Planning Commission — Burlington, VT
Date: 2026-06-09
Time: 18:30

Burlington Planning Commission
 Tuesday, June 9, 2026, 6:30 PM

Remote & Virtual Meeting via Zoom
In person option available:
Bushor Conference Room (Room 102), 1st Floor of City Hall, 149 Church St.
To Join the Meeting on a Computer
Link:https://zoom.us/j/97941883790?pwd=bGZBNzNyV1liL3p5NkhIL2dqUFIzdz09
Passcode: 658929
To Join the Meeting on a Phone
Number:+1 646 931 3860 US Meeting ID: 979 4188 3790



1. Agenda
  Subject 1.1. Planning Commission and City Council Ordinance Committee to separately
 adopt the meeting agenda.
  Meeting June 9, 2026 - Agenda - Tuesday, June 9, 2026, 6:30 PM, Burlington Planning
 Commission


  Category 1. Agenda

  Department Planning


  Type

  Recommended Action

2. Adopt Minutes & Accept Communications
  Subject 2.1. Planning Commission and City Council Ordinance Committee to separately
 adopt the draft minutes and accept communications.
 Any written communications will be added to Civic Clerk up receipt and
 circulated to the Working Group. If you would like to submit a written
 communication, please email smorgan@burlingtonvt.gov.
  Meeting June 9, 2026 - Agenda - Tuesday, June 9, 2026, 6:30 PM, Burlington Planning
 Commission
  Category 2. Adopt Minutes & Accept Communications
  Department Planning


  Type

3. Director's Report

4. Public Forum #1
  Subject 4.1. The first Public Forum held during this meeting is intended to be for
 members of the public to speak on items not included on the meeting
 agenda. While there is not a formal time limit when speaking during Working
 Group Public Forum, we kindly request that any comprehensive or extensive
 comments be submitted via email to smorgan@burlingtonvt.gov to be
 circulated as written comments.
  Meeting June 9, 2026 - Agenda - Tuesday, June 9, 2026, 6:30 PM, Burlington Planning
 Commission
  Category 4. Public Forum #1
  Department Planning


  Type

5. 5/12 Meeting Follow-up
  Subject 5.1. Staff will respond to follow-up actions and items requested during 5/12
 meeting. These responses can also be found in the meeting's staff memo.
  Meeting June 9, 2026 - Agenda - Tuesday, June 9, 2026, 6:30 PM, Burlington Planning
 Commission


  Category 5. 5/12 Meeting Follow-up

  Department Planning


  Type

  Recommended Action

6. Discussion on Proposal #1: Increasing the IZ Project Size Threshold
  Subject 6.1. Staff will present the proposed change, to be followed by a discussion with
 the Working Group.
  Meeting June 9, 2026 - Agenda - Tuesday, June 9, 2026, 6:30 PM, Burlington Planning
 Commission


  Category 6. Discussion on Proposal #1: Increasing the IZ Project Size Threshold

  Department Planning


  Type

  Recommended Action

7. Discussion on Proposal #2: Eliminate IZ tiering & replace with uniform
approach
  Subject 7.1. Staff will present the proposed change, to be followed by a discussion with
 the Working Group.
  Meeting June 9, 2026 - Agenda - Tuesday, June 9, 2026, 6:30 PM, Burlington Planning
 Commission


  Category 7. Discussion on Proposal #2: Eliminate IZ tiering & replace with uniform approach

  Department Planning
  Type

  Recommended Action

8. Public Forum #2
  Subject 8.1. The second Public Hearing held during this meeting is specifically for
 comments related to the Inclusionary Zoning amendment. While there is not a
 formal time limit when speaking during Working Group Public Forum, we
 kindly request that any comprehensive or extensive comments be submitted
 via email to smorgan@burlingtonvt.gov to be circulated as written
 comments.
  Meeting June 9, 2026 - Agenda - Tuesday, June 9, 2026, 6:30 PM, Burlington Planning
 Commission


  Category 8. Public Forum #2

  Department Planning


  Type

  Recommended Action

9. Time Permitting: Preview of Proposals #3 and #4

10. Adjournment

Burlington Planning Commission
 Tuesday, June 9, 2026, 6:30 PM

Remote & Virtual Meeting via Zoom
In person option available:
Bushor Conference Room (Room 102), 1st Floor of City Hall, 149 Church St.
To Join the Meeting on a Computer
Link:https://zoom.us/j/97941883790?pwd=bGZBNzNyV1liL3p5NkhIL2dqUFIzdz09
Passcode: 658929
To Join the Meeting on a Phone
Number:+1 646 931 3860 US Meeting ID: 979 4188 3790



1. Agenda
  Subject 1.1. Planning Commission and City Council Ordinance Committee to separately
 adopt the meeting agenda.
  Meeting June 9, 2026 - Agenda - Tuesday, June 9, 2026, 6:30 PM, Burlington Planning
 Commission


  Category 1. Agenda

  Department Planning


  Type

  Recommended Action

2. Adopt Minutes & Accept Communications
  Subject 2.1. Planning Commission and City Council Ordinance Committee to separately
 adopt the draft minutes and accept communications.
 Any written communications will be added to Civic Clerk up receipt and
 circulated to the Working Group. If you would like to submit a written
 communication, please email smorgan@burlingtonvt.gov.
  Meeting June 9, 2026 - Agenda - Tuesday, June 9, 2026, 6:30 PM, Burlington Planning
 Commission
  Category 2. Adopt Minutes & Accept Communications
  Department Planning


  Type

3. Director's Report

4. Public Forum #1


 Page 1 of 14
  Subject 4.1. The first Public Forum held during this meeting is intended to be for
 members of the public to speak on items not included on the meeting
 agenda. While there is not a formal time limit when speaking during Working
 Group Public Forum, we kindly request that any comprehensive or extensive
 comments be submitted via email to smorgan@burlingtonvt.gov to be
 circulated as written comments.
  Meeting June 9, 2026 - Agenda - Tuesday, June 9, 2026, 6:30 PM, Burlington Planning
 Commission
  Category 4. Public Forum #1
  Department Planning


  Type

5. 5/12 Meeting Follow-up
  Subject 5.1. Staff will respond to follow-up actions and items requested during 5/12
 meeting. These responses can also be found in the meeting's staff memo.
  Meeting June 9, 2026 - Agenda - Tuesday, June 9, 2026, 6:30 PM, Burlington Planning
 Commission


  Category 5. 5/12 Meeting Follow-up

  Department Planning


  Type

  Recommended Action

6. Discussion on Proposal #1: Increasing the IZ Project Size Threshold
  Subject 6.1. Staff will present the proposed change, to be followed by a discussion with
 the Working Group.
  Meeting June 9, 2026 - Agenda - Tuesday, June 9, 2026, 6:30 PM, Burlington Planning
 Commission


  Category 6. Discussion on Proposal #1: Increasing the IZ Project Size Threshold

  Department Planning


  Type

  Recommended Action

7. Discussion on Proposal #2: Eliminate IZ tiering & replace with uniform
approach
  Subject 7.1. Staff will present the proposed change, to be followed by a discussion with
 the Working Group.
  Meeting June 9, 2026 - Agenda - Tuesday, June 9, 2026, 6:30 PM, Burlington Planning
 Commission


  Category 7. Discussion on Proposal #2: Eliminate IZ tiering & replace with uniform approach

  Department Planning




 Page 2 of 14
  Type

  Recommended Action

8. Public Forum #2
  Subject 8.1. The second Public Hearing held during this meeting is specifically for
 comments related to the Inclusionary Zoning amendment. While there is not a
 formal time limit when speaking during Working Group Public Forum, we
 kindly request that any comprehensive or extensive comments be submitted
 via email to smorgan@burlingtonvt.gov to be circulated as written
 comments.
  Meeting June 9, 2026 - Agenda - Tuesday, June 9, 2026, 6:30 PM, Burlington Planning
 Commission


  Category 8. Public Forum #2

  Department Planning


  Type

  Recommended Action

9. Time Permitting: Preview of Proposals #3 and #4

10. Adjournment




 Page 3 of 14
 Burlington Planning Commission Andy Montroll, Chair
 Michael Gaughan, Vice Chair
 149 Church Street Alexander Friend
 Burlington, VT 05401 Erhard Mahnke
 www.burlingtonvt.gov/cityplanning Erin Malone
 Ryan Nick
 Julia Randall


 Burlington Planning Commission & City Council Ordinance Committee
 Collaborative Working Group on Inclusionary Zoning
 Tuesday, May 12, 2026, 6:30 P.M.
 Hybrid Meeting via Zoom and in City Hall’s Bushor Conference Room
 Draft Minutes

 Planning Commissioners Present: City Staff Present:
 ☒ Andy Montroll, Chair ☒ Erin Malone ☒ Charles Dillard, Director, City Planning
 ☒ Michael Gaughan ☐ Julia Randall ☒ Kara Alnasrawi, Director, CEDO
 ☒ Alexander Friend ☒ Ryan Nick ☒ Kimberlee Sturtevant, Assistant City Attorney
 ☒ Erhard Mahnke ☒ Scott Gustin, Zoning Division Manager, DPI
 City Council Ordinance Committee ☒ Sarah Morgan, Principal Planner, City Planning
 Members Present: ☒ Stella Jordan, Senior Planner, City Planning
 ☒ Councilor Gene Bergman, Chair ☒ Nancy Stetson, Senior Policy & Data Analyst, DFA
 ☒ Councilor Mark Barlow ☒ Maggie Callaghan, Housing Program Manager, CEDO
 ☒ Councilor Sarah Carpenter
 Public Attendance: Eric Farrell, Jak Tiano, Liz Curry, Sharon Bushor, Nolan Rogers

 1. Agenda
 Call to Order: 6:30pm
 Changes to Agenda: Councilor Bergman and Andy Montroll clarified that those in attendance are
 not making up a single body, and are instead two bodies that are working collectively, meaning
 that the two bodies will adopt the same agenda separately, so that both are happening at the
 same time. Andy and Gene will switch who will act as chair each meeting. Andy proposed that
 following the adoption of the agenda, those in the room should introduce themselves. Additionally,
 there would be two Public Forums held during this meeting – the first Public Forum is intended to
 be for members of the public to speak to things not on the meeting agenda, and the second is to
 speak on agenda items.
 Agenda adopted by both City Council Ord. Committee & Planning Commission

 2. Adopt Minutes & Accept Communications
 Planning Commission Action: No minutes posted to adopt, motion to accept communications
 Motion by: A. Friend Seconded by: R. Nick Vote: Unanimous
 Notes or Corrections: N/A
 City Council Ordinance Committee Action: No Action.
 Motion by: N/A Seconded by: N/A Vote: N/A
 Notes or Corrections: N/A

 3. Director’s Report
 C. Dillard shared that the development agreement was adopted the night before at the 5/11 City
 Council meeting and also highlighted the success of the planBTV 2050 Open House on 4/30,
 which had over 300 attendees. A. Montroll also echoed this success.


The City of Burlington will not tolerate unlawful harassment or discrimination on the basis of political or religious affiliation, race, color, national origin,
place of birth, ancestry, age, sex, sexual orientation, gender identity, marital status, veteran status, disability, HIV positive status, crime victim status or
  genetic information. The City is also committed to providing proper access to services, facilities, and employment opportunities. For accessibility
 information or alternative formats, please contact Human Resources Department at (802) 540-2505.

 Page 4 of 14
Burlington Planning Commission Minutes p. 2

4. Public Forum #1
  Nolan Rogers: Chose to speak during this first public forum due to another commitment. Thinks
 these proposed changes illustrate a great step forward. Likes moving the
 threshold at which zoning applies up to 16 units, and supports simplifying the
 tiers is a good step in the right direction. Thinks Burlington needs more housing,
 and that a lot of people feel that way. If we agree we’re in a crisis, we need to
 incentivize building the housing. Challenged attendees to build too much housing,
 because that’s a challenge it probably cannot meet.

5. Review of Collaborative Working Group's Workplan & Process
  Staff presented on the goals and process of the collaborative working group, which aims to review
  proposed zoning amendments before the Planning Commission's public hearing. The working
  group will meet once a month during Planning Commission meetings, with meeting materials to be
  posted on Civic Clerk ahead of time.
  Discussion Notes:
 • No questions or comments from Working Group members

6. Review of Burlington’s current Inclusionary Zoning program & policies
  City staff presented a comprehensive overview of the ordinance's history, including key
  amendments and policy updates, highlighting that while the policy successfully produced
  economically integrated housing, it hasn't kept pace with Burlington's high housing demand. The
  discussion covered current affordability standards, development thresholds, and challenges in
  making the program financially feasible for developers. This presentation also noted the
  importance of nonprofit partnerships and the Housing Trust Fund in supporting affordable housing
  development, while also noting that neighboring municipalities have higher development
  thresholds than Burlington's current 5-unit requirement.
  Discussion Notes:
 • R. Nick asked about South Burlington’s IZ threshold, which is at 10+ units.
 • A. Friend asked whether staff looked into how many IZ units have been constructed in South
 Burlington. Staff doesn’t have this data but will provide it for the next meeting, and G.
 Bergman requested that we have that information in relation to how much housing is or has
 been built. S. Carpenter requested that these numbers also be provided for Winooski.
 • E. Mahnke noted that, in reference to “IZ units built by source” chart, the nonprofit developer
 brings the affordability significantly lower than thresholds for IZ because they are able to
 bring additional subsidies.
 • Also, in reference to “IZ units built by source” chart, M. Gaughan asked whether the
 application of the IZ requirement was to the affordable housing project. Staff answered that
 yes, it is 15% of those affordable projects.
 • G. Bergman requested that numbers being collected for Winooski and South Burlington also
 include land cost, so we can identify barriers that impact the construction of housing. If their
 land costs are significantly less, then we need to consider that. C. Dillard said staff would also
 look at rent across boundaries, impact fees, and other permit fees.
 • S. Carpenter noted that it won’t be easy to get land costs. It’s a good question, but discussion
 will need to happen to parse that out. Asked if there is overlap with our density bonuses and
 other state policies. C. Dillard said that yes, if you are in a designated center, the project can
 be designated as a priority housing project and receive a 40% density bonus. To become a
 priority housing project, they need to create an additional 5% at 80% AMI. There is typically a
 cap on density bonuses, and the developer is typically locked in at a certain FAR or lot
 coverage bonus.
 • S. Carpenter had questions about the three groups in the “IZ units built by source” chart and
 will speak with staff offline about the distinction.




 Page 5 of 14
Burlington Planning Commission Minutes p. 3

 • In response to the questions about statutory provisions for affordable housing, there’s the
 lower affordability bar at 80%, and it’s a higher overall requirement at 20% of the units as
 opposed to 15%. It can be added on top of the City’s IZ bonus, so SECORD got 2 extra stories
 on those buildings. One for City IZ and another for the Priority Housing Project’s statutory
 requirement. The only reference to this in the CDO is footnote 3 in Table 11.1.5-1
 • S. Carpenter requested that, while she appreciates the number of units with partnerships, she
 would like to see what the projects are.
 • E. Malone requested a document comparing our IZ policy to South Burlington and Winooski,
 similar to the peer city analyses that are done as part of planBTV 2050. S. Morgan responded
 to say that they are working on a peer city comparison matrix for the next meeting. C. Dillard
 added that in our research, cities that have IZ are amending their regulations every 3 years to
 keep up with market conditions. G. Bergman requested a link to all of the documents being
 referenced during this meeting, which staff assured would be posted on the amendment’s
 online landing page.

7. Overview of Proposed Amendments
  City staff presented the proposed amendments to inclusionary zoning and also discussed the
  administration's three-pronged housing strategy, which includes a more strategic use of the
  Housing Trust Fund, removing barriers to neighborhood code-enabled units, and pursuing public-
  private partnerships on city-owned land. Staff also noted that while not included in the initial
  report, there are additional minor technical changes and clarifications to the ordinance were also
  being considered.
  Discussion Notes:
 • Related to Proposal #3, “Allow Off-Site Units Anywhere”: A. Friend more rationale and
 evidence supporting some of the proposed changes, particularly regarding off-site
 development policies.
 • Related to Proposal #6, “Allow Tenure Flexibility in Large Projects”: S. Carpenter stated that
 200 units is a lot for a single development, and clarified if staff was intending for this to focus
 on PUDs. C. Dillard replied that this proposal is intended to apply to phased projects that will
 take place over multiple years, rather than just one building.

8. Public Forum #2
 Jak Tiano: Jak, who currently is a renter, commented that the inclusionary zoning (IZ)
 amendments appear to acknowledge that the current ordinance is making housing
 development financially difficult. He stated that IZ currently functions like a regressive
 affordability fee placed on new housing, with costs ultimately passed on to tenants,
 while existing property owners contribute little. Jak questioned whether the program
 delivers meaningful affordability benefits, noting he would qualify for an inclusionary
 unit but the savings on rent would be less than $100 per month. He also expressed
 concern that IZ may reduce overall housing production and worsen broader market
 affordability, and emphasized that increasing housing supply is essential to lowering
 prices over time and expressed concern that IZ may slow the production needed to
 achieve that. Jak urged the city to reconsider whether IZ should remain a primary
 affordability tool and to explore alternatives such as preserving naturally occurring
 affordable housing.
 Liz Curry: Liz provided detailed feedback on the inclusionary zoning document, emphasizing that
 inclusionary zoning should be viewed as one of many tools rather than a primary
 driver of affordable housing production. She highlighted concerns about the 5-unit
 threshold, data supporting claims about IZ's impact on development, and
 inconsistencies in defining affordable housing income levels.




 Page 6 of 14
Burlington Planning Commission Minutes p. 4

 Sharon Sharon raised questions about AMI calculations, speculating that the reason the AMI
 Bushor: increased was because Burlington was grouped with South Burlington. Sharon
 proposed that we be separated from South Burlington when calculating that. Related
 to the Housing Trust Fund, she would like to know how much money we have in the
 fund and how much the HTF tax raises on an annual basis by itself. As it relates to the
 amendments, she supports an increase in the development threshold from 5 to
 potentially 10 units, but is concerned about the 15% tiering and feels that the
 waterfront should be a higher number. Also expressed the proposed off-site
 allowances will create neighborhoods of all low-income housing.

9. Adjournment (8:33pm)
  Planning Commission Action: No minutes posted to adopt, motion to accept communications
  Motion by: R. Nick Seconded by: A. Friend Vote: Unanimous
  City Council Ordinance Committee Action: Adjourned by Councilor Bergman.
  Motion by: N/A Seconded by: N/A Vote: N/A




 Page 7 of 14
 City of Burlington, VT
 149 Church Street, 3rd Floor
 Burlington, VT 05401
 Phone: (802) 865-7194
 www.burlingtonvt.gov/plan


TO: Burlington Planning Commission
 City Council Ordinance Committee
FROM: Sarah Morgan, AICP, Principal Planner
 Charles Dillard, AICP, Director of City Planning
 Nancy Stetson, Senior Policy & Data Analyst
 Maggie Callaghan, Housing Program Manager
DATE: June 6, 2026
RE: Proposed ZA-26-04: Inclusionary Zoning


The goal of this memo is to summarize the Collaborative Working Group on Inclusionary Zoning
meeting, respond to comments or data requested during that meeting, and provide an overview of
the proposals to be discussed at the group’s second meeting on Tuesday, June 9.

Summary of 5/12 Meeting – Link to Draft Meeting Minutes
The Burlington Planning Commission and City Council Ordinance Committee convened the first
meeting of the Collaborative Working Group on Inclusionary Zoning. During this meeting, staff
outlined the purpose, process, and anticipated workplan for the collaborative review, which is
intended to provide an opportunity to discuss the amendments across both bodies prior to the
Planning Commission Public Hearing.
Included in the meeting packet was a report reviewing Burlington’s current Inclusionary Zoning
program, overviewing its history, core policy framework, and affordable housing production
outcomes. The discussion among the working group members on the policy framework focused on
how Burlington’s IZ program compares with nearby municipalities, the roles of nonprofit housing
developers and the housing trust fund, affordability standards, and the relationship between
Burlington’s IZ policy and state housing incentives. Following this review of the existing policy, staff
provided an overview of the proposed package of amendments.
Working Group members requested additional data and analysis to better understand the potential
impacts of the proposed changes. This information has been compiled below:

Follow Up Items
Amendment Webpage: In response to requests for easy access to relevant documents, staff
created a webpage for this amendment that will serve as a one-stop shop for the working group. In
addition to being posted on Civic Clerk, meeting minutes, memos, and other relevant materials can
also be found on this webpage: www.burlingtonvt.gov/AmendingIZ. Please use this webpage to
review materials and follow updates related to this amendment.
Neighboring & Peer City Comparison Matrix: The following table compares key policy factors of
Burlington’s IZ ordinance with those of other municipalities in Chittenden County that have adopted
Inclusionary Zoning policies. Please use this chart as a high-level overview, given that it does not
include specific details for each policy point across municipalities:




 Page 8 of 14
 Burlington South Burlington Winooski Hinesburg
Compliance 5 units 10 units 20 units 10 units
Threshold
Inclusionary Set 15% - 25% 10% - 20% 10% - 20% 15%
Aside
Income Targets & Rental: 65% AMI Rental: 80% AMI Rental: 60% - 80% AMI Rental: 80% AMI
Ceilings Owner: 70% AMI Owner: 100% AMI Owner: 120% AMI Owner: 100% AMI
Off-Site Option Yes, but limited Yes, if there is a No No, but allow
 by geography hardship or conversion of
 physical limitation existing dwellings
Cost Offsets & Fee waivers, Bonuses for Density Bonus, parking Density bonus,
Incentives Density Bonus exceeding IZ reduction, expedited
 requirements, administrative review  permitting, fee
 addt'l compliance reduction/waiver,
 options for IZ units unit concessions
 with 3+ bedrooms
Payment-in-Lieu $35,000 - Not permitted, Determined by City Not Permitted
 $80,000 instead allows Council. Only
 depending on dedication of land. applicable to 50% of
 project size the req. affordable
 dwelling units.

Additional Comparisons between Burlington, South Burlington, and Winooski:
Housing Production: During the May meeting, a number of questions were raised about the
relative rates of housing production in Burlington, South Burlington, and Winooski, and the causes
of those differences. Data from the Chittenden County Regional Planning Commission (CCRPC)
shows that Burlington has built an
average of 77 units of housing per
year between 2000 and 2023, South
Burlington has built 142 units, and
Winooski has built 27 units. On a per-
resident basis, Burlington has built far
fewer homes than either of these
towns and most of the towns in the
county.
There is limited available data on
historic rates of affordable housing
production in surrounding
municipalities. In Burlington, about 600
of the approximately 2,700 housing
units built since 2000 are permanently
affordable, or about 20%. Of these
affordable units, half were built in
affordable housing projects, and the
other half are split between IZ units in
market-rate projects and IZ
partnerships.


 2

 Page 9 of 14
Land Costs Comparison: One clear difference between Burlington and its neighbors, aside from
Winooski, is the density of development. South Burlington has built far more housing than
Burlington in recent decades, but that is partly a function of the amount of developable land it has.
Land itself is more expensive in Burlington: the median assessed value is roughly $1,000,000 per
acre, while South Burlington's median is less than half that at $450,000 per acre. And because
Burlington is already dense, developing housing there usually means buying both land and the
improvements on it, which pushes costs higher still.




Rent Comparisons: While the rental market in Burlington likely overlaps significantly with that in
South Burlington and Winooski, we have some limited data on the different rent levels across the
towns. The chart below shows rent across the three municipalities as estimated by the census,
which uses a survey spanning five years, and aggregated by Zillow in the past year. The estimates
vary across these sources, though they both show South Burlington with the highest rents.




 3

 Page 10 of 14
Impact Fees: Impact fees are charges on new development to defray capital costs directly related
to new development. These fees may be spent on improvements needed to serve growth and
maintain level of service as the city grows. Importantly, impact fees must be spent on capital
projects with community-wide benefit and not on projects that benefit just one development.
Impact fees may not be spent on maintenance, operations, existing deficiencies, or project-specific
impacts. Burlington first established impact fees in the 1990s and were most recently updated in
2025. Across Chittenden County, impact fees range considerably, with South Burlington assessing
significantly higher rates than all other communities. Below are tables identifying impact fees
across eight Chittenden County municipalities.




Overview of Proposed Amendments:
This section is intended to provide an overview of what amendments will be discussed during the
June 9 meeting. For information on what amendments will be discussed at future meetings, please
review the report compiled by staff.

Proposal #1: Increasing the project size threshold at which Inclusionary Zoning (IZ) rules apply
Current Policy
The Inclusionary Zoning (IZ) threshold establishes the minimum project size at which affordable
housing requirements apply under Article 9 of the Comprehensive Development Ordinance. Under
the current policy, IZ standards apply to any development containing five or more dwelling units, as
well as to multiple projects undertaken by the same applicant within a twelve-month period.
Proposal
The proposed amendment would increase both the project-size threshold and the multiple-project
threshold from five units to 16 units.



 4

 Page 11 of 14
Rationale
A key goal of this change is to remove a significant barrier to implementing the recently adopted
Neighborhood Code. Raising the threshold to 16 units would exempt most Neighborhood Code-
enabled infill development from IZ requirements, including as-of-right projects of up to eight units
on residential lots and most development within the Residential-Corridor district. Small infill
developers and property owners pursuing Neighborhood Code-enabled housing often lack the
financial capacity to absorb the costs associated with constructing affordable units, as well as the
specialized administrative resources necessary to navigate ongoing IZ compliance requirements.
Affordable and inclusive neighborhoods will continue to be supported through a more diversified
use of the Housing Trust Fund, including the acquisition of existing properties, gap financing for
new affordable housing construction, and the pursuit of tax policies that encourage the creation
and preservation of quality affordable housing.
The proposed threshold would also bring Burlington more closely in line with peer communities.
South Burlington applies its inclusionary zoning requirements only to projects of 10 units or more
and requires affordability at a higher income level (80% of Area Median Income), while Winooski
applies its requirements only to larger-scale developments.
Recent housing production data suggest that increasing the threshold would have a limited impact
on the number of units subject to IZ requirements. Since 2000, approximately half of all new
housing units constructed in Burlington have been built within projects containing more than 40
units, while an additional 19 percent were built in projects containing between 16 and 40 units. A
similar share of units were constructed in projects with fewer than five units, which are already
exempt from IZ requirements. By contrast, projects larger than the current threshold but smaller
than 16 units are relatively uncommon, accounting for only about 10 percent of all units built during
that period.
Notably, no projects have been constructed at the current five-unit threshold since 2000,
suggesting that the requirement to include affordable units at that scale may be a barrier to
housing development.




 5

 Page 12 of 14
Projects completed in the last 20 years with five to sixteen units, affordable housing projects
highlighted in blue:

 Year Address Units Built IZ Units
 2025 188 South Champlain 6 1
 2024 15 Hungerford Ter 15 0
 2024 278 Main St (COTS) 16 2
 2022 251-253 South Union St 8 0
 2018 441-435 Shelburne St 10 2
 2017 87-95 North Ave (COTS) 14 2
 2017 109-111 Shelburne St (CHT) 8 1
 2016 289 College St (Mansfield Hall) 13 2
 2014 196-202 North St 7 1
 2013 30-42 King St (BHA) 16 2
 2012 371 Pearl St 10 2
 2012 142-144 North Champlain St 6 1
 2012 155 Plattsburgh Ave 9 1
 2010 50 Barret St 8 1
 2008 161 Saint Paul St (units off site) 16 2
 2008 1554 North Ave (BHA) 11 2
 2007 354 Manhattan Dr 14 1
 2006 187-191 South Winooski Ave 8 1
 Total 195 24
 Excluding Affordable Projects 116 14

Proposal #2: Eliminate IZ tiering and replace with uniform approach
Current Policy
Inclusionary zoning standards typically require the creation of affordable homes in proportion to a
project's overall size. Under Burlington's current policy, the percentage of required affordable units
is determined by the average sale and rental price of the project.

Projects with average sale and rental prices affordable to households earning:
 • Less than 139% of Area Median Income: 15%
 • 140-179% of AMI: 20%
 • 180% or more of AMI: 25%

Development within designated Waterfront districts is also subject to a 25% affordability
requirement, while off-campus student housing developments must provide 15% affordable units.

For reference, a household or family of three earning 140% of AMI has an annual income of
approximately $157,300 and can afford a monthly rent of roughly $3,930 using the standard
affordability benchmark of 30% of household income. At 180% of AMI, a household of three could
afford a monthly rent of approximately $5,054 or less.

Proposal
The proposed amendment eliminates Burlington's current tiered inclusionary zoning structure and


 6

 Page 13 of 14
instead establishes a uniform requirement that 15% of units in qualifying projects be affordable to
households earning 65% of AMI or less.
Rationale:
The primary rationale for this change is that the existing tiered system requires developers to
forecast future rents and sale prices years before projects are completed and occupied. The current
tiered system infeasibly requires that developers project expected rents far in advance of leasing
periods and occupancy. Expected rents often fluctuate based on market conditions at time of
project completion. Given the lengthy periods of construction for development projects, it is not
reasonable to expect that the City or developers can predict with complete accuracy the rents any
project will ultimately generate. Related to the above, the complex tiering system creates obstacles
to project underwriting, as expected rents and consequential amounts of affordable housing will
fluctuate. Additionally, in practice, the higher affordability tiers are rarely triggered because market
rents seldom exceed the thresholds associated with 140% AMI or above.
Burlington's proposed affordability target of 65% AMI remains lower than that required in many
regional and national peer communities, and reducing the required percentage of affordable units
to a uniform 15% is expected to improve project feasibility while maintaining meaningful
affordability for lower-income households. Establishing a consistent citywide standard would also
simplify administration, improve predictability for developers, and bring Burlington's inclusionary
zoning framework more in line with regional and national peer cities.




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