To the Editor,
The Zoning Board of Appeals (ZBA) is now faced with Manchester's most important permitting decision in many years: Strategic Land Ventures (SLV) proposed Chapter 40B, 136-apartment complex on Shingle Place Hill. I grew up and lived for many years in Manchester, and now reside in Essex. I love both towns and still consider myself a person engaged with and vested in Manchester.
I urge the ZBA to apply the most thorough and rigorous standards possible in their review of the comprehensive permit for this project, seeking the maximum protection for the interests of all the Town’s residents. Most people, I believe, want to see SLV stopped, but it is difficult to chart the wisest course forward through the Mass Housing appeals process and possible legal remedies further down the road. The ZBA’s options are 1) denial and 2) approval with conditions. The folks on this Board have a really difficult call to make, and I trust that they’ll do their absolute best on behalf of the Town.
ZBA will of course weigh the destructive environmental and aesthetic impacts of the project which are well known by now, particularly with regard to water resources. Herein, I want to emphasize a few further points. First, SLV would strip the vegetation from the entire hilltop and then blast and remove an enormous amount of earth, mostly rock, during “site preparation”. SLV has not stated how much this might be, but we know that they intend to use about 100,000 cubic yards of it for “cut and fill”, that is, for construction of the road snaking around the flanks of the hill from School Street up to the complex. The total amount of blasted earth is likely (and conservatively) twice that: 200,000 cubic yards (about 300,000 tons). Transport of the remaining blast material from the site would require over 8,000 dump truck loads, assuming 12 cubic yards per load. This operation is akin to West Virginia coal mining technique and comes with its own distinct impacts: shock waves, noise, and wear and tear, on nearby properties, conservation lands, and public infrastructure.
I hope further that the ZBA will give considerable weight to two issues. The first is that the 300-400 residents (my guess) of "The Sanctuary" will be marooned on a hilltop, remote from the rest of the community and its schools, businesses and services. The complex would be served by an extremely steep access road with no sidewalk or safe route for bicycles. This is nearly exactly opposite the State's own guidelines for the siting of Chapter 40B projects. It would also be a virtual guarantor of hundreds of car trips per day, at a time when the State of Massachusetts is pushing hard for more housing located close to business districts and transportation services, and is struggling to meet CO-2 emissions reduction targets set by the Legislature. The project is a climate change Double Whammy: it would destroy woodlands that would otherwise sequester carbon, while also locking in decades of avoidable tailpipe pollution and traffic congestion from its residents' cars. Please note that project principal Geoff Engler has declined to act on the suggestion to install solar generating capacity and EV charging stations.
Secondly, The Sanctuary grossly violates Mass Housing's guidance that 40B projects should be appropriate in scale and style for the surrounding neighborhood. Mr. Engler has repeatedly made the point that Shingle Place Hill "has no abutters", and that there is, in the sense of an affected neighborhood, no impact. I and many others in the community strongly disagree with this notion. The abutting landowners include the Town of Manchester and private non-profit land trusts, all holding land protected for conservation purposes in perpetuity, as well as private landowners who have held their woodland lots over many generations. In a larger sense, the abutters are the assemblage of plants and animals that make up the nearby wetlands and woodlands, as well as all the citizens of Manchester and the surrounding communities who value the intrinsic and aesthetic qualities of these lands. This vastly outsized complex would have profound negative impacts on its neighbors for decades to come: runoff, noise, artificial light, and visual blight, among others. It is in fact impossible to imagine ANY neighborhood in Manchester or its surrounding communities where The Sanctuary would fit in.
Mass Housing was made well aware of all these and other issues, including serious fire safety questions, in the excellent letter from the Board of Selectmen last year, and essentially brushed them aside in its Project Determination Letter of September 16, 2021. Mass Housing cannot be counted on to hold SLV's feet to the fire with regard to any conditions the ZBA may seek to impose. Mr. Engler is likely to assert that some or all of such conditions would render his project uneconomical. This may be true on the face of it, but it’s clear that the project's super-sized and shoe-horned scale is driven by the high price that he agreed to pay for the land, which is an extremely difficult site that most people thought had limited development potential: a steep, rocky hill nearly surrounded by wetlands, and with no proximate water and sewer utilities. The deeper truth is that the financial analyses of The Sanctuary do not include what economists call “externalities”, not all of them anyway. Externalities are costs resulting from negative knock-on effects like traffic, pollution, and infrastructure wear and tear, long term costs to be borne by the public, not SLV.
One final point, which the ZBA likely cannot consider in its decision, but which I and many others find vexing: The Sanctuary does not provide truly affordable housing to the people in our community who need it the most. The "affordable" units start at $1,900/month; according to Chapter 40B formulations, this is satisfactory, though on the high side. It's based on annual household income of about $85,000, but I'm sure there are plenty of people around here for whom these units are not "affordable". I must add that it was especially galling when, during a public meeting, part of Mr. Engler's reply to a question about rental rates and the project's financial sustainability was that he'd charge higher rates for units on the upper floors because of the views over the conservation area. Thus, Cedar Swamp is not an abutter; it's an amenity!
I dearly hope that this appalling and cynically conceived project can be stopped, but cannot say exactly how that might best be done. Manchester’s citizens and officials must continue working hard to protect the environment and character of the Town, while addressing its real and long neglected affordable housing needs. Let’s be hopeful!
Lastly, I must be clear that I am speaking here for myself, not for Manchester Essex Conservation Trust, of which I was president until last November. I am still on the Board, and still support MECT's efforts to oppose the project, but this letter is all mine.
Michael Dyer
Essex
