Bristol's Affordable Housing Requirements and Robin Rug
According to Bristol’s current Zoning ordinances, the redevelopment of any property of 5 or more units requires that at least 20 percent of the units on site or at another location in town shall qualify as affordable housing. Further, the previous option of “payment in-lieu”— or having the developers give the town some token payment instead of building the affordable housing — has been eliminated. Affordable housing is a growing problem in Bristol and throughout Rhode Island, but the “Bristol Yarn Mill” redevelopment project currently presented by the developer Brady Sullivan Properties, LLC, does not address it and, further, does not comply with Bristol’s current Affordable Housing requirements.
To set the stage for this discussion of Affordable Housing, it is important to place the Bristol Yarn Mill proposal in context, in a way that may help Bristol’s decision-makers maintain their commitment to the laws, regulations, and community goals they have set forth in the Municipal Code and most recent Comprehensive Plan. When the Friends of Historic Bristol brought Donovan Rypkema of PlaceEconomics to Bristol in February 2019 as part of our on-going economic revitalization program, he was taken on a tour of the community. As Mr. Rypkema, who is one of the foremost experts in the field of economic redevelopment in the nation, went down Thames Street past the mammoth manufacturing site under discussion, he remarked that the Robin Rug complex represented the biggest development opportunity on the East Coast of the United States. It is within this context that all members of Bristol’s Historic District Commission, Planning Board, Zoning Board and Town Council are urged to hold fast to Bristol’s laws, regulations and goals, and not to weaken our community’s standards in the fear that by doing so we may lose the current developers. First, these developers are not likely to walk away from the extraordinary level of profits represented by the generous government subsidies available to them. Second, if they should decline to move forward in the face of Bristol’s determination to stand by its laws, then this highly attractive redevelopment opportunity will be snapped up by another developer more willing to abide by Bristol’s laws.
Brady Sullivan Properties, LLC are requesting that Bristol’s 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. Whether the issue is:
the developers’ request for a Zoning change to a more profitable designation, or
a significant increase in Residential Density from 98 to 151 units, or
our municipal Affordable Housing requirements, or
the Town’s 25% requirement for Commercial/Institutional/or Public Use which developers are “meeting” with a 3.53% commercial footprint, or
the impact on Traffic Congestion of adding 311 additional vehicles to one block in the historic downtown, or
the dimensions required for the safe functioning of parking spaces and driveway lanes,
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.
As stated previously, 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 was not one of these communities. It’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.
Affordable housing has a long and successful record of achievement in the US. It includes a rigorous screening process used to select responsible families as partners in the affordable housing arena. The provision of stable, affordable housing has life-changing impacts on the health, aspirations and achievements of families who would otherwise struggle year after year. And the impact of affordable housing goes far beyond the families it serves — triggering the growth of communities that, through a commitment to providing affordable housing, have enabled those who were born and raised in a town to be able to stay and raise their own families in that same town, or have enabled families to come to that town to contribute their energy and hard work to the strengthening of that community.
In contrast to the commitment to affordable housing that Bristol has enacted into its Codes, the developers of the current Bristol Yarn Mill proposal are seeking to opt-out of their affordable housing commitment. 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. Whether you are talking about Affordable or Market Rate housing, we should consider the configuration of fewer studio, one- and two-bedroom units and, instead, the creation of 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 or the commitment of the people of 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 Bristol ordinance.
[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