Comments on

Case #: SDP-05-90 WCI Mid-Atlantic U.S. Region, Inc.

by

Alex Hekimian

9572 Basket Ring Road

Columbia, MD 21045

January 6, 2005

Based on my review, as a transportation engineer and planner, of the proposed Plaza Tower project in downtown Columbia, I have observed the following fatal flaws in the project:

The building is too massive. The building’s Floor Area Ratio (F.A.R.), the ratio of the total floor area of a building to the total land area of the site, is 7.95 – an extremely high ratio for a suburban location like downtown Columbia. Even in downtown Bethesda, which, unlike Columbia, is an urban area adjacent to Washington, DC and has extensive subway and bus service, a maximum of only 5.0 F.A.R. is typical for new buildings not in close proximity to a Metrorail station. Up to 8.0 F.A.R. is allowable only for buildings in close proximity to a Metrorail station, which is clearly not applicable to Columbia’s situation. Furthermore, the height of the proposed building (275 feet) is significantly greater than the maximum of 200 feet permitted in any part of downtown Bethesda.

Limitations on the height and the F.A.R. of buildings are good planning practice meant to control the bulk of the building in relation to the other buildings nearby and to better fit the building into the lot and the existing city fabric. The Planning Board has the authority to reduce the height and F.A.R. of the building to a more reasonable level.

The building is too close to the lot boundaries. The setback of the building from the Wincopin Circle right-of-way is only 2.5 feet, from the east property line only 4 feet, and from the north property line there is no setback at all. As a result, the building footprint consumes 93% of the lot. By way of comparison, in downtown Bethesda, setbacks of at least 15 feet and lot coverage of no more than 75% are typically required for new buildings under the standard method of development. In addition, 10-20% of a lot must be devoted to public space in downtown Bethesda.

Moderate setbacks and limits on lot coverage are good planning practice meant to allow sufficient air circulation, light, and landscaping to occur. The Planning Board has the authority to increase the setbacks and reduce the lot coverage of the building to a more reasonable level.

The building is so large that all of its parking needs cannot be satisfied on-site. According to the staff report on this project, this site’s Final Development Plan (FDP), which I have not yet seen, requires 1.5 off-street parking spaces for each “apartment” unit and 5 spaces per 1,000 sq. ft. of retail area. The resulting total parking requirement is apparently 342 spaces. The Planning Board needs a determination regarding the assumption that the FDP’s term “apartment” can legally also include “condominium.” The Planning Board also needs evidence that the coffee shop in the building will not be advertised along the exterior of the building and will be in an internal space primarily serving only building occupants.

The proposed project would provide on-site only 286 standard garage spaces, 28 tandem spaces, and 8 handicap spaces. An additional 54 spaces would be leased off-site from the Columbia Inn Parking Deck and Town Center East Parking Lot. If the FDP does not specifically address off-site parking for this site, the Planning Board may not be able to act on the application unless it sees evidence that the proposed off-site spaces meet the following conditions of Section 133 (Off-Street Parking and Loading Facilities):

For residential uses, the major point of pedestrian access to the parking facility is within 200 feet of the entrance to the residential building;

For nonresidential uses, the major point of pedestrian access to the parking facility is within 400 feet of the entrance to the building;

The parking facility is within a zoning district in which the use being served by the parking facility is permitted;

The parking facility is not separated from the use being served by a public street; and

The parking facility is subject to recorded covenants or easements for parking, or other proof is provided that the continued use of the parking area is guaranteed throughout the life of the land use.

Section 133 actually requires 2.0 spaces per unit, unless the units are age-restricted adult housing. Since the site’s FDP apparently specifies a different requirement of 1.5 spaces per unit, Section 133 requires the applicant to submit a Parking Needs Study as part of the site development application. The study would need to include an estimate of the parking needs for the use, a thorough explanation of the basis of the estimate, and any data used in calculating the estimate, including parking generation studies, previous experience with similar uses, or other information. The study also needs to include evidence of a commitment to have valet parking for the tandem spaces that are being proposed. I have not seen such a study. If such a study does not exist, then the application is incomplete and the Planning Board may not be able to act on the application.

The applicant’s traffic study is flawed. The traffic study concedes that exiting and background traffic will cause the Little Patuxent Parkway/Governor Warfield Parkway intersection to fail at Level of Service F in the PM peak by 2008. The proposed project would further worsen the traffic conditions. The study incorrectly concludes that the applicant needs to do nothing to alleviate the problem. Even though the intersection is among the “constrained” intersections designated by the County Council in 1992, Section 4.5 of the Roads and Bridges volume of the Howard County Design Manual states:

“When a developer is required to evaluate a constrained road facility, the adequate facility test evaluation is still required. In the event that the level of service is below the standards in this manual [Level of Service D for County roads], a mitigation plan is required. However, mitigation will be required to the extent that the mitigation plan improvements do not have a negative impact on the physical and right-of-way characteristics that have caused the constrained road facility to be designated.”

The Planning Board may not be able to act on the application unless the applicant shows evidence that a mitigation plan will be implemented and/or shows evidence that no mitigation whatsoever is possible without a negative impact on the “unique urban setting” of the intersection.

The traffic study is further flawed in the following respects:

The study’s assumptions for trip distributions are the same as those previously assumed for the Crescent Property traffic study. In citizen testimony provided to the Planning Board during the Crescent property public hearings, it was shown that the assumed distributions were highly distorted and unreasonable, showing hardly any trips between the downtown site and Wilde Lake and Harper’s Choice villages.

The study proved that a new traffic signal would be clearly warranted at the Little Patuxent Parkway/Wincopin Circle intersection, and yet it inexplicably fails to recommend installing a signal at that location.