Medium-Intensity Residential: Maximum-Intensity Pain

In our many conversations with residents upset about the Future Land Use Map, we have heard a clear pattern: the biggest “pain-point” is the Medium-Intensity Residential category. Recall that this category allows developers to build up to 12-unit buildings of up to 4 stories in height “as-of-right” and allows for more aggressive massing. This is a multiple of the “use-intensity” of General Residential and a much larger form. To justify such a dramatic increment in use-intensity and form, we would expect to see the areas tabbed as Medium-Intensity Residential to have characteristics that clearly distinguish them from those tabbed as General Residential. As you can see from the table below, however, that is not the case. We compare General Residential, Medium-Intensity Residential and High-Intensity Residential along a range of variables. We find that GR areas and MIR areas are not easily distinguishable from each other. It isn’t a question of the metrics we have chosen. On those very same metrics, High-Intensity Residential is starkly different. No wonder residents whose properties have ended up in MIR feel confused and potentially ill-used.

A well-designed land use map would designate higher use-intensity and larger form for areas that are in relevant ways well-suited for such designation. For example, we would expect areas slated for higher density would be more walkable than other areas. If the city wants to create more housing in an environmentally sustainable way, it would hardly suit to put that density where residents are likely to be car-dependent. Yet the mean Walkscore for GR and MIR are almost identical and both well below the citywide average of 58. HIR, on the other hand, has a Walkscore of 70.04, just above the threshold the Walkscore creators designate as “highly walkable.” Likewise, one would expect that if an aim of upzoning is to make housing more affordable by reducing the land cost of new units, it would be more urgent to allow greater density in areas with higher land costs. Land cost is not as likely to be a barrier to affordability in areas where land cost is low. Again, on all our metrics of land value, GR and MIR show very little difference, with both being quite a bit lower than HIR.

Moreover, if a land use map aimed to achieve its goals with minimal disruption, it would try to direct density to places that already have some precedent for it. This is important both because those places would likely already have the infrastructural predicates to support dense housing and because neighborhood character would be less dramatically impacted. This does not mean only areas that already have high-density residential, but would include redevelopable low-value commercial parcels, for example. Commercial areas are generally in accessible locations well-connected to transportation infrastructure. But again, that’s not what we see from the current FLUM, which has MIR areas that look very much like GR areas — relatively low on walkability, density, and connection. At this link, you can find a map where you can overlap MIR areas on a Walkscore map of the city to see what we are talking about.

Going above 3.5 stories in height was a major issue for MIR, and yet we see that neither the GIR areas nor the MIR areas have more than a tiny fraction of parcels with structures of that size. HIR has a more considerable fraction, and in fact a meaningful percentage of existing units are already in taller structures. Similarly for massing — the Floor Area Ratio for GR and MIR are very similar, but each is only around half the FAR of HIR areas. Finally, in terms of the existing zoning, both GIR and MIR are majority R-1 at present; HIR has only about 2% of parcels zoned R-1. To go from R-1 to General Residential is itself a significant move — from single-family housing to up to four units per lot. To take areas that are barely different and move them all the way to 12 units per lot represents an almost shocking discontinuity.

In light of this data, we think it would make more sense — and be fairer to residents concerned about the potential for dramatic unintended consequences — for Medium-Intensity Residential areas to be substantially scaled back or removed entirely. Most of the MIR areas do not merit treatment any different from GR areas, because they aren’t meaningfully different from GR areas on the attributes that would support successful higher-density development. To the extent the city leadership feels it is imperative that a medium-density category should exist, then they ought to focus on a subset of the currently proposed MIR areas that demonstrate the predicate characteristics for successful implementation of dense housing. In particular, they should look at the many areas that our prior research has turned up that are candidates for redevelopment from low-value commercial uses to residential use.