January 30, 2024

Mr. Anthony Hood
Chairman, Zoning Commission of the District of Columbia
441 4th Street, NW, Suite 210S
Washington, DC 20001

RE: Support with amendments for Z.C. Case No. 23-17 (Office of Planning – Proposed Text Amendment to Reduce Parking Requirements for Publicly Assisted Affordable Dwelling Units)

Dear Chairman Hood:

Please accept this testimony on behalf of the Coalition for Smarter Growth, the leading organization advocating for walkable, bikeable, inclusive, transit-oriented communities as the most sustainable and equitable way for the Washington, DC region to grow and provide opportunities for all. 

We wish to express our support for Case No. 23-17 in two ways. 

1. We support the recommended text amendment to reduce parking requirements for publicly assisted affordable dwelling units near transit, though we urge the commission to revise upward the threshold for relieving small projects of a parking requirement burden to 50 units rather than the 40 units proposed. 
2. We ask the Zoning Commission to take a more significant step by eliminating parking requirements for affordable housing units, at least near transit.

Below, elaborate on these two points. 

1. Raise threshold to 50 affordable units

We appreciate the Office of Planning’s consideration of appropriate parking requirements for affordable housing. The 2016 zoning revision made significant changes that reduced the burden of parking requirements through generally lower levels, a 50% reduction near major transit service, and targeted exemptions for situations such as single family lots without alley access. Further, substituting the special exception process for the more onerous variance process, allowed the city to address unique circumstances where the rules recognized many good reasons for exceptions to parking requirements. Thus, far fewer projects have grappled with parking requirements that are too burdensome for the specific project purpose, market, or site conditions. 

Nevertheless, affordable housing is still very difficult and costly to build, so providing additional relief to unnecessary impediments is always helpful. Within the limited scope of OP’s proposal, we recommend providing more accommodation for smaller lot and smaller-sized projects. After discussion with affordable housing developers, we conclude a better number is 50 units rather than 40 units for the upper threshold. Smaller lots in typical development scenarios fall in a 40 to 50 unit range. Thus 50 units would be a better upper threshold if the purpose of this threshold is to relieve the burden of parking requirements for smaller, highly constrained sites and projects.

2. Remove parking mandates altogether for affordable housing units in transit-accessible areas

Our second recommendation is to take a more decisive approach to supporting affordable housing by removing the mandate for parking altogether for transit-accessible affordable housing. A greater affordability benefit can be realized by allowing the housing provider to determine the optimal number of parking spaces for the households to be served by the project given all the conditions of the site and characteristics of the intended beneficiaries. 

While the special exception process supports reducing parking, this process is an added burden and risk for affordable housing developers. Instead of this burden, we ask the Zoning Commission to permit the housing provider to determine the appropriate number of parking spaces to be based on specific conditions of the site, the purpose of the project, and other characteristics that are difficult to know from a citywide regulatory perspective. 

Requiring more parking than warranted for affordable housing projects can make them financially unviable and reduce the affordable housing we can produce. Removing parking requirements better supports the affordability goals in the Comp Plan. It eases the process for building more affordable housing, and ensures it’s less costly to build. 

One note on community comments – while no comments were filed in this case 23-17, in 2021, the OAG filed a parking requirement reduction case for affordable housing. The current case by Office of Planning proposes changes as a direct result of that case. In that case, ZC No. 21-22, nearly two dozen people submitted testimony in support of the broader proposal by OAG to eliminate parking requirements for affordable housing. We suggest these comments be considered in this case. 

Thank you for your consideration.

Sincerely,

Cheryl Cort
Policy Director