TESTIMONY: Silver Spring Downtown and Adjacent Communities Plan

November 30, 2021 

Montgomery County Planning Board 
2425 Reedie Dr, 14th Floor
Wheaton, MD 20902 

Item 8 – Silver Spring Downtown and Adjacent Communities Plan 

Testimony for December 2, 2021 

Jane Lyons, Maryland Advocacy Manager 

Thank you, Chair Anderson and Planning Commissioners. My name is Jane Lyons and I’m testifying on behalf of the Coalition for Smarter Growth, the leading organization advocating for walkable, inclusive, transit-oriented communities as the most sustainable and equitable way for the DC region to grow and provide opportunities for all. 

We support the draft of the Silver Spring Downtown and Adjacent Communities Plan, although we believe there is room for improvement to think more strategically, creatively, and boldly about certain elements. In general, we are excited that the plan embraces downtown Silver Spring as the right place to grow, and to grow in a way that supports diversity, connectivity, resiliency, and health. 

Silver Spring is where people want to live — it is also the residential economic engine of the county. Housing is one of the key methods for Silver Spring to retain its diversity. However, this draft misses the mark on strategies to preserve existing income-restricted and market-rate affordable housing. The plan should use the department’s housing preservation study, which focuses largely on the plan area, to identify which properties are most at-risk and which tools would be most helpful to preserve the properties. 

Furthermore, this plan often discusses the redevelopment of publicly owned garages and parking lots and states a goal of 30 percent moderately priced dwelling units (MPDUs). We think this goal is not ambitious enough in its set-aside percentage or income targeting, and urge the Planning Board to look for creative models in neighboring District of Columbia and elsewhere for how to redevelop transit-oriented public land in order to maximize the amount of below-market rate units and deeply affordable units. In addition to this, publicly owned properties such as these are also a unique opportunity to try out new models for affordable housing, such as a community land trust. 

Next, regarding the adjacent communities included in the plan: The built form of the adjacent communities does not allow for a step-down transition with the high-rise buildings in the CBD and would benefit from gentle density, such as with three to five story buildings, connecting the CBD to lower density neighborhoods. We applaud the planners for considering allowing different housing types, but this underlying issue will not be addressed by only allowing buildings that are

“compatible with the surrounding development” in terms of height and massing. These properties are appropriate for more than just house-scale duplexes and triplexes. 

Also, this plan should not rely on the Attainable Housing Strategies guidelines for downtown Silver Spring’s adjacent communities because it is unclear when, and if, those recommendations will be formally adopted. We urge the Planning Board to think more boldly and creatively about what can be pioneered in this plan. 

Finally, in addition to these points, we would like to see the plan be more visionary for policies and programs to protect existing small businesses and help new ones to thrive, and to reimagine major arterial roads such as East-West Highway, Georgia Avenue, and Colesville Road. 

Thank you for your consideration. 

See below for our full, detailed comments on the draft plan: 

  • 2. Introduction 
    • 2.6. Plan Goals 
      • “Provide more diverse housing types and preserve existing affordable units to serve individuals and families of all ages, incomes, and backgrounds.” Not only should we preserve existing affordable housing, but also create more affordable housing. 
  • 3. Districts 
    • 3.2. Connecting the Districts 
      • 3.2.2. Green Loop 
        • We are intrigued by this idea, but would like more of an explanation on why a loop is the best design choice, as opposed to a grid, given that a grid generally is more efficient and improves connectivity better than a loop. 
        • This section would also benefit from an explanation as to how the Green Loop integrates with the already envisioned downtown Silver Spring bike network, as well as additional emphasis on the idea that the Green Loop bike lanes must be protected. 
      • 3.2.3. Connecting Across the Rail 
        • We are excited about the idea to have a new pedestrian connection over the train tracks. Accessibility for pedestrians and bicycles is extremely important. 
        • The Colesville Road (not Avenue) Metrorail underpasses would be enhanced by more frequent cleaning. 
    • 3.3. District Recommendations 
      • 3.3.1. Ellsworth District
        • The Silver Spring Shopping Center acts as the gateway for people visiting the Ellsworth District, but the shopping center’s parking lot provides an unwelcoming barrier. Redesigning the parking lot needs to be a priority. 
        • We are excited by the idea to redevelop the parking lot at the Whole Foods/Ace Hardware with a mix of uses, structured parking, and a green open space. 
        • In general, we would encourage higher FARs and heights allowed along the edge of the Central Business District (CBD). 
      • 3.3.2. Fenton Village District 
        • We concur with the recommendations regarding redevelopment of Safeway — this neighborhood must retain a full-sized grocery store.
      • 3.3.3. Metro Center District 
        • We strongly agree with the recommendation to have the highest intensity commercial development in the Metro Center District. This district has been underutilized for far too long. The idea to have a new landmark building at the Transit Center Development Site is especially desirable, and we concur that no parking should be provided given the site’s proximity to multiple modes of high-quality transit. We would like the county to encourage, partner, and prioritize space in this future development for child care. 
      • 3.3.5. South Silver Spring District 
        • This is clearly the district with the most opportunity for redevelopment and positive change. Within this district, we would like to see the plan also recommend making the Newell Street closure permanent and redesigning the intersection of East-West Highway, Georgia Avenue, and Burlington Avenue to prioritize the safety of pedestrians and cyclists. Newell Street’s closure has reactivated Acorn Urban Park in a way that is at-risk of being lost if the street is to return vehicular traffic. 
        • It is unclear from this document the specifics of The Blairs Master Plan, but similar recommendations regarding the continued service of a full-sized grocery story are similarly important for this location.
      • 3.3.7. Falklands District 
        • We strongly support the no net loss of market-rate affordable housing goal. 
        • Public open space on the north side of East-West Highway would be more welcoming if internal to the site rather than adjacent to busy East-West Highway and 16th Street. 
      • 3.3.8. Adjacent Communities 
        • In addition to our comments above, we would like to see more details on the envisioned renovations to Ellsworth Urban Park.
  • 4. Plan-Wide Recommendations 
    • 4.2. Housing 
      • In addition to our comments above, we would like to see the plan explore potential incentives for condominium development to create more homeownership opportunities. 
    • 4.3. Economic Growth and Resiliency 
      • The recommendation from Fenton Village to ensure buildings are divided into smaller components, instead of one large, monolithic structure, should be true of the whole plan area to allow for small businesses to thrive and better walkability in Fenton Village and beyond. 
      • We would like to see more creative thinking for policies, programs, and investments to ensure the future of small businesses in Silver Spring. 
    • 4.5. Parks, Trails, and Public Spaces 
      • For Jesup Blair Park, wouldn’t it be better to have the food truck zone near a social zone, rather than a contemplative zone? 
      • We will reiterate our strong support to permanently close Newell Street to vehicular traffic and expand Acorn Urban Park. Even with the new South Silver Spring Urban Recreational Parklet planned, an expanded Acorn Park is desirable for this rapidly growing neighborhood. 
    • 4.6. Transportation 
      • 4.6.2. Bicycle Network Recommendations 
        • We are glad to see the plan talk about bicycle parking, but more needs to be done to identify where more bike parking is needed. 
      • 4.6.4. Transit 
        • Glad to see dedicated bus lanes along Colesville Road and Georgia Avenue included 
      • 4.6.5. Roadways 
        • This plan should do more to reimagine East-West Highway, Colesville Road, and Georgia Avenue as safe, green, multi-modal boulevard. 
        • We support the construction of new streets with the purpose of improving connectivity. Any new streets should be built with adequate pedestrian and bicycle facilities. 
      • 4.6.6. Parking and Loading 
        • We support a constrained parking policy that supports an urban area well served by transit. It is unclear from the text whether Silver Spring has parking minimums, but if so they should be removed in support of this policy. 
        • The plan should offer a vision that public parking in Silver Spring be priced at market-rate so that the parking of private vehicles is not publicly subsidized. 
      • 4.6.7. Transportation Demand Management
        • We encourage the Planning Board to set an even more ambitious goal for Non-Auto Driver Mode Share than 55 percent, which has already been achieved and would only continue the status quo. 
    • 4.7. Resilient Downtown 
      • We urge you to include improving stormwater management and reducing flooding risks as a goal in this section. Furthermore, the plan should state specifically where improved stormwater infrastructure should be prioritized, similar to the maps showing ROW priority tree planting areas. 
    • 4.8. Community Facilities 
      • Over the next 20 years, downtown Silver Spring should strive to be more welcoming by offering public restrooms across the plan area. 
      • We are excited by the prospect for a public school in downtown Silver Spring through redevelopment of public parking garages and conversion of office space. 
    • 4.9. Historic Resources 
      • We support the adaptive reuse of the parking lot at the corner of Georgia Avenue and Colesville Road. 
  • 5. Implementation 
    • 5.1.1. Silver Spring Downtown Building Height Incentive Zone 
      • We support the Silver Spring Downtown Building Height Incentive Zone generally, but would like to see more specifics. It should be clear that developers’ contributions to the Connectivity and Infrastructure Fund (CIF) are not meant to fund all improvements listed. The county should primarily make these public infrastructure investments to improve quality of life and make Silver Spring more desirable. 
    • 5.1.6. MPDU Minimum Percentage 
      • We support the recommendation to increase the base MPDU requirement for the plan area to 15 percent.