Today is the deadline to submit public comments to the Holyoke Office for Community Development regarding the proposed demolition and disposition of Lyman Terrace.
Below you will find a record of the comments that I submitted. Please feel free to share your own letters as comments if you submitted any.
March 22, 2012
Alicia Zoeller, Deputy Administrator
Office for Community Development
20 Korean Veterans Plaza, Rm. 400
Holyoke, MA 01040-5036
Dear Ms. Zoeller,
Thank you for taking the time to go through and explaining the Environmental Review Record regarding the use of HUD (Housing and Urban Development) funds for the demolition and disposition of the Lyman Terrace Housing Complex located at 122 Lyman St. in Holyoke. Upon further review of the report, I have decided to submit the below comments to the Public Comment Period. They are focused on four areas in particular: historic preservation, land development, tenant notification, and tenant displacement/relocation.
Regarding historic preservation, I understand that the Massachusetts Historic Commission has submitted a letter dated December 28, 2011 stating that it has reviewed the materials submitted by the Holyoke Housing Authority and determined that the demolition of the housing complex is “unlikely to affect significant historic and archaeological resources.” I also understand that our local Holyoke Historic Commission has neglected to submit its own independent statement. However, I would like to argue that Lyman Terrace holds significant historical value based on two of the criteria that the Massachusetts Historic Commission outlines as qualifications for listing on the National Register-“association with events that have made a significant contribution to the broad patterns of our history” and “embodiment of distinctive characteristics of a type, period, or method of construction, or that represent a significant and distinguishable entity whose components may lack individual distinction.”
First, Lyman Terrace has an association with the history of public housing in the United States as Holyoke’s first public housing project and the nation’s fifth housing project built in 1938. Second, the style of architecture is particular to the housing built by President Roosevelt’s Works Progress Administration (WPA). Additionally, the 167-unit brick housing complex is constructed out of bricks that were originally from the Lyman Mills tenements built in 1854 that was removed through the “slum clearance” efforts that made way for the Lyman Housing Project. The brick architecture and copper awnings of the housing complex are visual signifiers of our city’s working-class history and architectural heritage that many today are working to preserve with downtown revitalization efforts throughout the city. Finally, I believe that the information provided to the Massachusetts Historic Commission by the Housing Authority is likely to have been biased toward securing HUD funding and may therefore
underemphasize the historical significance of the housing project and/or the present day value of maintaining brick architecture in our urban core.
Regarding land development, the Environmental Review Report states that the demolition of the Lyman Terrace Project in relation to both “Conformance with Comprehensive Plans and Zoning” and “Compatibility and Urban Impact” are listed as “Potentially Beneficial.” While I recognize that the standard HUD Environmental Assessment Checklist has a limited number of impact categories that may not accurately represent the real or future effects of demolition and disposition, to list on the Environmental Review Report that they will only have potentially beneficial impacts on the community is a subjective and lopsided assessment of what could potentially happen after demolition; one could just as easily state that there will be potentially negative impacts on the community. Simply put, it is not an assessment of demolition in and of itself and we just do not know what potential impact demolition and disposition may have as they are both contingent upon the RFP that is adopted in the disposition process. For the Environmental Review to suggest that only potentially beneficial impacts will be associated with the razing of the Lyman Housing Project is an anticipatively sanguine assessment.
Regarding tenant notification, the Environmental Review Report clearly documents the many public meetings the Holyoke Housing Authority has held with the Lyman Terrace residents. However, having spoken with Lyman Terrace residents about the current proposal to demolish and dispose of the property, there seems a degree of confusion among residents about what the Housing Authority is proposing exactly at this point in time. This confusion may be attributed to the degree of continuity between the Housing Authority meetings for their previous HopeVI proposal that was denied and the current proposal for demolition and disposition. Residents tend to report a description of the proposal that conflates the two projects and expect that new affordable and/or public housing units will be built to replace the Lyman Terrace housing complex.
While the Housing Authority may have fulfilled its requirements for holding public meetings, the confusion among residents as to what the current proposal for demolition and disposition entails raises several concerns regarding the substantive quality of those meetings and the communication between the HHA and the Lyman Terrace residents. I understand that the Housing Authority met with residents on March 5, 2012 to rectify some of this confusion, however many concerns remain. First, given the large population of Latino residents, have written materials been presented and oral presentations been conducted consistently in a bilingual format? Second, are materials and information presented in a way that is easy for lay people to understand, or in a manner that may appear overwhelming or indecipherable due to technical language or legalese?
Lastly, given the typically lower socioeconomic status of public housing residents vis-à-vis Housing Authority staff and personnel, what measures are taken to ensure that public meetings are spaces in which discussion and deliberation can take place? In other words, to what degree are Lyman Terrace residents comfortable asking questions and assisted in fully comprehending the implications of the information presented? Is participation in these meetings meaningful in that residents are encouraged to register their opinions and those opinions are seriously taken into account, or are the meetings simply an opportunity for the Housing Authority to report to residents about what is going to happen? The Environmental Review Report documents that the Lyman Terrace Project is in an Environmental Justice neighborhood which corroborates my claims that the residents make up a sensitive minority community whose access to decision-making processes needs to be ensured.
Finally, the Environmental Review Report lists resident displacement/relocation as having a “potentially beneficial” impact which is another contestable, subjective assessment. The outcome of tenant displacement due to demolition is unknown, so it is impossible to say definitively whether demolition and subsequent tenant relocation will have a positive or negative impact on residents. While the Holyoke Housing Authority has included a finalized Relocation Plan in the Environmental Review Report, the 98 percent occupancy of the Housing Authority’s units places the burden of finding, selecting, and securing new homes (through Section 8 Vouchers and replacement housing payments) primarily on the individual displaced residents as opposed to taking more comprehensive measures that would relocate the tenants while keeping the majority of the community intact.
As the Lyman Terrace community is listed as an Environmental Justice community, it is a sensitive, low-income, minority population that very likely relies heavily on neighborhood support networks that have been established over many years of living together in the Lyman Terrace project. Disruptions to those social and economic support networks could prove devastating to individual residents’ ability to secure amenities such as food, transportation, child care, and other social services that are easily accessed either directly through their neighbors’ support or from the familiar locations or agencies located in the neighborhood. I would argue that only a relocation plan that is able to retain the existing neighborhood network attributes should be deemed to have a “potentially beneficial” impact. Otherwise, we should assume that disruptions to those networks should be interpreted as having a potentially adverse impact and should require further study to assess what networks exist in the neighborhood, which would need to be recreated if displacement and relocation take place, and what are the plans and actions that would need to be taken to reestablish disrupted, yet valuable networks.
This concludes the comments that I wish to submit regarding the Environmental Review Report. I commend the Office for Community Development for the thoroughness with which they completed the review; the report’s high level of notifications and materials documentation have assisted me in making directed and pointed arguments. I’d like also to include for the record that the City Council will be considering on March 29, 2012 a Resolution that states its opposition to the demolition on ideological grounds. If it passes, we will be sure to send copies along to the OCD, HHA, and HUD.