TOWN OF IPSWICH

Board of Selectmen
25 Green Street
IPSWICH, MASSACHUSETTS 01938

Edward B. Rauscher, Chairman

Charles D. Surpitski, Vice-Chairman
William M. Craft
Nishan D. Mootafian
Judy A. Field

p: (978) 356-6604
f: (978) 356-6616
e: selectmen@ipswich-ma.gov
w: www.ipswichma.gov

December 5, 2016
Michael J. Busby
40B Project Coordinator
Massachusetts Housing Finance Agency
One Beacon Street
Boston, MA 02108

RE: Primrose Farm, 30-34 Town Farm Road, Ipswich, MA Chapter 40B Site Approval Review

Dear Mr. Busby:

On behalf of the Ipswich Board of Selectmen, I am writing to inform you that we have received your letter of
November 1, 2016, requesting comment on a Site Approval/Project Eligibility submittal to MassHousing by
Edward Champy of Waypoint Companies of Boston, MA, on behalf of the property owner, 30 Town Farm
Road LLC, for a proposed 40-unit development at 30-34 Town Farm Road. This letter serves as our response.
As part of our review process the Selectmen received input from the Ipswich Housing Partnership, Town staff,
and the general public. The Selectmen considered this matter at its November 21 and December 5, 2016
meetings.
The Selectmen are generally supportive of the proposal to create affordable for-sale housing for residents of age
55+ at this location. We are excited to see a proposal that will mean additional affordable housing and pleased
that: (1) the applicant has presented the proposed project to various Town boards and departments prior to the
submittal of the application to your office; (2) the project is at least somewhat in character with the surrounding
neighborhood; and (3) the site is located within a mile of the Town center, and capable of being served by
public water and sewer.
With that said, we do have concerns about the Town Farm Road and High Street (Route 1A) intersection and
the impact of adding vehicle trips associated with 40 new housing units at the subject site. High Street carries a
high volume of vehicles and at this particular intersection the sight distances to the north are less than optimal.
We urge you to consider the traffic impacts of the proposed development in your analysis of the sites suitability
for this project and suggest that you mandate a traffic study.
We also have some concerns about the design of the project, and suggest a number of modifications that would
enhance the developments benefits to its inhabitants and the Town. To the extent possible, we would like them
noted in your eligibility approval letter. Our concerns and suggested changes include the following:

1. The proposed development pattern has positive attributes: the duplexes allow for greater density while
remaining somewhat in character with the surrounding single-family neighborhood, and the proposed
through street from Locust Street to Town Farm Road would facilitate traffic circulation within the
property. But the current configuration does not provide sufficient spacing between the proposed
buildings, sufficient building setbacks from Locust Street and Town Farm Road, adequate separation
from adjacent wetlands, nor does it provide any accommodation for pedestrians or bicyclists. Further,
some of the buildings are situated approximately five feet from an existing major Town water main
easement, which causes concern to the Towns Utilities Department relative to its safe operation and
maintenance. We recommend that the site plan be redesigned to further concentrate the housing (e.g.,
convert some of the duplexes into triplexes), thereby allowing increased separation from the water main
easement and from wetlands, an expanded area of open space, and greater setbacks more consistent with
those of the residential streetscape of the established neighborhood. Without such changes the
development cannot be considered to concentrate development in a meaningful way that restores and
enhances the environment, or conserves resources as the applicant claims on their Smart Growth
Criteria Scorecard.
2. Because of the significant amount of wetlands on the site the applicant is strongly encouraged to work
closely with the Conservation Commission throughout the comprehensive permit review process and
any future development.
3. The preliminary site plan shows an approximate wetland line. Assuming its generally accurate, the
majority of the proposed units, the roadway and the related infrastructure are within the Commissions
100 foot jurisdiction. Twelve of the dwellings units, as well as the stormwater management pond, would
be located within 25 feet of the wetlands, four would be less than ten feet from the wetlands, and two
less than five feet. Development this close to wetlands will almost certainly adversely impact them, both
during and after construction, and the Commission is extremely unlikely to approve a project that creates
such impacts. If the Commission were to approve housing units or other structures within 25 feet of the
wetlands, they would very likely require a permanent No-Disturbance Zone demarcated by a wooden
fence with appropriate signage, to be maintained in perpetuity.
4. When the plans are further refined the applicant should address the site layout and landscape in
relationship to the adjacent cemetery. An adequate buffer between the cemetery and the development
should be proposed to produce a context sensitive design.
5. A portion of the subject property is located within Zone II of the Browns Well (Water Supply
Protection Zoning District), a component of the municipal water supply. The applicant will need to
demonstrate how he intends to ensure that development on the site will satisfy the objectives of the
Water Supply Protection District as it applies to the property.
6. The applicant proposes to connect the development to the Towns public water supply and sanitary
sewer system. This will require extending the sewer line a significant distance from its current
termination point at the intersection of Town Farm Road and Locust Street. The manner in which this is
done has significant implications for the Towns existing services so it is essential that the applicant
work closely with the Town on this matter. The applicant should submit a conceptual plan, preferably
before the submittal of the comprehensive permit application, so that the Towns Water and Sewer
Commissioners and the Utilities Department have the opportunity to advise the applicant of its
appropriateness.

Town of Ipswich | Office of the Board of Selectmen

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7. The development as proposed is essentially a subdivision, whether or not the constructed houses are
situated on individual lots. As such, the development should meet the requirements of the Towns
subdivision regulations to the greatest extent practicable. To facilitate the Towns ability to assess
compliance with this requirement, the comprehensive permit application needs to include, at a
minimum, the following information prepared by a licensed professional engineer registered in the
Commonwealth of Massachusetts: (a) existing and proposed topography sufficient to establish drainage
patterns and profiles and water bodies; (b) major features of the land; (c) proposed drainage systems,
sewer and water mains, and electric supply; (d) existing and proposed widths of rights-of-ways and
traveled ways within the site and in the immediate vicinity; (e) existing and proposed center line profile
of the proposed roadway system. Further, the applicant should submit a separate landscape plan
prepared by a Registered Landscape Architect licensed in the Commonwealth of Massachusetts and an
environmental and community impact analysis.
8. The aesthetic appeal of the buildings, though reasonably attractive in themselves, is undercut by their
repetitive siting (eleven structures in a string on one side of the street, nine on the other). This
unimaginative layout of the site could be improved by a more clustered siting of the duplexes along with
some three-unit buildings to allow for fewer buildings overall. Further, the developer should use
porches, dormers, color, siding, and landscape features to give more variety to the site and an identity to
each home.
9. There is no evidence that the applicant has employed low impact development techniques to improve
water quality and promote water conservation or to conserve other resources. To meet sustainable
development objectives of the Smart Growth Criteria Scorecard the applicant should incorporate water
conservation measures into the plan and units and either install solar panels (preferably) or site homes to
take advantage of solar energy, or both. Energy conservation measures should not necessarily be limited
to the above (native, drought tolerant plants; others).
10. Based on feedback from our Police Chief, we do not support the proposed method of numbering the
buildings. Instead, we recommend the standard numbering system with odd numbers on the left side and
even on the right side. We have no preference on which end of the road the unit numbers begin.
11. The proposed development appears to place 40 units on one commonly-owned property. As such, it will
require a homeowners or condominium association. The Town requests that the applicant be required to
provide information about the association as part of its comprehensive permit application to the Ipswich
Zoning Board of Appeals. The Town discourages restrictions that would be counter to the comments
contained herein, especially those pertaining to accessibility or energy conservation.
12. The application does not appear to address the issue of handicap accessibility. Our understanding is that
the State requires all of the dwelling units to be built in a manner that can be easily converted to meet
handicap accessibility requirements. We strongly support that requirement, but also strongly recommend
that the developer be required to make at least ten percent of the dwellings (i.e., four units) fully
handicap accessible, to meet the needs of persons in our community and region with mobility
difficulties.
Ipswichs Efforts to Create Affordable Housing and Facilitate Smart Growth
The Town of Ipswich has long supported the preservation and development of affordable housing. The Town
regards Chapter 40B as an effective tool and in many instances has welcomed its use. The Towns current
percentage of permanent affordable housing, 8.6%, is substantially higher than that of most of our neighboring
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communities. Over the years the Town has approved more than ten 40B projects, including: a 70-unit elderly
affordable housing project in the early 1980s; a 48-unit rental housing project approved in 2001; a 100%
affordable, 48-unit rental housing development in 2004; a 36-unit for sale development in 2005; and a 15-unit
rental development in 2006.
In addition to 40B projects the Town has taken a variety of steps to increase affordable housing supply in the
community. These include:
Adoption of an inclusionary housing zoning regulation that requires that all multifamily housing projects
creating fewer than ten units to either make a payment of $10K per unit to the Affordable Housing Trust
or make a unit affordable. For multifamily projects that create ten or more units the developer is required
to make one unit affordable for the first ten units and then either make the payment or provide a unit for
the additional fractional units.

Development of a tax-title parcel (for which the Town forfeited more than $200,000 in taxes) into three
single-family affordable houses and a four bedroom mental health group home.

Operation of a first time homebuyer down payment assistance program, which has provided financial
assistance to more than 30 income-eligible families.

Adoption of a Great Estates zoning regulation that allows non-traditional development (to preserve
estate properties) but requires that 10% of all dwelling units be affordable.

Conversion of a vacant Town-owned building into seven units of affordable elderly rental housing in the
downtown.

Conversion of a vacant Town-owned building into ten units of affordable elderly rental housing in
central Ipswich.

Establishment of a homeowners rehabilitation program in 2003 and another in 2012 that has assisted 14
families to date.

Adoption of a zoning regulation that allows accessory buildings in the two predominant residential
districts to be converted into residential dwellings, subject to certain requirements, which include
making the unit affordable or making a payment to the Affordable Housing Trust. Twenty two accessory
buildings have been converted to dwelling units under this provision.

Adoption of an infill housing zoning provision that allows the construction of homes on certain
undersized lots in the largely built-up Intown Residence district, provided the homes are affordable
(there is a payment in lieu option of $50K) and otherwise in character with the neighborhood. Four infill
lots have been approved to date, resulting in a total payment of $200,000 to the Towns Affordable
Housing Trust.

Adoption of a zoning provision allowing accessory apartments (in 2004 it was expanded to allow
accessory apartments in all zoning districts), which has led to the creation of 66 such units.

Adoption of a zoning provision whereby the Planning Board may, by special permit, allow a density
bonus in multifamily developments if the developer provides an affordable housing (units(s) or
payment) or public recreational benefit. This provision has resulted in the creation of several new
affordable housing units and helped make certain multifamily housing projects economically viable.

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As a result of the initiatives described above, the Town has approved or created approximately 339 units of
housing, 308 of which are long-term affordable. Through the first-time homebuyers and housing rehabilitation
programs, the Town has preserved or provided housing opportunities for another 14 households. To date, nearly
$600,000 has been contributed to the Affordable Housing Trust Fund; and another $195,000 is committed.
The efforts described above demonstrate the Towns commitment to affordability and our constructive bias
towards sustainable smart growth development. Given our commitment, we ask that you give our views and
concerns considerable weight as you evaluate the Primrose Farm application.
Sincerely,
Edward B. Rauscher, Chairman
Board of Selectmen

cc: L.A. Associates, Inc.

Department of Planning & Development
Housing Partnership

Town of Ipswich | Office of the Board of Selectmen

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