(Italicized sections were cut entirely from the delivered testimony for brevity.)

Thank you for the opportunity to speak. My name is Payton Chung. After grad school for planning at Virginia Tech in Arlington, I am now a developer of Missing Middle scaled housing. Because that job does not yet exist around here, I mostly work in Raleigh, NC, a prime destination for people who have been priced out of northern Virginia. I can attest that Raleigh’s Missing Middle text changes have made it possible for me to offer smaller, lower-priced houses than the large new houses built across the street just before the text changes. Many of those arriving in Raleigh have been priced out of places like Arlington, which has better infrastructure than Raleigh — much better transit, no water shortages, a regionwide trail network, less crowded schools — but which lacks sufficient housing infrastructure.

The “tall or sprawl” dichotomy of Arlington’s “bulls-eye approach” to planning relies almost entirely on two uniquely high-cost housing types: land-intensive detached houses and capital-intensive high-rise apartments. As a result, it necessarily results in high housing costs. Missing Middle Housing offers a middle ground: less land than detached houses and less materials and labor than high-rises. Yet Missing Middle Housing production, like production of anything else, best achieves lower costs once it achieves economies of scale. It can only reach its full potential for lower costs if it becomes widespread and well-practiced.

Not only does this call for removing artificial zoning limitations, but it also requires related changes to building codes, financing practices, and construction practices.  That means allowing more units, in more locations, and not rationing it with a countywide cap. Redevelopment is already an inherently slow process, since it’s limited by land availability. Only 3/10ths of 1% of Arlington’s single family houses are listed for sale today. Progress towards the county’s equity, affordability, or sustainability goals should not be further limited.

EHO will not solve the affordable housing crisis, but it will make existing subsidy dollars and programs go much further. For instance, Virginia Housing offers subsidized loans to first-time homebuyers up to a cap of $665,000. A house at that price is roughly affordable to the median Arlington household. Right now, there are zero new construction houses available in Arlington to meet that budget. Some older houses are available, but with either maintenance needs or condo fees that would sink many first-time homebuyers. However, there are 108 new homes available under that cap in equally land-constrained, equally highly regulated DC and Alexandria — and 98% are in “missing middle” sized buildings that are basically illegal to build in Arlington today. Instead, new houses in almost all of Arlington are available only for households earning more than the President of the United States — top-3% incomes in America.

The EHO text attempts to incentivize 4-6 flat buildings, but building codes and lending practices continue to favor fee-simple townhouses. I suggest further study to adapt building codes to enable flats, review townhouses’ specific urban design challenges, require public access easements so that driveways contribute to the street network, and allowing townhouse accessory dwelling units– “English basements” are an established pattern for attainable housing in this region.

And last, a quick response to complaints about infrastructure sufficiency. Infrastructure is continually repaired and replaced, for example through Arlington’s $4.4 billion Capital Improvement Program — including almost $1 billion just in water infrastructure. We’ve known since the federal government’s 1974 “Costs of Sprawl” report that expanding existing infrastructure in existing urbanized areas is more cost effective than building it new in rural areas.

Take rail transit, for example: restricting growth here means that Arlington pays WMATA extra to run trains with excess capacity here, while Virginia spends billions to expand rail service for Arlington commuters’ hour or two-hour trips to Ashburn and Ashland. Instead, Arlington should welcome more of those commuters to live here and take the trains built decades ago, when doing so was much cheaper. At a time when new houses are being sold to Arlington commuters in Caroline County, 70 miles down I-95, we need to be cognizant that while infrastructure in Arlington might not be perfect, it’s much better than infrastructure elsewhere.

It’s especially puzzling to hear complaints about strained infrastructure come from neighborhoods where the population has shrunk, rather than grown. Even as Arlington’s population grew by 15% since 2010, CPHD estimates that the population in Old Glebe declined by 13.6%. When Arlington’s low-density neighborhoods were built, life expectancy was still in the 60s; now a typical Arlingtonian lives to 85. That’s terrific news, but it means that Arlington needs more housing units even for exactly the same population — much less a growing one.

I commend the Commission and County for the progress made to date. This zoning change may seem momentous, but even the dry and bitter pill of zoning reform is not a magic pill. It can merely reshape changes that are already occurring to neighborhoods, and hopefully in a way that shifts rather than reinforces the unjust, unsustainable status quo.

Thanks to Councilmember Allen for this opportunity to speak. I’m Payton Chung, LEED Accredited Professional in Neighborhood Development, and I have 20 years of experience in urban planning policy, notably in urban design and affordable housing.

Comprehensive planning is how a city adapts to an inevitable future. No plan, and indeed no action a city can take, can prevent that future from occurring.

One inevitable aspect of the future that deeply worries me, as one of the three billion humans living near sea level, is climate change. I previously testified that the updated comp plan does an adequate job of outlining several of the challenges and forward steps that DC will need to take over the next decade to forestall and adapt to the climate catastrophe. If left unchecked, many of Ward 6’s most vulnerable areas, for example the James Creek corridor along Delaware Ave SW, will be uninhabitable within my lifetime. I also testified earlier that the next iteration of the Comp Plan should address this existential threat to DC’s future as its foundation, not as one element among many.

I’d like to briefly touch upon the price of housing. Increased rents cause new buildings, not the other way around. Once rents surpass a level that can pay the surprisingly high underlying cost to build new houses, then new buildings will get built. Stopping new buildings might avoid offending some people’s aesthetic sensibilities, but does absolutely nothing to change the underlying demand for new housing. We can see this in the fact that rents have increased faster in Capitol Hill, with almost no new housing construction, than in Capitol Riverfront, which has lots of new housing construction. 

I’m glad that the comp plan accepts that more houses are needed right here in Ward 6. Ward 6 residents enjoy many transportation choices, and so we produce far less carbon per capita than most Americans. The most effective contribution that neighborhoods like ours can make to the climate crisis is to let some more people in on our secret, and allow more neighbors to benefit from this fantastic location. To be clear, almost all of DC’s population growth results from babies that are born here, so growth is a matter of letting children stay here, not a matter of outsiders vs. insiders and us vs. them.

DC alone can’t change growing income and wealth inequality, or the fact that new houses are expensive to build – though it must continue to expand subsidies to help lower income residents access homes in high opportunity areas. But moderate- and middle-income residents could afford new construction on the private market, if only it were legal to build new homes everywhere, not just in a few tiny areas that I’ve called “instant neighborhoods,” and the comp plan calls Land Use Change Areas. This comp plan update begins to soften the distinction between Land Use Change Areas and Neighborhood Conservation Areas. That distinction has succeeded too well at comforting the District’s already comfortable single-family homeowners, sometimes overwhelming LUCAs with lots of change all at once, and pushing all new housing demand into high-rise apartments, which are the absolute most expensive kind of house to construct.

DC’s zoning makes it illegal to build all but the most expensive possible houses: detached palaces surrounded by huge yards in Ward 3, or high-rise studios surrounded by costly concrete and steel in Ward 6. Yet somehow, we act surprised that housing costs are out of reach. Allowing a broader variety of housing choices across the entire spectrum of housing types and neighborhoods, and particularly making it simpler to add new units in less costly low-rise apartments, will better balance the housing market and make sure that our housing dollars, whether private or public, go further.