See also:
ABN proposed changes to Article 80; letter to the BRA - March 28, 2000
Sixty-one Modifications to Article 80, prepared by the ABN (PDF file, 764K) - March 24, 2000
1. Full and Convenient Access to Information -- ABN asks that BRA records be better organized, more accurate, and better publicized so that the public can track agendas, comments, hearings, testimony, and decisions. ABN asks that all information of public interest be readily available for free or at low cost, in whatever format the requestor desires (paper, facsimile, e-mail, web site, diskette, or compact disc). ABN asks that the BRA expand its mailing lists to include more agencies, neighborhood groups, and media. Currently, Article 80 has no provision for full and convenient access to information.
2. Clarity and Completeness -- ABN asks that all technical terms be defined in a glossary, and that unclear terms be re-defined. ABN asks that other regulations be summarized inside Article 80, so that community groups can understand the review and approval process without reading the entire Zoning Code. ABN also asks that city maps showing neighborhoods and industrial sub-districts be published inside Article 80. Currently, Article 80 has no such maps. Some examples are in Sections 80D-5.2(b), 80-5.2, 80-7, 80B-3.3, and 80B-7.2(a)(iii)(ii).
3. Simplification -- ABN asks that language be shortened, simplified, and changed from legal style to common English so that people can clearly and easily understand the regulations that control their communities, and participate in the public processes designed to protect them. An example is in Section 80-5.3, paragraph 1.
4. Consistency -- ABN asks that similar rules apply to all projects. An example is in Section 80-3.
5. Fair and Realistic Comment Periods -- ABN asks that public comment periods never be shortened or eliminated, and that all public comment periods be at least sixty days so that communities have time to receive notices, conduct research, debate issues, vote on a position, and voice their opinions to city officials. Some examples are in Sections 80-6 and 80-A-2.3(b)(iv).
6. Responses to Public Comments -- ABN asks that copies of all written public comments be published along with numbered responses from proponents, as is done at the Massachusetts Environmental Protection Agency. Currently, there is no requirement to publish comments or responses.
7. Substantive Improvements -- ABN asks that project improvements include not only "mitigation" that merely accommodates adverse impacts, but also substantive revisions to use, dimensions, and design that eliminate adverse impacts. Some examples are in Sections 80B-1, 80B-5.3(d), 80D-3.5, and 80D-5.4(c).
8. Transportation Impact -- ABN asks that transportation be measured for impacts on both pedestrians and communities, not just on existing traffic, and that impacts be more comprehensively measured and include expected levels of service, vehicle miles traveled, queuing, and pollution generation. Some examples are in Sections 80B-1, 80B-5.3(d), 80D-3.5, and 80D-5.4(c).
9. Removal of "Economic Feasibility" Loopholes -- ABN asks that proponents not be allowed to skip improvements by claiming that they cost too much. Some examples are in Sections 80B-3.1, 80B-3.2, and 80B-3.4.
10. Removal of Automatic Approval Loopholes -- ABN asks for deletion of four types of loopholes: loopholes by which public comment periods can be shortened or skipped; loopholes by which approvals happen automatically after a certain number of days; loopholes by which the BRA can approve projects that other agencies haven't reviewed; and loopholes that waive all review and approval requirements in exchange for improvements or increases in affordable housing. Some examples are in Sections 80B-5.3(a), 80B-5.4(c), 80B-5.3(d), 80B-5.4(c)(iv), 80B-5.c, 80E-2.4(c), and 80-6.
11. Enforcement -- ABN asks that a provision be added which allows residents to suspend progress on any project for which the city has violated its own regulations until the violation is corrected. Currently, there is no such protection.