Dear Chair Carrier and members of the Board:
Please accept these comments on behalf of the Coalition for Smarter Growth. Our organization is a regional organization focused on ensuring transportation and development decisions are made with genuine community involvement and accommodate growth while revitalizing communities, providing more housing and travel choices, and conserving our natural and historic areas.
We appreciate this planning effort to prepare for the Purple Line stations and ensure that land use and the street network can support a more walkable, transit-oriented community. While we support the plan overall, we have specific concerns related to preservation of the affordable housing in the area, and the retention of small, local businesses.
The plan provides a useful analysis of anticipated trends in housing, showing increasing rents of low priced rental housing with or without the Purple Line, but the loss of a substantial number of market affordable units in the redevelopment scenario envisioned by the plan. Under either scenario, greater commitment by Montgomery County government is needed to preserve and expand housing opportunities for low and very low income households in the area. Without this commitment, we will either lose the affordability of low rent market affordable units slowly through rising rents, or more rapidly with the arrival of the Purple Line. We urge the Planning Board to work with the county to create an affordable housing strategy in conjunction with the sector plan. This effort should coordinate with the Department of Housing and Community Affairs to identify resources and properties that could be acquired and redeveloped with additional subsidy to secure and expand affordable housing in the area.
The sector plan relies almost exclusively on MPDUs as the response to the need for maintaining affordable housing in the area, while acknowledging much more needs to be done. We commend the 15% MPDU requirement, however, this standard falls short in a number of ways. The 15% standard for the plan can help address concern that the CR zones are reducing production of MPDUs to the minimum required. The 15 percent requirement, however, needs to be matched with assurance that the 22 percent bonus density is achievable. Where the CR zone standards are a constraint in achieving the 22 percent bonus density, this constraint should be removed. The height limit is often the key constraint to achieving the 22 percent bonus, thus this limit should be modified to allow for the full realization of the MPDU bonus.
Given the challenges with finding resources to preserve and build affordable housing in this area, we urge the Planning Board to leverage its use of MPDUs to create more below-market rate units. We suggest further incentive by creating a new 20% MPDU set aside standard that offers additional FAR and height.
We appreciate the plan’s goal to create a safe, walkable environment and the intention to designate the area as a Bicycle and Pedestrian Priority Area. We ask that as streets are redesigned, particular attention is given to improving the safety of pedestrian movements at major intersections. State and county street design standards should be reconsidered in light of the goal that public rights of way are places are truly inviting for pedestrians and shared spaces for all users.
Small business retention and assistance
We appreciate the plan seeking to retain small businesses and encourage public private partnerships to support affordable space for businesses providing unique products and services. The specifics of how this will be accomplished, however, need to be better addressed. The ability of the CR zone to support this goal should be carefully assessed. Assistance from county programs should also be better connected to the changes the plan seeks through rezoning.
Overall, all we appreciate the efforts of this plan to anticipate and guide change. We remain concerned however, that this plan and a coordinated response with the county is falling significantly short of addressing the housing needs of low income families in the area. We ask that the Planning Board reconsider the tools it can leverage, as well as better coordinate a response with the county which can provide resources and programs to address housing and small business needs.
Thank you for your consideration.