Comments on Proposed EYA Development at Takoma Metro Station, Washington DC

25 October 2006

Ms. Debra Johnson, Secretary
WMATA
600 Fifth Street, NW
Washington, DC 20001

Re: WMATA Public Hearing #175 on Proposed EYA Development at Takoma Metro (Docket No. R06-5)

Dear Ms. Johnson:

The Citizens Planning Coalition (CPC) wishes to submit written testimony on the above-referenced matter.

CPC is committed to the principles of mixed primary uses, as laid out by Jane Jacobs more than 40 years ago, in the classic urban studies tome Death and Life of Great American Cities. Related principles include intensification of land use adjacent to high-capacity transit, and an emphasis on alternatives to automobile-based mobility. At the same time, CPC is committed to the preservation of historic building stock and open space, as well as promoting and extending the use of transit more generally.

The proposed development at Takoma Metro offers incredible opportunities that appear, for the most part, to be wasted, according to the plans that have been submitted by the developer, plans that WMATA appears to find worthy of approval.

This is a mistake.

1. It makes little sense to develop townhomes on land immediately adjacent to the subway station, as this is a relatively unintense use of land. The roughly 90 houses would yield maybe 180 residents, which totals maybe one subway car's worth of riders for an average day.

2. It makes even less sense to promote automobility via the sale of WMATA land resources. According to the plans as submitted, most of the townhomes would have two-car garages.

Promoting automobility immediately on top of a WMATA subway station is short-sighted and seems to be a massive failure of vision. Transit-oriented development should promote transit. Development at transit sites that promotes automobile-based mobility is anachronistic, and seems counter to WMATA transit promotion objectives. In any case, such development can not be called "transit-oriented." At the very best, it should be termed "transit-adjacent development," but such is hardly beneficial to transit promotion.

3. CPC recommends that WMATA adopt a transit-first development policy generally, which should guide development plans for this and other similarly situated land parcels in the WMATA land inventory.

The City of San Francisco adopted a "transit first" development policy decades ago. For the most part this means that new development in the downtown core has been built without parking, but with access to efficient transit.

Moving to a "transit first" land use and development paradigm

Most citizens and government agencies are imprinted with an approach to land use that is automobile-centric and oriented towards segregated, relatively undense uses. This is commonly referred to as a suburban-oriented land use and development paradigm. Stakeholders have an unconscious and systematic bias towards "automobility" and improving the transportation system for automobiles, at the expense of transit and pedestrian capacity, and urban design.

The suburban land use approach is particularly inappropriate for center cities generally, and Washington specifically, especially because the city is so well connected by transit, in particular the subway, and relatively efficient bus service throughout most of the city, and because of the importance of leveraging the tremendous public investments that have been made in building and maintaining this system. (Note that the polycentric design of the WMATA subway system is criticized because it promotes sprawl even more than it improves access to and within the center city.)

A "transit-first" policy would establish and emphasize that the basic framework of how the City of Washington should grow is through the linkage-articulation of land use and transit. Intra-city and regional mobility can be improved and congestion reduced by investing in the capacity of our transit system, and by linking land use policies to these investments.

Furthermore, every parking space is an automobile trip generator. We cannot simultaneously expand parking and reduce congestion. The concept of induced demand presented both by parking spaces and roads is well understood throughout the transportation planning profession.

WMATA, as a transit agency, should not be in the business of promoting automobility, especially through its land development and disposition practices.

An illustration of how San Francisco's "transit first" development policies work in practice

According to the article "If you build it, will they take the bus? San Francisco builds an epic mall, with no parking," published in the Austin American-Statesman on Sunday, October 22, 2006, San Francisco's downtown growth management policy, adopted in 1985, for the most part, forbids the creation of parking spots when new development is constructed.

The article discusses the Westfield San Francisco Centre, which was just expanded, tripling the square footage to 1.5 million.

According to the article:

San Francisco's Westfield mall doesn't even have a parking lot. The nearest parking is across the street at a city-owned lot that also serves the Moscone convention center and other attractions. It can hold about 2,600 cars. Officials expect about 68,500 people a day on average, or about 25 million a year, will visit the mall. That works out to one parking spot for every 26 mall shoppers....

The mall also is in the middle of one of the biggest hubs for public transportation outside New York City. More than 30 different public transit sources are within a few blocks of the mall, including the Powell Street terminus of the city's famed cable car line, several stops for the Bay Area Rapid Transit subway system, and stops for municipal trains and buses.

4. A suggestion for how to apply a "transit first" policy to the Takoma Station development site: build a multiunit building with no parking whatsoever.

Many people suggest that choices be offered to house-buyers, yet true choices, especially a choice of not having to pay for a parking space, are rarely offered. Most new housing units come with parking. DC Zoning regulations provide for the most part (with some exceptions allowed for new housing constructed in historic districts) that at least one parking space be provided for every new unit of housing.

The concept of the location efficient mortgage, pioneered by the Center for Neighborhood Technology in Chicago, makes the point that households in close proximity to high-capacity and frequent transit are able to use transit rather than automobiles, thereby allowing more of the household revenue stream to be directed to housing costs, ideally towards ownership.

There are many people in the City of Washington who do not own cars. According to the most recent data from the U.S. Census American Community Survey, almost 40% of DC households do not own cars.

Why not provide a housing option for similarly-minded people--those who want to live in the city, who do not wish to own a car, who wish to live in proximity to convenient transit? The Takoma site offers access to the Red line subway, is one station stop north of a connection to the Green line, and is served by Metrobus and RideOn bus service. (It is also one stop from Silver Spring, which provides access to the MARC Commuter Railroad system, and is five stops from Union Station, with MARC, VRE, and Amtrak connections.)

Instead of building houses for cars with the townhome proposal, build more housing for people, by directing the construction of a multiunit, denser building, with more housing units overall.

This should provide more riders for both subway and bus service in the Takoma area, which might allow for an increased frequency of the bus services, given the generation of a greater number of riders.

The District Government's "stretch goal" of attracting 100,000 new residents is based on the fact that much of the city's property and a significant number of transactions in the city are not taxable because of the presence of the Federal Government and a wide variety of nonprofit tax-exempt organizations that have located in the city to leverage access to the Federal Government.

More housing will yield more residents to the District of Columbia, and therefore more property tax and income tax revenues, which comprise the greatest source of DC Government revenues.

Hence, a "transit first" policy with regard to the Takoma WMATA-owned development site would achieve multiple positive public policy outcomes.

5. One of the concerns expressed by Takoma area residents is that the construction of housing on the station site will reduce the number of parking spaces available to riders. Parking could be accommodated within a multiunit building but directed almost completely towards short-term and intermediate-term spaces for transit riders, as well as to visitors to the commercial districts of Takoma Park in Maryland and Takoma in DC. Visitors could park in this space and then make their way around on foot.

To accommodate occasional need for access to cars on the part of residents of the proposed multiunit housing alternative, some spaces could be allocated to carsharing services, and the building could negotiate priority membership privileges with these services. Otherwise, given the recommendations above, no parking spaces should be allocated to residents of the proposed multiunit building alternative suggested herein.

Note that many residents of the new multiunit housing constructed east and west of the Takoma Station do not own cars. Attraction of similarly minded new residents would be extended by the provision of new multiunit housing constructed without any residential parking (other than access to carsharing).

6. Open space concerns expressed by Takoma area residents should be acknowledged. A denser development, without parking, would allow for the retention of more open space.

7. However, urban design considerations would suggest that such space be reconfigured in part to allow for the strengthening of the streetwall and streetscape between the Station and Takoma Park, Maryland as represented by the relative activity vacuum created by the open space immediately abutting Carroll Avenue.

This could provide an additional revenue opportunity to WMATA, if instead of selling one parcel for a relatively insignificant amount of money by selling to EYA; that the parcel be split into two different segments: (a.) a site suitable for a multiunit single building of housing, likely on the parking lot; (b.) some amount of land immediately abutting Carroll Avenue.

8. The provision of quality bus service should be maintained. Although it is believed that this can be accommodated through better configuration of bays and management.

9. "Transit first" policies also promote pedestrian and bicycle mobility in addition to transit. CPC does not favor the proposed reduction of bicycle parking at the Takoma Station, which appears to be heavily used, perhaps at a level even greater than that of Union Station or College Park. Additionally, CPC suggests that opportunities be explored for providing additional exits off the platform, perhaps providing access to the west side of the railroad tracks (egress is provided solely on the east side currently).

Thank you for your consideration of these comments.

Respectfully submitted,

Index Keywords: transit; urban-revitalization