A proposed Manchester housing development sits at the intersection of two of Vermont’s biggest crises: a shortage of affordable housing stock and the growing threat of flooding.
The proposed 43-unit project on a 8.2-acre field beneath the shadow of Equinox Mountain would include at least nine units of workforce affordable housing, according to the Manchester-based developer Paul Carroccio. The project is sited in a mixed-use zone and a flood hazard overlay district, according to the developer’s permit application.
Manchester neighbors have voiced concerns at town meetings that the project, located on a flood-prone field, will have negative environmental impacts on future tenants and make flooding worse on their own nearby properties. Residents have also voiced aesthetic, public safety and other concerns with the proposed project.
But the state’s Land Use Review Board determined the project is exempt from Act 250 — Vermont’s land use and development review process — because it qualifies as priority housing under Act 181 passed in 2024. The project includes at least 20% affordable housing units, is located near Manchester’s downtown and can be served by public water and sewer systems, among other requirements under the exemption.
Four neighbors with property abutting the project sent a reconsideration request to the state’s review board, but the board upheld its original decision Monday.
One neighbor, Edward Gotgart, said he was concerned about the development increasing impervious surface and exacerbating surface erosion and property damage during future flooding events.
“The issue with placing it on the floodplain is that it reduces the available area for floodwaters to spread out and slow down, which is exactly what that field has been doing the last 100 years,” Gotgart said.
Land Use Review Board Executive Director Peter Gill wrote in a statement to VTDigger that the decision by district staff was informed by Act 181 interim housing exemptions.
“This exemption, of course, is based on a number of factors including a local process for review under the town’s zoning and subdivision bylaws,” Gill wrote.
The project is currently being assessed at the local level by the Development Review Board, which decided at a Wednesday meeting to continue discussing the project at its September meeting.
Manchester Zoning Administrator Peter Brabazon declined to comment while the project is under review.
Kyle Medash, floodplain manager for the Vermont Agency of Natural Resources, said the plan to place fill in the flood hazard zone to raise the building will reduce space for water to flow in the event of a flood.
Medash advised the town and developer to conduct a water movement analysis to assess if there would be adverse effects like additional flooding in the area due to the project’s current plan and if the development requires a redesign.
Carroccio told VTDigger he will pursue a water flow study per the state’s recommendation. He said he is following “rules by the book” under the priority housing exemption and seeking permitting through local review, including designing a stormwater system and planning to build one foot above the base flood elevation.
At the Development Review Board meeting, Michael Fernandez, district manager for the Bennington County Conservation District, said he and his team are opposed to developing a large-scale housing project in the “historic floodplain.”
Fernandez urged that any future hydrological study be based on a 500-year floodplain standard, not a 100-year standard. He said it is a “much more realistic standard, given the current rapid change of our climate and the increasing numbers of these extreme flooding events that we are seeing both here in Bennington County and throughout the state.”
From a planning perspective, it is valuable to site new housing projects in areas that are walkable and have access to services and jobs — but many of Vermont’s downtowns are located in floodplains, Sen. Seth Bongartz, D-Bennington, said. The requirements to qualify for the Act 250 exemption attempted to straddle that “tension” between the need to invest in “healthy downtowns” and prepare for flooding, he said.
Priority housing projects are allowed in flood hazard areas, which are considered areas of “rising water” that tend to have less severe flooding than areas in river corridors and floodways, Bongartz added.
Sen. Kesha Ram Hinsdale, D-Chittenden Southeast, who helped draft the priority housing project exemption, said the legislation is aimed at reducing duplication of permitting and appeal processes at the federal, state and local levels that create cost barriers for building multiunit affordable housing projects.
With many municipal downtowns near rivers and in flood zones, Ram Hinsdale said priority housing projects allowed under the exemption are subject to flood resilience building standards.
“Many new buildings that have been built by our affordable housing community withstood floods in areas where most of the other homes were inundated and potentially destroyed,” Ram Hinsdale said. “We are living in a new reality where we can’t simply make land off limits or we will not have land that people can build multifamily housing on.”
Federal Emergency Management Agency reports indicate that low-income areas with older housing stock were disproportionately impacted by past flooding events in the state.
Annette Smith, executive director of Vermonters for a Clean Environment, said the affordable housing crisis has spurred “irrational exuberance” for development without properly considering environmental impacts.
Smith said she is concerned that low-income Vermonters living in affordable housing units built in flood hazard zones without Act 250 reviews will be affected by future flooding and the town will be liable for flood remediation costs.
She said she would like to see the legislature repeal Act 181 and instead strengthen Act 250.
“It is disturbing to see that the legislative intent was to allow priority housing in flood hazard areas,” Smith said. “How does it make any sense at all to put people in harm’s way?”
