Provide feedback on the draft Public Land Site Evaluation Guidelines.

The proposed guidelines contain the following:

2. Once a site is recommended, staff will perform a pre-planning site evaluation, considering the following criteria:
a.
Site Characteristics
vii.
Parcel size, dimensions, and other physical characteristics; Existing conditions and inventory of uses – which may include data on daily users; special event attendance/use; history of attendance if available; etc. Transportation and multi-modal accessibility; Environmental features, such as Resource Protection Areas and tree canopy;....

The phrase "tree canopy" is too general. The section should state "tree canopy, to include the number of mature trees that the project may adversely impact". In addition, thia section should specify "presence and area of any natural areas on and near the site".

The proposed guidelines also contain the following:

6. In addition to the criteria listed in 2a, any planning process involving County-held land should also consider the following evaluation criteria:
a. County Policies and Priorities i. Conformity with the County’s articulated goals and policies with
regard to parks and open space; affordable housing; historic preservation; land use; transportation; parking; accessibility; energy, sustainability, and the environment; and education; among others;

This section is too general. I suggest that the guidelines specifically cite the Public Spaces Master Plan and other relevant specific elements of the County's Comprehensive Plan.

As an additional comment, I consider it to be unacceptable to utilize public property for private purposes, such as affordable housing. Such usages give private parties, including parties that operate and occupy facilities on a public property, control of part or all of the property. These private parties will gain the right to exclude members of the public from the portion of the property that they operate or occupy. As an example, members of the public who do not meet criteria for occupancy of affordable housing will be excluded from a public property that is used for such housing. As a matter of principle and fairness, a County government should not limit any of its public properties to the exclusive use of any private parties.

Therefore, one criteria should be: "Absence of barriers imposed by a proposed private use of a site that can prevent any members of the public from fully utilizing the site because of personal or household income or other restrictive factors".

Another criterion should be: "Objections of neighborhood civic associations to a proposed use of the site." This is important, as several civic associations have already expressed their opposition to one or more of County Manager's proposed sites (for example, the proposed use of the Lubber Run Community Center site for affordable housing, which at least three affected neighborhood civic associations now oppose).

Parks should remain parks. It's very simple. Parks are the essence of a public good.
As the population rises and density increases, we need to work harder to keep Arlington special. Preserving our parks is one way to do it.
-- Schools can build up not out.
-- Affordable units should be included in new developments, and every time a developer requests a variance. (Housing is a private good, not a public one).

The County Board charge for PL4PG stated the purpose “The County Board is the steward of the community's public land. In that capacity, we have a responsibility to assure that land decisions consider how best to provide what the community needs ‐ schools, parks, recreational opportunities, and facilities.”

The public good is what benefits a broad constituency and ranges from housing (affordable, elderly, disabled, homeless) for 22,200 households making less than 60% AMI, schools for all families and the 24,529 students attending, parks and recreation for use by all, public safety for all, transportation for all, and economic development to fund these broad initiatives and keep residential property taxes reasonable. The priorities are not exclusionary. The limited space and growing population in the county now means considering multiple priorities for land use. In the past this was not a concern.

The Arlington Mill public and private partnership is one of many examples of multi-use of public lands. The parking garage over I-66 by Washington-Lee high school takes advantage of air rights to provide a needed parking solution. The Westover Library and Reed School combined two valued community functions. The Thomas Jefferson middle school also shares space with a community center. Beyond Arlington is the Station at Potomac Yard in Alexandria combined affordable housing on top of a fire station, a public safety facility. There are many examples of multiple use of public land.

Let’s be reasonable. PL4PG is an additional to practices and policies the County Board already uses to address community needs. It’s not usurping, replacing, or abolishing others successfully used to meet diverse priorities. Those remain. What it does, for the first time, is broaden the discussion about public land use to consider creative, innovative, and different uses of a precious and limited resource. Arlington used to be a farming community and evolved to become a residential community. Metro and other public transportation investments transform it into an urban community. Planning and land use also needs to evolve.

I am glad to see Chairman Fissette’s letter of 10/30/2014 finally clarifying no “Tier III” sites and position on parks.

I believe that there are additional site characteristics that the County must consider in selecting public sites for development.
1) Environmental impact of building housing on the site
2) Density
3) Availability of services
4) Distribution of affordable housing
Lubber Run is a small oasis of green in the ever increasingly dense Ballston area. Building housing on the site will have an adverse environmental impact, and I do not believe that the area has sufficient services to support the additional population. The schools and stores (e.g., grocery stores) in the area can barely support the population that is there. This means that the residents of new housing must have cars to obtain the services they need so any advantage of being near public transit will be negated.
Finally, I believe the guidelines need to consider distribution of affordable housing. It should be developed throughout the County. There already is a great deal of affordable housing in the Ballston area and more is planned. Developing “affordable housing” in only one area of the County will have long term impacts that will be very costly for the County to address.

Arlington's schools are in the midst of a capacity crisis. Each new seat costs about $100,000, excluding any land costs. Arlington's Site Plan Review Process currently fails to consider the impact of large housing developments on Arlington's schools. The Site Plan Review Process should be modified to correct this oversight. Before developments are approved that will further increase the population of school-age children, the county should seek and obtain proffers to support the additional school infrastructure that will be required to service the new development's residents.

I support efforts to ensure geographic distribution of affordable housing throughout the county. The county should consider rezoning the old and often decrepit single-story strip malls along Lee Highway to allow for redevelopment with two or three stories of housing above the retail establishments. I oppose concentrating affordable housing in a few parts of the County. This puts even more pressure on public schools and county services in those areas.

Since VOICE is so strongly in favor of building housing on public land, the county should engage in discussions with VOICE's Arlington congregations about constructing affordable housing of the tax-exempt land belonging to those congregations, particularly their large surface parking lots.

If public land is required to support affordable housing, the county should purchase land for those projects using funds obtained through bond referenda. If support for affordable housing is as strong as Arlington's leaders would have us believe, there should be no problem in getting such referenda passed.

Parks are public land used for public good. Arlington has add only 76 acres of parkland over the last 20 years. This is woefully inadequate given Arlington's population growth and has meant that per capita parkland acreage has actually decreased by fifteen percent over the past two decades. In 1995, Arlington County had 10.8 acres of parkland per 1,000 residents. During the same period, Arlington's population grew by over 43,000 people. So the county acquired less than two acres of parkland for every 1,000 new residents and the ratio of parkland to population fell to its current 9.2 acres per thousand residents.

According to the county housing department, Arlington will add 30,500 households by 2040, an increase of thirty percent. All these new households will need services: schools, fire stations, transportation, parks, playing fields, libraries, recreation/community centers, etc. Almost all of these new households will be in multi-family buildings, mostly mid- and high-rise apartments and condos without much open/green space of their own, the need for open, green, and recreational spaces becomes even more acute. It would be irresponsible to build housing on scarce public land that should be used to provide community/recreation services to the public.

I support preserving and adding to Arlington's scarce parks and community/recreation centers to provide community/recreation services to Arlington's rapidly growing population. I oppose the use of parks and community/recreation centers for any purpose other than parks and community/recreation centers.

I support Arlington's Smart Growth model and I support preserving Arlington's single family neighborhoods as single-family neighborhoods. I oppose the construction of large multi-family apartment complexes within single family neighborhoods.

P. 1, para. 1: remove the last word, "facilities", and add "affordable housing". Or retain "facilities" and add "affordable housing".

Para 2: List the guidelines the County used in selecting the eight sites.

Para 2: Provide 5-6 examples of County needs that the sites could meet.

Para 3: Define and describe with examples "a balanced approach."

Para 5: Why describe the guidelines as assuming a site has already been identified as the best location to meet a need? If it's already been selected, why assess it again? OR Employ them if it appears that a much better result could be attained.

Page 2, para 1 and 2: Describe a balance to edify residents.

Describe "separate need assessment", site selection process, pre-planning site evaluation and evaluation using the guidelines and scope of study and the community review process. Perhaps the County could develop an assessment process that includes basic guidelines at the beginning. Then the County could transform the basic guidelines into parts of a second assessment and, perhaps a third, lessening the number of assessments from the six or so that it conducts presently.

I believe the Evaluation Guidelines are not specific enough nor do they meet the desires of the community to comment on the concept of Public Land for Public Good. They also do not serve for the broader discussion of the appropriateness of the sites identified for the development of housing that is affordable for low and moderate income households or for schools. I support Public Land for Public Good for all the uses of parks and recreation, public facilities, affordable housing, and schools and I recognize that in our small county that it is challenging. We can do it with creativity. Arlington Mill is a great example of co-locating a community center and affordable housing and should be replicated. It would also be appropriate to add affordable housing above libraries, schools, firehouses, and other public buildings so that our parkland can be protected. While there are structural limitations on adding to existing buildings it should be pursued when possible. Another choice could be retrofitting existing private buildings. But, schools can't wait. There is an urgent need for classrooms as soon as possible.

Comments on draft Public Land Site Evaluation Guidelines ("the guidelines")

* Parks and parkland should not be under consideration for any purposes other than parks and recreation uses. More specifically, any proposed repurposing of parks, parkland, and facilities/structures within park boundaries should be prohibited. I recommend modifying the "Site Evaluation Process and Criteria" section of the guidelines to include language to this effect; the language should rule out any consideration of a site if it is (in whole or part) a park, or was acquired with the intent of being used as a park, or contains a recreation center/facility. Additionally, it should make clear that repurposing (in whole or part) of buildings, structures and facilities within parks should be prohibited. Many parks have “developed” portions (e.g. parking lots, visitor centers, community centers, bathrooms, etc.), but just because these “developed” items may exist does not mean they should be considered fair-game for additional purposes.

Beyond the subset of public land that parks represent, I believe that the County does not have as broad and deep support for pursuit of additional subsidized housing as it might believe. For example, the County's ongoing affordable housing study has recently produced a survey that purports to show strong support for the County's affordable housing efforts. However, that survey did not ask about specific proposals, and, as such, does not support the conclusion that residents are in favor of using public land, in general, and park land, in specific, for other purposes such as housing. In contrast, when asked about specific proposals for repurposing sites such as those identified in the Manager's "Public Land for Public Good" (PLPG) report, most residents are opposed, many strongly so. For example, a recent survey conducted by the Arlington Forest Citizens Association showed almost unanimous consent in opposing a housing development at the Lubber Run Community Center (LRCC) site (one of the sites identified in the County Manager's PLPG report). The lesson here is that broad assertions that “I'm all for affordable housing” often vanish when individuals are confronted with specific projects at specific locations in their neighborhood.

* The guidelines are sufficiently vague that almost any use of public land could be justified. As such, I believe that they are not useful for their intended purpose. Almost any repurposing of public land could be justified under these guidelines, and participants in the process could reasonably argue that all of the guidelines were stringently followed. At its core, the guidelines document specifies that when a site is being considered, an "advisory commission or group" will "collaborate with staff to maintain a balance among county priorities"; a number of factors that should also be "considered" are listed. However, there is no guidance on how priorities should be balanced, and this is a fundamental omission.

For example, how might one decide to balance the hypothetical "priority" of adding a number of affordable housing units to a community center against the priority of maintaining parkland, and not negatively impacting the economic well-being of community members who find that the park across the street is about to become the site of an affordable housing facility? What units would one use to quantify these priorities, and what weights would one assign to these priorities to judge if they were balanced? At the risk of sounding pedantic, the devil is truly in the details, and there just aren't any details specified here. In the absence of any precise measures that can be used to perform this balancing act, I fear that this “balance” will likely be achieved based on participants' subjective judgments, which will undoubtedly reflect those participants' preferences and opinions. One person may decide that adding housing would be the “balanced” solution, and another may disagree. These guidelines offer no hints on how to resolve this predictable conflict.

To be clear, I recognize that the guidelines document mentions items that can and should be quantified as part of the evaluation (parcel size, dimensions, physical characteristics, etc.). And, these items give the patina of an objective process. However, the collection of statistics and descriptive information should not be confused with a well defined process for "balancing priorities".

* If the County wants land for a purpose, a better approach is to purchase it. In fact, Arlington has a demonstrated track record of being able to do this: Jay Fisette has repeatedly noted in recent days that the County has added 76 acres of open space over the last 20 years. He has also noted how the County is one of the most affluent in the country. To the extent that the County's residents are strongly supportive of a project (such as, but not limited to, affordable housing), I believe that the County should acquire new land for that project. Given Arlington's demonstrated track record of land acquisition for parks over the last 20 years, it is not plausible that one of the richest counties in the country cannot find the resources to acquire land for projects that are broadly supported by its residents.

* Geographic distribution should be added to the evaluation process. One of the criteria that is notably absent from the guidelines is any consideration of geographic distribution of "public good" projects. This is relevant for many different types of “public use” but especially relevant for affordable housing. I believe it is important that new subsidized, or "committed affordable" (CAF), housing should be much more broadly geographically distributed. In about half the neighborhoods in the County, there are currently no CAFs. However, in a few neighborhoods, more than a third of all units are CAFs. A concrete example of the poor current geographic distribution is in the vicinity of the LRCC site: Approximately one third of the County's entire stock of subsidized housing is within half a mile of the LRCC site; the area already contains one of the highest concentrations of subsidized housing in the County. It goes without saying that dense clustering of subsidized housing is a bad idea. Adding more concentration to this area is an even worse idea. The guidelines should be modified to explicitly consider geographic distribution as part of the evaluation process, and prohibit additional concentration of housing in regions of the County where it is already dangerously clustered.

* The Long Range Planning Committee of the Planning Commission Meeting and comments by Jay Fisette were premature. The comment period ends on October 31, although a meeting of the Long Range Planning Committee of the Planning Commission Meeting to "receive and review public comments" on the draft Public Land Site Evaluation Guidelines ("the guidelines") was held on October 28. Leaving aside the obvious irony that a meeting intended to "receive and review public comments" prohibited any comment from the public in attendance, and leaving aside the fact that not all of the commission members had actually read the comments, it seems obvious that a meeting to review and synthesize comments before the comment period is over is, at best, premature.

Similarly, the October 29 missive from Jay Fisette (posted at http://arlingtonva.s3.amazonaws.com/wp-content/uploads/sites/31/2014/10/PLPG_MessagefromCBChair_2014-1029.pdf) that characterizes “many commenters agree[ing] with these goals and practices” is not only premature, but misleading; even a causal reading of the comments received to date show that a majority of comments do not, in fact, agree with these goals and practices.

-Salvador D'Itri-
I do not support using parkland for private good, especially at Lubber Run Community Center where an expanded concrete footprint would be needed even for an underground parking lot on the same "footprint". I do support affordable housing and encourage the county to engage with church leaders to see which sites are budgeting for facility rebuilds. A partnership between developers for a mix of affordable units and market rate unit development with a small multi-use building for church activities might ease the infrastructure burdens on local churches. I encourage the county to publish a report on the discussions with church leaders on the opportunity for private collaboration to address affordable housing.

I respectfully request that the Lubber Run Recreation Center site be preserved for recreational use only. With the County's population expected to increase by 30% in the next 25 years, a shortage of recreational space will be
inevitable. Let's use County funds to purchase space for school and affordable housing, not encroach on existing
recreational and park land. Also, Buckingham and other nearby affordable housing already show that the Barrett
school jurisdiction already contributes to the County an above-average density of affordable housing. Affordable
housing should be located throughout the County, not concentrated in a few areas - a lesson long ago learned by public housing specialists across the country.