Rendering courtesy EYA
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| Existing shopping center |
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| Proposed Phase 1 redevelopment with townhomes at left and right |
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| Existing site as seen from I-270 |
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| Proposed site plan |
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| Office building rear with lobby entrance at left, and loading docks at right |
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| Side view of office building |
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| The other side view |
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| Parking garage |
I don't closely follow local politics in the City of Falls Church, so I can't tell you if the city government is controlled by developers like Montgomery County's is. Is there a Falls Church equivalent to the Montgomery County cartel? I can't answer that, either.
But the Falls Church plan's "scope of work" looks very close to a Montgomery County minor master plan amendment. Such an amendment, the legality of which has been strongly debated but not successfully challenged in Montgomery County court so far, is virtually always initiated by a landowner in the area in question. Because it is illegal to rezone a single property for the benefit of its owner, Montgomery County created the MMPA process to provide a quick road to developer profits without requiring the complication of a full sector plan update.
How does the MMPA process work? A landowner and developer quietly approach elected officials and the Montgomery County Planning Department with their plans. Planning staff are directed to draw up a small map that includes the property seeking upzoning and redevelopment, and several other random properties around it. The Planning Department, Planning Board, and County Council tell the public the MMPA is simply an attempt to create a vision for the future of the area in question. In reality, a precise zoning change sought by the landowner/developer is already known, and will be ratified by the Board and Council after a "public process." The landowner/developer then submit preliminary and sketch plans for the redevelopment that was planned all along, but which the public has usually been kept in the dark about throughout the MMPA process.
To add insult to injury, the Planning Board and County Council rarely use the significant power they wield in the MMPA process to extract community benefits from the future development the new upzoning will allow. For example, a developer initiated the MMPA process for an area around the intersection of Wisconsin Avenue and Elm Street in Bethesda over a decade ago. It was seeking to redevelop 7272 Wisconsin Avenue at greater height and density than allowed under the zoning at that time. Greater scale means greater profit, and the MMPA is what allows that profit to be reaped.
Did the Planning Board and County Council use the opportunity to require the future developer of 7272 Wisconsin to construct a replacement Capital Crescent Trail tunnel under Wisconsin Avenue? No. In fact, it extracted no concessions at all in that MMPA. The original developer got the upzoning it sought, but ended up dropping its plans, and a second developer later successfully redeveloped the site. Now Montgomery County taxpayers are facing an $82.5 million tab for a tunnel that may never even be built at this point, all because the Council couldn't burden its developer sugar daddies with any extra expenses on their extra profits gained at public expense (schools, roads, services, and...trail tunnels).
So, while it may well be true that the owner of Eden Center did not request the City of Falls Church to initiate the "Small Area Plan," the process and zoning tool sound extremely similar to Montgomery's MMPA. I would suspect it's very likely some property owner within the plan area absolutely did get this process started.
While many assurances are being made to the public and press about what the Small Area Plan plan won't do, city leaders are indeed going to be voting on a plan this Tuesday night. That plan states that introducing residential housing to the commercial sites that are included in the plan area is a high priority. It does propose squeezing a hotel with a ground floor cultural center onto the parking lot of the Eden Center, kind of a strange idea for shopping center that currently has a shortage of spaces at peak times.
However, the plan doesn't recommend redevelopment of the Eden Center at this time. It appears the well-organized efforts of the engaged community who patronize or own businesses at the center were effective in forcing a retreat by the City of Falls Church.
But if the feared gentrification does come to pass in the future, the City of Rockville will be more than glad to warmly welcome the businesses at Eden Center to relocate here. Similar gentrification of Asian commercial hubs in Washington, D.C. and Northern Virginia have been a boon for Rockville over the last two decades, as many of those businesses and residents have relocated here. As a result, Rockville is now arguably the top dining destination in the region for Asian cuisine, in addition to the many Asian retail and service businesses here.
The Asian community in Rockville has become a major economic engine for the city. One reason this has happened is that land use decisions in Rockville are not made by the Montgomery County Planning Board or Montgomery County Council. The city has its own planning authority. Politically-active residents, and two consecutive mayors who made it a priority to retain Rockville's small town neighborhood character, have been able to hold off the high-density urbanization happening elsewhere in the County. Among the benefits of that, is many storefronts ideal for small business that might have been lost are still here.
A plan that envisioned turning Rockville Pike into a concrete canyon was batted down and soundly defeated in the last decade. As a result, the Pike has remained the retail powerhouse that has made it the biggest generator of commercial revenue in the entire state of Maryland. Sites like the former Century Ford dealership, that had been envisioned by out-of-town consultants as another cookie-cutter urban "town center," ended up redeveloping in classic Rockville Pike style, with fast food restaurants, AAA auto services and an urgent care clinic. While the Twinbrook Quarter development received a density exception, largely on the basis of its eagerly-awaited Wegmans grocery store retail anchor, imagining developments of its size up and down both sides of the Pike reminds us of the bullet Rockville dodged in recent years.
Assuming Rockville voters continue to make wise choices at the ballot box this November, the city should remain an attractive destination for diners and Asian businesses alike. If Falls Church elected officials someday find developer profits to be a higher priority than keeping the jewel of Little Saigon within its borders, Rockville will be more than happy to add those businesses to our fold.
Map courtesy City of Falls Church
It was claimed that a tight budget year would also be a hindrance to restoring funding. In reality, the funding sought by Elrich for the People's Counsel represents only 0.0004% of the entire FY-2024 operating budget.
Committee members had some novel ideas as to why the office should not be restored at this time. Jawando appeared unfamiliar with the Office of the People's Counsel as it was constituted in the past, claiming the executive branch had failed to enlighten the Council on this since it was discussed a year ago. He also echoed a talking point used by a lobbyist for developers, that certain resident groups whom he did not identify would use the office to stop development.
Fani-Gonzalez, amid chewing out executive branch representative Meredith Wellington, said there is no need for a People's Counsel to assist and represent residents' interests in land-use matters because the councilmembers already do that. Alas, none of the eleven councilmembers is a licensed land-use attorney, which is the whole point and defining characteristic of the People's Counsel. Fani-Gonzalez also created an awkward moment while chastising Wellington. One of the youngest past commissioners on the Montgomery County Planning Board, and now one of the youngest people to serve on the County Council, Fani-Gonzalez described septuagenarian Wellington as having been on the Planning Board "thirty years ago. A long time." "I was there until 2008," Wellington responded. "Oh, there you go," Fani-Gonzalez replied. "It feels like ages ago."
Friedson, who has been feted at fundraising parties hosted by developers, had made his revulsion toward the Office of the People's Counsel clear long before the committee meeting. He actually introduced a bill this spring to permanently kill the position altogether. Everybody who has been paying attention knows what the office was, yet the Council keeps hiding behind a musty, old Office of Legislative Oversight report that didn't even say what they claim it said about the position. In fact, the OLO report never suggested defunding the office!
The unanimous opposition of the PHP Committee to restoring the Office of the People's Counsel was particularly astonishing given that 90% of the residents who testified on the matter before the Council last month favored funding the position. Once again, the Council - like the Planning Board - is openly legislating against the wishes of a majority of its constituents. How long this thumbing of the nose at residents can continue is ultimately up to the voters of Montgomery County.
All eleven councilmembers will vote on the question of the People's Counsel at their Thursday, May 11, 2023 meeting, and will have to go on the record at that time. The vote will be especially awkward for councilmembers who had promised the Montgomery County Civic Federation to restore the Office of the People's Counsel in interviews prior to the 2022 election.
There is a palpable fear among some on the Council, and their developer sugar daddies, of having an Office of the People's Counsel in place during the upcoming process of ramming through the zoning text amendments that will weaponize the controversial Thrive 2050 plan. Those ZTAs that will make it possible to build market-rate multifamily housing within single-family home neighborhoods, a tactic that has failed to lower housing costs in the few jurisdictions that have employed it.
Are we talking about Union Station in Washington, D.C.? No, it's the Harborplace development in Baltimore. But both now share a special pedigree. These properties have failed...twice. And each time, the taxpayer has involuntarily-volunteered to pick up the tab for "renewal" and "rejuvenation."
You can't entirely blame the political machines of Charm City and the District of Columbia. They know both cities are more transient than most in America. And both are rapidly gentrifying African-American residents out of their homes and neighborhoods, to make room for more luxury condos for rich, white people. Why, you probably haven't lived here long enough to realize this isn't the first time the city's gemstone was tarnished.
Except, some of us have. I remember when Union Station and the Inner Harbor were said to be in desperate need of revitalization. Some years, and many more taxpayer dollars later, we were told the effort was successful. Shops! Restaurants! Gleaming and new!
Three decades pass.
And suddenly, it's happened again.
Union Station and Harborplace are derelict! They're outdated and have fallen behind the times! Nobody goes there anymore! Wealthy development firms are standing by to save the day, but...they're going to need your help. So they're going to cut us in on the deal? We'll earn a dividend for the tax dollars we're putting up, just like the other investors?
Oh, no. And your investment is not optional. We just rammed it through in Annapolis. The taxpayers of Maryland - yes, even you in the hinterlands, are going to fork over $166 million. And Baltimore City residents, many of whom are living paycheck to paycheck, get to hand over an additional $1 million.
Why are Union Station and Harborplace "derelict and underperforming?" The tenants! Well, wait a minute. Union Station has Shake Shack, Pret-a-Manger, Au Bon Pain and CAVA, names about as hip as train station commercial retail can get. Tourist-driven Harborplace has tourist traps like UNO Chicago Grill, Johnny Rockets and Hooters - it even has The Cheesecake Factory, for Pete's sake! What else would you want to eat by the water?
Want local, small businesses instead? Charge a rent they can afford for the empty storefronts.
Well, it's not the tenants or the times, you see. Why don't people want to go to Harborplace or Union Station?
It's that the D.C. government let crime and the homeless take over Union Station. Columbus Circle at sunrise can resemble a giant bedroom, as the least-fortunate of Washington awake from slumber among scurrying rats and trash. Baltimore City let crime run rampant in the Inner Harbor, with tourists often the target. At some point, elected officials have to be held accountable. This is a novel idea in Washington and Baltimore.
$166 million? You could put 415 homeless people into permanent homes in the D.C. area, and even more in Baltimore, for that amount. It could be a not-insubstantial down payment on building the Red Line, especially the Dollar General version of the Red Line pols are cynically trying to pass off on West Baltimore these days. "By the time the buses start running, those voters will have been gentrified out of there, anyway," elected officials must figure. Imagine the parks you could build. Or schools that actually have air conditioning!!
But a better recipient than the general public has been found - wealthy and well-financed developers. The public involuntarily gives generously. Buildings are demolished. New ones rise in their place. The property is sold. Profits are made. Elected officials fail to execute their basic functions to provide a strong business climate, maintain city infrastructure and ensure public safety.
And the cycle starts over again. We've seen this here in Montgomery County, where a greedy mall buyer along with County officials allowing crime to get out of control led to the demise of Lakeforest Mall in Gaithersburg. As long as our elected officials get away with directing our money to their developer sugar daddies, we'll see it again.
Inner Harbor crime:
"Death at Baltimore's Inner Harbor"
"3 people robbed at gunpoint in Inner Harbor"
"New Jersey family attacked at Baltimore's Inner Harbor"
"If this is what a Saturday night at the Harbor is going to be like, we will not be going there"
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| Peggy Dennis and Ruben Meana Paneda testify before the Montgomery County Council |
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| Elizabeth Joyce of the Montgomery County Civic Federation |
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| Nicole Williams |
Once the Office of the People's Counsel - held by an attorney who could provide zoning and land-use advice to the public, and represent residents' interests at administrative hearings - was defunded, the public role in land-use decisions was rapidly phased out. An incredible series of events began to unfold. The Columbia Country Club - which had successfully held off construction of the Purple Line for decades - was defeated in that struggle by the county political cartel in 2013. That same year, the Planning Board stifled a potential Maryland Attorney General Investigation of the criminal Farm Road scandal, by appointing an investigator who had donated thousands of dollars to the Attorney General.
In 2014, the County Council approved a new zoning code that essentially rezoned everything except single-family home residential neighborhoods as mixed-use. 2016 witnessed unanimous Council passage of the controversial Westbard sector plan, despite overwhelming resident opposition. From 2017 to the present, the Council, Planning Board, and Housing Opportunities Commission would continue to stymie and suppress all efforts to conduct archaeological studies on the Moses African Cemetery in Bethesda. And last fall, the Council passed the controversial Thrive 2050 over countywide resident opposition, a plan that will end single-family home zoning across most of Montgomery County.
Had there been an Office of the People's Counsel over these thirteen years, it's likely that none of these events would have transpired in the way they did, if at all. The People's Counsel would surely have tangled with County officials on the complex zoning matters at stake. Instead, we've seen a Planning Board and Council that completely ignore public input from individual residents and civic associations, and steamroll ahead with whatever developers want to do.
If anything, the Council needs to scrap Bill 18-23, and get about the business of restoring funding for the Office of the People's Counsel. You won't be surprised to know that the author of Bill 18-23, Councilmember Andrew Friedson, isn't just the recipient of developer campaign donations - - developers even host fundraisers for him.
What's needed is not just the return of the People's Counsel, but a beefed-up version of the office, with expanded authority. Sector plan updates should once again require a committee to be formed with representatives of all stakeholders, including residents, not the sham charrette process that replaced it.
It's also time that a new layer of protection that District of Columbia residents enjoy is added to Montgomery County: Publicly-elected, non-partisan Advisory Neighborhood Commissions. As stated on the D.C. Board of Elections website, "Advisory Neighborhood Commissioners advise the District government on matters of public policy including decisions regarding planning, streets, recreation, social services programs, health, safety, and sanitation in their respective neighborhood commission areas. Advisory Neighborhood Commissioners are elected to two year terms every election year."
In an era where development interests are supercharged, it's time that residents also get a power boost from a People's Counsel, sector plan committees, and the establishment of ANCs.
The Council will hold a public hearing on Bill 18-23 tomorrow, April 18, 2023 at 1:30 PM. If the Council presses ahead with a vote on the bill before it adjourns for the summer, voters will want to watch closely. There haven't been enough votes on land use issues by this new Council to determine how many of the 11 seats are now controlled by developers. Any member who votes to kill the Office of the People's Counsel will have made crystal clear who controls their seat.
"I met with Mr. Hedrick for almost two hours on Friday, March 10," Elrich wrote, "and have reviewed his participation in land use issues in Montgomery County, his comments on social media, and other work. After this review, I have decided to disapprove his appointment to the Planning Board." Elrich noted that the recent replacement of the entire Planning Board due to a series of scandals, none of which have been investigated by the County Council or Maryland attorney general to date, made restoration of confidence and public participation in land use decisions essential to establishing a functional board.
"In the nuanced work of planning, there is a need to recognize the opinions and lived experiences of others and to come to the table ready to work together," Elrich wrote. "During my interview with Mr. Hedrick, he made it clear that he has no interest in doing this difficult work. Instead, his comments to me, as well as on social media, demonstrate an ideological close-mindedness as well as a disdain for those whose views do not comport with his."
"Mr. Hedrick’s view is that we need greater housing densities everywhere, that he has 'heard the same arguments' from those who oppose his view, and that he 'doesn’t have a lot of patience with those people,'" Elrich continued. "He seemed unaware that over the past 16 years, master plans have been used to substantially increase housing densities. He also seemed unaware of the fact that the forecasts for population growth in the county are based on the densities adopted in these master plans. This demonstrates a basic lack of understanding of the county’s master plan process, one of the most important elements of the Planning Board’s responsibilities and one that requires balancing sometimes competing policies – what rezoning is needed to encourage buildout; what steps must be taken to promote racial equity and social justice issues such as displacement and gentrification; what consideration must be given to the environmental consequences of increased land coverage."
Elrich has long pointed out that Montgomery County has already approved sufficient new housing units to meet the forecasted need by the Metropolitan Washington Council of Governments by 2030. He has also sought to highlight a number of projects that would either preserve or create new affordable housing that his office has orchestrated since 2022. And many note that developers haven't even begun to fully build out all of the available "smart growth" areas near Metro stations in downtown Bethesda and Silver Spring alone - nor the numerous "dumb growth"areas not within walking distance from Metro that the Council has deemed "activity centers," such as Westbard. In this context, Elrich and other slow growth advocates are perplexed as to why developers are now seeking to rezone existing single-family-home neighborhoods for multifamily housing, before even cashing in on the many land-use victories they've already won since 2002.
The controversial Thrive 2050 plan approved by the Council and previous, scandal-ridden Planning Board will provide only more luxury housing at market rates, despite claims that the plan was designed to increase housing opportunities for those who can't currently afford to live in the county. Even the Council's own consultants warned councilmembers that they had failed to adequately solicit and obtain feedback from people of color on racial and equity issues surrounding Thrive 2050. While proponents said Thrive 2050 would increase options, it in fact reduces options, by eliminating the single-family-home neighborhoods that are the main draw for homebuyers who choose the suburbs. Home prices in the few cities that have eliminated single-family-home zoning have not fallen as proponents have promised, but only continued to increase. The ultimate winners have been developers, not homebuyers or the poor.
However, Hedrick was not the only Council appointee to support Thrive 2050. Elrich wound down his letter to Glass by emphasizing the need to reduce the "toxic atmosphere" of the previous Planning Board, arguing that the appointment of Hedrick would not contribute to that effort. The boards of the last decade have been seen by many residents as only responding to the desires of developers and their paid lobbyists, very few of whom have registered as such with the state. Resident concerns were typically ignored, or even belittled, by planning commissioners.
"The appointment of a new Planning Board is an opportunity for a fresh start, removed from the toxic atmosphere that permeated the defunct Planning Board at all levels, including social media," Elrich wrote. "Unfortunately, Mr. Hedrick perpetuates, rather than alleviates, that atmosphere. He has made insulting and dismissive statements about those with opposing viewpoints. When asked about this, he disappointingly expressed no regrets."
"Such rigid views are anathema to restoring the reputation of the Planning Board and the public’s confidence in its decisions. Land use planning in Montgomery County is at an inflection point that will determine how we move forward in addressing housing and community building mindful of the important role land use decisions play in ameliorating the increasingly apparent effects of climate-driven storm events on our homes, businesses, and transportation systems. We need Planning Board members with good judgment who are open-minded, constructive, and, above all, interested in hearing from all sides in a fair and transparent process before they have reached a decision. Mr. Hedrick does not meet those standards."
Elrich concluded his letter with an almost-Trumpian touch of all-caps, declaring "the appointment of James Hedrick to the Maryland-National Capital Park and Planning Commission is DISAPPROVED." It was not immediately clear if the meeting between Elrich and Hedrick was recorded in any fashion, so that Elrich's characterizations of Hedrick's responses could be verified. Elrich's sizeable constituent base among homeowners countywide appeared to be satisfied by the decision, based on social media reaction. The move by Elrich was exactly the sort of action his voters put him in office to take, and puts the Hedrick holdouts from the February 28th Council approval vote on the spot this coming Tuesday, when Glass promised the Council would discuss Elrich's veto.
Renderings courtesy EYA
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| Proposed site plan for the new townhome community |
Those issues that led to a regional embarrassment for the County this fall were hardly the only ones to stain the Planning Board and County Council. The Board and Council have routinely passed master and sector plans over the outspoken objections of the communities the plans will guide growth policy and zoning in.
Thrive 2050 was only the most recent example, a "blow-up-single-family-home neighborhoods" plan and developer fever dream the Council rubber-stamped into law mere days after declaring that it had "no confidence" in the five commissioners who drafted and approved every word of it. Virtually all of the support for Thrive 2050 came from people who do not actually live in the single-family home neighborhoods the plan would bulldoze, developers, and Astro-turf "YIMBY" activists. The plan itself was neither novel nor innovative, but a hodgepodge document plagiarized from the few other jurisdictions around the country corrupt and crazy enough to end the single-family home zoning most consider to be the American Dream. Other than generating more developer profits, those earlier Thrive-style efforts elsewhere have failed to realize any of the false promises their advocates had touted.
M-NCPPC, the Planning Department and Planning Board have a horrific record on racial bias, particularly with the African-American community. The most prominent examples of this have been the Farm Road scandal, the desecration and attempted cover-up of the Moses African Cemetery in Bethesda, and the repeated calling of multiple armed police officers to silence or remove African-American protesters at Planning Board meetings. The Council had full knowledge of those events, and never exercised their self-proclaimed "power" to criticize, investigate or remove any employee, commissioner or chair involved in those well-documented racist actions. Not even after the summer of Black Lives Matter in 2020 did the Council revisit these transgressions.
Now that County Executive Marc Elrich and State Senator Ben Kramer are attempting to formulate a process to examine a reform or replacement of the current land-use authority structure, the Council is attempting to end the discussion before it starts. It's too late for that, because residents affected by the land-use decisions made over the last two decades have already been discussing it. That discussion has led to increasing calls to rein in M-NCPPC and the Montgomery County Housing Opportunities Commission. It's time to have this conversation, and explore the options.
Much like the County's outdated government monopoly on the sale of alcohol, the M-NCPPC is a highly-unusual arrangement for a land-use authority. It includes Montgomery and Prince George's County, two jurisdictions that just happen to have had many development-related scandals and outsized developer influence over the years. Those scandals - topped off last week by new questions about the ousted Planning Board's 2021 purchase of parcels in downtown Bethesda for $9.6 million for a park that now won't be built - have led us to the point that we need to look at how to make land-use decisions more accountable to all stakeholders, not just to those with the most money and power.
The proposed commission, representing cooperation between county and state leaders, is a good starting point for this discussion. It's clear that those who have wielded the "power" in land-use and zoning decisions have abused that power, shown major errors in judgement, and failed to exercise their oversight role responsibly. They've lost their unearned privilege to continue to hold that power.
Reforming the land-use authority structure could well mean transferring that power to others. It could also mean pulling Montgomery County out of the M-NCPPC. It should also mean restoring the Office of the People's Council and sector plan committees, and the creation of Advisory Neighborhood Commissions as Washington, D.C. has, to strengthen accountability to residents. We can't achieve reform until we take a hard look at the situation, through efforts such as the proposed commission.
A first step in being stripped of power is admitting you hold that power through a corrupt, antiquated and - on many occasions - racist structure of authority. The Council has made that admission loud and clear. Now is the time for adults in the room to chart a new way forward. If you openly state you have had the "power," you must also accept full responsibility for the wreckage that power is on the record as having caused, and not block the path to fixing it.
The project as currently proposed is opposed by the Mayor and City Council of Rockville. It includes a school bus depot, and a future Department of Corrections and Rehabilitation Criminal Justice Complex and restoration center. Rockville elected officials have argued the proposal is inappropriate for a site that abuts eight residential neighborhoods. The existing Detention Center has been there since 1978; a police station there was built in 1963.
Elrich advised the Council to put its political interests in passing Thrive 2050 before the November election aside, in favor of more outreach, and incorporation of more than 65 changes recommended by the consultant to prevent gentrification and displacement of residents of color and lower incomes. These proposed changes include Community Benefit Agreements, rent-to-own programs, and constructing more parks in areas that fit those demographics. Elrich said disapproving the current plan would also allow time for further public hearings.
A major complaint of Thrive 2050 detractors from the beginning has been the impression that the plan was rammed through by the County Planning Board while the general public was distracted by the pandemic. The most controversial aspect is that the plan would allow construction of multifamily housing in existing single-family home neighborhoods. This would drastically change the character of those neighborhoods, while the resulting attached housing units would be too expensive to help address the perceived lack of affordable housing in the county.
Thousands of new housing units have come online countywide since 2014, but that surge in inventory has had no downward effect on prices. As volume increases, home prices and rents have only gone upward, creating skepticism that Thrive 2050's massive construction scheme will make housing affordable. In fact, based on the data of the last decade, it would likely only jack up prices further. If new townhomes sell for over $1 million in an industrial area of 20816, how much would a new larger duplex unit sell for in the same desirable zip code? Not less.
The resolution passed by the Civic Federation addressed many of the same concerns Elrich raised, as well as environmental sustainability and the need for broad community support for master plans. Thrive 2050 supporters have dismissed that idea, arguing that despite their six-and-seven figure investments in a SFH-neighborhood environment, County home buyers should have no say or leverage in the zoning or development of any property besides their own.
New chapters should be added on each of the topics that the consulting team determined were shortchanged in the current draft, the Federation advised, including environmental, racial equity and social justice issues. A new public hearing should be held on each of those new chapters, its resolution added. The Federation also opposes universal upzoning and by-right zoning changes implemented through the controversial Zoning Text Amendment process, and notes that the consultant report suggests that a legitimate process to address the areas of concern it identified would take at least one year.
Other concerns that have been expressed throughout the Thrive 2050 process have included school overcrowding, loss of green space and tree canopy, inadequate parking spaces for the higher neighborhood densities proposed, and whether the existing infrastructure such as water and sewer can handle such a population increase in existing neighborhoods.
The Council currently has planned to vote on the Thrive 2050 plan by October 25.
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| New bus circulation routes proposed; future building shown in gray |
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| There is currently insufficient sewer capacity for the proposed development, including this line shown in orange far from the building site in Twinbrook |
