and cities to create these districts."
>
> Could you elaborate with respect to the incentives for towns?
>
> Best,
> H. LaCortiglia
> Georgetown P.B.
>
>
>
>
>
> On 6/18/2025 3:19 PM, Zamborlini, Filipe (EOHLC) via MassPlanners wrote:
>
> Dear MassPlanners,
>
>
>
> The Executive Office of Housing and Livable Communities (EOHLC) is pleased
> to announce the opening of the public comment period for the Starter
> Home/Chapter 40Y regulations. We welcome your continued feedback on these
> draft regulations during the public comment period that starts on June 20,
> 2025 and closes on July 25, 2025. Submit a comment at
> www.mass.gov/starterhomes. We anticipate that final regulations will be
> effective in the early fall.
>
>
>
> Thank you,
>
> Filipe
>
>
>
> *Filipe Zamborlini (he/him/his)*
>
> Manager, Community Assistance Unit
>
> Executive Office of Housing and Livable Communities (EOHLC)
>
> Livable Communities Division
>
> 100 Cambridge Street, Suite 300
>
> Boston, MA  02114
>
> filipe.zamborlini at mass.gov
>
>
>
> [image: Image removed by sender.]
> <https://outlook.office.com/bookwithme/user/b4eb39dbb6b34b3fb6d841ec0fdb7916@mass.gov?anonymous&ep=signature>
>
> Book time to meet with me
> <https://outlook.office.com/bookwithme/user/b4eb39dbb6b34b3fb6d841ec0fdb7916@mass.gov?anonymous&ep=signature>
>
>
>
>
>
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>
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