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Development


Montgomery County isn't really waging war against suburbia

Some Montgomery County residents are accusing county officials of waging a "war against suburbia." But the county isn't coming for your single-family house, no matter who tells you otherwise.


Bethesda residents protest the Westbard plan. Photo by Sonya Burke on Twitter.

Last week, about 70 protesters from Bethesda demonstrated outside the Council Office Building over the Westbard Sector Plan, which would redevelop a cluster of 1950s-era strip malls off of River Road into a small-scale town center with new shops, parks, and up to 1200 townhomes and apartments. The council is set to approve the plan tomorrow.

Holding signs saying "suburban not urban," the group shouted down Councilmember Roger Berliner when he tried to address them, calling him "corrupt." Berliner, who represents Bethesda, had successfully convinced the council to reduce the amount of allowable development in the plan, which effectively limits building heights to six stories.

The group, called Save Westbard, is led by Jeanne Allen, former Republican state delegate candidate and charter school advocate. In an email blast two weeks ago, she called the Westbard plan "Orwellian" and says Berliner's "visits to Cuba and China influenced" his support for developing the area.


One of the shopping centers in Westbard today. Photo by Todd Menhinick on Flickr.

She argues that the county wants to "destroy" wealthy suburban neighborhoods like hers, overcrowding the roads and schools, and possibly changing the culture of her community. "Suburbs breed generous people," she says. "They have community meetings and fundraisers in their homes (on streets where people can park)...take care of one another's kids (who can play in yards)...suburbs have a purpose."

Is the county really at war against the suburbs? Save Westbard released a document called the Westbard Papers containing emails between county planners and attorneys for Equity One, one of the major property owners in Westbard, though they don't reveal anything illegal. And Allen refers to three-year-old comments from Councilmember George Leventhal (though not about Westbard) in which he calls the suburbs "a mistake."

Except in reality, Leventhal is talking about the spread-out nature of some suburban places, which forces people to drive really far for work or shopping, resulting in lots of traffic and pollution. He's not making a value judgment about suburbs, but instead acknowledging that some kinds of suburban development have negative costs.

"We see the substantial separation of residential areas from commercial areas from industrial areas from retail areas as a mistake," he says. "Because the very thing that was so marvelous when Olney and Gaithersburg and Wheaton were laid out in the 1940s and 1950s is now killing our planet. We can't afford to drive as much as we do, we have to change our land use patterns, our transportation patterns...Our heirs will blame us for our failure to do that. It's one of the culprits in climate change."

It's possible to have suburban neighborhoods where you can have a big house with a yard and still be able to walk to things. You only have to go about two miles east of Westbard to Chevy Chase to see what that looks like. That's why Montgomery County wants to focus development in aging commercial areas like Westbard, or Chevy Chase Lake, or White Oak. The county is built out, and investing in these areas gives current residents access to more things without having to sit in traffic, while accommodating future population growth.


Rendering of the Westbard redevelopment from Equity One.

There are many current Westbard residents who agree with Leventhal and Berliner that having new shops and amenities within walking distance is a good thing. The Citizens Coordinating Committee on Friendship Heights, which represents nineteen neighborhoods and condo buildings in the area, supports the Westbard plan, calling it a "compromise of different interests," including the developers and some residents who wanted less development.

Another petition circulated by Equity One includes signatures from 182 neighbors who support the plan. "Westbard is a highly affluent area of Montgomery County," reads the petition, "yet its streets are not pedestrian-friendly, its residents shop at an unsightly retail center surrounded by a sea of asphalt, it's service workers can't afford to live there, and its natural resources are among the county's worst."

And there are the people who have yet to live in this community. While looking for a job after graduate school, I worked out of the Westbard Giant giving out samples for a local bakery who sold cakes there. I got to know some of the people who worked there, and discovered that few of them lived in Montgomery County, let alone in the neighborhood. These are the people who have to drive long distances to work in Westbard, which is one of the most expensive parts of an already expensive county. The county's plan for the area would set aside 15% of new housing units for lower-income households, allowing some people who work here to live there as well.

Leigh Gallagher's recent book "The End of the Suburbs" might freak out any Westbard resident who likes the suburban aspects of their community, But Gallagher's argument is that suburbs aren't actually going anywhere, particularly affluent ones with good schools that are walkable. It bodes well for Westbard, but it doesn't mean that Westbard, or anywhere else, isn't totally immune to change.

Development


DC has few "parking craters" downtown. Here's why.

Most American downtowns are surrounded by "parking craters," or big spaces with swaths of parking lots and no buildings. But they have virtually disappeared from DC (all the parking for Congress being a key exception, of course) because downtown office space is in high demand and because each building can only be so tall.


Downtown DC's last privately-controlled parking crater, left over from when the Convention Center was demolished. Photo by the author.

Most surface parking lots are built as what zoning calls "an accessory use," which means they're an "accessory" to something else on the same lot. The parking lot at Sam's Park & Shop in Cleveland Park, or the Capitol's parking lots, are "accessory" parking lots.

Parking craters, on the other hand, are usually not accessory parking directly tied to another land use; they're paid parking lots whose owners are holding onto land that they speculate could be a future development opportunity.

A parking lot requires minimal maintenance, but pays out some income in the interim. Most importantly, a parking lot is "shovel ready"—unlike a building with tenants in place, whose leases might or might not expire at the same time, a parking lot can be emptied and demolished on short notice when opportunities arise.

Here's a map of all of DC's parking craters in 2011, before NoMa saw a huge influx of residents and City Center was built.


Click to enlarge. Map by Dan Malouff.

High rents and short buildings make parking craters impractical

The opportunity that many "parking crater" developers are waiting for is the chance to build a big office tower. Offices pay higher rents to landlords than apartments (although in the best locations, retail or hotels can be even more valuable).

However, the banks who make construction loans to developers rarely allow new office buildings to be built before a large, well-established company has signed a long-term "anchor tenant" lease for much of the new building's space. If the building isn't pre-leased, the result can be a bank's worst nightmare: a "see-through tower" that cost millions of dollars to build, but which isn't paying any rent.

Within downtown DC, robust demand and high rents mean that landowners face a very high opportunity cost if they leave downtown land or buildings empty for a long time. Instead of demolishing buildings years before construction starts, developers can make room for new buildings by carefully lining up departing and arriving tenants, as Carr Properties did when swapping out Fannie Mae for the Washington Post.

Less often, a developer will build new offices "on spec," or without lease commitments in place. A spec developer usually bets on smaller companies signing leases once they see the building under construction. Downtown DC has a constant churn of smaller tenants (particularly law firms and associations) that collectively fill a lot of offices, but few are individually big enough to count as anchor tenants.

Because office buildings in DC are so short, they're relatively small, and therefore the risk of not renting out the office space is not that high. In other words, it's easier to build in downtown DC.

In a city like Chicago, by contrast, few developers would bother building a 250,000 square foot, 12-story office building to rent out to smaller tenants. Instead, they could wait a few more years and build a 36-story building, lease 500,000 square feet to a large corporation, and still have 250,000 square feet of offices for smaller tenants.

This customer is always right

There is one big anchor tenant in DC's office market: the federal government. The government has some peculiar parameters around its office locations, which also help to explain where DC does have parking craters.

Private companies often don't mind paying more rent for offices closer to the center of downtown, which puts them closer to clients, vendors, and amenities like restaurants, shops, or particular transit hubs. The government, on the other hand, has different priorities: it would rather save money on rent than be close-in. The General Services Administration, which handles the government's office space, defines a "Central Employment Area" for each city, and considers every location within the CEA to be equal when it's leasing offices. It also usually stipulates that it wants offices near Metro, but never specifies a particular line or station.

As rents in prime parts of downtown rose, the government began shifting leased offices from the most expensive parts of downtown to then-emerging areas. Large federal offices filled new office buildings in the "East End," helping to rejuvenate the area around Gallery Place and eliminate many parking craters.

Next: Parking craters have almost disappeared from downtown. So where are the new parking craters?

Development


Big developments serve a huge need, but smaller ones help cities too

It's pretty common to see new buildings with hundreds of units going up across the region. But what about smaller buildings, going up one at a time? That kind of small scale development, also referred to as incremental development, is an important part of building a city.


Neighborhoods like Georgetown came about one building at a time. Photo by Norman Maddeaux on Flickr.

Think about your favorite neighborhood in DC. Maybe it's tree-lined Swann Street by Logan Circle, with it's multi-colored row homes, all similar but with details that make them special, like the flower plantings on each stoop. Or maybe it's Wisconsin Avenue in Georgetown—a bustling neighborhood commercial street with café seating and colorful shop windows selling specialty wares.

These special places were not created all at once; they are the result of a buildings being built, changed, and rebuilt, which has resulted in a rich urban fabric that supports renters, owners, merchants and service providers.

Today, that process is much more rare, with whole new neighborhoods going up all at once. These projects are often quite successful, and address the need for increased housing and retail in DC. But when large companies are the only ones building in neighborhoods, would-be smaller developers are left out.

Why do we want to avoid that? Because when communities are built by the people who live there, then those people are engaged in the neighborhood. Incremental development brings more wealth into the community; the developers of small projects reap the benefits of property ownership, including income-producing properties and tax benefits. And since small developers are literally invested, they have a stake in the decisions of the community, and take part in decision-making and neighborhood advocacy.

Furthermore, the spaces created by incremental development—from pop-up food kiosks to retail under residential—are more conducive to small entrepreneurs who can't take on the high rents and long terms of new larger retail spaces. In the boom and bust cycle of real estate, communities that are built incrementally are more resilient.

Today, real estate financing, the development process, and housing demand favor larger projects. So even if you want to, say, build a small coffee shop on that vacant corner lot, or fill in a hole in a commercial corridor with a multi-use building, it can be challenging to get the resources and permits to do so.

For example, banks are hesitant to lend money to build project types that have not been proven to create a profit, especially in up and coming neighborhoods. And even if you get financing for a mixed residential/retail building, then your project could be stymied by parking requirements that were meant for larger residential projects. There are roadblocks and unforeseen issues every step of the way.

If smaller projects aren't part of the mix, neighborhoods might be less likely to get a fine-grained feel. Also, it can mean less space for small retail, and fewer business opportunities for people interested in building cities.

A new non-profit is trying to change this

The Incremental Development Alliance was created by small scale developers who had been overwhelmed by the number of people reaching out to them seeking advice on how to build small, multi-unit buildings. Since the group's founding in 2015, the group has conducted over twenty workshops on this topic, and are the recipients of a Knight Foundation grant to encourage incremental development in Columbus, Georgia.

On May 13 and 14, one of the founders of IDA, John Anderson, will be in Silver Spring to run a workshop on developing small real estate projects. The Silver Spring Small Developer Boot Camp will begin with a networking on Friday at Fire Station 1, and run all day on Saturday at the Montgomery County Planning Department. Participants will learn about technical skills and resources to navigate development financing, zoning and entitlement, site selection and building design in order assemble small scale real estate deals.

Discounted pricing is available until this Friday, and registration is available online.

Development


My neighbor is an empty house, one of over 3,500 in the District. The DC Council wants to make it affordable housing.

Within one block of my apartment, there are three separate vacant buildings, with little sign of pending construction or development. They've been that way for years, and I live in Shaw, which is booming. DC Councilmember Anita Bonds has introduced a bill that'd let the mayor turn vacant buildings into affordable housing.


My neighbor, the empty building. Photo by the author.

DC wants to buildings to be used, not stay vacant

Vacant, blighted and condemned buildings are of no use to anyone, especially the city. While the property owner might pay taxes and penalties, there's an overall loss of revenue when you consider that occupants would be both taxpayers and consumers. And that's not to mention the negative effect empty or boarded up buildings have on neighborhoods.

Because of this, DC has laws and systems to try and get these units occupied and reintegrated into neighborhoods. The DC Department of Consumer and Regulatory Affairs has an entire unit, the Vacant Building Enforcement Unit dedicated to buildings around the District that are like the ones on my street. Its job is to compile these lists twice a year, identifying all of the vacant and blighted properties in the district, and then enforce penalties and taxes on the owners of each unit.

Here are the current numbers on vacant buildings

Just how many of these building are out there in one of the fastest growing "states" in the country? Thousands.

In her opening statement last month introducing a bill to address the issue, Councilmember Anita Bonds explained that as of November 2015, there were a total of:

  • 3,535 vacant buildings
  • 345 blighted buildings
  • 132 condemned properties
  • 67 vacant lots of 650 square feet or larger
That is a lot of potential space in a city fighting for every scrap of usable land.

To encourage owners to occupy or develop buildings, the District taxes vacant and blighted buildings at a much higher rate than occupied ones. While occupied units are taxed at around $1 per $100 of assessed value, vacant buildings are taxed at $5 per $100 and must meet certain maintenance standards. Blighted buildings (those is more serious disrepair) are taxed higher: $10 per $100 of assessed value.

When taxes don't work, the city uses liens. But what about when liens don't work?

At first, it seems illogical for properties to sit unused: DC needs more housing, neighborhoods want more retail, and property owners and developers want returns on their investments, not fines and taxes. But there are many reasons for a building to remain vacant even when developing it might serve the greater good.

Sometimes the culprit is an absent owner waiting to cash in when property values rise, often utilizing loopholes to get out of the tax penalties. Other times it is simply a case where accumulated unpaid taxes and penalties have amounted to such a high amount, the situation is stuck.

If I'm a building owner and I don't pay my property taxes, the government has the option to bundle what I owe into an investment called a tax lien that it can then sell to an investor. An investor can then come and buy that lien, making the government happy (they got their money), and now I owe my overdue taxes, interest, and penalties to this investor. If I still don't pay over a long enough period of time, that investor can foreclose on my building and take it away.

Sometimes, though, nobody buys liens. It might be that an investor doesn't want to buy the lien for a building that is falling a part and is not worth the investment. It might also be that the tax lien has become so high no investor will bite. The list of tax sales that went up earlier this year shows the wide range of liens available to potential investors, and just how high they can be: over $1 million for one particular property.


Photo by NCinDC on Flickr.

Anita Bonds wants to change that

Councilmember Bonds' bill, introduced after work with different housing advocacy groups, intends to target vacant properties which haven't or probably won't sell. The bill would allow the Mayor to transfer the rights of properties where the property tax debt is 50% or more of the assessed value of the property to a developer or non-profit. The new owner would have to meet strict affordability standards with their plan for the property:

  • For single family buildings, the new property must be affordable to buyers or renters at 90% AMI (Area Median Income)
  • For multi-unit buildings, one-quarter the new property must be affordable for buyers or renters at 80% or below of AMI, one-quarter at 50% or below of AMI, and one-quarter at 30% or below of AMI
The bill also mandates a 40-year affordability covenant on the property (ensuring the affordability rules above in the deed), and outlines a process for the selection of the profit or non-profit developers who would take over the property. Currently the legislation has been referred to the Committee on Housing and Community Development and the Committee on Business, Consumer and Regulatory Affairs for analysis. The housing committee will probably address the bill in May.

Have an opinion? Send an email to the Councilmember Bonds, the chairperson of the Housing and Community Development Committee, at abonds@dccouncil.us, or to Committee Director Irene Kang (ikang@dccouncil.us).

In the meantime, know a vacant building you want turned into affordable housing? Call 311 or email vacantbuildings@dc.gov to report.

Development


The first two efforts to turn Petworth's Hebrew Home into housing failed. Will the third time be different?

Just a few blocks from the Petworth Metro, a District-owned apartment that most call the Hebrew Home has been vacant since 2009, and DC is asking for resident input on its latest effort to redevelop the land (the first two fell through). The end result could be 200 new units of mixed-income housing, along with retail and park space.


The Hebrew Home, looking west on Spring Road. Photo by Jonathan Neeley.

Located at 1125 Spring Road, the Hebrew Home's name is a reference to the building's original use serving the elderly Jewish population with housing and health care. From 1925 to 1969, the property grew to include an array of social services available to young and old within a community that both understood and supported the specific religious, linguistic, and cultural needs of its clients.

When the Hebrew Home determined it could no longer adequately serve the needs of the local Jewish population by remaining on Spring Road, it sold the property to the District government and moved into a new facility in Montgomery County.


The Hebrew Home and the adjacent Robeson School building, at 10th and Spring NW. Image from DMPED.

This isn't the first effort to redevelop the Hebrew Home

From 1968 until its closure in 2009, the District used the Hebrew Home site as a mental health facility for the homeless. Since it closed that facility, the District has attempted to breathe new life into the building without success.

In the fall of 2010, the DC Department of Human Services proposed using the site to shelter families instead of sending them to DC General. That plan would have cost an estimated $800,000 to renovate the building for 74 families. However, the site was removed from consideration due to then-Councilmember Muriel Bowser's concern that the immediate area had an "inordinate amount of group homes" and two homeless shelters within a two-block radius of the site.

More recently, efforts in 2014 to redevelop the historic structure and the Robeson School (which sits immediately adjacent, to the east) resulted in a plan to create approximately 200-units of housing with 90% designated as affordable, including a senior preference for 25% of the units.


The Robeson School building. Photo by Jonathan Neeley.

Development stalled again, however, when the District learned that it wouldn't be able to transfer ownership to the DC Housing Authority without a formal Request for Proposals process. Moreover, Bowser expressed reservations about the plan being weighted so heavily toward affordable housing. Due to these factors, the District restarted the process to develop the site in April with what it's calling OurRFP, a process in which the city solicits input from community members on how to use a site before developers start submitting proposals.

The Hebrew Home could become much-needed housing for all incomes

The first of two OurRFP workshops to decide how to redevelop the Hebrew Home was earlier this month. There, officials from DC's office of the Deputy Mayor for Planning and Economic Development (DMPED) shared some key data:

  • The lot is 144,400 square feet in size.
  • The site includes three buildings. The development will not include the small building at the western edge of the site.
  • The former Hebrew Home structure is historic, but the Robeson School is not and can be razed.
  • The property has good access to transportation. It's near the Georgia Avenue Metro station, numerous bus lines, and Capital Bikeshare stations.
  • The site has a walk score of 93 and a bike score in the 80s.

A map of the transit options surrounding the Hebrew Home. Image from DMPED.

Workshop attendees split into 13 working groups to discuss what they would like to see happen with the Hebrew Home.

The site has tremendous potential to provide a significant amount of housing in an area with ready access to public transportation and where housing prices and displacement are of great concern. Within my working group, there was general agreement that the RFP should start from the position of including a strong affordability component, with the financing then driving the configuration of affordable and market rate housing to a balanced level. There was an understanding that the economics of development will have an impact on what can be financed and that, at the end of the day, the development must become a reality for any housing to exist.

With regards to the living units, there's a need for both family-sized units and apartments for seniors. I would like to see every unit (if possible) be ADA compliant; as units become vacant in the future it would be ideal if any resident in need of housing would be able to move into the building and not be prevented due to the unit's configuration.


A map showing existing affordable housing surrounding the Hebrew Home site by location and number of affordable units. Image from DMPED.

As for the type of building that goes up, it is clear that people want the new construction to fit into the neighborhood context. Whether the building was traditional, modern, contemporary, or something else, the materials, massing, and architectural detailing's ability to make it fit the character of what's around it certainly exists.

We also discussed the massing of the new construction on the Robeson site. Some suggested that a by-right approach would be more in keeping with the neighborhood and better fit in. I countered that I would prefer a Planned Unit Developmentwhere a developer provides the community with benefits in exchange for a zoning exception— for three reasons:

  1. A PUD would allow for a slightly larger building. The existing Hebrew Home building is one story taller than allowed by by right, and I think that an additional story on the new construction that matched the height of the historic building would not be out of place, especially as it would be located between the Hebrew Home site and the Raymond School & Recreation Center.
  2. A PUD would also result in more oversight and community opportunities to participate.
  3. As zoned, the building is residential. But the existing Hebrew Home building has a space on the first floor with a separate entrance that could support a small store or possibly another use such as an early childhood development center.
I think the community would benefit from vetting these options to see if they're a good fit rather than not discussing them at all.

One of the last things the group discussed was the public space and sustainability. As part of this discussion, we talked about trees, benches, green roofs, and other possible uses for the existing green spaces. As this is an opportunity to enhance our natural environment, I also mentioned that we should advocate for all trees and landscaping to be native plantings. The green space between the small building at 1131 Spring Road and the Hebrew Home is also large enough for a small park or other type of public space.

There will be another OurRFP workshop in May, and DMPED anticipates releasing the RFP solicitation in June 2016.

A version of this post originally ran on Park View, DC.

Development


Tenleytown won't get 50 units of housing and a park

50-100 people won't be able to live in Tenleytown, and a major intersection won't get a pocket park and become more walkable. That's because DC's Office of Planning and some local leaders got anxious about a mixed-use building from Georgetown Day School that's shorter than another one across the street.


Rendering of the proposed residential buildings along Wisconsin Avenue. All images from Georgetown Day School / Esocoff and Associates.

GDS proposes a transformative project for Tenleytown

In June 2014, after three unsucessful attempts to redevelop a Safeway grocery store at 42nd and Davenport Streets NW, the neighboring Georgetown Day School (GDS) bought the Safeway property, a WMATA chiller plant, and a car dealership across 42nd on Wisconsin Avenue.

Despite initial fears that this would mean no chance to add retail, build much-needed apartments, and link Tenleytown and Friendship Heights, after 20 months of public meetings, GDS proposed a design that would consolidate the school and build two mixed-use buildings on the dealership property.


Plan of the GDS proposal at Wisconsin Avenue's elevation.

Since the low-rise school was much lower density than zoning would allow, GDS wanted to use a process called a Planned Unit Development (PUD) to shift density from the school, closer to single-family homes, and over to the dealership site on Wisconsin Avenue.

The project would have added 270-290 housing units, 22-29 of which would have been permanently affordable. Plus, it offered 38,500 square feet of retail, a pocket park at Elliott Street, a spectacular public staircase, and a 42nd Street redesigned with state-of-the-art traffic calming features.


Traffic calming on 42nd Street. The school is at the left and the mixed-use buildings at right.

The only complication: The zoning would have to be changed from a lower-density commercial zone, C-2-A, to a slightly denser one, C-2-B. The same change was successfully made across the street in 1999, for a project called Tenley Hill. That project's penthouse is actually 7'6" higher than these buildings would have been.

You can read the full PUD submission and an amendment.

The project gets positive reviews but some "height-itis"

Reactions to the project among community members were mostly positive, but two groups of neighbors expressed concern about the scale of the project, "Neighbors of GDS" and the "Wisconsin Avenue Gateway Group," whose leaders live in the Tenley Hill building. Supporting GDS's project were the longstanding smart growth group Ward 3 Vision and a new group called "Revive 3E," which formed to specifically focus on what members felt was obstruction in the local Advisory Neighborhood Commission, ANC 3E.

The ANC repeatedly expressed support for upzoning of the site, but dithered over whether the package of amenities and mitigation was adequate, demanding an detailed Transportation Management Plan, including a request that no new vehicle trips arrive at the site. The ANC's chair, Jon Bender, openly questioned whether alternative arrangements could fit more residential uses onto the school site.

The big sticking point, however, was the height of the buildings. The zoning change would have let both buildings rise 80 feet from Wisconsin Avenue. Because 42nd Street is down a steep hill, one would have been 86'3" on 42nd Street and the other maxed out at 97'4" adjacent to GDS's high school building.


Height of the school (left), north residential building (center), and across Wisconsin (right).

Office of Planning blocks the project

This week, there was a new surprise: DC's Office of Planning also took issue with the height.

To do a Planned Unit Development, a property owner first applies to the Office of Planning, which then recommends, or doesn't recommend, DC's Zoning Commission "set it down" for a hearing. As GDS's head wrote in a letter to the Northwest Current, OP expressed opposition to setting down the current proposal.

Why the Office of Planning opposed the project is not public knowledge. Once a project is set down, the Zoning Commission schedules a hearing and OP, as well as other city agencies, file public reports with their comments. But because of OP's opposition, the school withdrew this version of its plans.

Some housing and the park are gone

GDS now wants to go forward with fewer floor on the southern building and two fewer on the northern one. It's not even the first height reduction. Critics of the project had asked for a 65-foot nominal height and GDS compromised from the original height, cutting two stories off last fall. Now, the building will be as short as critics requested.

Because of the loss of revenue from three floors, GDS can't afford some of the big-ticket benefits that brought in community support: the pocket park at the north end, the special public space finishes, and the traffic calming measures on 42nd Street.

It's still a fine project, but had the first submitted design been accepted, it would have made Tenleytown one of the most complete urban designs in the city, crossing the work and play of multiple generations of Washingtonians in a single space.

More importantly, this second reduction means a loss of another 50 potential apartments. On a micro-level, that's unfortunate in an area that has a large student population but few small apartments, leading many students to live in group houses that could otherwise hold families with kids. It also reduced the density that can support small businesses and restaurants. On a macro scale it's just another opportunity increase the aggregate amount of housing in the city, lost to the tastes of a vocal minority.

Sure it's only 50 here, but 50 at the next one, and so on, contributing to a deficit across the city. If the 2006 Comprehensive Plan is what's keeping this site from an appropriate level of density, then it's failing. If OP is talking of the need to build shelter for a growing city and reduce automobile use, but disqualifies GDS' modest mixed used density, then the talk of two biggest issues the city faces is just a gesture devoid of substance.

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