June 12,  2023

Hon. Jolene Ivey
Chair, Planning, Housing and Economic Development Committee
Prince George’s County Council
1301 McCormick Drive, Wayne K. Curry Administration Building
Largo, MD 20774

RE: CB-052-2023 – Oppose; recommendations for a different approach; suggested amendments

Dear Chair Ivey: 

Please accept this letter on behalf of the Coalition for Smarter Growth (CSG). CSG is the leading non-profit 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. 

Please accept these as our revised comments. While we oppose CB 52 as not the right approach, we wish to express our support for the concern expressed in the bill in terms of ensuring residential growth is directed to the right locations. We find the singling out of townhouses for blame unjustified when permissive single family zoning across vast acres outside the beltway “established communities” are the underlying problem. Most of the land outside the beltway is zoned for low density housing, causing growth and additional demand on urban infrastructure, and robbing reinvestment resources from existing communities. We have also read and concur with the issues and concerns raised by the MNCPPC-PG staff report regarding CB 52. Therefore, we recommend a different approach to achieve key goals stated in the bill. 

Plan 2035 is not achieving its goal to allocate most growth to Regional Transit Districts and Centers. Too much growth is going to areas of the county with inadequate transportation and other services, increasing traffic and other impacts. In part, this is the result of the numerous inappropriate zoning text amendments approved by prior County Councils for higher density residential development in areas of the county not intended for this level of growth. A key step would be to halt further such ZTAs, which the Council is doing. 

However, the underlying zoning of most of the county is low density residential, which generates costly urban infrastructure demands that are inefficiently spread out over long distances. Single family detached zones account for 27% of the county’s land area, and more than 76,412 acres. Much of this single family zoning is outside the beltway. To address this underlying problem, we recommend that, in addition to the recommendations in the Planning Board staff report, the county directly address the permissive residential zoning which is allowing too much growth in rural areas and “established communities” outside the beltway where residents will be far from transit and many services. Too much land is zoned for low density residential development. Most of the land outside the beltway should be zoned for truly rural/agricultural densities. See the attached population and jobs density map. This map is a good starting point for designating places for infill and future growth, and areas where we should not encourage growth, and those costs associated with it that pull resources away from older communities. 

We recommend that the Council work with the Planning Board to assess significant portions of areas outside the Capital Beltway where residential zoning could be limited to the Reserved Open Space (ROS) Zone, which provides for a 1 dwelling unit to 20 acres zoning density. At this density, we can preserve both agricultural uses for local food production and more continuous forests which will help protect natural areas and water quality. We also recommend discontinuing “Future Water and Sewer Service Areas” and rezoning these areas to ROS. 

At the same time, we recommend reviewing and revising residential and mixed use zones inside the beltway to facilitate a variety of housing types including townhouses, but also different types of multifamily housing, accessory dwellings, and other missing middle housing types, with greater densities focused closer to transit stations and bus corridors. The county should focus future water and sewer service investments on inside the beltway existing communities rather than expanding service to future areas.

CB 52 would misguidedly ban townhouses inside the beltway that are not inside the boundaries of one of 8 Regional Transit Districts or 26 Local Centers. See the attached map – Appendix B Map of Transportation Service Areas – that shows the size of the transit districts (purple) and centers (green), which make up a small portion of the county’s land area, including inside the beltway. CB 52 also bans townhouses in townhouse zones, such as townhouse zones near the Largo Metro station, but outside the Regional Transit District Boundary. All together, these severe restrictions on one housing type would harm would-be residents from attaining a home that could be in their price range, in a location that gives them access to the region, and is supported by existing public service investments.

We also urge the council to work with the Planning Department to conduct an assessment of impediments to achieving the planned growth in Regional Transit Districts and Centers, and the role of moderate and middle density housing types, including townhouses, especially inside the beltway, in achieving housing, TOD, and climate goals.

If CB 52 advances, we recommend that townhouses be permitted generally inside the beltway, rather than limited to the boundaries of Regional Transit Districts and Local Centers. CB 52 should also allow existing townhouse zones to permit townhouses. Higher density Regional Transit Districts and Local Centers should have multifamily buildings at the core, while townhouses could be an appropriate housing type at the edges. More broadly, we should encourage more townhouses and moderate to higher density housing inside the beltway, and around centers, while reducing the capacity for single family developments in areas without sewer and water or proximity to other public infrastructure. To refine this change requires detailed study by the Planning Department in collaboration with the council and executive. The attached maps, however, indicates where to start. 

Thank you for your consideration. 

Sincerely,

Cheryl Cort
Policy Director

Map credit: D.W. Rowlands, 2021