Category: Testimony & Letters

Testimony to Ms. Lynn Robeson, Esq., Zoning Hearing Examiner Re: 4831 West Lane LLC, Local Map Amendment G-954 and Development Plan Amendment DPA 13-01

Posted on by Ted Van Houten

Please accept these comments on behalf of the Coalition for Smarter Growth. Our organization works to ensure that transportation and development decisions in the Washington, D.C. region, including the Maryland suburbs, accommodate growth while revitalizing communities, providing more housing and travel choices, and conserving our natural and historic areas.

We want to express our strong support for the West Lane multi-family residential project because it enhances the diversity of housing choices and number of MPDUs within such close proximity to the Bethesda Metro station. This is a great benefit to the county and the region because the building provides more housing, especially affordable housing, in a job-rich area, next to Metro. This reduces overall traffic in the region, shortens commutes, reduces household transportation costs, and gives more moderate income households access to the jobs and amenities of a highly desirable community.

After reviewing the proposed plans and public record, consulting with residents, and walking the site, we believe that the project offers its housing benefits through a sensitive and appropriate approach to the building design. The proposed building provides an attractive contribution to a pedestrian-oriented environment and complements the existing nearby residential buildings.

We are especially pleased to see the building’s relationship to Montgomery Lane which forms a supportive urban pedestrian environment. The existing and planned buildings along the north side of Montgomery Lane form a continuous street edge, which the proposed West Lane building completes. The 12 foot upper story setback provides visual interest to the building and addresses concerns of neighbors. A greater setback is not necessary or desirable. A greater setback will not further enhance the ground-level pedestrian environment. In addition, further unnecessary shrinkage of the building could threaten the number of MPDUs provided, while offering no increased public benefit.

The public use space provided at the corner of West Lane and Montgomery Lane is a good approach if it incorporates the main entrance of the building. The public use space at this location achieves two important objectives. It decreases the mass of the building by stepping back the building’s frontage, but still maintains the important building line along the street edge. It also provides a usable urban public space for people to wait or meet friends. The success of the public use space is dependent upon the entrance of the building opening up onto the public use space.

The appropriately scaled building and the well planned public use space are compatible with the neighborhood. The increased number of units ensures more pedestrians on the street – which is consistent with the Sector Plan and a benefit to all. The Sector Plan’s housing diversity goals are also furthered by the West Lane project. The proposed units are smaller and more affordable than those offered in surrounding buildings and include a substantial number of MPDUs – all within 950 feet of the Metro station.

For all of these reasons, the Coalition for Smarter Growth urges approval of the 4831 West Lane project.

Thank you for your consideration.

Sincerely,

Cheryl Cort
Policy Director

Helping Virginia grow — wisely

Posted on by Ted Van Houten

The March 13 editorial “Leave well enough alone,” on the Virginia transportation bill, characterized the coalition that defeated the 2002 referendum on a sales tax for transportation as “anti-growth activists and anti-tax conservatives.” This is a false characterization.

The leading activists have consistently supported planning for robust growth in the region. During the referendum debate, the Coalition for Smarter Growth and the Piedmont Environmental Council released a plan for redevelopment and economic growth that focused on the areas around the region’s rail stations. The region has embraced this vision through its Region Forward plan and local implementation of new transit-oriented development projects.

In Fairfax County, business and political leaders recognize transit-oriented development as the pivot for continued economic growth. The Coalition for Smarter Growth has endorsed and supported millions of square feet of development and thousands of housing units that bolster a smart-growth future. The Post should recognize this.

Douglas Stewart, Fairfax

The writer is a grants specialist at the Piedmont Environmental Council.

Read the original article here >>

Testimony before Ms. Françoise Carrier, Chair of the Montgomery County Planning Board re: Long Branch Sector Plan Comments

Posted on by Andrew Brown

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.

Affordable Housing

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.

Complete Streets

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.

Sincerely,

Cheryl Cort
Policy Director

Testimony before the Hon. Muriel Bowser, Chair, Committee on Economic Development and Housing Council of the District of Columbia regarding: DMPED Performance Oversight – affordable housing in public land deals

Posted on by Ted Van Houten

Please accept these comments on behalf of the Coalition for Smarter Growth. We are a regional organization based in the District of Columbia 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.

Recommit to leveraging public land dispositions for very low income housing in mixed use projects

Table 1We know that while the city has grown in population and income, low income D.C. residents are experiencing even greater difficulties finding housing they can afford. Thus public lands, and every other realistic tool we have available, should be used to help address this pressing need. Our recent report, Public Land for Public Good, shows that the District has and can do great things with its city-owned land. The creation of mixed income housing opportunities on public land is an important source of affordable housing for our residents.

We highlight the Hine Jr. High School redevelopment project next to the Eastern Market Metro station as a leading example of what a public land disposition should do. The project will offer a great mix of uses, close to 30 percent affordable housing, and a design compatible with a historic district. All of this occurs next to a Metro station, close to the core of the city. The project has been in process since 2008 when the former school site was offered for redevelopment. The project will provide 163,000 square feet of office space, 40,000 s.f. of retail, and a total of 159 housing units. Of the total, 46 units will be affordable, or 29 percent. The mix of affordability for the housing units is a good example of what the city should be seeking in LDAs: 5 units will be affordable at 30 percent AMI, 29 units at 60 percent AMI, 12 units at 80 percent AMI (in lieu of IZ). Other public benefits include reconstruction and opening of a block of C Street SE, and a public plaza along C Street.

The Hine School project pre-dates the current administration. We are concerned that the commitment to affordable housing in recent solicitations for public land dispositions, especially at the lowest income level, is declining. I would be surprised if a DMPED Land Disposition Agreement (LDA) ever again results in 30 percent AMI housing. Current practice by DMPED asks that any residential component meet or exceed Inclusionary Zoning standards of 8-10 percent set aside at 50-80% AMI. IZ is the law and what is required for any residential development. We should expect much more for public land.

Table 1 shows the affordable housing set side and income targeting that was the practice of the last decade for solicitations in public land dispositions. Currently, DMPED’s solicitations provide little of the specificity that was the practice in the past. We urge the council to ensure that we are making the most of the unique opportunity to leverage the value of the District’s land to create more affordable housing through the land disposition process. We ask that the council recommit the District to clearly requesting and prioritizing proposals that offer substantial amounts of affordable housing, including units affordable to those earning 30 percent AMI. As was the practice in the past, we ask that requests specify the city is seeking 20 percent to 30 percent of the total number of residential units affordable at 30 percent and 60 percent AMI for rentals, and up to 80 percent AMI for ownership. We suggest table 2 as a model. In addition, we ask that DMPED better coordinate with other agencies to pool resources to ensure the production of housing affordable at deeply affordable levels as a part of larger mixed income or all-affordable development.

Table2

Management of Affordable Dwelling Units

Since 2009, DHCD created a group to manage affordable dwelling units (ADUs) created through LDAs and Zoning Commission actions, along with IZ units. Given the many challenges to helping moderate and low income households buy and maintain affordable homes, we suggest that this process might be best done through DHCD contracting with a qualified nonprofit. Resale assistance for a price controlled home could benefit from extra attention that a nonprofit could provide to a seller. While we have suggested this for IZ units, we also think that ADU management would similarly benefit.

Thank you for your consideration.

Sincerely,

Cheryl Cort
Policy Director

Testimony before the Hon. Muriel Bowser, Chair, Committee on Economic Development and Housing Council of the District of Columbia regarding: DHCD Performance Oversight – Inclusionary Zoning

Posted on by Ted Van Houten

Please accept these comments on behalf of the Coalition for Smarter Growth. We are a regional organization based in the District of Columbia 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 would like to comment on DHCD’s administration of the Inclusionary Zoning program. We have been involved with Inclusionary Zoning (IZ) since its beginning in 2003 and remain committed to ensuring that this important affordable housing program delivers on its promise. We are gratified that IZ is finally becoming a reality on the ground given the delays in issuing regulations, the housing market collapse, and extensive grandfathering. The start up of this program has faced many serious challenges, but we believe all these challenges can be overcome. We first want to remind the Committee of the importance of this affordable housing tool that produces below market rate units in matter of right developments throughout the city with no cash subsidy from the District. Of unique importance, IZ creates below market rate units in neighborhoods where few or no affordable units are likely to be produced in the future. This is a valuable affordable housing tool practiced by hundreds of jurisdictions throughout the country, including Montgomery County. This approach is credited with achieving economic integration is ways that other affordable housing programs are unable to achieve.

Montgomery County’s experience is instructive for looking at D.C.’s pathway to successful implementation. The county has produced over 13,000 IZ units since 1976. Due to short affordability terms, currently only 2,600 units are still affordable at 65 percent area median income (AMI). In addition, another 1,573 IZ units that were purchased by the county’s housing authority are rented to lower income families (this is through a provision in the county’s law that D.C.’s prohibits). The county’s IZ program provides nearly half of its affordable housing production. Among the changes the county has made to its program over the years are: extending the affordability term to 30 years for ownership and 99 years for rental; allowing income targeting to rise from 65 percent AMI to 70 percent AMI for high rise construction, and elimination of a troubled buy-out provision that allowed fees in lieu of on-site construction of units.

Administration of D.C.’s IZ program requires urgent and specific attention to ensure that as the over 900 units come online in the next 5 years, implementation will be smooth for all parties. We now face three key administrative challenges that can be fixed: severe understaffing, FHA rules, and overly rigid administrative regulations. Below are our recommendations for these key challenges.

Administrative problems that must be resolved immediately

1. Severe understaffing –1-2 overworked staff members are struggling to launch a new IZ program and provide oversight for roughly 2,000 affordable dwelling units (ADUs) already built or in process, created by PUDs (in lieu of IZ) and public land dispositions. Staff will be difficult to retain and attract if capacity is way below a realistic workload. Program applicants and developers will also not get the assistance they require.

Recommendation: Budget more staff and contract to a qualified homeownership organization
experienced in permanent affordability:

a. Add 2 additional staff positions;
b. Contract with a nonprofit group experienced in managing the homeownership purchase process and stewarding permanently affordable homes. Given the extra challenges of affordable home purchasing in a post-2008 economy, more assistance to homebuyers is needed to speed up the sales process. A nonprofit experienced in selling and stewarding permanently affordable homes could manage the homebuyer recruitment, preparation, qualification, selection and placement process. This nonprofit can also provide effective relationships with mortgage lenders and developers to secure financing, along with ongoing stewardship, enforcement, and resale assistance. This kind of close working relationship with buyers and owners is likely going to be more effectively created through a nonprofit dedicated to successful affordable homeownership and permanent affordability than a government agency;
c. Sustain housing counseling assistance for IZ applicants.

2. FHA conflict with local covenants regarding foreclosure – The Zoning Commission has revised the regulations to conform with FHA rules, and DHCD is working to get FHA’s final approval. After FHA clarifies its acceptance of the D.C. program, DHCD needs to educate mortgage lenders and recruit them to offer mortgages for IZ units. Bank of America, for example, reviews and approves IZ programs for their mortgage lending. DHCD should ensure that D.C.’s IZ program gets onto Bank of America approved list, along other lenders’ lists.

3. Rigid regulations – The administrative regulations are currently being revised but it is urgent that we expedite these revisions given the many barriers they place to an efficient matching process for applicants and units. Given the difficulty matching qualified and interested applicants to units, we suggest suspending overly prescriptive lottery requirements until a lottery is needed to fairly allocate a unit among a larger pool of qualified applicants.

Policy issues for future consideration

Beyond the immediate administrative issues that should be our top priority, longer term policy issues should be considered to fine tune the program. The robust recovery of the housing market in D.C. over the last few years demonstrates that IZ is not a deterrent to housing production. For example, over 4,500 housing unit permits were issued in 2011. This is 64 percent greater than the last peak in the market in 2005 when over 2,750 permits for housing units were issued. D.C. housing production has gone from a few percent to more than half of the region’s residential output.

The experience to date on the development review and financing phase of IZ is that the economics work. Over 900 IZ units are in the pipeline at various stages of development approvals, and construction, with a handful of completed projects. This development pipeline demonstrates that financing for projects subject to IZ is not a problem. IZ policy standards have also contributed to creating approximately 1,000 affordable dwelling units (ADUs) through PUDs since the mid-2000s.

We flag the following policy issues for further assessment, as we act immediately to fix the administrative problems discussed above.

1. Income targeting: Current income targeting is at 80 and 50 percent AMI. Given that market conditions have changed since 2006, is income targeting still at the right levels? How many 50 percent AMI units can we expect to produce? How effective is the 80 percent AMI income targeting in providing units sufficiently below market?

2. Condo fees – while IZ standards have avoided the problems that early ADUs experienced before IZ policies were developed, unpredictable rises in condo fees could pose a problem in the future.

Recommendations:

a. Require par value assessments for condo fees for IZ and ADUs: Rising condo fees over time are potentially a problem even though IZ incorporates an initial fee based on what is projected to be a realistic fee to ensure that the overall housing payment by the buyer does not exceed a certain percent of her or his income. To avoid future excessive increases in condo fees, we suggest requiring that at least for IZ units and ADUs, par value tied to the affordable price of the unit be the basis for assessing the condo fee rather than a square footage basis. This will allow condo fees to rise as inflation and costs rise without subjecting the owner to a rapid escalation that would make the condo fee too expensive for the affordable unit owner.
b. Initial fee setting: This is already addressed by IZ regulations but could affect a building as a whole if a developer sets fees too low to support ongoing building costs. Given this problem for all condo owners, we recommend strengthening consumer protection against lowballing condo fees. Enabling OP and DHCD to comprehensively collect data on condo fee rates from existing buildings would provide these agencies the information they need to appropriately set condo fee rates as a part of the purchase price of an IZ unit or ADU. Secondly, consumer protection for condo purchasers can be improved by changing how the verification of the initial condo fee is set. Currently a certified third party is paid by the developer to verify the fee. We suggest charging the developer a fee that would have been paid to the third party, and have the city contract with a third party directly to verify the condo fee.

Overall, IZ is a sound policy that requires focused attention to address the administrative hurdles to a smooth-running program. The program promises to provide a substantial new source of below market rate housing throughout the city. While the program faces challenges, it is worth the effort. We thank the D.C. Council for its long-standing support for this innovative affordable housing policy.

Thank you for the opportunity to testify.

Cheryl Cort

Policy Director

Testimony before the Prince George’s County House Delegation in Support of PG 420-13: School Facilities Surcharge

Posted on by Andrew Brown

Please accept these comments on behalf of the Coalition for Smarter Growth. Our organization works to ensure that transportation and development decisions in the Washington, D.C. region, including the Maryland suburbs, accommodate growth while revitalizing communities, providing more housing and travel choices, and conserving our natural and historic areas.

We urge you to support Bill PG 420-13 – School Facilities Surcharge, in order to take reasonable measures to catalyze transit-oriented development by removing unnecessary barriers to investment near transit stations. The bill lessens the burdens on multifamily housing construction near major transit stations which is exactly what is needed for Prince George’s to compete for the workforce and employers of the future.

Multifamily units, especially studio units, produce a fraction of the school-aged children that single family housing generates, thus the reduction in the school facilities surcharge will not overburden the county. It will, however, strengthen the tax base by attracting more of the largest segments of our population — young professionals and retirees seeking to live in a more urban, transit-accessible environment.

The recent assessment by the Prince George’s Planning Department in “Where and How We Grow Policy Paper,” urges the county to depart from its historic pattern as a spread out bedroom community. Instead, it urges the county to encourage development in Centers and the Developed Tier by reducing fees. It cites regional growth forecasts showing that economic development and workforce housing preferences will demand a major increase in multifamily housing near transit:

“[M]ore than 79 percent of units in the [County’s] pipeline are single-family detached units intended for the Developing Tier; however, to meet future demand, more than 60 percent of new housing units to be built should be multifamily units located in walkable communities at transit-accessible locations.

“Furthermore…between 2000 and 2010 Prince George’s County acquired one of the lowest numbers of new residents in the region. Without a recalibration of county priorities and policies that promote TOD and high-quality, mixed-use development, it is likely that the county will be at a continued disadvantage relative to its neighbors when it comes to attracting residents and employers who value the connectivity and amenities that other such communities provide.”

Again, we ask that you support Bill PG 420-13 – School Facilities Surcharge. Thank you for your consideration.

Cheryl Cort
Policy Director

Testimony before the D.C. Zoning Commission: Support Case No. 04-33F Text Amendments: PUDs and Inclusionary Zoning – Termination of Affordability Controls upon Foreclosure

Posted on by Ted Van Houten

Please accept our testimony on behalf of the Coalition for Smarter Growth. My organization works to ensure that transportation and development decisions in the Washington D.C. region accommodate growth while revitalizing communities, providing more housing and travel choices, and conserving our natural and historic areas. I also note that we have been working to create and implement a successful Inclusionary Zoning program since its inception in 2003.

We are here to express our strong support for these amendments. We concur that the proposed text amendments are needed to ensure that IZ and ADU covenants conform to FHA guidelines. We appreciate that the city can take other steps through regulations to protect the public’s interest in its investment in below market rate homes without conflicting with FHA requirements. We look forward to the District developing these regulations to complement this action.

These amendments are critical to removing a major barrier affecting the IZ program. Administration of IZ has experienced a number of substantial challenges as units have come on line in the last year. While these challenges remain a major disappointment, they can be overcome. The first challenge is the severe understaffing of both the IZ program and the management of ADUs – affordable dwelling units generated through PUDs and public land dispositions. It appears that no more than one or at most two DHCD staff members manage every aspect of the ADU and IZ programs. Elected officials have touted the benefits of these affordable housing units, but they have not provided the modest funding needed to adequately support these assets. A few more staff members and continued support for adequate housing counseling services are needed to ensure that these programs have the resources they need to work with applicants and developers.

While ADUs are largely managed by individual developments with oversight from DHCD, IZ was designed to more closely manage the recruitment of applicants and the placement process. The intention was to provide greater assistance to residents in search of a home they could afford and allow them to come to one place to find assistance, rather than chase project after project. ADUs have not experienced the problems in leasing or sales of units at 80 percent AMI that IZ has. Considering these differences, and other factors, DHCD is in the midst of revising the IZ regulations. We hope this process will take no more than a couple of months. Apparently, the regulations were too rigid to respond to obvious needs in practice, such as ensuring that an applicant who enters a lottery for a for-sale unit is qualified to get a mortgage for that unit. There appear to be a variety of glitches in the IZ regulations that are inhibiting the smooth process of connecting the right applicant with the right unit. We are hopeful that this regulations revision will resolve these problems within the next several months.

You are here today to resolve one of the other barriers that we have recently encountered – the rise of FHA as the leading backer of affordable residential mortgages, and FHA standards that conflict with affordable housing covenants common among local government programs. These amendments will allow prospective buyers to secure FHA financing and purchase affordable units subject to the Inclusionary Zoning program and ADU requirements. We welcome these appropriate and necessary text amendments to the current PUD and Inclusionary Zoning regulations to improve the effectiveness of these programs and increase the availability of affordable housing in the District of Columbia.

Thank you for the opportunity to testify.

Cheryl Cort

Policy Director

Testimony to the Montgomery County Council re County Executive Ike Leggett’s Request for Supplemental Appropriation for Study of Rapid Transit System

Posted on by Joe Wisniewski

The Coalition for Smarter Growth supports the supplemental request by the County Executive for $1 million to further advance the proposed Rapid Transit System. We believe that the request is focused on the important implementation issues including service planning, integration with RideOn and Metrobus, bike/ped access, transit signal prioritization, organizational structure and agreements with the state on the right of way. We also have some recommendations, which include ensuring integration with Purple Line and Metrorail service.

We understand the position of our long-time allies at the Action Committee for Transit, and their recommendation that the county first move forward with WMATA’s bus priority corridor network. Yet, we believe that a win-win approach is possible. The outlines of an expanded, integrated, higher capacity and speedier transit network are becoming apparent. It is a system that includes a rehabilitated Metrorail and robust transit-oriented development at all stations on both arms of the Red Line, includes construction of the Purple Line, and includes the most promising of the Phase I Rapid Transit System routes and also integration with the WMATA Priority Corridor Network.

We will all depend on the technical staffs to give us something that works effectively and selects the most effective service mode, not just for today, but for the evolving transit-oriented future, meeting the goal of a much more robust and transformative transit network for the county. Therefore, we believe that the funding should also enable close coordination between the county staff, Planning Board staff, WMATA and state officials to design this interconnected and operationally integrated system.

To gain maximum benefit from this funding, these agencies should deliver to the County Executive and to you a consensus system design that is appropriately tailored to each corridor in terms of mode and level of service, and, is closely linked to  walkable, transit-oriented development where that development is appropriate. By the end of these studies, the technical experts should be able to give you a system that has drawn from the research and data available in the Task Force report, in the Planning Board’s staff report, the ITDP report, the state transit studies and WMATA, including their Priority Corridor Network.

It should be a system that seamlessly links fares, schedules, routes and transfers, and delivers significant increases in ridership of both transit-dependent and the so-called “choice riders.” It should be a system that transforms the county and enhances the movement of people, their access to jobs and services, and increases the economic competitiveness of the county.

As you know, Fairfax County is investing in the Silver Line.  But they, like you, are also engaged in a study of their next generation of transit investments including BRT/LRT options for their commercial corridors and enhanced cross-county suburban to job center services. We hope that you will give them a run for their money in developing an effective transit and transit-accessible future!

Thank you.

Stewart Schwartz

Executive Director

Comments on Proposed “North-South Corridor of Statewide Significance” (aka the Outer Beltway)

Posted on by acustis

On behalf of the Coalition for Smarter Growth, I wish to register our strongest objections to the conduct of the “North-South Corridor of Statewide Significance (COSS)” study and to the very concept of the proposal. Our first objection is to the lack of transparency and seriously inadequate public involvement and notice that have characterized this proposal from the outset, including…

Testimony to D.C. Comprehensive Housing Strategy Task Force

Posted on by acustis

Please accept these comments in addition to my oral testimony at the Oct. 22 hearing on behalf of the Coalition for Smarter Growth. We are a regional organization based in the District of Columbia 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.