As the saying goes, the devil is in the details. This is an essay.

When a zoning ordinance is publicly described as “passed,” it creates a powerful but potentially misleading perception of legal finality. Residents assume the law is settled, enforceable, and grounded in due process. But in Medford’s case, that label masks critical gaps: missing certified maps, absent infrastructure studies, and a reliance on a non-binding digital viewer. The word “passed” becomes a rhetorical shield, deflecting scrutiny while enabling discretionary enforcement and undermining public oversight. It’s not just semanticist’s a distortion of civic reality.

Summary: Medford’s Zoning Overhaul A Simulation of Reform

I. The Illusion of Zoning Reform

Medford’s zoning update was presented as a modernization effort, but in reality, it functioned as the development of a digital product, not a legally binding zoning ordinance. The centerpiece of this effort is the Zoning Viewer, built by Innes Associates and managed by the Office of Planning, Development & Sustainability under Alicia Hunt. And paid for by us.

The Zoning Viewer is explicitly labeled as “not an official reference” and is “subject to ongoing updates.” Source: Zoning Viewer disclaimer

The platform is built on GIS layers, not on legally adopted ordinances. It visualizes proposed zoning, but does not enforce it.

The city does not fully own or control the platform. It was developed by external consultants, and its data is not embedded in the city’s legal code.

This means that residents were shown a simulation of zoning, not an actual zoning map backed by enforceable law.

II. Key Actors and Their Roles

Alicia Hunt Director of Planning, Development & Sustainability. She merged sustainability, zoning, and economic development into one office and drove the tech-based planning approach. Her background in systems thinking shaped the zoning process into a digital-first initiative.

Innes Associates Consulting firm hired to lead the zoning overhaul. They built the interactive viewer, drafted amendments, and advised on MBTA Communities Act compliance. Their work was funded publicly but lacks transparency and enforceability.
Contracted Attorneys Zoning attorneys brought in to guide the recodification process. Thier involvement gave legal cover to the viewer’s narrative, but critics argue the substance of reform was hollow focused on language, not land use.

Mayor Breanna Lungo-Koehn Approved the restructuring of the planning office and supported zoning changes that enable vertical development. Her administration has remained silent on concerns about enforceability and infrastructure evaluation.

Our Revolution Medford (ORM) Political organization that endorsed councilors who promoted the zoning viewer as progressive reform. ORM-backed councilors Zac Bears, Kit Collins, Matt Leming, and Anna Callahan have framed the viewer as a zoning solution, despite its lack of legal authority.

III. The Political-Tech Convergence

The zoning process was technocratic, not democratic. It prioritized digital tools and optimization over community-led planning.

ORM-backed councilors used the viewer to centralize messaging, often dismissing dissenters as misinformed or obstructionist.

Public engagement was treated as data collection, not policy shaping. Resident input was used to refine the product, not the ordinance.

Required studies shadow impacts, parking audits, infrastructure stress tests were skipped, despite being mandated by the city’s own comprehensive plan.

IV. Public Awareness and Resistance

While some residents have raised concerns, few have realized that the zoning itself is not legally real:

Medford Community Conversations (MCC) has challenged the proposals but has not yet fully exposed the viewer’s lack of legal standing.

Residents have led info sessions pointing out procedural gaps and missing studies.

Critics have noted that “mixed-use” zones lack enforceable commercial requirements, and lot sizes were reduced without infrastructure analysis.

V. Why the Ordinance Is Not Enforceable

Despite being formally adopted, Medford’s zoning ordinance lacks enforceability due to several structural and procedural failures:

1. Ordinance vs. Viewer Disconnect The interactive Zoning Viewer is the public-facing tool used to communicate zoning changes. However, it is not legally binding. Zoning law must be static, codified, and enforceable not fluid and subject to revision without legislative process.
2. Lack of Codified Mapping Zoning ordinances must include official zoning maps adopted by vote and filed with the city clerk. In Medford:

The viewer map is not legally adopted as part of the ordinance.

The ordinance refers to zoning districts but does not embed parcel-level mapping in the legal code.

Without a certified map, enforcement becomes discretionary, and developers can challenge zoning designations based on ambiguity.

3. Missing Implementation Mechanisms The ordinance lacks several key components that make zoning enforceable:

• No infrastructure impact studies were conducted to support the zoning changes.
• No binding design standards or architectural review criteria are embedded in the ordinance.
• No enforcement protocols are outlined for violations or noncompliance.

These gaps mean that even if a project violates the intent of the ordinance, the city may lack the legal tools to stop it.

4. Procedural Vulnerabilities The ordinance was passed through a process that emphasized public engagement and visualization, but not legal precision:

• The Community Development Board held hearings, but many proposals were referred without finalized language.
• Amendments were made in response to public comment, but not always codified in the final ordinance text.
• The viewer was updated independently of ordinance amendments, creating a versioning problem.

This procedural looseness opens the door to legal challenges, especially from developers or residents who claim the ordinance is vague or inconsistently applied.

5. Legal Precedent and Risk Under Massachusetts law (M.G.L. Chapter 40A), zoning ordinances must be:

• Adopted by vote
• Filed with the city clerk
• Accompanied by certified maps
• Clear in language and scope

Medford’s ordinance meets some of these criteria but fails on others. The reliance on a non-binding viewer, the absence of certified maps, and the lack of enforcement mechanisms mean that the ordinance is vulnerable to legal challenge under M.G.L. c. 240, § 14A.

VI. What This Reveals

• The zoning viewer is a narrative device, not a legal tool. It shapes perception, not policy.
• Public funds were used to build a product that the city does not control or legally enforce.
• The zoning ordinance itself remains buried beneath layers of tech, PR, and political messaging.
• This is a blueprint for civic tech misuse: simulate reform, consolidate power, and sideline democratic engagement.

The endgame of Medford’s zoning overhaul when stripped of its public-facing narrative is not about land use, housing equity, or community development. It’s about building a flexible, data-driven planning infrastructure that serves political consolidation, economic speculation, and administrative control.

VII. What This Does

Creates a Perception of Reform Without Legal Risk By using a zoning viewer instead of codified maps, the city can claim progress while avoiding the legal and logistical burdens of enforcement. It’s zoning-as-a-service: a visual interface that simulates change without committing to it.

Enables Selective Development The ambiguity in the ordinance allows city officials and developers to interpret zoning flexibly. Projects can be greenlit or stalled based on political relationships, not legal standards. This discretionary power is a tool for gatekeeping.

Centralizes Planning Authority The merger of sustainability, zoning, and economic development under Alicia Hunt’s office creates a single point of control. The viewer becomes a dashboard for managing growth, not regulating it. It’s a shift from public planning to administrative programming.

Sidelines Public Oversight Residents are invited to engage with the viewer, not the ordinance. Their feedback is absorbed into the product, not the law. This transforms civic engagement into user testing, not policymaking.

VIII. Who This Serves

Political Organizations Like Our Revolution Medford (ORM) ORM-backed councilors benefit from the appearance of progressive reform. They can campaign on zoning modernization without confronting the complexities of enforcement. The viewer becomes a political asset an interactive talking point.

Consultants and Technocrats Firms like Innes Associates profit from building tools that cities cannot maintain or own. Their influence extends beyond the contract they shape policy through design. This is the rise of civic tech as governance, not just support.

Developers and Speculators The lack of enforceable zoning creates market fluidity. Developers can propose projects under the guise of compliance, knowing the ordinance is vague. Speculators can invest in parcels based on potential, not regulation.

City Administrators Officials like Alicia Hunt gain operational control. With zoning, sustainability, and economic development under one roof, planning becomes a closed system. The viewer is not just a tool it’s a control panel.

IX. The Broader Implication

This is a prototype for post-democratic urban planning. It replaces law with interface, policy with simulation, and public process with managed perception. It’s not just about Medford it’s a model that could be replicated in other cities under the guise of modernization.

The zoning viewer is not a map it’s a mirror. It reflects what power wants you to see, not what the law actually says.