HYM Investment Group’s plans for 10,000 housing units on the Suffolk Downs property would include 930 on-site affordable units, all on the East Boston side of the 161-acre property. Image courtesy of CBT Architects.

Boston City Councilor Lydia Edwards and two legal groups are calling for deeper levels of housing affordability at HYM’s Suffolk Downs mega-project.

The 16.2 million-square-foot racetrack redevelopment – 10.52 million square feet of which will be located in Boston – will have 13 percent of the 7,100 housing units built in Boston dedicated to affordable housing at prices or rents affordable to those making 70 percent of the area median income (AMI). In addition, HYM will deposit $5 million in a housing stabilization fund and make $28 million in linkage fee payments that can be used to subsidize up to 500 more affordable units, plus dollar-for-dollar contributions to the stabilization fund in exchange for any public infrastructure funding the project gets.

Instead, Edwards, Greater Boston Legal Services and the Lawyers for Civil Rights Boston argued in comment letters filed with the Boston Planning & Development Agency that the developer should provide housing affordable to those making between 30 percent and 40 percent of AMI, to reflect the actual incomes of current East Boston residents. The two legal groups are prominent voices on affordable housing issues, litigate fair housing cases and provide pro bono legal representation to some tenants in the state’s housing courts.

The BPDA approved the project’s master plan earlier this fall but is currently reviewing the proposed Planned Development Agreement which sets up the parameters of the project.

Edwards praised HYM’s commitment to the housing stabilization fund, which she said would effectively push the share of income-restricted housing created by the project past the 13 percent citywide requirement to 20 percent, a figure only mandated of projects in Boston’s core, where new projects’ rents and returns on investment are typically much higher than in outlying neighborhoods. Edwards has been a high-profile critic of the project in the past, saying it would likely make the affordable housing crisis in East Boston worse and that it could create another Seaport-esque neighborhood that wouldn’t open economic and business opportunities for the city’s minority and working-class residents.

However, the Greater Boston Legal Services and the Lawyers for Civil Rights Boston said in their comment letters that the $5 million in the fund could subsidize as few as 76 housing units off-site, given rapidly rising Eats Boston property prices and the difficulty any affordable housing developer would face in finding buildable sites near Suffolk Downs.

Edwards also lauded HYM’s recent decision to not subsidize a third southbound lane on Route 1A, given Boston’s traffic woes, but cited increasing crowding on the MBTA’s Blue Line, which will serve the Suffolk Downs development, as a reason the BPDA should consider requiring HYM to make additional mass transit investments.