Section 3A of the Zoning Act requires every MBTA community to have at least one district of reasonable size where multi-family housing is permitted as of right — minimum gross density 15 units per acre, within half a mile of a station where one applies. Boston, though served by the MBTA, is exempt from the Zoning Act and therefore from § 3A.

177

Communities subject to § 3A

1,941,671

2020 housing units across them

297,190

Minimum multi-family unit capacity

15.3%

Required capacity as a share of stock

⚠

Capacity is not construction. The required figure is zoned capacity under EOHLC's compliance model, not a number of homes any community must build or any developer must propose. EOHLC says so itself: the model produces “reasonable estimates” for verifying compliance and does “not provide absolute measures of development potential.” Every capacity number on this page should be read that way.

Community categories

Obligation scales with transit access: rapid transit 25% of 2020 housing stock, commuter rail 15%, adjacent community 10%, adjacent small town 5% — capped at 25% where the two calculation methods would exceed it.

Compliance status

As determined by EOHLC. Adopting zoning locally is not the same as being found compliant; a community must also apply to EOHLC for a determination.

The twenty largest capacity requirements

In units of zoned capacity. These are the raw obligations, which track population — the proportional burden is a different ranking and is below.

Where the requirement exceeds the community's own category

Each category carries a nominal share of 2020 housing stock — rapid transit 25%, commuter rail 15%, adjacent community 10%, adjacent small town 5%. For 44 of the 177 communities the requirement lands above that share. This is the gap, in percentage points.

For small towns the percentage is not what binds — a unit floor is. Minimum land area is 50 acres, and at the statutory 15 units per acre that works out to a floor of roughly 750 units whatever the town's size. Georgetown is an adjacent community, nominally 10%, and is required to zone for capacity equal to 24% of its housing stock. Several commuter-rail towns of under 3,000 homes land at the 25% cap for the same reason. Ranking communities by raw share hides this completely, because the cap puts the largest cities and the smallest towns on the same line.

What the statute actually says

Requires: At least one district of reasonable size where multi-family housing is permitted as of right, without age restrictions, suitable for families with children.
Density: Minimum gross density of 15 dwelling units per acre, subject to the Wetlands Protection Act and Title 5.
Location: Not more than 0.5 miles from a commuter rail station, subway station, ferry terminal or bus station, if applicable.
Does not require: Construction of any unit. Affordability of any unit. § 3A contains no affordability mandate.
Penalty: A non-compliant community loses eligibility for the Housing Choice Initiative, the Local Capital Projects Fund, MassWorks and HousingWorks.
Exempt: Boston — served by the MBTA, but carved out of the Zoning Act.

Source: Executive Office of Housing and Livable Communities, “Multi-Family Zoning Requirement for MBTA Communities,” and its published category and capacity table — both retrieved 29 September 2026. Statutory text from MGL c. 40A § 3A; regulations at 760 CMR 72.00.

The most-quoted number attached to § 3A is a cost estimate that did not come from the state. It comes from research prepared by Anne Brensley for the State Auditor, and it estimates one narrow slice of compliance cost — architects' and engineers' base fees — by applying the state's own DCAMM fee schedule to the mandate's required capacity. It is presented here as her attributed estimate, with its inputs shown, because the figure only means anything if you can see how it was built.

⚠

Two caveats this page will not bury. First, the arithmetic in the published methodology does not reproduce the headline: 273,080 units × 900 sf × $250/sf gives $61.4B, and 5.9% of $61.4B is $3.63B, not $4.49B. Reaching $4.49B from that base needs a rate near 7.3%. Second, the unit count it uses — 273,080 — is no longer EOHLC's published total, which now stands at 297,190. Neither point makes the estimate worthless; both mean it should be read as an order of magnitude from a stated method, not as a precise liability.

$4.49B

Designer base fees, as Brensley states them

$3.63B

What her stated inputs actually multiply out to

$15M

Catalyst Fund — the state appropriation

—

Infrastructure cost: never calculated by anyone

The assumptions, as published

Construction cost: $250 per square foot — deliberately below the roughly $350/sf Massachusetts average
Gross unit size: 900 sq ft, including an allocation for common area
Designer fee rate: 5.9%, the standard DCAMM schedule
Units applied: 273,080 — EOHLC Compliance Model v1.5, as of the report
Method: units × sq ft × cost/sf × fee rate

What the estimate assumes. It prices the design of every unit of zoned capacity as though it were going to be built. Since § 3A mandates capacity rather than construction, the estimate is better read as the cost of the buildout the zoning contemplates than as a bill any town has received.

What the estimate leaves out

Designer fees are the narrow part. None of the following is in the $4.49B, and none of it has been quantified by the state either.

Land acquisition
Water and sewer infrastructure — the binding constraint in septic towns
Roadway improvements
Environmental remediation
Legal and permitting fees
Financing and carrying costs
Impact fees and mitigation
School capacity
Emergency services scaling
Municipal staff time for compliance

What the courts have said about cost

“The regulations do not compel construction. They merely encourage it.” — Plymouth Superior Court, June 2025. The ruling addressed whether the plaintiffs had quantified a direct cost, not whether costs exist. An unquantified cost and a cost of zero are different findings, and only one of them was made.

Source: Brensley Cost Impact Report (December 2025), prepared for the Massachusetts State Auditor, as summarised in this project's methodology document; DCAMM designer fee schedule; EOHLC Compliance Model v1.5. The reconciliation of the arithmetic is this page's own, shown above so it can be checked.

Every community subject to § 3A, with its category, its 2020 housing stock, the minimum multi-family unit capacity EOHLC requires of it, its current compliance determination, and any housing EOHLC has tracked inside its 3A district. Search by name, or sort any column.

Community	Category	2020 units	Required capacity	% of stock	Compliance	Units tracked

Source: EOHLC, “MBTA Communities — Community Category Designations and Capacity Calculations” (published table, June 2025 edition); EOHLC Compliance Status Sheet (31 August 2026); EOHLC 3A Development Tracker (11 September 2026). Retrieved 29 September 2026. “Units tracked” is total units in developments EOHLC has associated with 3A zoning, and EOHLC notes that list is compiled from third-party information and may not be comprehensive.

EOHLC maintains a tracker of multi-family developments it has determined are associated with 3A zoning. It is the closest thing to an answer to the question the law's supporters and opponents actually disagree about: does rezoning produce housing? Here is what the state's own tracker currently shows.

104

Developments tracked in 3A districts

10,065

Total units across them

1,822

Deed-restricted units

Of 177 communities with any tracked activity

⚠

Tracked is not the same as built. The tracker mixes completed, permitted and proposed developments, and EOHLC compiles it from third-party information. Read it as the visible pipeline, not as a completion count.

Pipeline against the mandate

Units in the tracker as a share of the zoned capacity the law requires.

3.4% of required capacity. Five years after the law was signed, the tracked pipeline stands at 10,065 units against 297,190 units of required capacity, concentrated in 43 of the 177 communities. Whether that reads as early progress or as evidence that zoning is not the binding constraint is the argument; the ratio itself is not in dispute.

Where the pipeline is

The fifteen communities with the most tracked units. Activity is concentrated, not spread.

The affordability question, answered by the tracker

§ 3A requires no affordable units, and 18.1% of tracked units are deed-restricted anyway. That share comes from other machinery — local inclusionary zoning, Chapter 40B, subsidy programs attached to individual deals — not from § 3A, which contains no affordability requirement. It is the strongest available evidence on both sides at once: the law is not producing affordability by its own terms, and the units being built under it are not uniformly market-rate either.

Source: EOHLC 3A Development Tracker, published table as of 11 September 2026, retrieved 29 September 2026. Shares are computed against EOHLC's own published required-capacity total.

This section is carried over from the original “Follow the Money” investigation and is a fixed piece of research, not a live feed. It rests on public records: OCPF campaign finance filings, Secretary of the Commonwealth lobbyist registrations, IRS Form 990 filings via ProPublica, corporate registrations, and published reporting. Aggregations were performed on roughly 107,900 OCPF contribution records for the four officials who authored, implemented or enforce § 3A — Sen. Brendan Crighton, Gov. Maura Healey, AG Andrea Campbell and Rep. Kevin Honan. Full method is in the project's methodology document, linked at the foot of this page.

⚠

What this shows and what it does not. Donations, board seats and career moves are matters of record. A pattern of giving is not by itself evidence of an agreement, and nothing here alleges one. The figures are aggregate totals from filings as of the original analysis (February 2026) and have not been re-run against OCPF since; treat them as of that date.

Eight findings

Two Charlie Bakers — One Convenient Confusion

$4,650 in donations

DSG co-founder Charlie Baker (Democratic operative) donates to officials who enforce the law that Governor Charlie Baker (Republican) signed. They are not the same person.

Governor Charlie Baker (R, Harvard '79) signed § 3A into law in January 2021. He became NCAA president in March 2023. Dewey Square Group co-founder Charlie Baker (D, Harvard '80, BU Law '84) is a lifelong Democratic operative who served under Gov. Dukakis and ran operations for Hillary Clinton's 2016 campaign. From DSG, this Baker donated: $1,000 to Campbell (2/24/25), $1,000 to Campbell (5/6/24), $1,000 to Campbell (8/31/22), $250 to Crighton (12/1/25), $200 to Crighton (11/1/22), $200 to Crighton (1/5/21). DSG also houses Lynda Tocci, president of Healey's dark-money nonprofit One Commonwealth. The lobbying firm funds the enforcers.

Patrick's Housing Secretary → Now a Developer

$21,200 from Redgate

Gregory Bialecki was Gov. Patrick's Secretary of Housing & Economic Development. His work 'helped pave the way' for § 3A. Now at Redgate, a RE development firm donating to Healey, Campbell, and Honan.

Bialecki served as Gov. Deval Patrick's Secretary of Housing & Economic Development (2009–2015), helping shape the policy framework that became § 3A. He left government and joined Redgate — a real estate development firm. Redgate employees donated $21,200 across 37 donations to Campbell, Healey, and Honan. The man who helped design the housing policy now profits from the development it mandates. Classic revolving door.

Foundation Funds Compliance → Leaders Fund Enforcers

$16,000 to Campbell & Healey

Barr Foundation gave $1.5M+ to orgs doing 3A compliance work. Co-founder Hostetter and CEO Canales then max-donate to the officials who enforce the mandate.

Barr Foundation gave $1M+ to MHP (quasi-state agency) for § 3A compliance technical assistance and $500K to Abundant Housing MA for 3A advocacy. Then: Barbara Hostetter (co-founder) donated $5,000 to Campbell across 5 max donations (2021–2025) and $4,000 to Healey across 4 donations. Jim Canales (CEO) donated $5,000 to Campbell (4 × $1K + 1 × $500) and $2,000 to Healey. Pattern: Fund the compliance apparatus → donate to the enforcers.

One Firm, Every Official, Every Year

$42K+ across all 4 officials

Dewey Square Group employees donated to all 4 key officials. DSG runs Healey's dark-money nonprofit. Michael Whouley alone gave $3K to Campbell, $8K+ to Healey.

Dewey Square Group — lobbying firm, $2.7M in salaries 2019–2025. Client: MA Affordable Housing Alliance ($30K/yr). DSG runs Healey's 'One Commonwealth' dark-money nonprofit. Key donors: Michael Whouley → $3,000 to Campbell (3 × $1K), $8,750+ to Healey (multiple max donations), $1,000 to Honan, $250 to Crighton. Joseph Ricca ($300K/yr salary) → Crighton. Daniel Napolitano → Crighton, Campbell. Parisa Golkar → $1K to Healey. Every DSG lobbyist donates to every official in the chain.

Commission Member's Firm → 160+ Donations to Officials

$50K+ combined to Healey & Campbell

Goulston & Storrs partner David Linhart sits on Healey's Housing Commission while 160+ G&S attorneys donate to the officials whose policy his firm profits from.

Goulston & Storrs is a major real estate law firm. David Linhart is a partner AND sits on Healey's Unlocking Housing Production Commission — shaping § 3A implementation. Linhart personally donated to Healey ($700+), Campbell ($400), Wu ($1,450), Edwards ($300), and 4 other officials. Meanwhile, 60+ G&S attorneys donated $30K+ to Healey and $20K+ to Campbell. Top donors: Douglas Husid ($1K × 5 to Healey), Bill Dillon ($1K × 3 to Campbell), David Abromowitz ($1K × 4 to Campbell). The firm profits from every real estate transaction § 3A enables.

The Builders Writing the Checks

$43K+ from Suffolk alone

Suffolk Construction — John Fish (CEO) gave $7,500 to Healey. Combined with JMA ($32K), NEI ($17K), Commodore ($15K): the builders donating to the mandate-makers.

The construction firms that would build what § 3A mandates are heavy donors: Suffolk Construction: $43,580 across 74 donations. CEO John Fish gave $7,500 to Healey. John Moriarty & Associates: $32,100 across 48 donations. Moriarty lists himself as 'contractor/builder.' NEI General Contracting: $17,125. Commodore Builders: $14,750 (Joe Albanese, CEO). New Boston Ventures: $20,525 (builder/developer). RISE: $7,950 (development & construction). Dagle Electrical: $24,800 — almost entirely to Campbell (the enforcement official). Total from major builders: $160K+.

CHAPA Board = Developer Board → They All Donate

$47K+ across 5 board members

Developers who sit on CHAPA's board or Healey's commissions — shaping § 3A policy — donate to every key official. They shape the rules, then profit from them.

Kenan Bigby (Trinity Financial) — CHAPA board + Healey Housing Council → $9,825+ across 50+ donations to Wu, Walsh, Campbell, Galvin, Holmes, and others. Dara Kovel (Beacon Communities) — CHAPA board → $13,400+ across 55+ donations to Healey, Campbell, Driscoll, Wu, Spilka, Collins, Edwards, Honan. Levi Reilly (Marcus Partners) — Housing Production Commission → $15,500+ to Healey ($5,500), Wu, Spilka, Collins, Flynn. David Linhart (Goulston & Storrs) — Housing Production Commission → $3,375 to Healey, Campbell, Wu, Edwards, 3 others. Jason Korb (Capstone) — CHAPA board → $4,875 to Healey, Campbell, Azeem, Laredo.

The Bundling Pattern: Same Date, Same Amount, Every Partner

$32K coordinated donations

Smith, Costello & Crawford: every partner donates identical $200 to the same candidate on the same date. Textbook bundling.

Smith, Costello & Crawford — lobbying/government affairs firm. Total: $31,925. The pattern is unmistakable: On 12/7/25: Beth Card ($200), Michael Costello ($200), Jennifer Crawford ($200), Danielle Fleury ($200), James Smith ($200) → ALL to Crighton. Same date, same amount. This pattern repeats: 12/15/24, 1/5/24, 1/6/23, 7/24/21, 8/22/20, 5/24/19, 7/25/18 — always identical $200 from each partner, always same date. Crighton received $9,400 from SCC (16% of his total from lobbying firms). This is textbook bundled fundraising.

Real-estate, development and construction money to the four officials

44 firms identified, 1,105 donations, $680,415 in total. Sorted by amount.

Firm	Type	Total	Donations	Recipients	Notable donor
Suffolk Construction	Builder	$43,580	74	Campbell, Healey	John Fish (CEO) — $7,500 to Healey
Markley Group	Properties	$34,000	33	Healey	Adam Burnham, Donald Esson
John Moriarty & Assoc.	Builder	$32,100	48	Campbell, Healey, Honan	John Moriarty III — contractor/builder
Peabody Properties	Property Mgmt	$30,750	43	ALL FOUR	Melissa Crane (CEO)
Newmark	CRE Brokerage	$30,175	39	Campbell, Healey	CRE brokers — commissions on every deal
HYM Investment Group	Developer	$28,000	40	Campbell, Healey, Honan	Thomas O'Brien — $1K × 11
Dagle Electrical	Builder	$24,800	42	Campbell	James Dagle (President) — 99% to AG
Davis Companies	Developer	$24,500	31	Campbell, Healey, Honan	Stephen & Jonathan Davis — $1K each
HNTB	Engineering	$23,850	39	Healey	Engineering/infrastructure consulting
Redgate	Developer	$21,200	37	Campbell, Healey, Honan	🚨 Gregory Bialecki (Patrick's Housing Sec)
Coldwell Banker	CRE Brokerage	$20,785	51	Campbell, Healey, Honan	RE agents — listing revenue
New Boston Ventures	Builder	$20,525	36	Campbell, Healey, Honan	Bob Olson, David Goldman — builder
National Development	Developer	$19,590	46	Campbell, Healey	Multiple partners max-donating
Trinity Financial	Developer	$17,345	48	Campbell, Healey, Honan	Kenan Bigby (CHAPA board)
NEI General Contracting	Builder	$17,125	20	Campbell, Healey	President, VP, Chief Estimator
Schochet Associates	Property Mgmt	$16,750	25	Campbell, Healey, Honan	Richard Henken — $10.7K to Honan
Meredith Management	Developer	$16,600	18	Campbell, Healey	John Rosenthal — RE developer
Beacon Communities	Developer	$16,277	69	Campbell, Healey, Honan	Dara Kovel (CHAPA board)
Marcus Partners	Developer	$15,500	18	Campbell, Healey	Levi Reilly (Housing Commission)
Commodore Builders	Builder	$14,750	30	Campbell, Healey	Joe Albanese (CEO)
Kraft Group	Properties	$14,000	14	Campbell, Healey	Jonathan Kraft
Compass (RE)	CRE Brokerage	$13,645	35	Campbell, Healey	RE brokers/agents
AECOM	Engineering	$13,175	27	Crighton, Healey	Engineering/planning firm
City Realty	Developer	$12,500	17	Campbell, Healey, Honan	Steve Whalen (Founder)
Beacon Residential	Property Mgmt	$11,525	13	Campbell, Healey	Howard Cohen (Chairman)
New England Development	Developer	$11,500	15	Campbell, Healey, Honan	Doug Karp (Chairman/CEO)
Samuels & Associates	Developer	$9,000	14	Crighton, Healey	Abe Menzin, Joel Sklar
Wingate	Developer	$9,000	9	Campbell, Healey	Gerald/Mark Schuster
Paradigm Properties	Property Mgmt	$8,750	12	Campbell, Healey	Kevin McCall
Chestnut Hill Realty	Developer	$8,610	11	Campbell, Healey, Honan	Edward Zuker (CEO)
CBRE	CRE Brokerage	$8,350	17	Campbell, Healey	CRE brokers
Finegold Alexander	Architecture	$8,325	21	Campbell, Healey	Architects — every rezoning = work
Mark Development	Developer	$8,200	9	Campbell, Healey	Robert Korff (Owner)
Maloney Properties	Property Mgmt	$8,150	17	Campbell, Healey	Diana Kelly (CEO)
RISE	Builder	$7,950	11	Campbell, Healey	Dev & construction
Sandra Edgerley	Developer	$7,833	8	Campbell, Healey	Individual RE developer
Fallon Company	Developer	$7,700	12	Campbell, Healey	Joseph Fallon (CEO)
Winn Companies	Property Mgmt	$7,400	9	Campbell, Healey	Arthur/Gilbert Winn
Keith Construction	Builder	$6,500	10	Healey, Honan	John Keith (President)
Dellbrook Construction	Builder	$6,100	12	Healey, Honan	Michael Fish (CEO)
Boylston Properties	Developer	$6,000	7	Campbell, Healey	William McQuillan
Carpenter & Co	Developer	$6,000	6	Healey	Richard Friedman — legendary dev
Cronin Development	Developer	$6,000	6	Campbell, Healey	Jon Cronin (Principal)
Brait Builders	Builder	$6,000	6	Healey	Robert Brait

Lobbying firms

Registered lobbying and government-affairs firms active on housing, with their disclosed salaries, their clients, and their connections to the officials.

Firm	Salaries	Years	To officials	Client	Connection
Dewey Square Group	$2.7M	2019–2026	$42K+ to all 4 officials	MA Affordable Housing Alliance ($30K/yr)	Runs Healey's 'One Commonwealth' dark-money nonprofit. Co-founded by Charlie Baker (Democratic operative, not the former governor). Whouley donates $3K+ to Campbell, $8K+ to Healey.
Smith Costello & Crawford	N/A (govt affairs)	2016–2025	$32K coordinated	N/A — lobbying/govt affairs	Textbook bundling: every partner donates $200 to same candidate on same date. $9,400 to Crighton alone (16% of his lobbying money).
Issues Management Group	$5.2M	2022–2026	$6K+ identified	Construction Industries of MA ($84K/yr)	Employees donate coordinated $200 each to all 4 officials. Maureen Glynn ($300K/yr salary) → regular donor.
Goulston & Storrs	N/A (law firm)	Active	$50K+ to Healey & Campbell	Real estate practice	David Linhart: partner AND Healey Commission member. 160+ attorney donations. Hosted NAIOP events with Lt. Gov. Driscoll.
O'Neill & Associates	$23K+ identified	Active	$23K+ to all 4 officials	Government relations	Ben Josephson (COO/Lobbyist), multiple VPs donate across all officials.
NAIOP (via Sullivan & Worcester)	$30K (S&W 2022)	2022	$4K+ PAC + staff	Filed amicus brief in Milton case	CEO Tamara Small on Healey's Commission. Filed brief arguing AG should have enforcement power over towns. Then NAIOP PAC donates to AG.

The revolving door

People who have moved between state housing agencies, developer boards, advocacy organisations and advisory commissions.

Name	Path
Jay Ash	Baker's Sec. of Housing → CEO of MACP (John Fish's org of 16 CEOs)
Jesse Kanson-Benanav	B'nai B'rith Housing (developer) → Healey Transition Committee → Exec Dir of AHMA (501c4)
Kenan Bigby	Trinity Financial (developer) → CHAPA Board → Healey's Housing Advisory Council
Rachel Heller	CEO of CHAPA (advocacy) → Healey's Housing Advisory Council → quotes in pro-3A coverage
Tamara Small	CEO of NAIOP (developer lobby) → Healey's Unlocking Housing Production Commission
Lynda Tocci	Healey 2022 campaign advisor → Dewey Square Group (Baker co-founded) → President of One Commonwealth
Chrystal Kornegay	MassHousing (quasi-public lender) → Healey's Housing Advisory Council — finances the developers who sit next to her
Ed Augustus	Healey's Housing Secretary → announces HDIP awards to developers → attends developer groundbreakings

Developers positioned to benefit

Firms that receive state housing funds, sit on boards that shape policy, or build in as-of-right districts.

Firm	Position
HYM Investment Group	10,000-unit Suffolk Downs. $5M HDIP grant. $10K to legislator's nonprofit. Suffolk Construction (Fish) is GC.
Beacon Communities	Howard Cohen. Dara Kovel on CHAPA board. Multiple Healey-funded projects. $5K to protect 40B. $850K decarbonization grant.
WinnCompanies	Larry Curtis / Gilbert Winn. 106,000+ apartments. Nation's largest affordable portfolio. $2B McCormack redevelopment w/ state funding.
Trinity Financial	Kenan Bigby on CHAPA board AND Healey's Advisory Council. $360M Curtis Apts w/ state. $1B+ in development managed.
Suffolk Construction	John Fish ($2.3B). Chairman MACP. GC on Suffolk Downs Portico. Founded Mass Opportunity Alliance 2024. Donates R and D.
Peabody Properties	Fish-Will / Fish-Crane family. 16,350 units. Inspector General probed 40B profits. $22.5K to protect 40B. Salem, Scituate projects.

The sequence, step by step

Baker → § 3A

Step 1: The Law

Governor Baker signs § 3A into law (January 2021), mandating 177 towns rezone for multifamily housing near MBTA. No affordability requirements. No construction mandate. Just zoning.

Bialecki → Redgate / Ash → MACP / Kennealy → Gov Race

Step 2: The Exit

Three Housing Secretaries leave government for industry. Patrick's Gregory Bialecki (2009–2015) joins Redgate, a RE development firm. Baker's Jay Ash (2015–2018) becomes CEO of MACP, whose board includes John Fish of Suffolk Construction. Baker's Mike Kennealy (2018–2022) now runs for governor.

Barr → MHP → CHAPA → Compliance $$$

Step 3: The Money Machine

Barr Foundation gives $1M+ to MHP for § 3A compliance work. $500K to Abundant Housing MA for advocacy. CHAPA — stacked with developers (Bigby, Kovel, Korb) — lobbies for enforcement. The compliance industry is born.

Healey + Campbell = Enforcement

Step 4: The Enforcement

Governor Healey creates EOHLC, issues compliance guidelines. AG Campbell gains enforcement power via SJC Milton decision (Jan 2025). NAIOP files amicus brief (via Sullivan & Worcester) arguing for AG authority. Towns face loss of state funding for non-compliance.

$$$ → Officials → Policy → $$$

Step 5: The Donations

Now trace the money: Developers who profit from § 3A donate $600K+ to these 4 officials. Lobbying firms donate $600K+. Barr Foundation leaders donate $16K directly. CHAPA board members donate $47K+. DSG’s Charlie Baker (not the governor) donates to Crighton and Campbell. The money flows in circles.

Developers ↔ Commissions ↔ Policy

Step 6: The Commissions

Healey appoints to her Housing Commission: Levi Reilly (Marcus Partners, $15K+ in donations), David Linhart (Goulston & Storrs, commission member AND partner at RE law firm), Tamara Small (NAIOP CEO who lobbied for enforcement). The policy-makers ARE the beneficiaries.

177 Towns Pay → Developers Profit

Step 7: The Question

A law signed by one governor, enforced by the next. Shaped by three housing secretaries who all left for industry. Enforced by an AG funded by the development industry. Implemented by commissions stacked with developers. Compliance funded by a foundation whose leaders donate to the enforcers. 177 towns pay. Developers profit. Is this housing policy — or something else?

Sources: Massachusetts OCPF contribution filings (approximately 107,900 records analysed); Secretary of the Commonwealth Lobbyist Public Search; IRS Form 990 filings via ProPublica Nonprofit Explorer; Massachusetts corporate registrations; and reporting by the Boston Globe, Boston Herald, WBUR, Banker & Tradesman and CommonWealth Beacon as cited within each finding. Aggregations current as of February 2026.

The questions the available record raises and does not answer. These are framed as questions because that is what they are — each one is answerable with data that exists but has not been published, or with disclosure that is not currently required.

The short version

Question	What the record shows
What does the law require?	Zoning changes — not construction.
Does rezoning create housing?	No. Capital, labor, and market demand create housing.
Will the rezoned units be affordable?	No affordability mandate exists in § 3A.
What does new multifamily cost to build?	$350+ psf. A 900sf unit = $315K+ construction cost alone.
Is the market building?	Permits down 44%. Interest rates 6%+. Market is frozen.
Who pays for compliance?	Towns. $4.49B in designer fees. State appropriated $15M (0.3%).
What happens if towns don't comply?	They lose state infrastructure funding they already need.
So what does the law actually accomplish?	It transfers zoning control from towns to the state — and shifts liability for future development costs to municipalities.

Open questions

Why is Boston exempt?

The city with the most acute housing pressure, the most MBTA service, and the highest rents is carved out of the Zoning Act entirely. If this is about transit-oriented housing, why exclude the transit hub?

If this is about transit, why are 93 'adjacent' towns with NO transit stations included?

53% of mandated communities have no MBTA station. They're included because they border a town that does. The 'transit-oriented' framing doesn't hold when the majority of affected towns have no transit to orient to.

Who owns the land in the rezoned parcels — and did they know before the zoning maps were drawn?

Rezoning creates instant land value appreciation. If anyone with advance knowledge of district boundaries acquired parcels beforehand, that's worth investigating. Public records exist.

What's the relationship between housing advocacy orgs and the development industry?

CHAPA's board includes Trinity Financial's Kenan Bigby, Beacon Communities' Dara Kovel, and Capstone's Jason Korb — developers who directly benefit from as-of-right zoning. AHMA's Kanson-Benanav came from B'nai B'rith Housing (a developer) and was placed on Healey's Transition Committee. The Barr Foundation funds $1.5M+ into MBTA Communities compliance advocacy. The advocates ARE the industry.

Why does the law contain zero affordability requirements?

The law is sold as helping 'teachers, nurses, firefighters.' But nothing in § 3A requires a single affordable unit. What gets built is market-rate: $2,500-4,000/month. The people in the talking points can't afford what this law produces.

What happens to property taxes and school budgets when multifamily goes in?

Multifamily typically generates less property tax per student than single-family. Towns bear the service costs (schools, fire, police, water) for new residents. The state shifted the zoning obligation — but not the fiscal burden.

Who produced the Cost Impact Report?

Anne Brensley, running for lieutenant governor in 2026. Her report used the state's own DCAMM fee schedule against its own mandate and found a $4.48B gap the state never calculated.

What's the endgame if 3A doesn't produce units?

Boston Indicators' report already calls for the state to 'bypass local zoning to directly allow different types of housing.' 3A isn't the end — it's the precedent. The next step is eliminating local zoning review entirely.

Why does the Governor's housing advocacy nonprofit refuse to name its donors?

One Commonwealth, Healey's 501(c)(4), has spent $250K+ on ads and run pro-compliance messaging in towns — but won't disclose who funds it. Its president Lynda Tocci works at Dewey Square Group, co-founded by a different Charlie Baker (Democratic operative, not the former governor). DraftKings is the only known donor, disclosed only because gaming regulators required it. If the policy is good, why hide who's paying for it?

Why do developers who benefit from 3A sit on the boards that shape 3A policy?

Trinity Financial's Bigby sits on CHAPA's board AND Healey's Housing Advisory Council. NAIOP's CEO sits on Healey's Unlocking Housing Production Commission. Beacon Communities' Kovel sits on CHAPA's board while receiving state housing grants. The people advising the Governor on housing policy are the same people who profit from the advice.

How do developers bypass campaign finance limits via lawmaker nonprofits?

Boston Globe (April 2025): MA lobbyists are capped at $200 in campaign donations — but can give unlimited, undisclosed amounts to nonprofits run by legislators. HYM gave $10K to Rep. Madaro's nonprofit while building 10,000 units in his district. Federal law prohibits this. Massachusetts does not.

Where this page could be wrong

Stated plainly, because a page that only argues one way is not worth reading. The tracked pipeline is five years into a law whose compliance deadlines mostly fell in 2024 and 2025, so a low build-out figure today is consistent both with “zoning is not the constraint” and with “it is too early to tell.” The cost estimate is a third-party calculation whose own arithmetic does not reconcile, shown here with that gap visible. And the campaign-finance section establishes association, not causation: Massachusetts development and construction firms donate heavily to statewide Democrats generally, which is an alternative explanation the donation totals alone cannot rule out.

Sources as cited in each section above. The full source catalogue and analytical method are in the project's methodology document, linked below.

The MBTA Communities Act