Takoma DC Small Area Plan

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Comments of Historic Takoma, Inc. on the
Draft Takoma Central District Plan

Submitted October 31, 2001

Historic Takoma, Inc. appreciates the opportunity to submit additional comments to the Draft Plan for the Takoma Central District ("Draft Plan") dated September 27, 2001. We also appreciate having been given an opportunity to serve on the Citizens Advisory Group that participated in discussions throughout the public comment period. This was an especially important role, as our nonprofit organization is incorporated in both Maryland and the District of Columbia, with membership in both jurisdictions.

While we agree that aspects of the plan represent some of the collective views of the two communities, we regret that the comments we have consistently offered regarding this Draft Plan are not more fully reflected in the document. In our view, the Plan should be, as it claims to be, community driven. [See Draft Plan at p.1] Unfortunately, it fails to live up to this claim on a consistent basis.

The Draft Plan overall tends to reflect community input and priorities regarding the appropriate treatment of the area of study lying outside of the WMATA site. But it should not be overlooked that the impetus for initiating the Small Area Plan is a need to resolve how we are to treat the Metro property, which all agree serves as a gateway to the community. This portion of the study area is the one likely to drive actions by the Council of the District of Columbia, its Zoning Commission and the DC Historic Preservation Review Board. Realistically, the other recommendations in the Draft Plan – particularly because they are offered without any detailed action agenda or game plan for implementation, as we discuss below – are less likely to affect residents’ lives in the short term.

For this reason, the flawed components of the Draft Plan that center on the WMATA site are the ones to which these comments largely will be devoted.

Our most important recommendations concerning the Draft Plan and this area can be summed up as follows:

First, the Draft Plan cannot and must not be finalized and sent to the Council of the District of Columbia until there has been a meaningful substantive analysis of the transit needs of the community that are served by and will in future be served by the WMATA site, and the related automobile traffic on adjacent streets This analysis should be swiftly initiated and concluded, and should include all relevant parties. Our request that this work be undertaken is not new. We are forced to reiterate it here because we have not been listened to over the past eighteen months.

Second, the Draft Plan reflects an unsubstantiated bias in support of one particular proposed commercial development project in the face of widespread community concern about the project’s density and its impact on transit, traffic and community quality of life. This bias is based on the demonstrably false premise that no revitalization will come to the area without this one development project, and it needs to be corrected.

Third, while the Draft Plan does lay out proposed ideas for the revitalization of a number of other sites near the community’s Metro Gateway, many of which we support, it fails to offer any kind of serious implementation strategy for those elements. The community is united in support of action on these parts of the plan and has repeatedly expressed its desire for details, details on implementation throughout the charrette process. First and foremost has been a repeated demand for traffic and parking analysis. None is forthcoming in the Draft. (In fact, the Draft Plan vaguely suggests ‘a parking garage’ for the WMATA site with no indication of where it might go or how it might be financed!) Unfortunately, this lack of detail adds further weight to our impression that the rest of the Draft Plan exists largely to prop up the biased pro-development proposal for the Metro site rather than as a vision for community revitalization.

We recommend that the finalization of this Draft Plan be temporarily postponed until the affected jurisdictions have convened a mass transit and traffic working group to analyze transit needs for the Metro site and determine how those needs can be met; during this hiatus the Office of Planning can return to the drawing board to fill in the gaps in the remainder of the plan, correcting errors and addressing other unmet concerns about how implementation will be financed and who will carry it out.

We are committed to the successful completion of this planning process in a way that ensures our community will continue to grow and flourish, welcoming new residents and shoppers. We support well-planned growth, consistent with the community’s obvious needs for transit services and green infrastructure.

Below we offer additional details in support of these key points.

I. The design of the WMATA Gateway site is fundamentally flawed and unacceptable. As the Draft Plan acknowledges, transit needs and traffic must come first in determining the fate of this site. Unfortunately, the proposed re-design of the Metro site [see p.14] is unacceptable because it fails to address the following pressing transit and traffic needs and concerns.

Existing bus service crowded out: the Draft Plan appears to reduce the space currently available for bus bays, failing to provide adequate space for existing bus service to park, enter and exit the WMATA service area. More important still, the Draft Plan would cut off the current Eastern Ave. entry/exit route for buses and greatly exacerbate traffic and air pollution at the one remaining (sharp turn) bus entry/exit on Carroll. Since overcrowding at the site is already an issue – resulting in buses improperly idling on neighborhood streets rather than remaining on the Metro site despite repeated community demands that this practice be halted – it is clearly inappropriate to propose these changes.
Future increases in bus service are made still more difficult: The Draft Plan provides no room for growth that is already planned. Three new Ride-On routes have already been approved by Montgomery County’s Ride-On service; a fourth route of Prince George’s County’s "The Bus" service also is in the works. These routes will serve high density and bus-dependent communities that badly need the additional transit service. If the Draft Plan squeezes them out in favor of residential development it will defeat the region’s Smart Growth planning objectives.
Future foreseeable growth is ignored: The Draft Plan fails to plan ahead. If residential or retail development occurs on part of the WMATA site that forecloses future foreseeable transit options it will further impair regional Smart Growth initiatives. For example, at present Governor Glendening’s Smart Growth Task Force is examining additional transit options in the Langley Park area that are likely to result in increased bus service to Takoma. Shrinking available bus space at Takoma would undercut such future transit initiatives.
Intermodal needs ignored: The Draft Plan fails to account for space to accommodate the planned Metropolitan Branch Trail bike path (although paying lip service to the need to welcome it elsewhere in the report; see p. 55). The Trail, which could be a boon to the local economy if well-designed, will require a wide swath within the relatively small WMATA site. The Draft Plan offers no details about the amount of space the path would require and simply punts the decision about route selection to another planning entity. Bicycle routes are an integral component of inter-modal transit, and the siting and routing of the Trail must be more fully considered before the Draft Plan is made final, including other routes that would not impinge on the historic Cady House, an exceedingly important property that is individually listed on the National Register of Historic Places.

Moreover, further reducing the convenience of the Takoma station to bikers, the Draft Plan actually appears to reduce space for bicycle parking rather than providing the additional bike parking that the community has requested.

Discouragement of Auto/Metrorail users: The Draft Plan fails to provide adequate kiss-and-ride space at the location where the community wants to have such space, based upon current usage patterns. It appears to try to squeeze this vital function onto the same over-burdened intersection where bus traffic would double with the proposed re-routing of all bus service onto Carroll Ave.
Failure to consider taxi riders: The Draft Plan fails to provide a safe and convenient location for a taxi stand, which is an important feature to improve rider convenience and security, particularly at night and for vulnerable transit users such as the elderly and women traveling with small children.
Reduction in pedestrian access: Perhaps the most baffling recommendation of all, the Draft Plan proposes to make Metro pedestrian access even more limited than it is today, by barricading the railroad underpass where many pedestrians now cross [see p. 49] to attempt to discourage jaywalkers. A transit-friendly approach, which the community clearly favors, would be to study the current heavily traveled pedestrian routes and place crosswalks where the walkers are, not to erect barriers to prevent them from crossing (as well as discouraging commerce under the tracks)!

The Draft Plan also proposes to eliminate several pedestrian routes that now traverse the Metro greensward, and to divert those pedestrians around the back of proposed new townhouses. The walk to the Metro actually will be made longer and more roundabout, and perhaps less secure.

Failure to Consider Green Infrastructure Needs: The Draft Plan shrinks to the size of a ‘pocket handkerchief’ the green space currently fronting the Metro entrance and running along Cedar and Eastern Avenues. This area is the one that many regard as the neighborhood’s gateway. The attached memorandum, incorporated by reference into these comments, clearly explains that it was the intention of the citizens of the community and the Planning Office to preserve this green space as a buffer between the Metro and adjacent residences; these intentions were reflected in the last round of zoning changes in the late 1970’s. (See Attachment One).

Further decreasing the value of this tiny remaining green space, the Draft Plan would divert significant additional bus traffic to the site exit immediately adjacent to the ‘green,’ creating increased fumes because all bus routes would be funneled onto this already-inadequate intersection [see figure on p.14 ].

Failure to coordinate with WMATA: Despite the obvious centrality of WMATA to the planning process for Takoma revitalization, the Draft Plan puts forward proposals for changes to the Metro site that, while favored by the community, have been openly opposed by WMATA. In particular, WMATA officials announced early on that they will not spend any additional money on upgrading the Takoma station or building the badly-needed additional metro entrances west of the tracks. These proposals are important to the success of the Small Area Plan, and it seems inappropriate to move forward with the planning process without resolving these WMATA issues. For example, plans for revitalization of Chestnut and Spring Streets may hinge on the feasibility of the new west –side entryway.

All of these deficiencies in accounting for transit needs point out the need to step back and develop a comprehensive and multi-jurisdictional revised transit plan first. It makes no sense to finalize a Small Area Plan that depends upon reconfiguration of the WMATA site to account for changing transit needs when the transit and traffic planning have not yet been done.

We recommend that a transit- planning process be initiated immediately for the Metro site and surrounding streets impacted by transit-related traffic and through traffic. Such a process must include the relevant transit officials, at a minimum representatives from Metrobus, Ride-on, the Metropolitan Branch Trail, Prince George’s County’s "The Bus," the authors of a needed traffic study (from both MD and DC together, as key routes are border streets) and planning officials from DC, MD, Montgomery County and Takoma Park, MD. The planning process should be conducted as expeditiously as practicable and should include community representation for both affected jurisdictions from the outset.

Re-designing the transit elements at this hub site should be the first priority. Once we know how much of the site is needed for transit purposes now and in the foreseeable future we can make cogent decisions about other potential uses for some subset of the site.

We are mindful that some may complain that this comment suggests that Historic Takoma seeks merely to delay the inevitable development of the WMATA site. Such complaints are unjustified. We have maintained since the outset that the planning process demanded full consideration of transit needs, and our repeated demands have apparently fallen on deaf ears thus far. See Attachment Two, letter from Historic Takoma to WMATA, July 10, 2000.

It is clear that the many new bus routes on the drawing board, and the plans for a major new bike path through the WMATA site, are sufficient to require a revision or alteration of the Mass Transit Plan for the Takoma Metro station site.

As WMATA has acknowledged, revision or alteration of the Transit Plan at the Takoma Metro will trigger the requirement for a hearing under Section 15(b) of the WMATA Compact. See Attachment Three, letter from WMATA to Susan Silber, Counsel to the City of Takoma Park, MD, April 26, 2000.

II. The second most important flaw in the draft plan is its relentless focus on private development of a portion of the WMATA site.

The Draft Plan is factually wrong when it states that ‘[t]he large available parcel at the Metro station site makes redevelopment possible" [p.28], implying that revitalization of Takoma’s Central District will falter without this particular project as an impetus. In fact, other development already has begun and more is planned. Several new businesses have opened their doors in the last few months in existing properties. Two of the other sites that the study labels as redevelopment targets, yet claims are not developable without the WMATA site, have already been purchased by prospective developers; at least one is well into the design and permitting process. A third site is already owned by a successful developer who has discussed his development plans with the community over the past several years.

Moreover, a visit to Maryland’s Takoma Old Town, which is further from the Metro than the other sites targeted for revitalization, demonstrates that revitalization is achievable through coordinated planning and community support in a desirable niche neighborhood like our without selling off public green space to make it happen.

The failure of Central Takoma to thrive cannot simply be blamed on the absence of a private developer to take over our public land. The District of Columbia has failed to exercise its creativity or use its resources to encourage revitalization throughout the neighborhood, and needs to do so now. A quick read of the 1977 draft plan for Takoma’s revitalization reveals that very few of the 1977 proposals have been carried out. (It should be noted that the 1977 plan clearly supported preservation of open space at the Metro site, noting that Takoma was severely lacking in green space!)

As noted above, the proposed Metro site development has not been shown to be compatible with transit or green infrastructure/buffering needs at the site. Nor are the proposed density and configuration of the site in keeping with the community’s wishes or with the current flavor of the Takoma Park neighborhood it would abut.

First, there are no townhouses in the current community layout. Second, the proposed density is considerably higher than the adjacent residential community, making it inconsistent with the Historic District. Third, the Draft Report introduces for the first time here (without community discussion or support) a call for "higher density development (up to four stories) along edges that front the proposed ‘Village Green’ and Metro functions," [p. 48]. This density and height would loom over and shadow the tiny remaining pocket handkerchief of current green infrastructure that the Draft Plan retains. We find this proposal baffling; even the would-be developers of the site offered to retain about 2/3 of the current open space; the Draft Plan slashes it to less than 1/3.

In short, the Draft Plan reads as if satisfying the needs of one private developer were its paramount objective.

We recommend that the plan be revised to remove its unfounded bias in favor of development at the WMATA site, and that it instead re-direct its focus to supporting revitalization of the numerous other (correctly identified) sites it identifies and for which community support is virtually unanimous.

III. The plan contains a number of revitalization proposals for sites other than the Metro site that do in fact have broad based community support, but offers no game plan for moving from proposal to action on those elements. It should be revised to include a plan of action before it is voted on.

Elements of the plan that can be implemented without having resolved larger traffic and transit issues could and should be the subject of an action plan with meaningful chances for success. We support moving forward with many of these elements immediately, while others related to traffic will need to await the completion of the traffic and transit study referred to above. For example:

Plans to implement an upgrade in infrastructure such as sidewalk and street repair, lighting and trash removal in and around the Central District;
Plans to greatly increase code enforcement, to address failures of delinquent property owners that devalue their and neighboring properties;
Plans to institute tax preferences and zoning changes to encourage rapid development of residential housing at the other targeted sites (i.e., sites A, C and D [p.35] in the Central District, for which community support appears virtually unanimous;
Plans to down-zone other sites to discourage the sprawl of the retail/commercial district and to ensure the placement of additional residential uses on purely residential streets;
Plans to coordinate cross-jurisdictionally for improved policing and safety around the Metro station;
Plans to create and support a merchants’ association, in order to implement marketing and façade improvements for the DC/MD shared central shopping district;
Plans to adopt historic district designation in a larger area around the central core, as may be recommended by Historic Takoma, Inc., pursuant to a study of the area.

While these initiatives are underway, other elements of the plan that are dependent on resolving traffic circulation and transit issues should be put on a fast track for resolution through implementation of the traffic and transit task force outlined in I. above.

We recommend that the report be revised to include specific recommendations for taking immediate action to implement these action items, including the assignment of responsibility and development of measures of accountability that are based on specific timelines.

IV. Gaps in the Draft Plan remain to be filled.

There are additional areas of concern that have been raised by the community but have thus far failed to appear in the Draft Plan. In particular, there has been a repeated call for environmental awareness in the planning process. The community has repeatedly requested that future buses be natural gas users to address air quality concerns around the Metro site. Several people have called for the integration of storm water management and other green building design principles into redevelopment planning. We ask that the Draft Plan be revised to be responsive to these requests.

Conclusion

The community consultation process for development of this Draft Small Area Plan has been a valuable one, as it has helped citizens to crystallize more clearly their visions for a revitalized Takoma Central District that draws two neighboring jurisdictions more closely together. We regret that the unified vision of the community is not fully or accurately reflected in the Draft Plan, and we ask that you move swiftly to address the concerns spelled out in these comments.