Playing the Long Game

In spite of the repeated assurances that the changes in store for Narberth are "incremental", "mild", or that only "soft density" is being pursued, the broader agenda is hiding in plain sight.

The Narberth Borough Council Business Meeting taking place Thursday May 21^st at 7PM will be hosting an enormously consequential discussion for the future of our beloved town. It will be a rare instance wherein two of the entities with the most consequential decision-making powers impacting the trajectory of Narberth’s future will convene in the same forum. Before Council and the attending members of the public, the Narberth Planning Commission (NPC) and the Montgomery County Planning Commission (MCPC) will be conducting a presentation on the zoning changes they have been drafting together and would like to see implemented in our Borough. In spite of their insistence that the coming changes would be minor, incremental adjustments to the enacted Form-Based Zoning (FBZ) code that was originally adopted in 2016, many in the community rightfully suspect that the impacts on our built environment will be profound.

Last week, the agenda and meeting packet for Thursday’s council business meeting was published to the Borough website. It is 161 pages and features a lengthy report from the MCPC about their collaborations with the Borough and NPC in drafting the proposed changes to Narberth’s zoning code as well as an equally dense “Policy Analysis” authored by Council member Michael J. Gaudini, whom, it should be noted, is a professional land use consultant as well as a registered lobbyist for the development industry in Austin, Texas and holds degrees in journalism and public affairs and is therefore not an expert analyst, economist, or planner qualified to objectively evaluate the nuances of the proposed changes and their likely impacts on our town’s character, economy, and built environment. The items composing these two documents thoroughly validate community concerns about the potential for drastic impacts on the character of our town.

On the MCPC’s report – perhaps by design, the document contains an overwhelming amount of information impossible to adequately deconstruct in one sitting. However, there are a number of key details that all residents should be aware of, as they are highly indicative of the kind of preset agenda concerned members of the community feel is being pursued without regard for the will of the people. Indeed, this is not simply illustrated in the particulars of the proposals put forward for consideration in the immediate future, but also in the choice of case studies selected as benchmarks for reference, and the organizations and publications cited to reinforce the need for zoning reforms intended to usher in increased housing density.

Firstly – MCPC’s assertions and the proposals themselves. Much of the focus on the proposed changes revolves around the area designated as Zone 5b under the FBZ, which primarily constitutes the area of Narberth along Montgomery Avenue bordering Lower Merion Township, as well as portions of adjacent residential streets. This is because the commissions designated that commercial corridor as the site of their most ambitious zoning reforms. Responding to the overwhelming consensus that the Montgomery Avenue strip is a prime location with potential to be a thriving asset to the community which has long been and currently remains neglected and underutilized, the MCPC takes a surprising view. They posit that the lack of vibrance displayed along the 5b corridor is the result of too much focus on retail and commercial development. Whereas common sense would indicate that the blight and underutilization of this retail-oriented space is presumably the result of the ongoing neglect of commercial revitalization demonstrated by local officials in recent years in favor of a ceaseless pursuit of increased residential development, they conclude the opposite. They assert that the “existing vision for Montgomery Avenue as a mostly commercial corridor has not created a flourishing place”. They also bemoan that the major roadway is “car-centric” and state their intention to work with Lower Merion Township to “implement an alternative configuration that slows down cars, provides more traffic calming, and provides for an improved pedestrian experience when walking along the sidewalk and crossing the street”. Tidbits like these arguably provide more compelling insight into the questionable priorities of the county and local bodies that perhaps led to the deterioration Narberth finds itself reckoning with today, than any sort of misplaced focus on commercial revitalization (there has been virtually none). Working from the conclusion that there need be an increased focus on residential development over commercial, the MCPC lays out a series of proposals to act on that perceived mistake. These proposals entail some of the most controversial items among the changes the commissions deem it necessary to implement. Acting on the notion that there should be an increased focus on residential development on Montgomery Avenue, the commissions propose a larger spatial allowance in each building for residential units and a decreased spatial allowance for commercial uses. Whereas the current zoning in the 5b zone allows for mixed-use buildings with retail on the bottom floor and residences above, the commissions put forth a proposal to reduce the space reserved for commercial use to “the first 12 feet of depth facing Montgomery Avenue”. They explicitly declare that one intended impact of this change is to limit the potential business uses that structures in the 5b zone can accommodate, stating “this will maintain the retail corridor, but allow for smaller retail uses such as cafes to lease the commercial space in Mixed-use buildings”.

The next change broached in the MCPC/NPC collaboration is the one that has gained the most attention – density bonuses. A precious pet project of Council leadership and one delegated directly from the Borough to the commissions for implementation is the density bonus, put into motion in the changes assigned to the 5b zoning district. The controversy surrounding the density bonus proposal stems from its likelihood of being the most disruptive change to Narberth’s built environment as it is currently composed. At the Borough’s “Zoning Open House” in late February, representatives from the MCPC mingled with attending residents ostensibly to exchange viewpoints regarding the appropriateness of changing the FBZ, but in actuality it was a forum for the NPC and MCPC to market the necessity of the changes to a skeptical public. In fact, MCPC planner Adam Schantz, a key contributor to the drafting of the zoning proposals, emphatically insisted to attendees that the changes being considered for Montgomery Avenue were strictly limited to an increase in the allowance of floors each building can have from 3 to 4, while maintaining the current 45’ height limit. However, the proposed implementation of the density bonus in the report directly contradicts these assurances. Density bonuses are something resembling a bargain that localities engage in with developers, wherein the builder is permitted to build beyond the set height and/or other spatial limitations in exchange for reserving a particular number of units for affordable rent rates. In the commissions’ proposal, developers who are awarded the density bonus are allowed an additional floor and ten feet of building height – 5 stories and 55’. Also important to note is that what constitutes affordable housing in the context of Narberth is wildly different from what would constitute affordable housing in most other places. In Narberth and under these proposals, wherein the average income far exceeds that of most of the country, a unit is considered affordable if it can be sustainably inhabited by a median-income resident. Median income in this case is over $100,000 annually according to the chart labeled Figure 1 in the packet. In other words, Narberth would be allowing developers to build higher in exchange for units that are affordable for individuals and families who would be considered high income in most other localities and contexts.

While less remarked upon in the public discourse already ignited by the information previously released regarding the impending changes, other proposals applying to a larger swath of Narberth are equally jarring when their implications are examined. Perhaps due to its confusing nature, the commissions’ proposal for reductions in parking requirements for future residential developments has been the subject of debate but less fixated upon than the proposed height increases, as its actual impact is rendered harder to comprehend due to its opaque nature. The zoning code currently mandates a baseline 1 parking space per residential unit in developments in most sections of town as well as a 0.1 space per unit required for visitors. The commissions’ proposal would eliminate the requirement of any visitor parking as well as any parking whatsoever for “affordable units” and those 750 square feet or smaller and allow “applicants to reduce the parking mandate for other units to 0.7 spaces per unit if the applicant participates in the SEPTA Key Advantage Multifamily Residential Program”. Much of the attention garnered by this portion of the proposal has been motivated by the bizarre nature of its contents. How would this be theoretically acted upon by a builder? How would a builder actually provide one seventh of a parking space per unit? Why would renters of affordable units be less in need of a place to store a vehicle, especially when the standard for what constitutes affordability is the ability of an individual with an income of over $100,000 to pay the unit’s rent, when those individuals are likely to own an automobile? Why would an individual residing in a smaller unit be less in need of parking? Given that the budgetary crisis facing SEPTA has not been permanently resolved, but rather delayed by emergency relief granted by PennDOT, is it sound to implement these changes hinged upon the availability of public transit provided by SEPTA?

Another proposal, which may have stirred more controversy within the NPC itself than amongst the public, is the reduction of setbacks for new apartment developments. Coupled with a proposal to reclassify apartment development from a conditional use to by-right in the 4a district, a section of the borough heavily comprised of single family and duplex residential homes (which is a major change in and of itself), the commissions propose reducing required apartment building setbacks from the current 25 foot distance from the street to 10 feet, opening the door to the development of much more hulking and overwhelming structures, particularly on the south side. This change instigated debate between NPC Chair Adam Krom and Commission member Heidi Boise at the March 2^nd Planning Commission meeting, wherein Boise argued that the change was highly inappropriate for the Borough. This dissent was downplayed in the packet’s retelling, however.

Beyond what the specific proposals put forth in the meeting packet entail, the attitude and ambitions of the entities involved serve as a through line apparent in both the MCPC and NPC’s contributions and Mr. Gaudini’s “analysis”. What the commissions, Gaudini, and their partner organizations offer up as fact and the sources and case studies they cite to reinforce their advocacy for these changes illustrate vividly the agenda underlying the aggressive and unwavering push to further densify our already incredibly dense borough. Case-in-point under the section of the packet entitled “Input from Outside Partners”, the MCPC themselves express their enthusiasm for the proposed amendments to the FBZ by referencing examples from other localities wherein changes more radical than those currently under discussion have been undertaken. In praise of the proposed reductions in parking requirements, MCPC cites the example of Montgomery County, Maryland, a suburb of Washington DC which implemented the full elimination of parking requirements in new developments across the board “within 0.25 miles of D.C. metro stations” (presumably applicable to most of Narberth by comparison due to our proximity to a commuter rail station). The Delaware Valley Regional Planning Commission (DVRPC) is given the next word. They similarly look to localities wherein far more radical land-use deregulation has been enacted, approvingly referencing “cities with major land use reforms, such as Minneapolis and Houston”. It is particularly notable that the DVRPC would cite Houston as an example to be emulated, given that Houston is known for being home to some of the most bizarre and alarming urban-planning oddities due to its status as the only city in the country with no zoning whatsoever. This has led to the allowance of everything from a crematorium blowing human smoke into the atmosphere amongst a row of residential homes, a roller coaster menacing a single family home, a massive parking deck built on top of a small cottage, twenty story office buildings and hundred story apartment towers hulking over a residential street, and homes built dangerously close to industrial grade electrical infrastructure. DVRPC also cites a “study” conducted by the organization Up for Growth which asserts that the nation (and therefore Narberth) suffers from an acute “housing shortage”, a bold claim to make in the context of the second densest locality in the state that also happens to inhabit all of one square mile. Despite their framing, Up for Growth is not an academic or objective entity studying the dynamics of housing in America. They are an unabashed real estate industry advocacy organization deeply intertwined with the pro-development YIMBY movement nationwide. The organization is chaired by the CEO of the National Multifamily Housing Council (a developer and corporate landlord lobbying group), co-chaired by the Executive Director of YIMBY Action (the YIMBY Movement’s primary national advocacy organization), and the Vice President of Policy Advocacy of the National Association of REALTORS. Similarly, Gaudini cites the libertarian Niskanen Center to reinforce his commitment to increasing density. These examples are among many that reinforce the widely held view that the push for further density in Narberth and surrounding areas is motivated by ideological commitment rather than objective analysis or a genuine belief that these changes will serve the best interests of our community. Elsewhere among the input from the commissions’ “partners” is the feedback provided by SEPTA, spoken on behalf of by the transit authority’s Manager of Joint Real Estate Development Ken Starr. SEPTA is a staunchly enthusiastic backer of the proposed zoning amendments and a key institutional backer of the proliferation of dubious “Transit-Oriented Development” or TOD proposals across the region. SEPTA cites the TOD Overlay implemented in Ambler, PA, another case wherein more radical changes were undertaken than those the public is being led to believe are the only ones under consideration in Narberth. SEPTA boasts of Ambler’s allowance of 6 story density bonuses and the adoption of a height limit of 65 feet for residential developments in the adoption of their TOD Overlay. This is highly illustrative of a noticeable pattern contributing to the uneasiness of residents concerned about what the future holds for Narberth on its current trajectory. Noticing that the ambitions of the entities involved are far more expansive than they explicitly state is unavoidable. Thinly veiled by reassurances that the changes under consideration are “gradual”, “mild”, “soft” or “incremental” is the insatiable drive for more and more development, further densification, and a dizzying reconfiguration of the very fabric of our town, summed up in the often heard refrain spoken at council meetings in response to contentious public comments: “We’re not considering anything like that…yet.”

It is of the utmost importance that as many residents as possible show up at Thursdays meeting and make their voices heard and maintain an overwhelming presence at every meeting and council session into the foreseeable future. The people making the ultimate decision about the future of Narberth are our elected representatives, and they were elected to serve the community that voted for them. It is well past time they that be reminded of that.