The following statement, approved by the Green Acton Board of Directors, was shared with the Acton Board of Selectmen (now Acton Select Board) and multiple other Town entities between March 28 and April 1, 2021:
This memo urges the Acton Board of Selectmen to deny permitting the proposed 67 Powdermill Road development project. Acton needs affordable, sustainable, and accessible housing; this proposed project satisfies none of these criteria.
As an organization that advocates for environmental sustainability, Green Acton is particularly concerned that all new residential building projects: (1) conform with the Town Sustainability Policy, which calls for sustainability to be taken into account in Town actions, decisions, et al.; (2) comport with the Green Acton Housing Principles, which call for Acton to have truly sustainable, affordable, and accessible housing (see #2, below); and (3) employ non-fossil-fuel energy systems for provision of heating and cooling, and solar arrays (or readiness) where appropriate, given the 2020 Town Meeting decision to declare a Climate Emergency. It is our contention that the proposed 67 Powdermill Road building project meets none of those criteria. We explain how below.
- Town Sustainability Policy
Acton’s Sustainability Policy calls for sustainability to be taken into account in decisions and actions that the Town, including the BoS, may take. Specifically, the policy states: “The Town of Acton, in its actions, policies, budgets, bylaws, and purchasing decisions, will consider and strive to advance sustainability.” This project does not appear to include any consideration of sustainability, either overall or in specific features. Our specific concerns in this regard include:
• The 67 Powdermill Road parcel, which includes both forested land and grassy meadow, runs along the fragile ecosystem of the Assabet River. The small but critical stretch of ecosystem that would be destroyed by the development is one of the last such remaining areas in that commercialized section of Town. Riverside ecosystem parcels such as this are particularly precious, vulnerable, and threatened by development.
• The project involves removal of 12 –15 large trees (of 1-foot and 2-foot dbh, or diameter at breast height), which per se would increase the carbon footprint of the parcel by reducing its carbon sequestering capacity. In addition, the building’s footprint would add to that loss of “carbon capacity” because it is designed, in addition, to occupy a non-forested area of grass and small shrubs. Both trees and such ground cover have important carbon holding capacity.
• Habitats like that at the 67 Powdermill site — forest and meadow ecosystems — are important habitats for ground-nesting birds and other species. Also, such areas often host insect and pollinator populations, yet no study has been done to evaluate potential impacts of the project on any of these populations. Given the insect and pollinator crisis, the impacts to biodiversity of building on this parcel, and especially, so close to the Assabet riverine environment, ought to be assessed.
• The project plan appears not to employ any sustainability features, such as minimizing materials use and/or reusing materials; employing nontoxic building and finishing materials; maximizing energy efficiency; or using water conservation systems. We maintain that the Town Sustainability Policy obliges the Town to advantage projects designed and executed with as many such features as is practicable.
- Green Acton Housing Principles
This project’s rental units do not respond to the housing needs that the Green Acton Housing Principles, and aspects of the Town Housing Production Plan, have identified as priorities, e.g., housing for low-income people, seniors, those who work in Acton, and those with disabilities. The apartments as proposed would likely be inaccessible to many seniors and people with disabilities. This is odd, given that the site itself would seem to point to the common sense of design for people who might wish to use the resources of the nearby Acton Human Services/Senior Center facility.
- Non-fossil-fuel Energy Systems
There is no evidence that the project developer plans to use renewable (i.e., non-fossil- fuel- based) energy to build or power the planned residential and retail facility. Given the Town’s declaration of the Climate Emergency, Green Acton believes that new residential construction ought to be designed and built using all-electric systems and appliances, and solar arrays or solar readiness where appropriate, and include, or be wired for, EV (electric vehicle)-charging infrastructure. It is our view that the Town’s Climate Emergency declaration obliges the Town to insist, to the extent of its authority, on such features.
Summary
Green Acton urges the Board of Selectmen to use the Town’s municipal land use permitting authority to minimize the impacts to the environment and climate, and to further the goals of Acton’s Sustainability Policy and the Climate Emergency declaration, rather than to mitigate against their intent by granting this permit. In summary, because Green Acton advocates for new construction being focused on projects that meet community needs, such as truly sustainable, affordable, and accessible housing, we encourage the Acton Board of Selectmen to deny the requested special permit for the 67 Powdermill Road development.