CSG Comments in Support of Expanded Housing Options in Arlington

March 15, 2023

Arlington County Board
Ellen M. Bozman Government Center
2100 Clarendon Blvd
Arlington, VA  22201

Re: CSG Supports Expanded Housing Options in Arlington

Dear Chair Dorsey and Board Members:

Please accept these comments on behalf of the Coalition for Smarter Growth (CSG), the leading organization in the DC region advocating for walkable, inclusive, transit-oriented communities as the most sustainable and equitable way for the Washington, DC region to grow and provide opportunities for all. We commend Arlington’s long record as a trailblazer in smart growth, record of careful analysis, and extensive public consultation they’ve undertaken as part of the Missing Middle Study. CSG writes to convey our support for the proposed expansion of housing options and provide feedback on the different options.

Arlington is centrally located in close proximity to Washington, DC and large concentrations of jobs in DC, in the Rosslyn-Ballston and National Landing transit-oriented centers, and Tysons. Providing more housing close to these major job centers where people can have much shorter commutes, drive less, and use transit and bike more, is a more sustainable way for our region to grow. Reduced vehicle miles traveled contributes directly to reducing greenhouse gas emissions from transportation at a time when we need to use every tool in our toolbox to reduce emissions. Arlington households drive about half as much as those in outer suburban locations where many residents are being pushed due to the lack of housing options closer in. In addition, housing units that share walls generally use less energy for cooling and heating due to shared walls.

Yet, Arlington County faces a housing affordability crisis for middle-class and lower-income families, with too little supply and very few ownership options in many communities beyond single-family homes. Staff analysis shows that exclusionary zoning was initiated in the 1930’s when non-single family detached homes were zoned out. The effects of this are still evident today with nearly half of the county’s land area restricted to single-family detached dwellings, according to staff analysis. Recent data from the HAND Housing Indicator tool indicates homeownership rates in Arlington are currently 19% for Black families and 31% for Hispanic/Latino families in contrast to 50% for White families.  

Arlington’s proposed expansion of housing options will make the county more inclusive by dismantling exclusionary zoning and offering opportunities for more housing types at lower price points in communities with great schools, jobs, needed services and amenities. Notably, the missing middle housing could be attainable for up to 39% of Black or African American households, 39% of Hispanic or Latino households, and 60% of Asian households in the Washington region, according to county analysis.

The Partners for Economic solutions analysis of financial feasibility shows that the economics of missing middle housing is not likely to create massive transformation of communities. This should assuage fears of drastic neighborhood upheaval and indicates more gradual adoption of missing middle models.  

Expanded Housing Up To 6 Units

CSG supports the county’s proposal for expanded housing options up to 6 units. In response to community concerns, the county has eliminated the 7-8 unit options. It is important that the 6 unit option be maintained to ensure the opportunity for more lower priced units and allow missing middle housing types to be more attainable to moderate-income families. Reducing the number further will make the price of those units more expensive, and undermine the intent of providing housing options at lower price points. 

The zoning requirements for missing middle housing types is closely tied to that of new single family homes so this puts all types of housing generally on the same playing field.  

Lot Size and Transit Accessibility

CSG supports option 2C allowing up to 6 unit buildings on transit accessible lots (¾ mile from Metro stations, ½ mile from premium transit, and ¼ mile from primary transit) or on properties greater than 10,000 sq. ft. This encourages expanded housing options closest to transit while still providing greater equity by allowing additional options on larger lots.


Parking mandates increase housing costs, increase paved surface, and encourage car-dependency. CSG supports option 5c allowing no parking minimum for lots near transit based upon the quality of the transit (¾ mile from Metro stations, ½ mile from premium transit, and ¼ mile from primary transit). Additionally, we support option 5E that would not require off-street parking if only one spot is needed and would require the addition of a curb cut to put in a driveway. 

Expanded Housing Option Caps

Providing more housing types in the county is the goal and therefore should not be capped. Not capping the production of missing middle housing types would provide the greatest opportunity for these housing types to be built in the county. If the Board deems a cap necessary, we recommend including the shortest sunset. 

Lot Coverage

All of the expanded housing types would have the same lot coverage requirements as single family homes including height, footprint, lot coverage, setbacks. CSG supports the option 4B that missing middle housing types can use the additional 5% coverage offered for a garage towards the building if no garage is being built, allowing additional space for people instead of car storage.

Gross Floor Area 

CSG supports staff’s recommendation for a combination of options 11A and 11B, which would be: Duplexes 4,800 sq ft., semi detached 5,000 sq ft., townhouses 7,500 sq.ft, and Multiple-Family: 3 units 6,000, 4 units 7,200, and 5-6 units 8,000 sq ft. We agree with the staff that this will:  1) incentivize housing options with more units by increasing the gross floor area as the number of units increases, thus supporting goals for increasing housing supply; 2) encouraging modest-sized individual dwellings within a building, thus supporting lower cost options; and in limiting the total size of the building, thus supporting neighborhood compatibility priorities.


Missing middle housing will be subject to the new stormwater regulatory program and will be on par with single family homes. Flood Resilient Arlington’s Land Disturbing Activity 2.0 upgraded the regulatory program for single-detached homes to improve on-site stormwater management, with increased emphasis on stormwater quantity and system-scale investment in major new stormwater facilities. There is also ongoing work on design guidelines to facilitate more flood resilient redevelopment on properties subject to higher risk of flooding and a Risk Assessment and Management Plan, including climate projections, inundation maps, risk and vulnerability analyses, costs of inaction, and mitigation and adaptation strategies. 


The proposal rightly requires shade trees to be provided as part of expanded housing options. CSG supports option 6A requiring a minimum of 4 shade trees for 2 to 4 units buildings, and 8 shade trees with 5 or 6 unit buildings. Staff indicates this would bring the missing middle housing closer to the 20% required for single family homes rather than the 10% to 15% Chesapeake Bay standard. Currently, 8 trees are required for single family homes only for lots of 14,000 square feet or more. With 5 and 6 unit missing middle housing types, 8 trees would be required for developments on smaller lots than that.

In addition, the county is working on a Forestry and Natural Resources Plan(a preliminary draft recently released) and is expected to be proposed for adoption as the twelfth element of Arlington’s Comprehensive Plan. The draft plan identifies numerous recommendations for tree conservation, for studying lot coverage and building placement requirements, and for leveraging special exception development review to meet forestry and natural resource goals.

In summary, CSG supports Arlington County’s expanded housing options that offers to create more inclusive, sustainable communities by allowing more people to live near their work, providing access to opportunities for their families, and contributing to a diverse and vibrant community. 

Thank you for your time and consideration of our comments. 


Sonya Breehey
Northern Virginia Advocacy Manager

Stewart Schwartz
Executive Director