March 8, 2013

Ms. Heidi Merkel Senior Planner Department of Planning and Zoning Fairfax County Re: Reston Citizen Association Comments on Draft Areawide Comprehensive Plan Language for Reston Dear Ms. Merkel, Thank you for the opportunity to review the County staffs first draft of its proposed areawide Comprehensive Plan language. We have reviewed it in some detail and have a few key areas for comment as you move forward in revising this draft and preparing the more detailed language for the specific TOD district plans. We appreciate the obvious level of effort that went into preparing the draft areawide plan. We appreciate its inclusion of the Reston vision and planning principles summary virtually verbatim. We believe you know what Restonians want for their urbanizing community. We do believe, however, that there are shortfalls in the long term target jobs-to-housing balance and the great imbalance in language regarding developer and citizen needs. Our comments below attempt to address the relative weaknesses in the draft language. We hope that the line of thinking proposed here also is reflected in the upcoming district-specific draft planning language. 1. We want to be smart about moving to a more urban environment by keeping commercial and residential development in better balance. A general goal of the Task Force effort has been to reduce vehicle miles travelled while increasing density through the use of transit-oriented development, especially within the -mile circle of the station areas. Such development encourages the use of Metrorail, bus transit, biking, and walking. As Center for Transit-Oriented Development (CTOD) and innumerable other analyses have shown, the greater the proportion of residents in a TOD area, all other things being equal, the greater the reduction in VMT and greater use of other transportation means. Given this broadly accepted finding, we believe the 3:1 jobs-to-household ratio target (see p. 4 of the DPZ draft) is too high for Reston, which presumes to become a diverse planned community with both substantial urban and suburban dimensions with a strong environmental orientation. The stated ratio is more in keeping with an urban area such as Tysons, which has a J:HH target of 4:1. At this point Tysons has fewer than 20,000 residents and some 100,000 jobs, a roughly 10:1 J:HH ratio. Its longer term goal reflected in the 2010 Comprehensive plan is 200,000 jobs and 100,000 residents (at 2.0 residents per household). In contrast, Reston already has nearly 60,000 residents to go with its roughly 71,000 jobs as shown in the attached spreadsheet. 1

Right now, Reston (the CDP) has a jobs:households ratio of 2.8:1, including a J:HH ratio of 12.0:1 in the TOD areas. The unfortunately high ratio within the TOD areas is an artifact of the ban on housing in the old RCIG area and the desire by developers to overly emphasize office development in the Reston Town Center core area. Using Scenario G Traffic Impact Analysis (83% of potential) as a guide to a forecast for 2030 rather than full Comprehensive Plan development potential and making some modest assumptions about job, population, and household growth beyond the TOD areas, the current community-wide J:HH ratio may likely fall to 2.1:1 in about 2030 led by a major reduction in the J:HH ratio in the TOD areas to about 4.2:1. There is a small increase in the forecast change in the J:HH ratio for the non-TOD areas, based largely on redevelopment of Lake Anne Village Center. All of this is good for easing transportation improvement requirements, County budgets, County taxes, and protecting the environment. It is a win all the way around for Restonians and the County. Hypothesizing a 3.0 jobs:households ratio at, say, mid-century would be a reversal of the currently proposed plan development direction in a jobs:housing balance. In our forecast, we anticipate job growth of about 29,000 in the 20-year period from 2030 to 2050. At the same time, overall residential growth would have to limited to about 4,000 households to achieve the 3.0 targetmeaning a vast increase in the number of people commuting to Reston to work. Moreover, it would not cut the J:HH ratio in the TOD areas even as much as Scenario G envisions. All this would lead to greater traffic, greater need for road improvements, greater budget increases, greater taxes, and greater damage to the environment. We have hypothesized two alternative mid-century jobs:households forecasts derived from the Scenario G and 3:1 J:HH forecast discussed above. In both of these, we tried to sustain the jobs growth while increasing residential growth to reach the targeted balance. A community-wide development scenario with a 2.5:1 jobs:households ratio would improve on both the current and forecast balance under Scenario G with all the desirable effects described above. It presumes a major revamping of the village centers in line with Bob Simons vision and redevelopment of older apartment/condominium complexes (such as Fairway and Charter Oaks apartments). It would see the population of Reston double with slightly 40% of that gain outside the TOD areas. Achieving this 2.5:1 J:HH goal would bring the TOD area J:HH ratio down to 3.9largely in line with the combined task force station area sub-committee proposalswell below the 5.4 J:HH ratio obtained by the 3:1 community-wide balance. A community-wide development scenario with a 2:1 jobs:households ratio would extend the benefits of residential/non-residential balance even further. The TOD areas would see their J:HH balance drop to 3.6where the driving alternatives of transit, biking, and walking would be most attractiveresulting in substantial reductions in VMT and associated road improvements, County budgets, property taxes, and less environmental damage. Restons population would grow more than two and a half-fold from current levels with some 29,000 residents more than in the 2.5:1 target scenario. Although we believe a long-term community J:HH ratio of 2:1 would be optimal, we believe a community-wide jobs:households goal not to exceed 2.5:1 is acceptable and achievable with good planning execution. There is certainly no good reason to go in the opposite direction. We cannot support a community-wide 3:1 jobs:households goal. It is congestion producing, not cost-effective for the county and its taxpayers, and would do substantial additional damage to the environment. We want to achieve a smart urban environment, not just more high-rise office space. 2

2. We question the validity of assumptions used for office worker space during the Task Force process and implicit in the DPZ draft areawide plan language. Our concern about the targeted jobs:housing ratio above is amplified by our concern about the assumptions used to calculate the space occupied by a single office worker, that is, 300 GSF per worker. This is especially pertinent since we all envision the development of office space as a critical element in the growth of Reston, especially in its transit station areas. We believe the assumption of 300 GSF per worker may be double the actual number as future office development unfolds. The consequences for traffic congestion, etc., are obvious. When the Task Force began, the core assumptions about office space was put at 250 GSF/worker and the space per household put at 1,000 GSF per housing unit. We soon began to accept that housing units might, on average, be largerat 1,200 GSF/HUand raised the GSF/office worker to sustain the 4:1 jobs:housing ratio. The former is questionable and the latter totally unjustified. In 2010, RCA engaged in a dialogue with Arlington Countys then-chief planner, Robert Brosnan, as we tried to understand the various size allocations for categories of workers and housing and their implications. In a candid e-mail exchange, he was adamant that, for planning purposes, 1,000 GSF/HU was appropriate and 250 GSF/office worker was correct. We can accept that high-density housing units in Restons TOD areas may be larger than those in Arlingtons transit corridors, but the data suggest thatif anythingthe GSF/office worker is declining sharply. As you may recall, executives from Jones/Lang/LaSalle told us less than a year ago that GSA is downsizing its office space requirements to between 110-180 GSF/office worker and, according to contemporaneous notes taken by Reston 2020, Downsizing to 80-120 sq. ft per employee is not uncommon. The Washington Business Journal also picked up on this theme, noting in an article about former Reston office client Accenture, Accentures virtual nature allows real estate downsize, that: Because of the virtual nature of our office environment, we no longer need the amount of space we have in Reston, said Accenture spokesperson Kate Shenk. Accenture has been office hoteling for the last several years, meaning workers dont have assigned office space anymore. Instead, employees, many of whom spend much of their time offsite with clients or working from home, share space in Reston, using a reservation-based system for use of office space. When asked how many employees will move into the new office space, Shenk said, At this point, what we can tell you is that out of the 4,000 people aligned to Accenture Metro D.C., only a fraction of those employees are expected to actually utilize the space at any given moment. A major article by Eliot Brown in the Wall Street Journal entitled, Corporate Cram Bedevils Office Market begins: Trend of Companies Packing More People Into Less Space Picks Up Pace; A 'Tiny Library' at One Law Firm 3

As the office-space market slogs along in a slow recovery, landlords face another hurdle: shrinking tenants. Companies looking for cost savings are increasingly packing more employees into less space, a trend that is helping cause U.S. vacancy rates to linger at high levels even as employers add jobs in the slowly expanding economy. . . Employers gradually have been taking up less space for decades, but real-estate professionals say the drive to use less space has picked up since the economic downturn, as companies look to trim costs where they can across their budgets. Workstations are shrinking and private offices are disappearing, replaced by cubicles with low walls, and more employees are working remotely. Companies today are taking space with an average of about 200 square feet per employee, down about 20% from a decade ago, said Alan Nager, an executive managing director at brokerage Newmark Knight Frank who advises companies on their real estate. The amount of space is continuing to shrink, he says. The trend is slowing the recovery of the office market. . . . With these cost-saving trends in place for decades per WSJ and the likelihood of greater telecommuting, office hoteling, etc., in the 21 st century, we can find no reason to believe 300 GSF/office worker is anywhere near a realistic assumption. We cannot support an office worker space planning assumption greater than 200 GSF/office workerand the real number will probably be much less as time unfolds. At 200 GSF/worker, the J:HU ratio jumps from 4:1 to 6:1. The implication is that the DPZproposed community target jobs:housing ratio of 3:1 would lead to half-again as many workers in Reston as households, worsening an already severe imbalance. If we want to build a 21 st century balanced transit-friendly planned community, we need to use realistic 21st century assumptions and analysis to achieve that end. 3. The County must aggressively pursue air rights over the Dulles Corridor for TOD development and the grid of streets to work effectively. Future air rights development around the stations should be pursued to enhance development opportunities, encourage transit use, and improve north-south connectivity across the Dulles Access Road. (p. 6, draft areawide plan) The above statement is the only comment in the draft areawide plan about the matter of Dulles Corridor air rights and while it is correct in its intentions, it is far too qualified to provide useful guidance. We do not believe that Reston can achieve the numerous benefits of TOD, including a substantial transformation of the station areas, without corridor air rights. The lack of air rights and, thereby, the opportunity to build a grid of streets (rather than maybe three more connectors) across the corridor is exactly the huge issue that is confronting the Task Force as it tries to balance development with traffic congestion in Scenario G. Developers are concerned that it too severely restricts their development opportunities. Residents are concerned that Scenario E (and maybe still G) levels of development will bring north-south mobility in Reston to gridlock.

In contrast to the situation in Reston, there are at least eight crossings of the underground Metrorail system at every station transit areaand Arlingtons station areas are limited to a 1/3-mile radius. At best, we are contemplating a total of six crossingsthree current and three plannedin Reston across three transit station areas, each -mile in radius. While Arlington has achieved some reductions in traffic congestion because of its TOD development, we can anticipate traffic gridlock. We recommend strongly that the language in the plan be changed to reflect the necessity of air rights and building a trans-corridor grid of streets in Restons station areas. We propose substituting the phrase should be pursued to is vital to success of transforming the transit station areas and must be pursued on a priority basis... We would add a sentence that says, These corridor air rights must extend east from the Fairfax County Parkway to a line linking South Lakes Drive with Business Center Drive, the eastern-most planned connector crossing of the corridor. 4. The Reston community deserves to be on at least an equal footing with landowners in the Comprehensive Plan language. The issue of the relative stature of landowners and the community in which they exist is exemplified by the by right status that will accrue to landowners for stated densities and mixes in the Planincluding flexibility in that languageand the ensuing zoning ordinance compared with the legally irrelevant language of should and encouraged that has been applied in this draft and the existing Plan to essential community infrastructure and amenity needs. Every square foot of every type of development that a landowner buildsor preserves--has an impact on the community around the property community-wide as the preceding discussion on jobs:housing balance highlights. Flexibility accruing to landowners in ranges of mix of housing vs. commercial uses in Plan language, as exists in the current Plan, consistently results in development that generates the greatest profit, not the development that is best for the community as a whole as defined in the full range of its vision and planning principles. For example, the imbalance in housing vs. jobs in the current Reston Town Center is a function of flexible language in the Planand the Countys failure to enforce the Plans intentions by granting exceptions. The Countys failure to enforce the current, and presumably future, Plans intentions is further undercut by the Countys record of less-than-effective negotiation and management of proffers on behalf of the community. The obvious example is transportation proffers, which are miniscule in comparison to the congestion produced by the permitted development. But the same issue applies to provision of open space, contributions to public facilities development, and other. Each new development erodes the quality of life in Reston because of the Countys failure to sustain its and the communitys standards. Finally, the legally irrelevant language of should do this or that is encouraged throughout this draft all but assures that the intentions of the Plan will not be achieved. In the attached edited draft of the Plan, we have offered alternative language in most of the places this phraseology is used. In general, we substitute must or requires for the phraseology offered in the draft. The 59,000 of us who live here and the thousands more to come, including the 17,000 owner-occupied homes in Reston valued at more than $9 billion and climbing, have a stake every bit as large as developers in our community, if not larger. We very much want to see Reston develop in a manner consistent with all the elements of its vision and planning principles and not leave fulfillment of that vision to the discretion of developers because of weak planning language. 5

We appreciate your serious consideration of these substantial proposed changes in the areawide plan draft and look forward to reviewing the next draft as well as the TOD area-specific draft plans created by the Department of Planning and Zoning. On behalf of the Reston Citizens Association, Sincerely, Terry Maynard RCA Representative Reston Master Plan Task Force

Alternative Jobs-to-Households Ratios in Reston

Jobs 71,287 70,037 1,250 98% Residents 58,404 11,720 46,684 20% Households 25,522 5,860 19,662 23% HH Size 2.29 2.00 2.37 J:HH Ratio 2.79 11.95 0.06 J:W Ratio 4.47 7.47 0.04

2010 Existing Reston-wide TOD Area Non-TOD Share % in TOD Area

2030 Scenario G TIA Forecast Reston-wide 91,276 TOD Area 88,776 Non-TOD Share 2,500 % in TOD Area 97% Forecast at 3:1 J:HH ratio about 2050 Reston-wide 145,000 TOD Area Non-TOD Share % in TOD Area 135,000 10,000 93%

93,540 42,353 51,187 45%

43,922 21,177 22,746 48%

2.13 2.00 2.25

2.08 4.19 0.11

3.33 2.62 0.07

102,950 66,000 36,950 64%

48,333 33,000 15,333 68%

2.13 2.00 2.41

3.00 4.09 0.65

4.80 2.56 0.41

Forecast at 2.5:1 J:HH ratio about 2050 Reston-wide 145,000 TOD Area Non-TOD Share % in TOD Area 135,000 10,000 93%

123,540 76,000 47,540 62%

58,000 38,000 20,000 66%

2.13 2.00 2.38

2.50 3.55 0.50

4.00 2.22 0.31

Forecast at 2.0:1 J:HH ratio about 2050 Reston-wide 145,000 TOD Area Non-TOD Share % in TOD Area 135,000 10,000 93%

154,425 96,000 58,425 62%

72,500 2.13 48,000 2.00 24,500 2.38 66%

2.00 2.81 0.41

3.20 1.76 0.26

Sources & Assumptions: 1. Existing HH & Pop data from US Census 2010, Reston CDP 2. Existing jobs: Jobs count is GSF per worker times occupancy rate (84% office, 90% other) 3. 2030 DPZ "Scenario G" TIA Testing Scenario (83% of CP potential development) 4. 2030 forecast assumes significant non-TOD worker growth, mostly at Lake Anne VC.

5. 2030 forecast assumes moderate household (10%) & population (5%) growth from non-TOD apartment/condominium re-development. 6. Forecasts based on longer term J:HH ratio targets are derived from 2030 Scenario G TIA forecasts. 7. Alternative J:HH target ratios keep share of residential development in TOD areas near 53%. 8. Number of jobs outside TOD areas increases some as non-TOD HHs/population increases, largely on VC redevelopment.