Open letters

I’m not about to fall into the essentialist trap and say that “drivers here are obviously different,” but I don’t remember having to watch out for sudden U-turns before biking in traffic in DC. Sometimes, I see a few sudden U-turns within the span of traveling just a few blocks. I’ve long thought that U-turns are best avoided (better to just go around the block); evidently this is a locally learned behavior, as local laws vary.


A letter sent to Council in December in response to a CSG action alert:

I’m writing to urge you to support DDOT’s plans to launch a Performance Parking trial program in the Gallery Place-Chinatown-Penn Quarter area, adding to the three successful trial areas that already exist in Columbia Heights, the Ballpark District, and the H Street NE Corridor.

By way of introduction, I am a researcher and writer on urban planning topics who has had articles published by journals like the prestigious Transportation Research Record. I am also a frequent visitor to the Gallery Place-Chinatown area — it’s the nearest retail center to my DC home and since I volunteer at one of the area’s museums. Not only that, but three generations of my family have called DC Chinatown home, and my family continues to gather in Chinatown for special occasions. I have also used had the pleasure of using Performance Parking in four cities — Los Angeles, Pasadena, San Francisco, and, yes, the District of Columbia (around Nationals Stadium). My experience has been uniformly excellent across the board.

Results from these cities are unanimously clear, and unanimously positive:
– Lower prices for parking on average
– More customers
– Less time wasted in traffic
– Less traffic from those circling for parking
– Fewer distracted drivers and safer streets
– Less double-parking, and thus less congestion
– Fewer aggravating parking tickets
– Less pollution

Sadly, the news media has widely parroted fear-mongering lies about this program, spread by non-resident lobbyists for suburban commuters. These falsehoods focus almost entirely on the absolute highest possible price for parking — a price that will only be charged in a small subarea, for a small fraction of the available time. This price will absolutely not the vast majority of times and places. In particular, the peak rate will not affect people like nighttime workers who are traveling at off-peak hours and for whom driving may be the most reasonable mode choice. Perhaps most absurdly, these lobbyists appear to be completely unaware that Performance Parking already works very well here in the District, and over its seven years of existence has not resulted in any of the nightmarish scenarios that the media has seized upon.

For the small percentage of occasions when this peak rate will apply, the rate really is not at all noteworthy. Nationals fans already pay $8 an hour for metered parking during games, and it’s only fair that Capitals and Wizards fans do the same. Meanwhile, private lots within this area charge an average of $16 for one hour of parking during weekdays, and up to $51 an hour for special events.

Again, I urge you to expand the already-successful Performance Parking scheme to new parts of D.C. Thank you for your time and consideration.


Adapted from a 311 service request filed today.

I am writing to call your attention to a dangerous, but very easily and cheaply fixed, intersection: where the northbound exit ramp from 14th Street SW (US 1) intersects with eastbound Maine Avenue, SW.

Right turns on red are already banned at this intersection, since structures make it impossible to see around either corner. Such turns present an extreme danger to pedestrians and bicyclists proceeding northwest on the Anacostia River Trail (on the Maine Avenue sidewalk here); they would be approaching from the right on a green light.

This intersection already has three different signs that alert drivers to this particular danger:
– NO TURN ON RED under the right signal
– WATCH FOR PEDESTRIANS AND BICYCLISTS APPROACHING ON YOUR RIGHT mounted to the left
– [Bicycle] XING 250 FEET further up the ramp
Regardless, I often see drivers attempt, or make, right turns on red here. This is especially a problem at night, when the three glowing red lights overshadow the unlit signs.

The simple fix that I’m requesting is that the red-ball signal lights be modified to show red-arrows instead. All three of the green lights at this intersection show arrow signals, indicating that the way is clear to make a right turn on green. However, none of the red lights are outfitted with the same $20 arrow inserts.

Adding the inserts would make it absolutely clear to drivers, day or night, that right turns cannot be made on a red light. DCMR 2103.8 stipulates that a “steady red arrow” signal does not permit a right turn on red under any circumstance. Nor does the intersection permit any other movement except a right turn.

Your prompt consideration of this matter would be much appreciated.

Friday photo: a room with a view

C&O Lockhouse 22: your very own waterfall (well, waste weir)

Click for video

The C&O Canal’s Lockhouse 22 made a great destination for a Thanksgiving-holiday S24O. Not only is it an easy 40-mile roundtrip from Georgetown along the easy towpath, but Pennyfield Lock is situated on a secluded stretch of the river, surrounded by protected lands on both sides of the river — Blockhouse Point Park, the Dierssen waterfowl sanctuary, and NoVa’s Seneca Park.C&O Lockhouse 22, Travilah/Tobytown, MD

Not mentioned among Lockhouse 22’s amenities was that running water surrounds this lockhouse. Mike High’s book notes that Pennyfield has a “waste weir” that directs canal overflows into the Potomac just upstream of the lock; since this is the first lock below Seneca, where the downstream reach of the canal is watered, there’s usually a good flow across the weir. There’s also a bypass flume just inland from the canal, which also burbled with water headed for a small, stream-fed pool just below the lock.

By contrast, the closer-in Canal Quarters lockhouses (#6 and #10) might have electricity but are surrounded by traffic (Clara Barton Parkway) rather than water. Lockhouse #25 is just a few miles up, but looks out at the Lansdowne golf course rather than parkland. At mile 49, #28 pushes the boundaries of a weekend trip and sits next to busy railroad tracks, and #49 looks grand but is way out west.

Yes, the cabin was chilly — the thick stone walls keep the interior cave-like year-round — and a bit spooky at night, especially when light reflected off the rising moon suddenly appeared. The firewood had been scattered about the woods by vandals, but fallen wood was plentiful. Since it was winter, the water pumps are locked and we had to pack in a couple of bottles of water. At $100 a night, it would make a superb rustic getaway for a small group.

Al Hanna and the case of the missing Chicago comp plan

Chicago zoning envelope illustration, 1923

My once-colleague Steven Vance recently noted Chicago’s surprising lack of planning. Indeed, for a couple of years there (as Hunt and DeVries point out in Planning Chicago [great PDF overview]) the city bureaucracy didn’t even have a planning department — just Housing and [economic] Development. That was just as well, of course, since there wasn’t any planning being done then, or since.

Chicago technically did adopt a Comprehensive Plan… in 1966. (Next year, it’ll be eligible for the National Register of Historic Places.) I had long been under the impression that Chicago simply strong-armed pliant courts into not prosecuting this absurd state of affairs, but Steven’s post prompted me to look up Illinois’ municipal code regarding planning and zoning. To my surprise, Illinois has always had a surprisingly lenient Municipal Code — which relieves cities of any obligation to update their comp plans, or to have their zoning be consistent with a comp plan. Under Illinois law, if the Plan Commission says the zoning is so, then so be it; “arbitrary and capricious” claims be damned.

Nonetheless, one brave gadly, Lincoln Park mortgage broker Al Hanna, once somehow managed to escalate the little matter of zoning’s potential unconstitutionality into state courts some years ago. (This was while I was in college, and working on a project related to the city’s zoning code update — which, of course, drew no legal authority from any stinkin’ comp plan.) Judge Sidney Jones remanded the case with the comment that “[t]he City of Chicago has, and had, no comprehensive plan for development… which renders its zoning decisions to become more subject to scrutiny… [the downzoning] was not passed for public welfare or the public good, but was passed only in deference to the wishes of a few individuals.”

Alas, the city’s lawyers have wiggled their way out from most of Hanna’s suits. For example, Chicago long ago (apparently in 1970, via Public Act 76-583) dropped a special “lawsuit poison pill” into the state’s zoning enabling law [emphasis added]:

(65 ILCS 5/11-13-8) In municipalities of 500,000 or more population,* when any zoning ordinance, rule or regulation is sought to be declared invalid by means of a declaratory judgment proceeding, not more than 30 days before filing suit for a declaratory judgment the person filing such suit shall serve written notice in the form and manner and to all property owners

I don’t agree with Al about the legal merits of Chicago’s historic landmark law, but on zoning, he does have a point. Outside of downtown, no plan grounds Chicago’s zoning ordinance in the facts.

* This, and similar constructs, is legal code for “City of Chicago” and is found throughout Illinois state law. Illinois’ second-largest city has a population of fewer than 200,000.

Friday photo: Canopy street

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America’s federal government (unlike governments elsewhere) has historically frowned upon continuous canopies of roadside trees — or, indeed, any roadside trees at all. After all, anything that distracts drivers from the task of racking up lots of miles, at high speeds, is simply inadmissable.

Thus, I was pleasantly surprised to find these few hundred linear feet of bucolic bliss lining a federally maintained road just a few miles from the Beltway. Of course, this road is within the USDA’s Beltsville Agricultural Research Center, and the USDA is probably friendlier to (cultivated) trees than its counterparts in other agencies.

Full of sound and fury, Signifying nothing.

Already in my front yard, but my side yard? The world will END

Already in my front yard, but my side yard? The world will END!

A high-rise is already across the street from this resident’s front yard. But build one across the street from the side yard? That’s “contextual disharmony”! These signs have the gall to proclaim an urgent need to “Save the SW community” from high-rises — and, ostensibly, from the awful people (like most of their neighbors) who would dare to live in them.

This language marginalizes and dehumanizes the majority of Southwesters, who already live in high-rises and so apparently don’t count as “the SW community.” (They’re hardly the only rowhouse residents in DC who think apartment-dwellers don’t have equal rights.) And since we high-rise residents don’t have land-wasting, water-sucking yards, we can’t litter the streets with dead-tree petitions that list our grievances.

I read and re-read the City Paper’s cover story about the former Southeastern University building, looking for even a glancing mention that the “multi-story building” proposed is surrounded not only by “dozens of two- to three-story townhouses” but also by several other multi-story buildings — including Waterside Towers, just across the corner, which dozens of the townhouses already abut. But no, the writer took the side of the “underdog” homeowners, sitting pretty in their $700K-$1.2 million homes, and who only want to be surrounded by other million-dollar houses.*

The NIMBYs can whine all they want about “contextual disharmony,” but towers + townhouses is exactly the urban pattern that defined Urban Renewal Southwest from the moment ground was broken on Capitol Park. The neighborhood’s own architects** called it “an interlocking pattern of high apartment buildings and town houses.” In a neighborhood where high-rise residents make up the vast majority of the 10,000 local residents, 300 signatures means little. Indeed, 300 signatures are outweighed by the 300+ residents and employees who will live and work in the proposed apartment building.

Others will argue about the sanctity of the zoning and the comprehensive plan — but those documents are politically defined, not monuments to sound planning; they merely enshrine existing conditions and a “do-nothing” approach. When the Office of Planning zoned Southwest in 1992 (OZ case 92-7) after the old NCRC (urban renewal authority) was disbanded, everything was zoned for precisely what existed at the time. I can walk down the hall from my apartment and through three different zoning districts, all without going outside. If my building burned to the ground, it could only be rebuilt in exactly the same shape that was planned in the 1960s; even something that rearranged the same density differently on the site would be illegal. Thus, any change to the built environment in Southwest necessarily requires a zoning change, and that’s been true of almost all of the new developments being built.

Zoning only specifies an upper boundary to density, dating back to its origins as a legal tool that 1920s economic elites could use to enforce their own anti-“parasite” aesthetic tastes. Thus, only “overdevelopment” gets a legal definition and police-power enforcement tools, whereas the equally subjectively defined (but just as pernicious) “underdevelopment” isn’t a matter worthy of government interference.

The comprehensive plan, as I’ve hinted at, includes a fundamental contradiction: Its text begrudgingly admits that great change must come to the city, but its map bravely assures an anxious public that almost nothing will change across almost all of the city. Like most climate-change plans, the contradictory Comprehensive Plan sets lofty goals — the easy part — but doesn’t quite follow through. It’s like a diet book that tells readers that cutting calories is great in the abstract, while also assuring readers that they don’t have to change a thing about their current diet of cheeseburgers and chocolate cake.

The Southwest small area plan was meant to raise the idea of updating the zoning and facilitating more development, but as usual any attempt at defining a long-range vision was subsumed by short-term reactionary opponents of this specific project. Eric Shaw’s insinuation in the CityPaper that there was unanimity around this site is false; I know that I specifically added comments in support of rezoning this site, and about generally accommodating new development on select sites.

Other long-standing institutions in the neighborhood — specifically, Greenleaf Gardens, the mainline Protestant churches, and the government facilities in the “auto service center” around the DMV and post office — all got spot upzones through the small area plan. Their sites were redesignated as “medium density” rather than “moderate density,” in order to facilitate the eventual sale of their air rights through redevelopment. Ironically, SEU’s inability to secure an identical upzoning happened not on the merits — it’s much closer to transit and to everyday retail than the “auto service center,” and the church across the street got a density bump — but probably because it didn’t last long enough as an institution to argue its case before OP.

Yes, it’s silly that the developer bought the property banking on a zoning change; that’s not a strategy I would have put money behind, and not one that would work almost anywhere in Northwest. But developers do it all the time, since both zoning and the comp plan are more closely related to NIMBY objectives (read: the world is perfect as-is and shouldn’t change, so everyone hold their breath!) than to actual planning goals.

Apartments in Georgetown, across from Tudor Place (5 acre estate)

Apartments have been staring down upon Tudor Place, one of the most elegant estates in Georgetown, for almost a century — yet the world still goes on.

* Not to mention that nobody at all stood up for plans to build million-dollar houses at two sites in Southwest where they would have had negligible impact on neighbors: the Wharf’s Pier 4 (mentioned here; they actually would have reduced noise and traffic, relative to the ship loading) and at the Portals.

Which reminds me of another pet peeve: The Fifth Amendment does not guarantee any Constitutional right to forever-appreciating property values. If there was one, there would definitely be a “disparate impact” claim to be made.

** I.M. Pei, “Urban Renewal in Southwest Washington,” AIA Journal 39 (January 1963): 66.

Infilling Columbus Circle: What’s it worth?

Dan Morales’ proposal to fill the parking crater between Union Station and the Capitol complex.

Dan Morales recently shared some renderings on GGWash of what new buildings fronting Columbus Circle (the plaza in front of Union Station) might look like. The site is now mostly Senate-staffer parking, which has long annoyed the local chattering classes. The Capitol parking lots are, after all, the very last parking crater to mar the otherwise continuous urban fabric of central DC, and they sit right in front of heavily used Union Station.

It’s not that the Architect of the Capitol (AOC) particularly loves its surface parking. After all, they commissioned WRT to do a lovingly rendered plan to eliminate not just all of the surface lots, but even many of the surface roadways (ahem, I-395) on the House side. Instead of surface parking and unlovely parks, the 2050 plan shows more office buildings, with parking relocated to new standalone garages over/next to I-395. (A prime motivation is to eliminate the parking beneath office buildings, now considered a security hazard.) In short, AOC’s been land-banking the entire Hill in the assumption that its space needs will grow in the future.

Yet new planning efforts might identify that offices and support facilities continue to get more space-efficient, and that some of the land may be surplus to even the longest-term planning horizon. And, well, commercial prices are really rich…

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Those numbers piqued my interest. Let’s see, clockwise around Columbus Circle NE, the parking lots are:

  • Massachusetts to 1st (square 723, lot 800): 107,436 sq. ft.
  • 1st to Delaware (square 682, lot 808): 52,721 sq. ft. (currently park, not parking)
  • Louisiana to E (square 680, lot 801): 30,329 sq. ft.
  • E to Massachusetts (square 680, lot 805): 40,474 sq. ft.
  • I chose not to evaluate six other blocks that Morales proposed to fill in, in the interests of leaving a park between Delaware and Louisiana, and a one-block buffer between C and D.

The blocks to the west are zoned C-3-C, with a maximum FAR of 6.5. That would fit underneath the 80′ height maximum applied to Columbus Circle under the Height of Buildings Act. Thus, a maximum of 1.5 million square feet of office could be built on all four parcels, or 1.16 million on the three parking lots. Based on a land value of $200 per FAR-foot for offices in downtown DC, that’s $300 million for all four parcels, or $231.7 million for just the parking lots.

That value’s substantially higher than the $350 million that Lydia DePillis calculated as the value of all AOC’s surface parking, using tax valuations (which often lag market values).

How could a deal be structured? GSA, under the leadership of Dan Tangherlini, started dealing in “swap-construct exchanges” for sites like Federal Triangle South. In that arrangement, a developer builds a new building for GSA, which in turn “pays” the developer by granting title to surplus property. Maybe AOC could pay for further renovations, for removing its existing subterranean garages, or for new standalone parking garages (perhaps on the block between 1/2/C/D that houses the Monocle and the Capitol Police) with the revenue.

All of those sums sound like a lot of money. However, AOC projects do tend to be pricey: even $300 million is only half of the unfunded cost of Cannon House Office Building renovations. At least AOC would be able to get the money without enduring the wrath of its occupants, who sometimes point fingers at AOC’s spending.

So, Dan, now that you’re in the private sector, how about an unsolicited proposal to AOC?

Decking over freeways isn’t as lucrative as you might think — but there are alternatives

Ponte Vecchio for a new era

I-670 hides below this building in Columbus, Ohio.

Whether I’m biking down F Street and running headlong into it, or dodging its construction equipment on the infrequent occasions when I have to drive through the I-395 tunnel, it’s hard to miss Capitol Crossing — now the largest development underway within downtown Washington, DC. I knew that this was an unusual project, but it turns out that it’s incredibly unusual: the only instance of a privately financed freeway deck anywhere in the country.

The “Ponte Vecchio” example that everyone points to is The Cap at Union Station: two narrow retail buildings alongside the principal spine of Columbus, Ohio, all built on a bridge over a freeway. It is a marvelous example of a place connector, one that seamlessly unites two emerging neighborhoods to one another.

However, these caps aren’t exactly something that can be replicated everywhere, since it’s an incredibly expensive way to fix a place. The Columbus example was funded by the federal government, as a mitigation measure for widening the freeway below. Most other recent cap proposals resulted from similar mitigation measures — and thus most are parks, both because that’s what the government builds and because their relatively light weight keeps the cost of building a deck down. Klyde Warren Park in Dallas is one example; 70% of the money came from the federal and state governments.

Three things to keep in mind when evaluating a freeway cap:

2009 01 20 - 0573-0575 - Washington DC - I-395

The future site of Capitol Crossing, on a rare car-free day (Inauguration Day 2009). Photo by Bossi, via Flickr.

1. The price of the structure is only justifiable if you’re surrounded by very high-value land — namely, a high-rise, high-rent CBD of a high-cost city. This limits the situations where these caps make economic sense to premier sites. For instance, a few blocks of air rights over the Massachusetts Turnpike in Boston’s Back Bay are currently in the planning/proposal phase, having seen prior plans fall apart during the Great Recession.

Capitol Crossing’s developers paid the District $60 million for air rights and are sinking another $400 million into constructing a platform over I-395 just east of Union Station, yielding a cost per “FAR-foot” (square foot of potential development) of around $150-200. That’s substantially higher than the $75 per FAR-foot seen in recent transactions for development sites at the periphery of downtown — but comparable to the $190 per FAR-foot paid for “dirt” within downtown DC, which is pretty much extinct. The net result of this scarcity and high prices is that only the very highest value land uses, namely office and retail, are economically feasible at this development — residential just doesn’t pay enough.

(Calculation based on pre-construction cost figures and final buildout of 2.2 million square feet. Post building calculation doesn’t include demolition costs.)

The economic feasibility line might also be teased out from the RFI responses that Virginia DOT received regarding two sites over I-66 in Arlington — one at the edge of Rosslyn’s high-rise core, and another in low-rise East Falls Church (actually within Arlington County). Almost none of the responses deemed the EFC parcel economically feasible, but many of the responses indicated that the effective “land cost” for the Rosslyn parcels, including cost of construction, at nearly $100 per square foot of FAR.

Unlike private development, a park’s feasible land value is set off-market and is thus completely subjective. In a neighborhood in dire need of a park, or on an irreplaceable waterfront site, the value of a new park may indeed justify the cost of construction.

2. It’ll be much easier, and cheaper, to build a cap if the freeway is completely closed for a while — say, for a major reconstruction. Staging construction over an operating freeway is risky, dangerous, and ultimately costly. Hence, many existing freeway-lid projects, like the Prudential Center and Copley Place in Boston, were constructed before the road underneath them opened to the public. Columbus’ lid was built during an 18-month closure of I-670, for example.

Even at Capitol Crossing, the developer realized the folly of trying to keep the freeway open during construction, and proposed to close 395 entirely for 15-18 months. The closure eventually came to naught due to politics, but would have “cut in half the construction time,” according to the Post: “Building the deck requires installing about 150 caissons along the median to support a network of steel girders… installing the caissons while the highway is in use would be hazardous and disturb nearby residents.”

3. A more entrepreneurial approach that governments can take to such a project is suggested by Matthew Kiefer, who worked on an earlier iteration of the MassPike deal:

MassDOT should adjust its expectations about the revenue potential of these difficult sites to reflect economic reality. It should rely more on rent derived from the net profit of a stabilized real estate asset – percentage rent or a share of proceeds of future sales or refinancings – and less on initial land value, which can be illusory. The Commonwealth will be around for a long time to realize patient returns.

In this PPP structure, the state “speculatively” builds the platform, then executes a “ground lease” for the air rights while keeping the property under state control. This may require a more entrepreneurial attitude towards monetization than most state DOTs are willing to take, but well-located center-city land is a great long term investment. If you really believe in the quality and long-term value of the place that you’re creating, a percentage-rent ground lease is a great way to discount the rent up front but to participate in the long-term gains.

Interestingly, Brandywine Realty Trust also suggested the same net-lease arrangement in its response to VDOT.

4. There are lower-cost alternative to a full bridging project while minimizing the freeway’s footprint and impact. In many cases, the most expensive bit will be bridging the through-traffic lanes — but even sunken urban freeways usually have lots of other spaces. Embankments are usually excessive, and building platforms can be cantilevered out over their edges. Lower-traffic ramps and shoulders are easier to close temporarily for construction. Skybridges can be assembled off-site rather than in-situ, providing more connectivity across the site while minimizing closures of through lanes.

ULI sponsored a governors’ advisory panel study about another downtown Boston air rights parcel in 2012; it recommended a lighter approach than a full-on deck, with buildings surrounding the interchange and bridges over it. (Ironically, the parcel was created through the Big Dig project!)

5. Railroad air rights have also seen active development in recent years, e.g., Hudson Yards in NYC, River Point in Chicago, and 30th Street Yards in Philadelphia. However, the costs aren’t truly comparable to freeway decks: the column spacing can be much closer for railroads than for freeways, and the vehicle movements are rather more predictable.