Category: Testimony & Letters

Testimony to Regional Transportation Planning Board on Regional Transportation Policy Plan

The Regional Transportation Priorities Plan represents progress in identifying and setting transportation priorities. Particularly noteworthy is public identification and support for fixing the existing system first and the focus of the RTPP priorities on fix-it-first including maintenance, operational performance, transit crowding and improved alternatives to driving for every trip.

However, significant concerns were raised last month by officials on this body, particularly the failure to conform the RTPP to the goals and objectives of Region Forward. The updated letters packet includes a detailed set of recommendations from DC, and I understand that the Region Forward co-chairs have, or will be, making recommendations. WMATA and others, including my organization and the business group – Urban Land Institute, have also provided important recommendations.

These recommendations center on the failure of the RTPP to integrate within the Region Forward vision, goals and objectives, the failure to incorporate Momentum, the failure to address climate change, and the focus on toll lanes which lack the proven record of our transit and TOD investments. I wonder if you are all ready to endorse a vast, costly network of toll lanes.

The newly adopted draft falls short of addressing these concerns and we are concerned about it being released for public comment without additional fixes. In particular, the Executive Summary doesn’t even mention Region Forward and the Introduction continues to portray this 2010 regional compact as a subset of the now very old 1998 TPB Vision. Instead of Region Forward, it adds a lot of text regarding the recent Economy Forward forum, but that one day unscientific poll was hardly as carefully thought out an investigation of the land use/transportation connections as the effort that went into Region Forward.

While the RTPP now mentions Momentum, it only proposes incorporating the 2025 investments provided funding can be found, while not applying the same standard to its toll and other highway investment proposals. The RTPP also fails to incorporate Momentum 2040 and other transit expansion in the scenario B, even while it proposes a very costly, and still unproven, network of high occupancy toll lanes. The RTPP also utterly fails to mention the threat of climate change and the resulting need to dramatically reduce greenhouse gas emissions from transportation using land use and transit solutions.

In addition, the draft solicitation document for the CLRP fails to mention Region Forward, the climate report, and activity centers, despite the fact that we’ve debated this before, when you adopted an amendment to the solicitation document a few years ago. The goals of Region Forward, activity centers and climate report can be integrated into the federal planning factors. And, of real concern is that you are being asked to vote on the CLRP solicitation document in November, one month before you vote on a revised RTPP, but your expressed goal of the RTPP is to shape the CLRP. The solicitation document should say more than that the RTPP “should be considered.”

We are at a crossroads as a region, nation and world. We must fight climate change. We must recognize the success of our region’s transit-oriented development in growing our economy, reducing the amount of driving, fuel consumption and greenhouse gas emissions. We must recognize how demographics and the market have changed. Therefore we urge you to amend the RTPP to conform it to Region Forward, fully incorporate Momentum, and let it guide the most effective transportation investments for a sustainable and efficient future.

Letter to Governor McDonnell from Delegate Hugo regarding Bi-County Parkway

We are writing to respectfully request a meeting with you to discuss the actions of the Virginia Department of Transportation (VDOT) and the Commonwealth Transportation Board (CTB) regarding the Bi-County/North-South Corridor project. We are further requesting that neither the VDOT nor the Virginia State Historic Preservation Officer sign the National Historic Preservation Act, Section 106 Programmatic Agreement until we are able to meet with you.

COMMENTS to MWCOG on Regional Transportation Priorities Plan (RTPP)

We appreciate the work that has gone into the Regional Transportation Priorities Plan (RTPP) and your public outreach efforts. We commend the focus on Near Term and On-Going Strategies, which include a number of important priorities including first and foremost the maintenance of the existing system. We also strongly support and urge the TPB to adopt Scenario B, transit and TOD, as the long-term strategy for the region.

Testimony before the Hon. Andrea Harrison, Chair, Prince George’s County Council Re: Prince George’s CB 27-2013: Rental Conversion First Refusal

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.

The Coalition for Smarter Growth would like to express its support for CB 27, with the amendment that “Sec. 13-1120. Designation” be deleted. We are concerned that this designation by resolution provision is unnecessary and inhibits the function of this tool. Overall, we support this bill as a careful tool to assist with the preservation of quality rental housing to better meet the needs of many Prince George’s residents who struggle to find decent housing they can afford.

It is a measured tool to allow the county to help preserve affordable rental housing either through direct purchase, or through assigning the right to a third party. It also allows for waivers if certain conditions are met. This approach offers the county the opportunity to protect affordable rental housing without unduly burdening the building owner. Thus this tool is likely to be used where there is institutional and community capacity to purchase and rehabilitate rental housing. We welcome this useful tool to help Prince George’s residents secure quality, affordable rental housing.

Like all Washington, D.C. area jurisdictions, a significant share of residents find housing costs too high for their incomes. Building a toolbox of policies that help more Prince George’s working families find suitable housing that they can afford is a critical task for public officials. CB 27 is one of the tools that the county should have to assist renters with the opportunity to preserve their homes as affordable. This should be one of many tools. In 2010, we published a policy paper examining Prince George’s housing needs and initiatives (summary attached). This effort followed extensive work we have done in other jurisdictions on affordable housing policy. Through our research, we found that Prince George’s uses few local policy tools, both in absolute terms and compared to surrounding jurisdictions (see attached Table 5). Thus we welcome CB 27 as an important contribution to a local housing toolbox we hope to grow over time.

Thank you for your consideration.

Cheryl Cort, Policy Director

Testimony before the Northern Virginia Transportation Authority Re: NVTA 2014 and 6-Year Plan Draft Project Lists

Following up on my verbal testimony from your hearing on June 20, the Coalition for Smarter Growth submits the following written comments. As you recall, we strongly disagree with the approach being pressed by Delegate LeMunyon and Bob Chase of the Northern Virginia Transportation Alliance, and Delegate Minchew.

Testimony before the WMATA 2025 Special Committee in Support of the WMATA Momentum Plan

The Coalition for Smarter Growth is the leading organization in the Washington D.C. region dedicated to making the case for smart growth. Our mission is to promote walkable, inclusive, and transit-oriented communities, and the land use and transportation policies and investments needed to make those communities flourish.

Having helped win remarkably strong regional consensus for transit-oriented development as the framework for regional growth — reflected in the Region Forward and Economy Forward vision plans of the Council of Governments, and in the priorities of local leaders — the Coalition for Smarter Growth views investment in the Next Generation of Transit as a top priority and essential for supporting this regional vision.

We view the Momentum plan as the vision and framework for setting regional transit investment priorities and for working with all of our jurisdictions to create an expanded, well-maintained, and seamlessly integrated transit system our region needs to remain healthy, prosperous, efficient and competitive.

The Coalition for Smarter Growth is fully committed to achieving the Next Generation of Transit, as reflected in our report earlier this year. Key components include:

  • Rehabilitating and improving our Metrorail system as the region’s top priority investment;
  • Ensuring high-capacity public transportation networks to support a sustainable region of livable, walkable centers, and neighborhoods;
  • Expanding and improving the bus system by adding more service and providing bus priority on roadways is critical to meeting growing ridership demand and using our roads more efficiently;
  • Seamlessly integrating, physically and operationally, Metrorail, new priority corridor networks, bus rapid transit, light rail, streetcars, commuter rail and our bicycle/pedestrian infrastructure.

The Momentum Strategic Plan effectively makes the case for the value of the Metro system to our region and of reinvesting and strategically expanding the system. We believe that WMATA, through an extensive consultation process with COG and the jurisdictions, is the best entity for leading the strategic planning for our region’s Next Generation of Transit.

Perhaps no statistic stands out in the Momentum plan more than the value of investing in 8-car trains, which provide 35% more capacity-equal to 35,000 more passengers per hour to jobs downtown. To achieve this with roads, we would need 16-18 new lanes of highways. For comparison, widening just 2.5 miles of I-95 recently cost state and federal taxpayers $261 million or $52 million per lane mile.

Other statistics that we find compelling are that:

  • Regional riders will save an additional $100 million per year by purchasing less fuel and other out-of-pocket travel costs.
  • The region will avoid building 30,000 new parking spaces, saving $675 million.

Investing in Metro is the most critical step in supporting compact, efficient transit-oriented development, lowering per capita infrastructure costs and saving land.

If we are to continue our regional success and grow without reaching total traffic gridlock, we must rehabilitate Metro, maximize the capacity of the existing system and strategically expand Metro and connecting transit services. This must be our top priority.

Thank you.

Stewart Schwartz
Executive Director

Testimony before The Hon. Andrea Harrison, Chair, Prince George’s County Council Re: Support for CB-20-2013: Expedited Transit-Oriented Development

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 wish to express our support for CB-20-2013, which is an important step to reducing an institutional
barrier to attracting new investment at Metro stations. CB 20 offers a public process that gives greater
predictably to the review of development applications while also preserving essential public accountability.

We ask the Council also consider creating an evaluation mechanism in the bill so that its performance can be
regularly assessed and reported out to the Council, Planning Board and public. This bill’s expedited
development review process, along with other incentives for TOD, should be regularly assessed so that the
County can fine tune incentives and procedures that are most effective at achieving the goal of quality
transit-oriented development.

While we believe CB 20 will be helpful in encouraging more quality transit-oriented development
applications, we suggest that this does not substitute for rationalizing and reducing the complexity of the
zoning ordinance. We urge the Council to pursue the longer-term and systematic recommendations of the
2009 report: Prince George’s County Zoning Ordinance and Subdivision Regulations Streamlining the
Development Review Process.

Thank you for your consideration.

Sincerely,

Cheryl Cort
Policy Director

Testimony before the Hon. Muriel Bowser, Chair of the Committee on Economic Development and Housing re: FY 2014 Budget Oversight for DMPED and DHCD

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.

DMPED should recommit to leveraging public land dispositions for affordable housing

We are greatly disappointed in DMPED’s reduced expectations for affordable housing in new public land dispositions. Given the increasing challenge of housing affordable to our residents, we urge the Council to ensure DMPED recommit to leveraging public land dispositions for affordable housing, including for very low income households. In our 2012 report, Public Land for Public Good, we show that the District has and can do great things with its city-owned land. We are disappointed that DMPED is departing from the practice of the past decade to ask for 20-30 percent of affordable housing in public land dispositions affordable to households earning 30%, 50%, 60% and 80% Area Median Income (AMI). We are also surprised that the Mayor’s Housing Task Force dropped any recommendation to make the most of public land sales for affordable housing and sent this issue to the future study list.

Under DMPED’s current leadership, commitment to affordable housing in solicitations for public land dispositions has steeply declined. DMPED no longer asks for a specific percent of affordable housing or specific income levels. Instead, DMPED asks that proposals comply with or exceed the Inclusionary Zoning (IZ) law, which is already required for most residential development. IZ sets a minimum of 8-10 set aside at 50-80% AMI, with most income targeting at 80% AMI. To compensate, developments receive a 20% bonus density. Given the city can (and used to) leverage the value of its own land to subsidize housing, we should expect much more from public land deals. We recommend that DMPED restore the earlier practice of to asking for a 20-30% set aside with income targeting at the 30% AMI, 60% AMI and no more than 80% AMI income levels. (See tables 1 & 2 below).

This drop off in affordable housing in public land dispositions as a priority is particularly surprising given the attention the administration has put on renewing efforts to preserve and create more affordable housing. Public lands are an important tool for creating new affordable housing that the administration should not abandon now. We ask the council to ensure 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 public land disposition process. Public land disposition and development requests should clearly ask for and prioritize 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, below, 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.

DHCD – support $100 million to affordable housing, ensure IZ & ADUs have support they need

Regarding DHCD’s budget, first and foremost, we want to express our support for the $100 million commitment to affordable housing, with $87 million going to the Housing Production Trust Fund. We commend the Mayor for this commitment and ask the Council to support this. These funds are critically important to addressing our city’s escalating housing prices that are burdening a large share of D.C. households with higher and higher housing costs.

Inclusionary Zoning & affordable dwelling unit management

IZ administration has experienced significant problems in the start up phase. DHCD has indicated that is making headway addressing these significant challenges. DHCD will propose revisions to overly cumbersome administrative regulations, which should improve the process. DHCD has worked with Office of Planning and the Zoning Commission to resolve conflicts with FHA mortgage lending standards. DHCD has solicited for additional assistance to implement IZ and Affordable Dwelling Unit (ADU) programs. These are all important steps to addressing the major administrative challenges IZ implementation has encountered. We remain concerned that the office responsible for administering IZ and ADUs is understaffed. We suggest that at a minimum, and new Capital City Fellow be added to their small team.

I want to thank Director Michael Kelly and his staff for their openness and responsiveness to us.

Thanks also to Chairman Bowser’s keen interest in ensure these programs work, and affordable housing opportunities are increased.

Thank you for your consideration.

Sincerely,

Cheryl Cort
Policy Director

Table 1
Table 2

Testimony before Martin Grossman, Director of the Office of Zoning and Administrative Hearings in Opposition to Special Exception Request for S-2863, Costco Wholesale Corporation

Dear Hearing Examiner Grossman:

Please accept these comments on behalf of the Coalition for Smarter Growth. Our non-profit 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 opposition to the Special Exception request for the Costco automobile filling station – a large scale gas station which will attract vehicle trips from outside the local area. We believe this proposal is wholly inconsistent with the 2012 Wheaton CBD and Vicinity Sector Plan, and antithetical to the goal of promoting transit-oriented, pedestrian-friendly development within one half mile of a Metro station. The Wheaton Sector Plan area not only offers high quality Metrorail service, but also extensive bus service and a planned rapid transit service. This concentration of transit services will increase the share of trips made by transit, encourage more walking, and reduce how much people drive in the area.

As a regional organization, we advocate for well-designed transit- and pedestrian-oriented development which focuses more housing and commercial activities within an easy walk of Metro stations and other high quality transit services and historic downtowns. We seek to mitigate existing automobile-oriented uses in transit districts, and prohibit new ones. Reducing auto-oriented uses and their impacts are important to fostering a public realm and private development that better cater to pedestrians rather than prioritize the movement of motor vehicles. Uses such as gas stations, automobile repair services, drive thrus, and similar uses that attract motor vehicular traffic and encourage automobile-oriented designs such as additional driveways, wider driveways, surface parking, and curb cuts should be minimized, reduced, and in some cases, prohibited in transit districts like the Wheaton Sector Plan area. The proposed, a high volume gas station, is an unnecessary new auto-oriented use that would detract from the county’s and our efforts to create a more pedestrian-friendly environment around the Metro station.

The Plan specifically identifies the existing “auto-oriented uses” of the area as one of the key issues to be addressed through the implementation of the Sector Plan. The addition of a large scale gas station would compound the “auto-oriented uses” problem identified in the Sector Plan. We recognize that the site of the gas station is on the outer part of the mall property and Plan boundary. Yet we find the proposed use not a neutral use related to our goals to improve the pedestrian environment, but rather a use that actively degrades the pedestrian environment and works against Sector Plan goals. With such a large scale gas station, additional vehicle trips will be attracted to the transit district from outside the local area simply for the purpose of refueling vehicles with cheaper gasoline. This regional automobile service use  contradicts the Sector Plan’s and our goals to reduce vehicle miles traveled. Introduction of a new large scale gas station would directly oppose the Plan’s guidance to:

“Provide better pedestrian connectivity and support safe, secure, and appealing street level activity” (p. 25)

In an area like the Wheaton Sector Plan area, we have often found that the transition from auto-oriented land uses take time, but can be phased in to create more transit-oriented and pedestrian-friendly development. The Wheaton Sector Plan accommodates the existing auto-oriented regional mall surrounded by surface parking, but seeks to manage the negative impacts on pedestrians but proposing pedestrian access improvements, pedestrian-oriented street design changes, and encouragement of redevelopment to a more pedestrian-friendly design. Preventing new uses that would further degrade the transit district is also an important part of progressing towards a more pedestrian-friendly Wheaton Sector Plan and Metro station area. The large scale gas station would degrade the pedestrian environment by attracting additional automobile trips to the area and force more automobile-oriented designs for public rights-of-way to accommodate this auto-oriented use. Preventing this kind of use also promotes our overall goals to support greater use of transit, and build safe, walkable places, especially around major transit hubs.

For all of these reasons, the Coalition for Smarter Growth urges denial of the Special Exception application for the Costco automobile filling station.

Thank you for your consideration.

Sincerely,

Cheryl Cort
Policy Director