October
31, 2006
To: Fairfax County Planning Commission
Re: APPLICATION RZ/FDP 2004-PR-044
Fairfax Citizens for Responsible Growth, Inc. (FairGrowth) would like
to register our opposition to the above-referenced application at the
present time. If the developer declines to defer its application,
FairGrowth urges that the Fairfax County Planning Commission recommend
denial on the grounds that it does not comply with the Fairfax County
Comprehensive Plan’s transportation requirements for the Tysons area.
The Comprehensive Plan (CP) for Tysons Corner states that, "To
accommodate higher levels of development (significantly above the
current zoning)...the planned roadway system [would] have to be
implemented." The CP also says, "To accommodate the level of
traffic likely to be generated by this level of development, the
planned transportation system would need to be fully implemented" (see
http://www.fairfaxcounty.gov/
dpz/comprehensiveplan/area2/tysons1.pdf ). Since the planned
transportation system will not be fully implemented in the forseeable
future, this rezoning goes against the recommendations of the CP.
The transportation deficiencies have been outlined in resolutions
approved by the McLean Citizens Association and the Providence District
Council.
Tysons Corner is going through a historic redevelopment that will
reshape this regional hub for the next 30 - 50 years. All citizens will
be much better served if this new Tysons has fully integrated
transportation networks and design standards. This is best achieved by
including the Tysons 1 property as part of the broader task force
study of Tysons Corner’s future. That can only happen if the zoning
application does not go forward at this time.
Given the stakes, allowing the time for thoughtful, integrated planning
is an important investment in our county’s future.
We are concerned that this application represents another example
of piecemeal planning, which is contrary to a more coordinated
approach that is necessary for the proposed Tyson's rail line corridor
according to Transit-Oriented Development (TOD) principles.
FairGrowth is particularly concerned that this application is being
considered even as both the Transit-Oriented Development committee and
Tysons Task Force continue their respective yet related work.
Specifically, consideration of the application at this time is contrary
to the TOD principle of Transit Node Specialization. In its paper
"Transit Oriented Development: Moving From Rhetoric to Reality,"
(Belzer & Aulter, 2002) the Brookings Institution's Center on Urban
and Metropolitan Policy stated that transit agencies and local planners
should work together in order to:
"Plan for TOD at the system-wide scale, assessing opportunities at each
station site and thinking regionally about the interplay between land
uses around each station and the way they can affect system-wide
ridership.
"Although each individual station must balance node and place functions
to some extent, the value of the system as a whole can be enhanced if
there is some degree of specialization. In addition, from a
market perspective it does not make sense to try to force a mix of uses
that is radically different from what is in demand. Goals of TOD can
sometimes be enhanced more at the regional level than at the local
level.
"Thus, many of the stations along the extension will be fairly
specialized, but the line as a whole will provide a reasonable mix of
jobs, housing, retail, and commuter parking. While the details of the
development along the line can be criticized, the overall concept of
specialization works well. Even when specialization is not
carried to the same extent as in this example, any TOD project will be
made more effective if it is planned with other station areas in mind"
(
http://www.brookings.edu/es/urban/publications/belzertod.pdf,
page 32).
FairGrowth has reiterated on numerous occasions that Transit Node
Specialization is an important concept, and we do so again here.
While the staff report attempts to address some traffic, school and
other impacts, there does not appear to be any coordination with the
impacts of other significant proposals along the Tysons rail
line. Not only does there appear to be little attempt at
maximization of a mix of uses along the new line, but there appears to
be little attempt at coordination. Such coordination is
essential, especially for TOD sites.
Underscoring again the piecemeal nature of this proposal is the fact
that instead of being the result of intensive community dialogue, this
application comes from an interested party. While it is their
right to make such a proposal, this process does not pass muster with
the community involvement component that the TOD committee is showing
is so vital to a successful TOD project.
FairGrowth has previously cited an Urban Land Institute commentary,
which states:
"Smart growth is a process, a dialogue, a way to build consensus; it
does not hand down preconceived notions or plans for development."
(Bill Hudnut, "What is Smart Growth Not?" - Urban Land Institute
Commentary at
http://www.uli.org/AM/Template.cfm?Section=Commentaries&CONTENTID=5395&TEMPLATE=/CM/ContentDisplay.cfm.)
Yet once again, it appears that instead of being crafted from the
collective, collaborative efforts of the community, developers, local
officials and the transit authority, another preconceived plan is being
handed down.
For these reasons, the Commission should reject the application at this
time, and integrate any proposals for this site into the larger work of
the TOD committee, Tysons Task Force and broader community involvement.
Thank you for your attention,
Sincerely yours,
The Board of Directors
Fairfax Citizens for Responsible Growth, Inc.
http://www.FairGrowth.org
FairGrowth@fairgrowth.org
"FairGrowth: Transit-Oriented Development with Community Input"