Posts about Green Area Ratio
Washington, DC may adopt a "Green Area Ratio" requirement for multi-family and commercial buildings in its new zoning code. It's an attempt to promote sustainable practices in large projects, but its ultimate effect might just be to make environmentally friendly urban living more expensive with limited actual benefits.
The newly-released draft of the zoning code contains very promising changes, like reducing parking requirements and allowing homes on narrow alley streets after a decades-long ban.
It also introduces "Green area Ratio," modeled on similar laws in European cities such as Berlin and Malmö. Seattle has already implemented a version of the same idea, called the "Green Factor," where it has drawn praise and some criticism.
The basic idea of the GAR is this: in order to address a perceived imbalance of paved/built to green space in urban areas, the zoning code must mandate dedicating a certain proportion of each lot to landscaping or permeable surfaces.
According to its proponents, the GAR will push buildings to better treat stormwater, improve air quality and reduce urban "heat islands." However, the draft regulations do not appear to contain any standards to determine whether landscaping elements actually aid in stormwater retention or treatment. Nor is there information about whether the estimated benefits are large enough to matter regionally or city-wide.
Existing research also raises potential concerns that nobody will monitor the environmental performance of these features once built. George Washington University professor Melissa Keeley, whose work the draft documents cite, sounds a cautionary note about "policy deficits and the lack of adequate outcome monitoring" in her 2011 study of Berlin's green ratio.
Some of the benefits seem questionable, like the statistic that "1,000 square feet of green roof can supply 110 people with oxygen." While this is beneficial, that the carbon monoxide-emitting motor vehicle creates much more pollution in urban areas than the lack of landscaped surface.
Berlin's air quality, which some sources estimate is the cleanest in Europe, largely owes its success to car restriction zones and policies that encourage traveling by foot, bicycle and mass transit. Cities are unlikely to substantially improve air quality without confronting the role of the car.
Additionally, GAR does not appear to distinguish between non-green ground coverage. An asphalt-covered surface parking and a 10-story apartment building with no parking and which covers its entire lot both receive a GAR of zero. On the other hand, it appears that the same apartment building with a 160-car garage but with a green roof could earn a high GAR.
The most notable element of the GAR is, perhaps, what it does not include. Single-family homes receive a special exemption from the proposed regulations because, the hearing report states:
Implementing this standard would impose an undue financial and logistical burden upon homeowners. Properties with one-family dwellings typically maintain higher standards of landscaping and retain more green area.Imposing expensive mandates on multifamily housing while exempting single-family homes from regulation creates a perverse outcome in which dense, space-efficient housing suffers penalties for being environmentally unfriendly, while low-density homes occupying a small portion of their lot enjoy rewards for "retaining more green area."
While the GAR is compatible with high density urbanism, regulations which apply differently to various densities can make some types of housing more expensive, especially small apartment buildings.
In old cities, the highest art is often maximizing visible greenery while minimizing GAR. That creates streetscapes of intense greenery at low cost. The tools of this approach are not bioswales and rain gardens, as useful as these may be, but window boxes, hanging pots, climbing vines and clay urns:
Ultimately, certain landscape elements, green roofs and other innovations may have an important role to play in Washington, but residents deserve to learn more about the long-term costs and benefits of such a large scale, mandatory and relatively untested regulation before adopting it as part of the zoning overhaul.
Accessory apartments, corner stores, alley dwellings, and less parking, all of which were legal when DC's historic neighborhoods grew into their current form, could become more prevalent under a proposed new zoning code. The first third of the code is now out as a public draft, and residents will debate these and other changes in the coming months.
Formal Zoning Commission hearings to approve or reject the zoning code will come later this year, but there is a sort of preseason exhibition hearing tomorrow. The DC Council's annual oversight hearing for the Office of Planning will bring sparks as advocates on various sides push their cases, though the council doesn't actually decide these issues.
The Office of Planning has been working for 4 years to rewrite the District's zoning code. Now, after hundreds of public meetings and many rewrites, OP's draft of the actual new zoning text clocks in at 458 pages, and that's just for the first third of the text, covering general issues as well as low- and moderate-density residential zones.
The vast majority of the work just updates, streamlines, and simplifies the text. Today, under the zoning code approved in 1958, rules and restrictions appear in general chapters that cover zone types or other, neighborhood-specific sets of rules called "overlays." Many rules use terms that aren't defined anywhere, like "building façade line," which seems very simple until you start thinking about buildings with rounded turrets.
There are also a few significant policy changes. In particular:
- More homeowners will be able to create accessory dwellings, like garage or basement apartments.
- A limited number of small art studios, corner groceries, shoe repair shops, hardware stores and the like will be able to open in residential areas when there aren't any commercial areas nearby.
- Fewer buildings will be forced to provide parking, or will not be forced to provide as much.
- More alley lots will be able to have houses.
- Green Area Ratio will require landscaping and other stormwater-managing features in projects, though not the low- and moderate-density residential buildings covered in the chapters released so far.
With the exception of the Green Area Ratio, a very 21st-century sustainability idea, the other changes acually harken more back to a past era than to the future. They correct some of the most egregious problems from the 1958 code, where it imposed social engineering ideas in vogue at the time that ended up eliminating local corner stores, pushed people out of urban neighborhoods, and forced new buildings to take a suburban form incompatible with the walkable communities that previously existed.
If Georgetown, Capitol Hill, or Petworth didn't exist today, they couldn't be legally built as they are. Even many single-family neighborhoods of detached houses like AU Park, Brookland, and Hillcrest are mostly illegal as well under current zoning. Where the new zoning code makes changes, it's to legalize the kind of development patterns that formed the neighborhoods residents treasure today, rather than forcing radically different forms which characterize much of the mistakes of the mid-to-late 20th century.
Therefore, fewer people live in DC's existing houses than they did at the time. Allowing accessory dwellings is a way to let those buildings serve their historic population levels in the modern day. An accessory dwelling is a separate legal unit either in the same building as a larger, main residence or in an accessory building like a garage or carriage house.
Row house neighborhoods like Capitol Hill, Columbia Heights, and Bloomingdale already allow these units because they are R-4 districts, which allow 2 apartments per building. But in the few R-3 row house neighborhoods, like Georgetown, the northern half of Petworth, Anacostia, and a few small others, these units are illegal except in those unusual buildings which are completely detached, and then only with a "special exception" from the Board of Zoning Adjustment.
There are many neighborhoods with semi-detached houses, where houses are connected in pairs (the orange areas in the above graphic), and accessory dwellings are also illegal in these buildings. Fully detached single-family homes (the yellow areas) can have accessory dwellings, but only by special exception (except to create housing for domestic employees in the 2nd story of a garage), and only in a main building, not a standalone garage or carriage house.
This is bad policy. These houses used to hold more people. Today, many owners are empty nesters who used to have kids in the house but no longer do. Retirees on fixed incomes find it harder to afford to keep up their homes. The simple solution is to let people rent out separate units to get some extra income, or even live in those small units and rent out the main house.
OP proposes a policy change to let people create accessory dwellings by right in the detached and semi-detached residential areas. In the R-3 row house areas, owners could create them as well, but would still need special exceptions.
This is a good change, but there's no reason to impose such burdens just on people in these row house districts, especially when only slightly denser row house districts allow far more by right. OP should amend its proposal to permit accessory dwellings by right in R-3 zones (which will be called R-14 in the new code) as well as in lower density ones.
Corner stores in residential areas
The local shops of today might be different than those of the past, like yoga studios rather than general stores, but the principle remains. Under current zoning, however, no commercial use can locate in a residential zone.
OP's proposal would allow some limited retail in residential areas, but with a great number of restrictions:
- Only "Arts Design and Creation" (arts studio, furtniture making, radio broadcast station), "Food and Alcohol Service" (deli, ice cream parlor), "Retail" (drugstore, grocery, jewelry store, but not auto shop or firearm sales), and "Service" (bank, travel agency, tailor, but not daycare, animal boarding, health clinic, or sexually based business) uses are allowed.
- They can't be in any building within 500 feet of a commercial or mixed-use zone, so this doesn't let existing retail corridors expand (though, arguably, some of that might be a good idea).
- There can't be more than 3 other arts, retail or service uses within 500 feet, or more than 1 other food establishment, to prevent too much of a concentration of these non-residential uses in one area.
- It can't be above the ground floor of any building, except for artist live-work spaces. This prevents a building from becoming entirely commercial.
- It can't be larger than 2,000 square feet.
- It can't be open after 7 pm or before 8 am.
- There can't be more than 4 employees at the business at any time.
- It can't have more than 1 sign, a lighted side, or a sign sticking out from the building.
- All of the trash and materials have to be stored inside; there can't be a dumpster, for instance.
- Any alcohol sold has to be for consuming elsewhere, not at the business, and can't take up more than 15% of the business's floor area. That means a small grocery could offer some beer and wine, but there can't be a wine bar or liquor store.
- Food sales can't involve cooking food on-site, but reheating pre-cooked food is okay. Grease traps (a part of kitchens that do frying or other cooking with grease) aren't allowed.
- There can't be dry cleaning chemicals, so a dry cleaner in a residential district has to be the kind that sends its clothes out to be cleaned rather than doing the work in the building.
Despite these regulations, a number of people are nervous about allowing any commercial use in a residential area. They understandably worry about noise, traffic, and other effects of commercial activity. OP seems to have tried to set rules that cut off the problematic impacts, like late night activity.
Maybe there need to be additional restrictions, or maybe some of the proposed uses are just too risky for neighbors to be comfortable. If so, we should amend this section rather than scrap it entirely.
Minimum parking requirements
It turned out, however, that many of the parking requirements were far too high, forcing buildings to dedicate precious space to parking lots. That makes construction more expensive and creates gaping holes in the urban fabric. It also pushes architects to design buildings around cars rather than people, making them less pedestrian-friendly and forcing residents to drive more and walk less.
In the low- and moderate-density residential areas covered by the zoning rules OP just released, buildings of 9 or fewer units don't have to build any parking. That's great, but many buildings still do. Nobody can build larger residential buildings in these zones, but existing ones become nonconforming.
All non-residential uses in these districts also have to build parking. That includes churches, schools, daycares, rec centers, chanceries, and retail. These are the very kinds of buildings that shouldn't be car-oriented in residential neighborhoods. A daycare in a residential area ought to be serving the neighbors, not attracting people from far away. If it has no parking, that's more likely.
Many neighborhoods have fought with churches which want to tear down historic row houses just to create parking lots for parishioners who don't live in the city. Minimum parking requirements only exacerbate this problem instead of solving it. Neighbors have fought with embassies about converting grassy yards to parking lots. Why make this mandatory in the zoning code?
The rationale for these requirements is that curbside space is limited, and neighbors don't want the patrons of these other uses to take up curbside parking. But the proper way to solve this problem is by pricing or restricting curbside parking, not to force such buildings to devote a lot of their space to parking which makes traffic even worse. If DCPS builds a new school in a residential neighborhood, building less parking, not more, lets kids have more space to play and encourages as many teachers as possible to take the train or bus.
The higher-density residential, mixed-use, and other areas of the city will distinguish between transit-oriented areas, near Metro, high-frequency bus or streetcar lines, and areas without good transit access. While it's probably unnecessary to require it in zoning, there's some argument that a store in a commercial area far from transit might need some parking.
But these parking minimums for non-residential uses in low- and moderate-density residential areas even will apply right next door to a Metro stop. A potential school just a block or two from Takoma, Potomac Ave, or Deanwood Metro will nonetheless need to build considerable parking. That's wrong.
Current rules allow alley dwellings as long as the alley lot is 400 square feet or greater, it has adequate plumbing and so on, and the alleys serving it are particularly wide, at least 30 feet. The new code removes the 30-foot alley rule, but any alley unit will still have to get a special exception and satisfy DC agencies on fire safety, traffic, waste and more.
If the fire department doesn't think it can put out a fire in an alley dwelling, it shouldn't go in, but if one satisfies them, DDOT, DPW and the others, an arbitrary alley width shouldn't be the obstacle.
A 21st-century change creates a new "Green Area Ratio" for large buildings. Projects which have a GAR requirement must include a certain as a percentage of the lot area. Grassy space, green roofs, water features, trees, and other sustainability elements each give a certain number of points based on their size, and the sum of all of those must equal a set fraction of the lot's size.
Parking lots, in particular, also have landscaping requirements, mandating a certain number and size of trees and grassy areas to ensure that parking lots have shade, don't form urban heat islands, and can handle some stormwater runoff.
This version is still just a draft. OP will make changes from comments by residents including a citizen task force, hold more public meetings, make more changes, and finally move to formal public hearings before the Zoning Commission. You can send OP your comments here.
Opponents of these changes are organizing groups to attend tomorrow's oversight hearing, which starts at 10 am. If you want to speak, email email@example.com to sign up, or you can watch the fireworks online.
DC's extensive zoning update process continues with a hearing tonight on the Green Area Ratio proposals and the deadline for submitting written comments on car and bicycle parking minimums and maximums.
First, today is the last day to submit written testimony to the Zoning Commission on the parking chapter, including relaxing parking minimums, adding limited parking maximums for very large projects, and guiding the location of parking on a lot.
I'm particularly focusing my written comments on the need to accelerate section 1506 (PDF) of the parking proposal, which disallows putting parking in front of buildings. OP and the Zoning Commission should enact this section before the complete zoning rewrite takes effect over a year from now.
Projects like the Aldi in Carver-Langston or the Van Ness Walgreens (later changed) will keep getting proposed while the zoning rewrite is underway. Developers will design a project the way zoning requires, but in the absence of guidance, they'll just fall back on the standard suburban models. These projects will last for 50 years, so the least we can ask is that the developer put the parking behind the buildings.
To submit comments, fax or emailed a signed PDF of not more than 10 pages to firstname.lastname@example.org by 3 pm today.
The Green Area Ratio (PDF), the subject of tonight's hearing, incorporates a standard of environmental sustainability into development. New development or large-scale renovations for buildings will have to meet a GAR standard, except for single-family homes, 2-unit condos/apartments, or accessory dwellings .proposed text sets scores for different kinds of landscaping and stormwater management. Trees count for a certain number of square feet depending on their size. Landscaped areas count for 30-60% of their size depending on the depth of their soil, permeable pavers about 40-50%, green roofs 60-80%. That score is then divided by the total size of the lot to generate a GAR.
The actual GAR each property will have to achieve has yet to be determined, and the Office of Planning will propose specific thresholds as they write zoning text for each individual type of zone.
Implementing the GAR will cost some money, though statistics from a similar program in Seattle showed that it added only ½% to 1% to the total cost of the project. In addition, buildings have to pay impervious surface fees from the District Department of the Environment and DC Water, and higher GAR will directly lower those payments. GAR features on buildings will also help DC reach its EPA-mandated stormwater quality goals, improve air quality, and reduce air conditioning costs.
OP estimated the current GAR of properties in DC. For commercial zones, the GAR today falls between .2 and .3, with industrial zones a little lower, moderate density residential between .3 and .4, and lower density residential zones higher due to their lower lot coverage.
The Zoning Commission asked OP to estimate what GAR requirements it might set for a zone. OPS ran the analysis for Production, Distribution and Repair (PDR) zones, which are designated C-M for Commercial and Manufacturing or just M for Manufacturing in the old zoning code. PDR zones average .137, the lowest category in DC.
Each 0.1 of GAR would add about $1.50 per square foot to projects. OP would recommend a starting GAR requirement of 0.2, with the opportunity to reevaluate raising the threshold in the future. This would add less than 1% to the construction costs of new projects.
The hearing is tonight, 6:30 pm at 441 4th Street, NW (One Judiciary Square), room 220-South. Typically in these hearings, OP presents first, then the Zoning Commission asks questions, and finally public witnesses can speak, first witnesses in support and then those opposed. Fill out two of the little witness cards that are on the table next to the far right door while you wait.
The Committee of 100 has relentlessly attacked the Office of Planning's multiyear effort to update the DC zoning code to match the current Comprehensive Plan and the needs of a 21st-century city. The strange part is that based on their stated goals, the Committee ought to actually be thrilled with the zoning rewrite.
In their letter opposing Harriet Tregoning and Gabe Klein, Committee of 100 chair George Clark wrote,
During the past four years, Ms. Tregoning has pursued an agenda that she characterizes as smart growth, with the implication that the city is a victim of "dumb growth" and needs a radical makeover. We disagree with her definition. Smart urban growth is a targeted and disciplined approach that equates sustainability with preserving neighborhoods; and integrates environmental standards, community preservation, infrastructure improvements, economic opportunity, and public participation.I suspect Harriet Tregoning would absolutely agree with all of the elements Clark lists as part of smart growth. And the zoning rewrite does all of these.
For example, at a recent preservation roundtable, Committee members Charles Robertson and Anne Sellin said they were "concerned" about the loss of "green space" from zoning changes that affect side courts and yards, though the effect of these will be very minor and even remove incentives to fill in small courts.Green Area Ratio, a requirement that new buildings and those that more than double in size (excluding single-family homes) include a certain amount of landscaped, permeable surface, whether trees, lawns, landscaped areas, green roofs, and more.
In other words, instead of just requiring empty land and calling it "green space" even if it's a trash-strewn alley or parking pad, the zoning code will actually require green space that's really green. It will also increase environmental sustainability, another element of Clark's list. Yet the Committee of 100's letter does not praise Harriet Tregoning or the Office of Planning for this meaningful innovation.
You also wouldn't guess from listening to Committee of 100 rhetoric on the zoning rewrite, but under OP's proposals for residential zones, many neighborhoods would gain zoning limits that are stricter than those in effect today.
For example, current low and moderate density residential zones (R-1 for single family homes up to R-4 for rowhouse areas) all currently allow building heights of up to 40 feet. That means that any house or townhouse can get a "pop-up" 3rd above-ground story as long as it complies with lot occupancy and other restrictions.
The proposed zoning changes will change this. Areas with mostly two-story houses will get zoning that only allows two-story houses, for example. This will do far more to "preserve neighborhoods" than the current zoning. Those that believe in fewer regulations may oppose this change, putting OP on the side of the Committee of 100. Oddly, though, the Committee isn't praising this element.
Meanwhile, I live in an R-5-B area, which allows far denser development than row houses like mine. In the last few decades, including in recent years, residents in some R-5-B zones like the area around 15th and T got their zoning changed to R-4, limiting development to something closer to what exists there now. However, this was a very time-consuming process, requiring long hearings and lengthy waiting periods for each small area.
OP, instead, is proposing new zoning that will set development limits in all row house neighborhoods to a level that matches existing buildings. For some reason, however, we haven't seen any statements from the Committee of 100 cheering this development, which achieves a goal they have been pushing for decades.
Why is the Committee of 100 so apoplectic about a zoning code where planners have strengthened zoning rules to preserve neighborhoods and required green space? Richard Layman might have an answer from a hearnig a few years ago on the zoning code:
[George Clark] said it was basically fine. I said it was automobile-suburban oriented (it is a document from the 1950s after all), and that every overlay and special zoning category is an indicator that the underlying code is inadequate and not robust.Perhaps this is why all of the advocacy that's come from the Committee of 100 in recent years has focused on stopping undesirable projects. Members, including our commenter Lance, insist they support many of the same things as Greater Greater Washington readers, but I can't recall a single case during our existence where the Committee has actively pushed for a change.
The current code might not be great, but it is predictable, and all the people against the rewrite have a lot of experience dealing with it as it is. They are comfortable with it, even if it is in fact very flawed with respect to urbanity.
Martin Austermuhle put it another way on DCist:
At the end of the day, both the Committee of 100 and Greater Greater Washington are forward-looking organizationsTruly responsible planning tries to shape the city's growth in a positive way. Build here, but not there. Don't change this; change that instead. Arlington did this with their famous "deal" around the Metro: build very densely right next to Metro, but protect single-family neighborhoods elsewhere. DC could likewise shape its growth into specific areas around Metro stations and in neighborhoods that want new residents and businesses.
— but what has changed is the time from whence they claimed to start looking forward. The Committee has been around long enough that it's harder to define what it does as being particularly "progressive." In fact, it seems downright conservative.
As Layman pointed out in that preservation roundtable, groups like the Committee of 100 grew up during an era of a shrinking city. Now, we have a growing city, which brings different challenges and different solutions. The Committee has a great opportunity to shape that growth into the places in the city they want to see it and suggest the form it could take. That, however, would require moving beyond the current mindset that everything is "basically fine" and the best approach is not to change.
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