CBAR comments on PIP and Open Space PSS Proposals

Print Friendly, PDF & Email

I submitted the following letter on Tuesday, June 28 to Mr. Casey Anderson, Chairman of the Planning Board, and the Planning Board Commissioners. The issue of the Parks Impact Payment will be revisited by the Planning Board at Worksession #16 on Thursday, June 30.

As of June 24 the Planning Staff have received three letters opposing the Staff proposal and/or suggesting a much lower contribution by the developer community.

To express your support for equitable consideration of developers, property owners, and community interests, please click here to send an email to the Planning Board. Edit the message however you wish. Be sure to sign the message with your full name!

Until next time,


Dear Chairman Anderson and Vice-Chair Wells-Harley, and Commissioners Dreyfuss, Fani-Gonzalez, and Presley:

I am writing to support several staff recommendations that were introduced at Worksession 14 (BDP_worksession 14_060916combined.pdf) to incorporate high quality, open green space into the Bethesda Downtown Plan, which is necessary to grow Bethesda into a successful and desirable city. I am especially supportive of most recommendations set forth in the Parks Impact Payment and Priority Sending Site proposals.

I am also encouraged that the Board is evaluating options that would allow County-owned public parking lots to be converted in whole or in part to parks. I want to emphasize the absence of active recreational spaces in downtown Bethesda, and contrast it with our projected population and the County-wide lack of transit-oriented recreation facilities. Converting publicly owned parking lots into parks, as opposed to selling private building development rights on this land, is a logical way to boost the extremely low percentage of public open space in Bethesda. I am working with area residents to refine our collective understanding of the complex issues surrounding the County-owned public parking lots, and will follow up with a separate letter.

As with previous letters, please note that while I am the only signatory, I am copying local community leaders as a courtesy. I ask that any responses be directed to all recipients.

Parks Impact Payment (PIP): Necessary

The Staff recommendation for combining a Parks Impact Payment with Priority Sending Site incentives is the only proposal thus far that has any promise of fulfilling the Parks and Open Space goals (section 1.3.6). Bethesda needs more dedicated park space to bring the downtown area into balance as density increases. Importantly, parks will be needed sooner than later to counter the loss of mature shade trees as construction begins for the Purple Line along the Capital Crescent trail, for the expansion of B-CC High School, and for all other construction throughout the plan area. As planning Staff learned through the public comments process, the greater Bethesda area community values green space as a top priority.

PIP Pricing Methodology: Equitable

I support the Staff’s pricing methodology for calculating the Parks Impact Payment as recommended on slide 29:

Moderate Cost Estimate * 75% Proportion PIP Funding
Available BOZ Density

The three parameters are supportable for the following reasons.

Moderate Cost Estimate
  • With so little land available, small urban parks need to be high quality areas. It is important that public spaces are built with public enjoyment and safety in mind.
  • The moderate estimate allows some flexibility in the plan. For example, less expensive parks can complement and link to more expensive, multi-use spaces.  
75% Proportional PIP Funding
  • Urban buildings that are close to beautiful public spaces are in higher demand, and thus more profitable. Developers bear no risk from contributing to the PIP pool, and will earn financial rewards simply by proximity. It is appropriate that those who stand to profit the most should invest the most.
  • Montgomery County taxpayers should pay no more than 25% of the total bill, as those outside the downtown area will not enjoy the same level of benefit as local residents and businesses.
Available BOZ Density
  • The Available BOZ (Bethesda Overlay Zone) Density is an appropriate denominator because it recognizes that the increased need for public park space is a consequence of increased density.
  • Linking the Parks Impact Payment with available density is also consistent with the Plan Framework presented in section 1.2.2 of the Staff Draft: “With the increase in density proposed by this Sector Plan, enhanced public benefits are expected with any new development.”

Increase Density and the Public Good

I also note that the Parks Impact Payment proposal is a good and fair deal for developers in that it makes incentive (bonus) density accessible to all eligible property owners at nearly half the cost of what can be obtained through density averaging under the 2014 Zoning Ordinance, Optional Development method (division 4.5.4). (See the next section regarding eligibility and the edges.)

Incentives for Open Space Priority Sending Sites: Necessary and Equitable

The Parks Impact Payment fund will accumulate money and sit unused until land is acquired. In order to compensate and encourage property owners of designated Open Space Priority Sending Sites to convert their land to public parks, I support the Priority Sending Sites Working Draft Incentives and Staff Recommendation for additional incentives (slide 31):

  • Lift the 1/4-mile restriction for incentive density averaging

IMPORTANT NOTE: Density from any priority sending site (regardless of its designation as Open Space, Landmark, or Affordable Housing) should be transferred only into the High Performance Area (see Figure 2.18). Further, design guidelines should define additional “edge” areas and make clear that incentive density from any source can never be imported into edge areas. This is necessary to fulfill the Plan goal of protecting neighboring communities from excessive development.

  • Eliminate the requirement for common sketch and site plans
  • Remove the BLT (Building Lot Termination) requirement for priority sending site density
  • Keep the MPDU requirement for mapped density in the Bethesda Downtown Plan at 15%, and reduce the MPDU requirement for PSS incentive density to the County’s lower level of 12.5%
  • Remove the Park Amenity Payment (the “PIP”)

Note that slide 32 lists suggestions that Staff evaluated and explicitly do not recommend. I agree that these suggestions should not be approved by the Board, as they do not treat builders, property owners, and the community equitably.

In contrast, the current Staff proposal benefits all stakeholders:

  • Builders who wish to exceed their mapped FAR will gain significant value from acquiring incentive density from a Priority Sending Site (see incentives above).
  • Because their incentive density offers much greater value than the alternatives, Priority Sending Site property owners can negotiate higher prices and thus receive necessary and appropriate financial rewards for extinguishing their development rights.
  • With the above incentives to private property owners, Open Space Priority Sending Sites have a much greater chance of being converted from private land to public parks early in the sector development process. Additional parks are needed sooner than later to help relieve area residents from the stresses of ongoing construction and to attract customers to local businesses.  


Only 2.2% (9.9 acres) of the 451 total acres in the Bethesda Downtown Plan area is currently dedicated to open space. Planning Staff propose an additional 12.3 acres, which, if fully implemented, still amounts to only 4.9% of the total area. This number is substantially less than the green space in successful and desirable cities. For example, green space occupies 51% of Vienna, nearly 40% of London and almost 20% in New York City and Washington DC. Bethesda is far behind, and risks becoming increasingly less competitive compared to neighboring jurisdictions. The only way to get ahead is with deliberate and smart urban planning that takes a holistic view of how cities become desirable.

To summarize, the Parks Impact Payment and Priority Sending Site incentives are necessary, balanced, and consistent with Plan goals.


Mary M. Flynn
Founder, Coalition of Bethesda Area Residents
4114 Blackthorn St, Chevy Chase


  • Montgomery County Planning Department: Gwen Wright, Planning Director
  • East Bethesda Citizens Association: Lisa Volpe McCabe, president
  • Town of Chevy Chase: Scott Fosler, mayor
  • Chevy Chase West Neighborhood Association: Naomi Spinrad, vice president
  • Sacks Neighborhood Association: Cristina Echavarren, president
  • Edgemoor Citizens Association: Judy Gilbert Levey, president

Mary Flynn is a resident of the Town of Chevy Chase and the founder of CBAR.