Over five meetings of the Parking and Loading working group, citizens gave their input on how much DC’s zoning code should require parking lots or garages in new development, where parking can be located on a lot, how many trees parking lots need, what bike parking is mandatory, and more. And last week, the Office of Planning released a draft of the new rules which they’ve allowed me to post.
Here’s the draft of the zoning rules.
Here’s Nelson\\Nygaard’s (the consultants) memo summarizing policy recommendations.
Overall, this is a huge step in the right direction, though I feel that it doesn’t go far enough. Of course, there are people like Barbara Zartman who think it goes much to far.
My detailed analysis is below. But first: the next step for this draft is to go to the Task Force, composed of reps appointed by each Councilmember and some representing established organizations (mostly anti-change groups). If we’re to win meaningful reform, we’ll need a lot of citizens writing these task force members (and, later, the Council itself) to make sure they realize that the small but loud group of NIMBYs is not representative of Washingtonians.
On to the details of the plan…
P.2.1 has the meat of things, the minimum requirements. Only the zones listed would have minimums under this draft; everything else would not, which is an enormous improvement from the current rules which mandate a minimum for everything. I think that there should be no minimums at all—if a developer feels parking is necessary, they’ll build it, and if they don’t, then we shouldn’t require it.
The R-1 and R-2 minimums supposedly came from the Task Force which wanted to preserve ample parking in low-density areas. This will basically have the impact of impeding walkable corner stores, because any store will need parking. Likewise, keeping the requirement in C-2s (the neighborhood retail corridors) will ensure that policy continues to make driving an appealing alternative. As long as these requirements exist, these corridors won’t grow into pedestrian-oriented centers.
I’m particularly disappointed in the rule that any multi-unit residential building requires 1 space per 3 units if it is within 400 feet of a low or moderate density residential zone. Since moderate density goes all the way up to R-5-B, which encompasses dense row house neighborhoods like Dupont Circle and Logan Circle, and since 400 feet is an entire block or more, the vast majority of the city would be subject to this rule. Dupont, for instance, has many row houses that have been converted to 3 or 4 apartments but have no parking, and the 4-apartment houses would require two spaces. My current building has 13 units and no parking, and would require 7 spaces. These requirements would maintain the status quo that row house neighborhoods could not be rebuilt as they are today unless they are designated “transit-oriented districts” (see below).
Still, many parking requirements are gone. Retail developments in high density areas no longer require parking. Same for hotels and offices outside residential districts. And in some of the highest density residential districts that aren’t near row houses, even apartment buildings won’t require parking.
One factor in the Nelson\\Nygaard report and from the working group discussions didn’t make it into the draft rules: transit-oriented districts. The group agreed that if a district is designated as transit-oriented, then no minimums should apply at all. This could potentially relieve many of my objections, but that depends on two factors: first, that the right districts are designated as transit-oriented, and second, that the designation does indeed eliminate minimums. Right now, there’s nothing in the regulations that says this, which means that in the future, whatever law might be passed to designate districts would also bring out many people arguing to keep some minimums. And I’m not confident in the fortitude, or even the desire, of the Council to entirely eliminate minimums in this case.
I’ve encouraged the Office of Planning to include language in these rules that clarifies no minimums for transit-oriented districts. With that, the only debate would be around which are designated. Georgetown might not be, meaning it would keep too-high minimums. But areas like Dupont Circle and U Street almost surely would. Then, the question would become whether to designate areas served by future streetcars, like H Street; buses but not Metro, like Georgetown or Logan Circle; or farther-out areas that ought to become transit-oriented in the future, like Benning Road or Fort Totten.
The draft language calls for parking maximums, but doesn’t specify what they are. This means that the Task Force or the Zoning Commission will have to specify these, and who knows what they will decide. The same transit-oriented objection applies as well—if an area becomes designated transit-oriented, will maximums start to apply? The working group agreed they would, but this is just going to become a future political fight.
The too-high (but still a big improvement) minimums are offset by some important exemptions in addition to the theoretical TOD rules:
Shared parking. The draft allows “shared parking,” where two non-residential uses, like a bar and an office building, could get an exemption from parking requirements by signing an agreement that allows the office to use most of the parking in the daytime and the bar to use it at night. Today, most jurisdictions with minimum parking have most of the parking unused most of the time since they are planning for peak demand even when the peaks happen at different times of day.
Still, this also requires a study to show “no negative impacts,” which means that the sharing agreement has to completely satisfy all of the parking demand that would be satisfied with entirely separate parking, and “the uses have different time and day requirements,” which makes sense as long as “different” doesn’t mean “completely different”: would the office building have to be completely closed by the time the bar opens? What about the office sharing with a store that gets most of its business at night, meaning it needs little parking during the day, but which is open all day? Does that count as “different”?
In-lieu fees. A development can automatically get out of 50% of its requirements as long as it pays a fee to a DDOT transportation fund to offset the loss of parking. This money could become a significant source of revenue to enhance the non-driving experience in the city, as the performance parking revenue should be in Columbia Heights and the Ballpark district.
Parking Lot Design
The new rules also include some key improvements to the way parking lots are designed and sited:
Location. Under the draft rules, parking lots cannot be located between the building and the street. On a building that’s not a corner lot, the parking has to go behind the building; it can no longer go on the side. And on a corner lot, it has to go on the side that’s behind the building when you are facing the building from the larger of the two streets. This is a great improvement.
Allowing mechanical parking. Mechanical garages are used in many places around the world to fit more parking into a smaller space by having machines store and retrieve the cars. DC’s current regulations mostly forbid this; the draft rules allow it.
Trees and landscaping. Parking lots that are just a sea of pavement are terrible for the environment and for aesthetics. They are impermeable to rainwater, so rainfall sweeps dirt into the rivers and drinking water (the stormwater runoff problem). Sunlight heats up the pavement creating “heat islands” that add to air pollution and air conditioning costs. The draft regulations have two options for requiring landscaping, including “canopy trees” which provide shade and dissipate the sun’s rays.
Coming up in a future post: the draft bike parking requirements.