Comments as the public record closes

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This is it. The public record closes Tuesday, November 1. I will submit the following written comments to the Montgomery County Council and Board of Education. To stand with residents throughout the area who all want adequate schools, transportation, parks, and compatibility plans for residential communities, please click here to send an email. Edit the message however you wish. Be sure to sign the message with your full name!

Thanks for all you do,



  • Full CBAR written comments with appendices
  • White Paper on the July 2016 Draft Bethesda Downtown Sector Plan: Is the Plan “In Balance” and does it Provide Adequate Public Facilities?

Members of the Montgomery County Council:

Thank you for the opportunity to provide written comments regarding the proposed Bethesda Downtown Plan. The Coalition of Bethesda Area Residents (CBAR) is a grassroots organization supported by residents and community leaders who live in, adjacent to, and near the Bethesda Downtown Plan area. All of us will feel the impacts of the final Plan.

This submission provides input on how to bring four troubling components of the Plan into balance: Parks, Schools, Transportation and Compatibility with Edge Communities. We also discuss the community’s strong desire to incorporate an “Infill Staging Policy” in the Plan to address deep concerns about the impacts of ambitious growth during its short 20-year time period.

We submit as part of our testimony a white paper prepared by Town of Chevy Chase resident, John Freedman. It exposes problems in how the Planning Board concluded that traffic, schools, and other infrastructure capacity is adequate for the proposed development. It is because of these problems and other issues of great concern that we respectfully submit the following comments that expand upon the CBAR testimony delivered at the Public Hearing on October 18, 2016.


The CBAR community does not oppose development. We understand that density, when supported by adequate public facilities and a strong sense of place, can provide environmental and economic advantages. Our objection is that Bethesda does not adequately support the current population with adequate public schools, parks, or transportation infrastructure, and the Bethesda Downtown Plan makes no effort to improve them to support the proposed population.

We come to this conclusion after observing and participating in the 17 Planning Board worksessions, and through a long and disciplined analysis of the data. Based on that analysis, we see the Plan calling for a 91% increase in households, an 89% increase in population, and a 135% increase in employees:

2015 MW-COG

Rnd 8.4

2040 MW-COG

Rnd 8.4

20 Year Plan Projections Plan Projections Above MW-COG
Households 9,207 12,545

(+3,338 | +36%)


(+8,456 | 91%)



Population 18,127 25,060

(+6,933 | +38%)


(+16,060 | +89%)



Employees 38,411 49,540

(+11,129 | +29%)


(+51,900 | +135%)



Considering that (a) the entire County suffers chronic overcrowding in the schools, (b) the Wisconsin corridor and many of its cross-streets are gridlocked and an overhauled Metro maxes out at 43,000 to 45,000 passengers an hour, and (c) the only undeveloped land that could be used for parks are the County’s surface parking lots, it is entirely reasonable to question how current infrastructure will support the level of growth proposed in this Plan.

Our recommendations are few, respect the premise that redevelopment should occur, and are overarching in nature. We anticipate that County officials and staff will work with each other and our communities to determine how to implement each recommendation.


You have heard extensive testimony from parents concerning the quality of our children’s public educational experience. Overcrowding is now a County-wide, chronic problem that must be addressed holistically and independently of the Bethesda Downtown Plan.

In the context of this Plan, residents are deeply troubled that both Bethesda Elementary and B-CC High School are overcrowded and lack any room for expansion. The remediation options listed in section 2.8.4 are vague, some have been discounted in the past as unfeasible, and in some cases the same remediation options have been proposed to other MCPS clusters. Unlike other areas of the County, there’s no land left for building new schools.

Most troubling is the preference in the July 2016 Planning Board draft for outdated information. Planning Department staff explained to CBAR that MCPS wrote section 2.8.4: Educational Facilities, for the May 2015 Staff Draft. Michael Durso, president of the Board of Education, updated the official guidance in a March 24, 2016 letter addressed to Planning Board Chair Casey Anderson and County Council President Nancy Floreen. This official letter also raised concern that the combined effect of the Bethesda Downtown, Westbard, and Lyttonsville plans were “coming at a time when many of the schools in the area either currently exceed capacity or are projected to exceed capacity in the near future.” (Note that missing from this letter is the additional enrollment B-CC High School will experience as a result of the Chevy Chase Lake sector plan.)

It is deeply troubling that the July 2016 Planning Board draft retained outdated information. Section 2.8.4 is clearly invalid, and must be revised prior to approving the Plan.

Therefore, CBAR communities request that County Council staff collaborate with the Board of Education staff (MCPS) to:

  • Provide realistic student generation numbers for the proposed housing units (currently in section 2.8.4, pages 92-94)
  • Include feasibility and capacity assessments for each remediation option offered in the Plan
  • Identify sites in the Plan that are suitable for new school construction (Figure 2.24, Community Facilities, page 89)


Another area of concern for many residents is traffic. After careful analysis, we have come to the unfortunate conclusion that the draft Plan used transportation test and analysis methods that are flawed, and resulted in conclusions that do not represent our day-to-day experience.

Attached to this report is a white paper authored by John Freedman, a private citizen who lives in the Town of Chevy Chase, that thoroughly sets out the inconsistencies and errors. We urge you to review it carefully and recognize that the inadequacies exposed in the paper are embedded in the Plan’s traffic analysis.

To remedy the resulting bias in the Plan towards transportation adequacy, CBAR communities request a new transportation study from an expert third party, such as the National Transportation Center at the University of Maryland. To assuage residents’ concerns about the validity of a revised traffic study, we recommend that the data, assumptions and commentary be published with a revised Plan.


Public amenities, and parks in particular, attract employers, employees, residents and visitors to an area. They are “place makers.” As Bethesda buildings start reaching for the sky, the County must foster a strong sense of place on the ground through its public amenities requirements. Parks are the foundation for that work.

Unfortunately, the promotion of parks as the number one priority in the Plan leaves residents disillusioned, as the proposals do not match the vision. CBAR added up every fraction of an acre of proposed park and open space in the Plan (see the appendices), and applied two standard metrics to assess adequacy:

Total proposed Parkland acreage at full build-out (in acres)
Source: Appendix A
Parkland area as a percentage of total acres
Calculation = 18.19 / 457 acres in total Plan area
Acres per 1000 people
Calculation = 18.19 / 34.2

As a priority, the parks proposal fails. At full build-out:

  • Park land as a percentage of total Plan area acreage tops out at a mere 4%
  • Acres per 1000 people is a dismal 0.54. For comparison, Washington DC provides 13.2 acres per 1000 people.

Also note that we are disappointed with the lack of implementation planning. On June 28, CBAR wrote in support of the Parks Impact Payment and Open Space Sending Site proposals ( While many residents and communities support a specific dollar amount, CBAR never did. Instead, our support was focused exclusively on the logic of the pricing methodology proposed by the Planning Department:

Moderate Cost Estimate * Proportional Developer Funding

Available BOZ Density

A pricing methodology is a necessary component in implementation planning. Disappointingly, the pricing methodology was never discussed in the Planning Board Worksessions. Instead, commissioners tossed about arbitrary numbers until they settled on $10 per square foot, and with that, the Board completed deliberations and approved the July 2016 Board Draft Plan 5-0. CBAR believes we need more substance in the Plan to assure current and future residents that the small number of proposed greenways, pocket parks and plazas will be built.

We also strongly believe that larger recreational parks and community event spaces must be added to the Plan, and County-owned parking lots and the open space owned by WMATA are the places to develop them. These lots are economically attractive (to taxpayers) because (a) they are already owned by the public, and (b) as the last undeveloped spaces, the public saves in deconstruction expenses.

On the parks issue, what we witnessed at the Planning Board was not planning. We witnessed politics, and perhaps fatigue. We ask that you revise the Plan to include guidance on how and when public parks will be funded, built and managed. Bethesda cannot afford not to have more recreational spaces or a parks implementation plan.


We applaud the greenway concept as a way to transition between the built-up centers of activity and residential neighborhoods. However, as currently proposed, it’s an unfair barter that brings with it excessive traffic and noise from commercial up-zoning, and imposes unacceptable heights that diminish the sense of neighborhood. We believe that the County’s economic objectives can be achieved without encroaching on edge communities. There are over a hundred “non-edge” properties with appropriate zoning capacity to build out the Plan.

Therefore, we request that a revised Plan include a new framework, specifically a Compatibility Plan, that explicitly:

  • Ensures that new development is compatible in use and scale with neighboring residences.
  • Transitions heights and densities down even more from the centers of activity into neighborhoods.
  • Guarantees a greenway that provides a truly functional transition space that is (a) sheltered from traffic and (b) connects neighborhoods to each other and with the centers of activity.

We stand with each other in our support for these common requests, and support each community’s requests to avoid or remediate potentially negative effects within and along each community’s borders.


Because residents have justifiable concerns about the impacts of development on public schools, transportation infrastructure and park space, CBAR urges the Council to modify the Plan to include explicit stages of review before development may proceed to the full 32.4 million square feet of proposed development. As we and our children experience classroom overcrowding, gridlock and transit failures, and scarcity of recreational space, it’s clear that we need to stage new development to coincide with infrastructure improvements.

Staging is not a new concept to the County and has been incorporated into prior plans such as Great Seneca, White Flint and Chevy Chase Lake. We recognize that establishing appropriate measures or triggers for an “infill staging policy” will be challenging, but we are convinced that it is necessary and the right thing to do. We are confident that County officials and staff can work with each other and our communities to determine how to proceed.


Before the Plan goes to the Council for a final vote, CBAR, with support from Bethesda communities, requests a revision that:

  1. Updates student generation rates from the Board of Education (MCPS), identifies sites that are suitable for new school construction, and includes feasibility and capacity assessments for each remediation option offered in the Plan.
  2. Designates county-owned parking lots and open space owned by WMATA as recreational parks and community event spaces, and includes guidance on how and when public parks will be funded, built, and managed.
  3. Validates transportation adequacy with a new study from an expert third party.
  4. Incorporates greenways into a new compatibility plan that limits height, density and allowable uses along the edges.
  5. Incorporates an infill staging policy that requires infrastructure improvements to support proposed redevelopment.

The public is looking to you individually and as a governing body for your leadership. Please demonstrate your commitment to serve the tens of thousands of current and future Bethesda area residents by strengthening the Plan with respect to parks, schools, transportation, and compatibility with edge communities.

Thank you for your consideration.

Mary Flynn
Founder, CBAR


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