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Anti-Displacement Action Plan Public Letter

Anti-Displacement Action Plan Working Group
· Last updated September 10, 2025
Letter
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To the City of Boston Interdisciplinary Anti-Displacement Action Plan Team:

Allston-Brighton Housing Action (ABHA) is a community group that advocates for abundant, affordable, diverse housing options in our neighborhood. The draft A Place to Thrive: Anti-Displacement Action Plan for Boston articulates a list of residential and commercial tenant protections that, in concert with zoning, building code, and development review reforms that allow for the development of new housing, can help the City steward change in the neighborhood while giving residents the time and dignity they need to adapt and thrive.

The “4 P’s” (Protect, Preserve, Produce, and Prosper) described in the Plan provide a framework for examining issues of neighborhood change and ABHA will comment below on the tools ABHA thinks are most useful for ameliorating residential and commercial displacement pressure in the city. That said, ABHA is concerned that the Action Plan does not emphasize the need to produce more housing. Reducing the cost of housing construction through re-zoning as well as building code and development review reform are not highlighted as critical tools, despite their ability to address the root cause of housing unaffordability and displacement: a housing shortage. To address this shortage, the City must produce more housing of all kinds and types while implementing policies that help our neighbors remain in our community without inadvertently making housing production even more expensive.

While the Action Plan lists many needed strategies, ABHA asks the City of Boston to recognize and address building code, zoning, and development review reform as important tools that help prevent displacement. Expanding tenant protections without a path for expanding housing supply will only make the current housing stock more unaffordable and stymie many of the benefits inherent to a growing and diversifying neighborhood. ABHA is especially interested in supporting Action Plan tools that anchor residents in Boston neighborhoods, support local and small businesses, and fortify our creative community.

Of the residential tools proposed, ABHA SUPPORTS the following:

  • Income-Restricted Housing Application Portal: ABHA strongly supports streamlining the application process for income-restricted units to ensure Bostonians are able to access housing and remain in their communities.
  • Lottery Preferences for Involuntary Displacees, Extreme Rent Burden: ABHA decidedly supports lottery preferences for individuals and families who have experienced the pressures of displacement first-hand.
  • Boston Acquisition Fund
  • Eviction Prevention Plan
  • Access to Counsel Pilot Program
  • Affirmatively Furthering Fair Housing Zoning
  • Extending the Affordability Terms of Inclusionary Zoning Units
  • Office to Residential Conversion Program Expansion
  • Housing Accelerator Fund

Of the commercial/cultural tools proposed, ABHA SUPPORTS the following:

  • Accessory Commercial Unit Zoning: ABHA especially supports an affordable alternative to traditional commercial spaces so that communities and small businesses benefit from more local and diverse commercial options.
  • Affirmative Cultural Zoning: ABHA particularly supports rezoning to bolster cultural and entertainment uses in Allston-Brighton, such as in Allston Village.
  • Space Grant - Next Generation
  • Site Finding Assistance and Space Readiness
  • Space for Creative Enterprises in Downtown

Of the tools proposed, ABHA STRONGLY OPPOSES the following tools unless the definitions are changed.

  • Expanding the Number of Conservation Districts. Conservation districts have historically been used to bog down or prevent changes to the built environment that would positively contribute to housing affordability, transportation mode shift, and achieving the net-zero climate goals to which the City has committed itself.
  • Citywide Survey of Historic Resources. Without a strong rationale that connects this to commercial or cultural displacement, a survey of citywide historic resources would not be a wise use of time and resources.

Based on conversations with local leaders, there are several tools or considerations that ABHA feel are missing from the Action Plan. ABHA SUPPORTS ADDING the following tools to the plan:

  • Parking Minimum Elimination: ABHA proposes eliminating the currently required parking minimums citywide to reduce the cost of housing and commercial space construction.
  • Building Student Beds: ABHA proposes requiring universities to do their fair share and build more on-campus student housing to relieve the burden on surrounding neighborhoods.
  • Expanding the use of the Massachusetts Rental Voucher Program vouchers for IDP units.
  • Tracking how many IDP units are filled, expiring use, etc.
  • Addressing fears that may be keeping community members from attending public meetings.
  • Creating criteria for identifying and approving assistance to residents facing eviction.

ABHA hopes the City of Boston continues to develop the Action Plan. ABHA asks the City to give priority to items that are presently available, funded, and possess a critical path forward. Please note ABHA has additional comments and concerns below.

Additional Details and Concerns

Residential Displacement Risk Map:

It is important to understand what factors contribute to the pressure our neighbors feel to move out of Boston. The Residential Displacement Risk Map  is a good first pass at quantifying this risk. That said, ABHA has some concerns. Several methodological choices make ABHA question the empirical validity of the tool and interpretability of the analysis’ results. And for users who do not have a deep understanding of the statistical analysis that this map represents, it can be very difficult to interpret.

While ABHA supports the goal of the map to understand displacement risk and proactively support residents in danger of displacement, ABHA also fears this could reduce private investments in areas already vulnerable to displacement and thus increase housing shortages there.

Displacement risk map should show city-owned land. Allston-Brighton has very little publicly owned land, so it is difficult for non-profit developers to build affordable housing here.

Tools Requiring State Legislation to Implement:

While ABHA supports many of the tools proposed in the Anti-Displacement Plan that need state legislation to implement, ABHA feels that it cannot count on such legislation. It will be important to address what the city can do in the event that legislation is not passed to support these tools, and if there is any way to address the resulting deficiencies. These tools include:

  • Tenant Opportunity to Purchase Legislation
  • Access to Counsel Legislation
  • Real Estate Transfer Fee (note for this proposal specifically, recent research evaluating a similar program in Los Angeles suggests that exempting development less than 15 years old might end up providing more affordable housing units than a transfer fee that included newer construction; while ABHA does not know the specifics of the LA regulation, this should be investigated more carefully. See Shane Phillips, 2025, Taxing Tomorrow: Measure ULA’s Impact on Multifamily Housing Production and Potential Reforms, UCLA Lewis Center)

Residential Tools

Tools ABHA supports:

ABHA supports the following tools identified in the Residential section of the Action Plan:

  • Income-Restricted Housing Application Portal. Eliminating information asymmetries is entirely positive for low-income renters seeking income restricted housing. We would like to see more policy tools like this.
  • Lottery Preferences for Involuntary Displacees, Extreme Rent Burden. Helping those most in need is important and admirable. That said, ABHA has several questions about the administration of the program. How will the means testing work? What information must be provided? Will it cost more to administer than to get the greatest number of community members into affordable housing?
  • Boston Acquisition Fund. Property ownership by people and organizations who are committed to the care of and compassion to their tenants contributes to a more just housing market in Boston. Ensuring adequate future funding for those organizations is imperative to maintaining existing properties and allowing them to be developed to meet the needs of future residents as well.
  • Eviction Prevention Plan. It will be important to develop tenant protections that do not discourage housing production.
  • Access to Counsel Pilot Program. Families are often too busy to contest housing actions in court. Providing them with information and representation can ease that burden if and when it happens.
  • Affirmatively Furthering Fair Housing Zoning. While ABHA supports the expansion of fair housing policy, we believe the City must continue with caution. There is a national movement to dismantle the Fair Housing Act and AFFH is particularly vulnerable, especially considering the mandate to enforce AFFH was recently terminated and is no longer enforced by HUD.
  • Extending the Affordability Terms of Inclusionary Zoning Units. ABHA supports extending the affordability term for IZ units to ensure the units remain available at affordable prices.
  • Office to Residential Conversion Program Expansion. Buildings are adaptable to meet the short term needs of our residents and expanding them to be converted to dorms or workforce housing can be beneficial to our existing institutional and business partners. For Universities, this should not preclude them from building new dorms for students.
  • Housing Accelerator Fund. A volatile global economy only exacerbates funding gaps and materials costs. Filling those gaps and getting in-progress projects to certificate of occupancy on schedule ensures our communities do not need to deal with potentially unsafe conditions due to economic policies the City has no control over.

Tools for which ABHA has concerns and questions:

  • Diversity preservation preference. While ABHA supports the overall goal of this proposed tool, ABHA is concerned that it could create legal challenges (potentially at the national level) that might lead to undoing important fair housing precedents nationally. The city needs to be extremely careful in this regard. ABHA is also curious as to whether the 2017 pilot worked as intended.
  • Co-purchasing pilot program. While ABHA supports the intention of this proposal and ABHA believes it can be helpful, ABHA is concerned that it subsidizes demand without expanding supply, thus increasing home prices for potential purchasers. ABHA also does not want to see this lead to the freezing of aging, substandard housing where redevelopment might create more housing, including more affordable housing, at less expense to the city. But it could be a very useful tool in well-defined conditions, along with tools like zoning reform that will help increase supply.
  • Acquisition for Affordable Homeownership Program. ABHA supports the proposal for mission driven organizations to acquire multi-family residential. ABHA has concerns that it might be using scarce funds to lock in low density housing that would be better used towards more multifamily units.
  • Article 80 Displacement Disclosure. ABHA supports the intentions of this disclosure (assess potential displacement impacts of a project, give tenants a 12-month notice if a developer is going to displace them, identify opportunities to support displaced tenants like financial and technical assistance for relocation, option to return, etc). But it seems like the mix and extent of mitigation support will be determined on an individual project basis. The Article 80 modernization effort is proposing to make mitigation and community benefits more predictable, but ABHA has not seen any details on that formula yet. Whatever mitigations are required, this should not lead to less affordable housing in the long run.
  • Expanded Condominium Conversion Ordinance. Because 2 and 3-family homes are the most frequently converted type of structure, it is important to regulate these fairly for existing tenants, and ABHA supports this, especially where there is a 1:1 conversion. However, ABHA has concerns that this could discourage the creation of affordable home ownership units if it made the construction of a denser condominium complex more expensive or difficult because of the 5-year notice requirement for certain populations. ABHA believes that in this situation (a smaller 2-3 family building converted to a larger multi-unit building) which would have an overall benefit of providing more housing than existed before, there should be other avenues available to address the displacement needs of special populations, rather than the 5-year notice.
  • Planning Department Fair Housing Review. While a review is generally positive, ABHA believes the City should hire a consultant who will consider the department’s practices and the recommendations in the current national context and movement to dismantle the Fair Housing Act. ABHA asks the City to consult with attorneys and advocates working at the national scale to ensure no policies are forwarded that may, while well intended, inadvertently provide the opening for critics to attack.

Commercial and Cultural Tools

Tools ABHA supports:

ABHA support the following tools identified in the Commercial and Cultural Stabilization section of the Action Plan:

  • Space Grant - Next Generation. Affording space is only one challenge businesses face in establishing roots in a community. ABHA supports evaluating existing programs to understand how they can be made easier for business to navigate as well as expanding existing programs, such as the SPACE grant, and creating new programs in the same vein which make finding a storefront in Boston as seamless as possible for new members of the community.
  • Site Finding Assistance and Space Readiness. Location assistance is not only relevant to new businesses that would like to open in Boston but also to current members of the community. Change is inevitable, businesses move for a variety of reasons. Helping business owners adapt to a changing economy or vision for the community can usher the neighborhood through change while maintaining the places and people who contribute to its’ vibrancy and livability. This is especially important for Main Street Districts, like Allston Village and Brighton Main Streets.
  • Space for Creative Enterprises in Downtown. Although this is addressed to Boston’s downtown spaces which are having trouble recovering from the pandemic, ABHA believes a vibrant city center is important for all neighborhoods. ABHA would like to see these spaces prioritized for local artists, musicians, and creative enterprises.
  • Accessory Commercial Unit Zoning. Accessory Commercial Units are one way to link commercial activity in one part of the neighborhood to others by providing goods and services to what used to be primarily residential areas. When residents can shop at a small grocer or specialty store a block from their house, they won’t feel compelled to drive to stores further afield in the city. Many cities have similar commercial unit typologies. Buffalo, New York, and Portland, Oregon, are great examples of cities that mix residential and commercial uses through small scale business spaces in primarily residential neighborhoods.
  • Affirmative Cultural Zoning. Part of stewarding growth throughout the city includes expanding the range of possible ways to build, live, and do business. Under current citywide zoning regulations, commercial districts can feel disjointed within areas of commercial activity and between those hubs. Affirmative Cultural Zoning can make these districts more internally coherent (a person can go rock climbing and grab a meal right afterwards in the same place) and flow between different parts of the neighborhood (i.e., a person can see a show at Roadrunner and then grab a drink at The Speedway on their way home). It's also our understanding that this would change the base zoning code and allow entertainment and other culture uses in those zones without a special permitting process.

Tools for which ABHA has concerns and questions:

  • Commercial Stabilization Fund. For stabilization funds to be effective, they need to be reliable. Without identifying a consistent course of funding for the Cultural Stabilization Fund, artists and other cultural businesses cannot expect the City to support them when they are in need. The City must identify a funding source for this initiative for it to become a viable policy option.

Tools ABHA opposes:

ABHA strongly opposes the following tools unless the definitions are changed.

  • Expanding the Number of Conservation Districts. The description of this tool in the Draft Plan text is confusing. In one paragraph it says that this will “recognize areas of cultural significance while respecting the economic circumstances of residents”. This needs more explanation. But in the next sentence it says “architectural conservation districts recognize and preserve distinctive design features”, and doesn't state any connection to the culture or economic circumstances of current residents. Our issue with this is that conservation districts have historically been used to bog down or prevent changes to the built environment that would positively contribute to housing affordability, transportation mode shift, and achieving the net-zero climate goals to which the City has committed itself. Increasing the number of these districts and expanding the types of architectural or cultural assets under the purview of these districts runs counter to many of the city’s policy goals. Freezing change to protect the aesthetic of one period of our history precludes the city from being home to new and innovative architectural styles. It also does nothing to protect the people and businesses using those structures today. We would simply be preserving structures, not the people and businesses they support, and making the spaces increasingly expensive for future residents and businesses.

Citywide Survey of Historic Resources.

Without a strong rationale that connects this to commercial or cultural displacement, a survey of citywide historic resources would not be a wise use of time and resources.