Bristol Yarn Mill Tech Review on 12/22/2021
A Technical Review of the Bristol Yarn Mill proposal submitted by Brady & Sullivan Properties, LLC, was held on 12/22/2021 at the Burnside Building. Representatives of the Bristol Historic District Commission, Planning Board and other pertinent entities met to discuss issues related to the proposal, including issues raised in submissions by the public. Hear the Robin Rug Technical Review meeting audio here.
The following issues were raised by Caroline Jacobus of 35 Church Street:
Thank you for the opportunity to provide comments on the proposed re-development of the Robin Rug mill complex by Brady Sullivan Properties, LLC. While I welcome the potential economic and residential housing expansion that this re-development proposal embodies, there are significant concerns relating primarily to the degree to which the developers, Brady Sullivan Properties, LLC are requesting that Bristol’s Zoning ordinances be significantly breached. These ordinances were voted into place by the Town because they represent what Town leaders believe to be the minimum standards for the re-development of its historic heritage, for housing its residents, and for promoting economic development. As the data provided by the developer demonstrates, their initial proposal falls significantly short in major design areas which will impact Bristol culturally, fiscally, functionally, and aesthetically.
I request that the following points be thoroughly examined and discussed at the Technical Review on December 22, 2021.
1. RESIDENTIAL DENSITY REQUIREMENTS
Article IX Sec. 28-284(d)(2): Residential density for historic buildings greater than 100,000 square feet in the W zone are required to have a minimum GFA/DU (gross floor area per dwelling unit) of 2,250 square feet per dwelling unit. My analysis of unit size for all 151 residential units (see attached) shows that not a single one of the 151 units meets the required 2,250 sq. ft. Units range in size from 546 to 1,929 sq.ft with the majority of units falling into the 700-1,299 sq. ft. range:
First floor: 5 units with total 5,065 sq. ft.= 1,013 ave. sq. ft. for each unit
Second floor: 53 units with total 59,750 sq. ft. = 1,127.4 ave. sq. ft. for each unit
Third floor: 50 units with total 56,242 sq. ft. = 1,124.8 ave. sq. ft. for each unit
Fourth floor: 43 units with total 50,975 sq. ft. = 1,185.5 ave. sq. ft. for each unit
When this project’s total residential unit square footage of 172,032 sq. ft. is divided by the 2,250 sq. ft. per unit required by Bristol Town ordinance, the allowed number of units totals 76.5. In 2008, Bristol Town Council granted a conditional Zone Change which enabled an increase in residential density to 98 units, or 22 more than allowed by the Town ordinance – a 28% dispensation. Now Bristol is being asked to raise the residential density to 151, or 197% of the Town ordinance allowable number of units. Many of the units on the submitted plans could be combined to create fewer, but larger, units that more nearly comply with the Town’s requirement of a minimum 2,250 square feet per dwelling unit.
The Attachment to the Brady Sullivan Application Form For Zoning Map Change states that “The Applicant is now seeking to construct 151 residential units with a minimum gross floor area per dwelling unit of 1,500 square feet per dwelling unit as opposed to the 2,900 square feet per Dwelling Unit allowed in the Decision. It is noted that Section 284(D)(2) of the present Zoning Code allows a Density of 2,250 square feet per dwelling unit for an urban rehab land development project which contains a historical building greater than 100,000 square feet.” In fact, as documented on the Site Plans and in the attached Analysis of Residential Units, fully 71.5% of the proposed units (108 out of 151) are smaller than the 1,500 square foot per dwelling unit minimum gross floor area stated by Brady Sullivan as the size of their units and fully 100% of units are smaller than the required 2,250.
A report by the Pimental Consulting Group was submitted, providing justifications for the Zoning Ordinance changes the Applicant is requesting. While not wishing to provide a detailed response to this report at this time, I will state that many of the justifications, especially those relating to residential density, space devoted to commercial use, and affordable housing, are not based on sound data and are of questionable value.
2. COMMERCIAL/INSTITUTIONAL/PUBLIC USE REQUIREMENTS
Article IX Sec. 28-284(d)(1): Required minimum of 25% of site must be reserved for commercial, institutional, public use. Total square footage of all 151 units is 172,032 sq. ft. When the Brady Sullivan estimate of 6,300 sq. ft of commercial space is added, there is a TOTAL building occupancy square footage of 178,332 sq. ft. Therefore, the 6,300 sq. ft. of commercial space represents 3.53% of the total site, which is significantly below the required 25%. As it is generally recommended that no residential units be situated on the first floor as a safety condition in the event of flooding, the 5 units on the first floor would, if re-purposed to commercial space, contribute to raising the required 25% of commercial, institutional, public use from the current proposed 3.53% and would contribute to the tax base.
3. AFFORDABLE HOUSING REQUIREMENTS
Affordable Housing is a growing problem in Bristol and throughout Rhode Island. The Low and Moderate Income Housing Act, first enacted in 1991, calls for at least 10% of the housing supply in Rhode Island municipalities to be classified as “affordable.” In June 2021 it was reported [1] that only six out of 39 communities — Burrillville, Central Falls, Newport, New Shoreham, Providence and Woonsocket — met the 10% threshold as of last year, according to the 2020 HousingWorks RI FactBook. Bristol’s affordable housing supply fell into the “5-10%” range. Currently, housing unaffordability is at a near-record level. Cortney Nicolato, CEO and President of the United Way of Rhode Island, said the problem of the lack of affordable housing is the most critical issue now facing the state. In October 2021, Nicolato stated: "Economists here in the state of Rhode Island have shown that we are tens of thousands [housing units short]. I think the last number I saw was about 25,000 units short of safe and affordable housing here in the state." [2] In Rhode Island, the median price of a single-family home is nearing $400,000. [3] Too many people who were born and raised in Bristol cannot afford to raise their own families here. They are priced out of the housing market.
On page 2 of the Attachment to the Application for Zoning Map Change and Modification, at the end of a lengthy discussion of parking minutiae, there is a sentence dropped in that states: “In addition, pursuant to Condition 2 of the Decision [relating to the 2008 Council approval], the Applicant will be making a Fee in Lieu payment to the Bristol Affordable Housing Trust Fund based upon 10% of the approved Units.” We would remind the Applicant that Section 28-370 - Inclusionary Zoning (modified January 2021) now requires 20% affordable housing at the project location or new buildings elsewhere in town, or rehabilitation elsewhere in town to accommodate the required units. (“Affordability requirement. For all applicable projects as defined in subsection 28-370(a), at least 20 percent of the units on site must qualify as affordable housing, as defined by this article. Fractions of a lot or dwelling unit shall be rounded up to the nearest whole number.”) Also, the January 2021 zoning revision eliminated the in-lieu payment option previously available.
The Fuss & O’Neill proposal cover letter prepared for Brady Sullivan Properties, LLC which includes requested zoning variances, does not include a request for variance to Section 28-370 - Inclusionary Zoning.
The report submitted by Pimental Consulting stretches credibility on a number of issues when it asserts that their proposal conforms to Bristol’s Comprehensive Plan regarding commercial space, parking, traffic, density, and affordable housing. To state, as both Fuss & O’Neill and Pimental Consulting do, that their proposal is in compliance with Bristol’s ordinances because they are asking Bristol to significantly change their ordinances and also rezone the properties involved, is disingenuous.
As to affordable housing, the Pimental report and, more fully, the JDL Enterprises Fiscal Impact Study allude several times to the preponderance of studio, one- and two-bedroom units and that this would discourage family rentals and, consequently, limit the presence of children in the complex. I would advocate for the configuration of fewer studio, one- and two-bedroom units and more 3-bedroom apartments, specifically so that families will be attracted to the complex. Bristol is fast becoming a town where only seniors can afford to live, where the population of school children is steadily decreasing, where the children who grew up in Bristol can no longer afford to rent or buy a home and raise their families. We need to reverse these trends if we want to have a healthy, growing, economically viable community. Pimental’s position regarding affordable housing – that they are only prepared to recognize 10% of units be devoted to affordable housing and that this obligation will be handled through a “payment in lieu” – is no longer the law in Bristol. We should welcome the opportunity to have the maximum number of families renting in affordably priced units at the Bristol Yarn Mill complex or somewhere else in Bristol, in compliance with the ordinance.
4. FISCAL IMPACT
The Fiscal Impact Study prepared by JDL Enterprises and amplified by Fuss & O’Neill provides extensive documentation on the impact of housing configuration – specifically the number of bedrooms – on the number of children who will reside in the complex. It also analyzes the per capita cost of schooling those children. Based upon their current proposal for the Bristol Yarn Mill, this project is financially detrimental to the town, resulting in an estimated Net Revenue Loss of $345,773 per year to the town. If a higher number of families were to be encouraged through fewer but larger units, the financial loss to Bristol would presumably grow due to higher total education costs. I would suggest that reducing the total number of units to conform more closely with Bristol ordinances and raising the percentage of space devoted to commercial use more closely to the required 25% will both reduce the fiscal burden on the Town and promote the housing of Bristol’s families.
5. TRAFFIC CONGESTION
The submitted traffic impact statement is based on a 15 year old study. This study also took place on inclement days in March, which would have resulted in lower than average traffic incidence. With the planned addition of some 302 cars all within one block on Thames Street, emptying out onto the Town’s main thoroughfare, Hope Street, it is imperative that a new traffic study and crash analysis by a neutral firm be implemented. The submissions by Brady Sullivan as to the probable impact of the residents of 151 housing units look unrealistically low. Will traffic lights be needed at Constitution or Church Street in order to feed cars from sides streets onto Hope Street?
6. DIMENSIONS OF PARKING SPACES AND DRIVEWAY LANES
The developers are requesting multiple changes to Town ordinances relating to the size of parking spaces, parking aisles, parking space markings and driveway dimensions, shaving off a foot here, 2 feet there, as well as line markers for spaces. These easings of Town safety ordinances result from efforts to squeeze spaces for 302 cars (2 spaces for each of the 151 rental units) into the existing parking lot and the space available at the ground level of the mill complex. If the number of rental units is reduced to more closely conform with Bristol Zoning Ordinances, then the number of parking spaces that are needed will also be reduced and there will be no need to compromise the safety of users of the parking lots.
[2] https://www.golocalprov.com/business/should-ri-spend-500m-on-affordable-housing
[3] https://www.golocalprov.com/business/is-the-median-price-of-a-rhode-island-home-headed-for-400000