June 11, 2019
Re: Resolution to Amend the 2016-2020 Subdivision Staging Policy (Support)
By Jane Lyons, Maryland Advocacy Manager
President Navarro and Councilmembers, thank you for the opportunity to speak today. I am here on behalf of the Coalition for Smarter Growth, the leading organization in the D.C. region advocating for walkable, inclusive, transit-oriented communities. We support current efforts to lessen the negative impacts of the Subdivision Staging Policy’s (SPP) housing moratorium and echo the need for affordable housing. However, we ultimately urge the Council to replace the moratorium with policies that better address the County’s school construction, housing, and economic development needs.
The 2016 SSP projected that the county would grow by over 200,000 residents between then and 2045, with 14 percent of land absorbing 82 percent of new jobs, 76 percent of new households, and 73 percent of population growth. Preventing new housing, especially mixed-use, mixed-income, transit-oriented, and affordable housing in efficient locations close with good transit, stifles the county’s ability to meet the housing needs of current and future residents, as well as to grow the local economy and maintain the county’s fiscal health. We can have a county that has both good housing and good schools for all of our residents.
Further, new medium to higher density development has not been a major contributor to student generation. Single-family homes countywide generate almost double the number of students that multi-family homes generate, and single-family home turnover is the primary factor driving school population increases. Finally, school impact taxes paid by new development provide more than the total cost for each projected generated student. Medium to higher density development also provides significant property tax revenue. It does not make sense to punish new development that the county needs for impacts it does not cause.
For these reasons, we ask the Council go further to address the harm that the moratorium brings. Today’s resolution is an important first step to mitigating the harmful impact of the moratorium on affordable housing supply. However, the stringent requirements of the resolution are likely to help just one current housing proposal, the transit-oriented 850 Sligo Apartments in Silver Spring. Other important transit-oriented new housing developments, like Strathmore Square, are left in moratorium for at least another year, limiting the number of units that are being approved at this time. We’ve also heard that the uncertainty and potential limitation on buildout caused by the moratorium can put the private financing of projects like Strathmore Square at risk.
There are many alternatives to the moratorium for the Council to consider, including:
- Reinstating school facility payments in overcrowded clusters, while maintaining the current school impact tax. This would allow development to continue, but impose a slightly higher cost to do so. As clusters and individual schools became more overcrowded, the county could require a corresponding increase in school facility payments.
- Aligning the timelines of the CIP and annual school test. While the Capital Improvements Program (CIP) includes projects six years into the future, the annual school test in the SSP only looks at the next five years. This means that even if there is a project in the sixth year of the CIP that would remedy overcrowding, that school or individual cluster could still go into moratorium. To address this, the annual school test should consider projections six years into the future.
- Taxing teardowns more substantially. Teardowns do not currently pay impact fees, even though they are new construction and new families moving in can be expected to generate new students. This might also reduce the “mansionization” of our communities, which turns formerly modestly-sized homes into much larger homes, housing a similar household size.
- Exempting Metro Station Policy Areas from the annual school test. Building more homes, especially affordable homes, near transit is necessary for a sustainable future. We cannot afford to miss out on opportunities to grow in a more walkable way. Businesses and residents are looking to locate in more transit-oriented communities.
- Redistricting school boundaries. Although education policy is not our specialty, we encourage those who are experts to make more substantive recommendations on this topic. Redistricting has the potential to relieve overcrowding, as well as further goals of socioeconomic and racial integration.
- Reviewing school design standards. If schools are designed to occupy a smaller footprint by being three stories instead of one, or integrated into mixed-use development, and if playing fields can be shared with recreational centers and parks, then it might be easier to find sites for new schools.
- Pushing forward the 2020 SSP effective date to June 2020. The current timeline for the SSP update is November 2020, well after the next annual school test in July 2020. Changes should be made to the SSP by June 2020 to avoid another year of moratorium restricting the housing supply and economic development.
These are our suggestions to consider, but we strongly urge the Planning Department to offer other alternatives to the housing moratorium policy. Montgomery County can have great schools, plentiful housing, and a strong economy, but we must have policies that support that future. We look forward to being a part of these conversations throughout the 2020 SSP process. For now, this resolution is a first step.
Thank you for your time.