Here’s the link to the published project: Atlanta City Design
The City of Atlanta just completed their city design project and there is a lot of good material in here for Cobb County and its cities to mimic and mirror. From generally eliminating single-family exclusivity and increasing density around transit lines to removing parking minimums and increasing investment in affordable housing. Whether or not we’re 100% satisfied with the specific efforts the City is taking, we recognize the importance of the progress their proposals represent, and hope to see Cobb County, as well as the rest of the metro, follow the City of Atlanta’s lead to right the wrongs of past decisions.
Here’s a list of the key takeaways, with additional detail below:
- End exclusionary Single-Family Zoning
- Allow more density, including small apartment buildings, near transit
- End minimum parking requirements
- Increase density in growth areas
- Reduce minimum lot size requirements
- Distribute dedicated affordable housing more equitably
- Expand the Urban Enterprise Zone Program
- Create affordability districts near major public investment projects
- Leverage publicly owned vacant land
- Expand the Housing Innovation Lab
“The first premise of the Atlanta City Design is that the city is going to change; that not changing is not an option; that our change will involve significant growth; and that if properly designed, growth can be a powerful tool for shaping the Atlanta we want to become”Atlanta City Design
“The second premise is that almost always, more people are better than fewer; that a diverse population is better than a homogeneous one; and that the most strategic scenario for growth includes everyone.”Atlanta City Design
The City of Atlanta is undergoing a self-reflection of its build environment, and asking itself some rather tough questions around a rough history. To understand the City Planning Department’s suggestions, and why they may not be good enough, though, first we need to recap some history. We highly suggest you read through the City’s own explanations, as well as pick up a copy of Richard Rothstein’s The Color of Law for more wholistic details.
Zoning as we recognize it today in Atlanta really started in the 1920s, where, following a series of legal defeats around the constitutionality of creating sections of the City directly limiting homeowners’ race, the City decided to try its hand at form-based zoning. The first system designated separations of uses such as residential and commercial, height restrictions, and lot size controls, all the foundations of modern zoning systems. The first code also proposed racially-explicit zones, creating ‘colored’, ‘white’, and ‘integrated’ districts throughout the City.
During this time, the federal government had been working to create a baseline system that cities could use as a sort of ‘plug and play’ set of laws. This federal Advisory Committee on Zoning, however, was not without its own racial taint. The committee had such members as Frederick Law Olmsted, who argued in 1918 that not only were certain housing types “coincident with racial divisions”, but that, since it was undesirable to “force the mingling of people who are not yet ready to mingle”, great care should be take not to mix housing types, as well as Irving B. Hiett, who was the president of the National Association of Real Estate Boards, an organization who would produce a code of realtor ethics stating that “A Realtor should never be instrumental in introducing into a neighborhood… members of any race or nationality… detrimental to property values” just a few years later. By 1922, the committee had developed A Zoning Primer, which argued that zoning was required to preserve property values, and which was widely distributed across the country. The policies would push out wide and far across the nation, following the federal government’s example.
The Georgia Supreme Court struck down the City of Atlanta zoning code in 1924, and the City was forced to replace its system with a more racially agnostic method, which the federal government had supplied. While the Advisory Committee on Zoning’s system was not explicitly segregationist in its laws, its method of separating land use had much the same result, isolating and separating more affordable housing types available to blacks and immigrants of the time from wealthier, whiter neighborhoods.
It’s important to note that none of these codes actually tried to make improvements to living conditions through legislation like better building codes, which could have helped prevent the squalor conditions that were so readily associated with apartments, and which had been present in the U.S. since at least 1859, in Baltimore, choosing instead to essentially quarantine apartments to prevent their spread into single family areas. Rather than actually try to address the stereotypically squalid conditions, it was simply assumed that blacks and immigrants would naturally lead to decay, and thus separation of building types was justified.
Were all else equal, we might be able to ignore the initial racial components of exclusionary zoning, and merely call the resulting codes classist (the reality is that racism and classism were/are tightly intertwined, with each giving perceived justification to the other), but things weren’t equal. The median household income for a black family in 1947 (the earliest year I could actually find data) was just 51% of a white household (it was only up to ~63% in 2018). Even though modern discussion around apartments tends to bemoan the ‘luxury’ branding, and how accurate it may or may not be, the hard reality is that living in an apartment is cheaper than buying a house, at least in the immediate. For lower income people, it’s pretty much the only option. For poor, and thus disproportionately black, people, the primary need for housing affordability was in the form of apartment buildings and residential density, even if that was only desired as a stepping stone. But that’s not what the zoning system provided.
Overwhelmingly, the City’s land was designated for low-density housing. While the low-density housing eliminated most affordable options, it still allowed 2-3 unit homes by default. Today, things are actually worse, with 60% of the land being single-family exclusive. Large lots, and individual homes drive up the per-unit costs of housing, locking poorer people out of being able to buy into neighborhoods. Worse yet would be the zoning systems of suburban and smaller towns, which would eliminate the ability to build apartments all together, essentially locking lower income, and thus disproportionately black, persons from being able to relocate there at all. This led to crowding in the limited apartments, and, since the building codes hadn’t been adequately updated to actually prevent it, the very slum conditions used as a justification for preventing apartments in the first place became self-fulfilling.
Of course, not all black people were so poor that they couldn’t afford to buy a single-family home, and quite a few did look to leave the limited availability of apartments. They were not met well, and indeed, in the years following the installation of exclusionary zoning systems, the federal government would essentially codify black exclusion from single-family neighborhoods, with cities clinging to the federal policies as justification for blocking black and integrated housing.
Property (particularly home) mortgages used to be very, very different than how we think of them today, which locked many people out of the ability to get them. High-interest rates, huge down-payments, interest-only payments, and short (5-7 year) payback periods. These terms kept middle and low class persons (of all races) from being able to afford to buy property. As part of the New Deal, the Home Owners’ Loan Corporation was established. The loan system was restructured to be closer to the lower rates, lower down-payments, overall payment, and long-term periods we’re more familiar with today. Additionally, many existing mortgages were bought and restructured to save property owners from foreclosure.
In the process of this, though, HOLC wanted an inventory of risk across the nation, so it could manage these new loan terms without crippling itself financially. This is where the moderately okay policy stopped. The risk inventory was carried out by local real estate agencies, who had national ethics codes and local policies for their agents to explicitly consider race when evaluating risk. So much so that they were actually under direction to maintain community segregation when otherwise selling properties. The inventory took the form of color-coded maps, where red sections on the map represented high-risk (don’t loan people money / bail them out here). Many, many of these red areas were based on racial prejudice, with even wealthy / middle class integrated or black communities being rated far worse than equivalent income white areas, and explicitly calling out the amount of colored people in their ratings.
This entire mess was made even worse with the establishment of the Federal Housing Authority, which was intended to insure private bank loans to first-time home buyers. Even though the FHA had its own auditing system separate from the HOLC, it still had direct segregation and whites-only policies. Additionally the FHA very specifically did not insure mortgages within urban centers. This meant that both HOLC and FHA services were denied to nearly the same areas: black or integrated neighborhoods, most often in urban centers.
The FHA justified its racial rules by claiming that black people ruined property values. This was actually backwards, as the limited options available to black people meant that black and integrated properties were in high demand, and thus could be sold at a much higher price. What did happen, though, was ‘block-busting’. So, because the FHA (and other organizations) continuously sold the idea that black people ruined property values, as well as the base-level racism, this left white neighborhoods vulnerable to manipulation. Speculators would buy up properties in blocks on the border of black / integrated and white areas, and then rent / sell them to black people. These speculators would also hire black people to walk around white neighborhoods asking about home sales, and looking like they lived there. Then the speculators would go around warning white property owners that their housing values would tank with all the black people moving in, and make stupidly low offers, buying out white properties well below the actual value (this is where the FHA was getting its data). Then the speculators would turn around and, because there were so few other options, sell the same properties above their actual value to black people at bad rates. This drove up costs for black people who otherwise just wanted a home, and the high prices contributed to perpetuating poverty and again creating self-fulfilling slum conditions.
Many cities, private lenders, and other government agencies (like Veterans Affairs) anchored their lending and development approval processes on the FHA backing of home loans, which meant that blacks were barred from even the opportunity to really leave parts of the City within which they lived.
It’s worth reiterating that the HOLC and FHA policies were targeted directly at owning private homes, working off of a national policy that private homes were less communist than apartments. No, I’m not kidding. The U.S. Department of Labor distributed pamphlets entitled We Own Our Own Home to schoolchildren stating that it was a “patriotic duty” to cease renting, and to buy a house. Millions of posters were printed, and hung in factories and other businesses, while newspaper ads were run throughout the country. This national housing direction propped up single-family residences, and the infrastructure to support them, while leaving pretty much everything else to languish.
The combined HOLOC Redlining and FHA exclusionary lending has had a lasting impact on Atlanta. Eighty years later, many of the neighborhoods that received the “Hazardous” rating either no longer exist (many destroyed through Urban Renewal and freeway projects) or remain predominately low income today. This type of erasure and economic suppression hit cities all over the US. A 2018 study noted that, “Most of the neighborhoods (74%) that the HOLC graded as high-risk or “hazardous” eight decades ago are low-to-moderate income today. Additionally, most of the HOLC graded “hazardous” areas (nearly 64%) are minority neighborhoods now.” Atlanta’s redlined neighborhoods are even worse than the national average, with 86% of Atlanta’s redlined areas either destroyed or still low-income areas today.
All of these policies, when combined with a host of others, has created a situation of an Atlanta that is actually more segregated than when zoning was first considered. The City itself is split heavily along racial lines, with median household income, household value, and educational attainment following this split closely, all together creating an intense racial wealth gap.
Single-family exclusionary zoning continues to contribute to this racial isolation and achievement gap, locking people out of areas with more services and better prospects, while also creating entrenched racial and economic segregation.
The City of Atlanta has recently passed 500,000 residents in 2019, and is expecting to reach a population of 1.2 million within the next few decades. This is part of an overall regional growth to 9 million in the metro by 2050.
This growth, though, has not been managed well so far. From 2010 to 2018, Atlanta added 3,500 more households (families, groups of roommates, or individuals living alone) than it did units of housing in that time. As such, housing prices have been rising. This has been exacerbated by the overall increase in household income of new residents creating a situation where higher-income people can out compete lower income persons for the same limited units of housing, including replacing currently affordable housing with more expensive units.
In a City that has nearly 1 in 2 renters and 1 in 4 homeowners now spending more than 30% of their household income on rent, it is likely that residents that are the most rent-burdened will increasingly look for more affordable housing options in other cities or in the suburbs. The current pace of affordable housing development is not matching the population growth of residents in need of those housing options.
So, what is going to be done about this? The City has identified a number of policies to change, adjust, or outright remove as part of an effort to undo the damages of exclusionary zoning. Some of these policies are better than others, and some are not as intense as we may like, but over all the collection of proposals is a huge step in the right direction. Here we’ll provide a summary of the proposals:
End Exclusionary Single-Family Zoning
The City is proposing a mass-elimination of exclusively single-family zoning. To be clear, single family homes would still be allowed, but now small-scale multi-family housing would also be allowed. Practically speaking, this is getting proposed as allowing an additional dwelling unit, in the form of a detached accessory dwelling unit, a basement apartment, a second floor apartment, a recessed second unit, a garage conversion, or other similar efforts.
These are fantastic proposals, and can be an important part of the housing solution. If just 15% of current single-family properties added a second unit, that would create ~11,500 new housing units within the City.
Additional changes to the rules around Accessory Dwelling Units, such as opening up new financing and property division options, as well as tweaking existing zoning laws around ADUs could make them more financially viable.
Something we would like to see expanded in this theme would be to end the exclusionary nature of housing-only zoning itself. Practically speaking, this would take the form of small-scale mixed use and commercial space intermixed with houses. An accessory commercial unit, a basement level store, a ground level shop, a garage office space, a second floor office, etc.
Allow Small Apartment Buildings Near Transit
This change would allow small-scale apartment buildings, in the range of 3-12 unit apartment buildings and sometimes also called walk-up apartments, by default within a half-mile of high-capaCity transit.
This one is a bit frustrating to us. Not because we don’t like small-scale apartment buildings, but because the designations feel a bit arbitrary and underwhelming. The example buildings shown within the Virginia Highland neighborhood are decidedly not within the half-mile range of high-capaCity transit, and yet the neighborhood is full of such buildings from a time before zoning made them illegal. In fact, much of the City of Atlanta’s most desirable neighborhoods are thoroughly sprinkled with these exact kinds of developments without being near high-capaCity transit, nor within the City’s designated growth zones.
It makes no sense to us why these should continue to be limited as the City is suggesting.
Particularly since the City seems to be ignoring its own transit system, and plans. The proposal calls out heavy-rail stations specifically, but ignores the City’s streetcar, which is in the process of being expanded out into a larger light-rail system. Additionally, there are planned bus rapid transit routes on the way, along with arterial rapid transit, and more basic frequent bus routes to consider.
The fact that the City later calls out transit as a reason to make changes within growth areas that are not within the capture area of a heavy rail station makes this all the more confusing.
Ultimately, we would rather see small-scale apartments allowed across the entire area, as part of the general elimination of single-family exclusive zoning, while areas near transit stations would be allowed even more density by default.
End Minimum Parking Requirements
This is a fantastic policy that we fully support. Parking minimums unnecessarily force developers and property owners to build way more parking than they need, which wastes space, increases traffic, and raises housing costs. Some estimates put parking costs at 18%-20% of total housing construction costs. A garage can often cost up to $40,000 per space, which can equate to $125 a month in added costs to renters or buyers.
Increase Density in the Growth Areas
The City of Atlanta has generally designated two types of areas for its City: growth and conservation. Both have a number of sub-categories, but the main difference here is that the City is looking to concentrate the majority of its high-density, high-intensity development within the designated growth areas. Conservation areas are not exempt from densification, particularly in the form of doubling up units in existing single-family areas as mentioned above, but generally the more stereotypical types of urban growth would be relegated to the growth areas.
This is not, in and of itself, a bad way to handle things, but the way the City is carrying it out is a bit odd. First of all, only ~25% of the City’s land area would be designated as a growth area, with 75% either being a ‘productivity’ (current industrial), or else conservation area. The overlap between current single-family only zoning, and conservation areas is nearly one-to-one, which brings up worries, to us, about actually being able to manage growth in such a restricted area.
Especially when the growth areas themselves are often disjointed, oddly narrow, or even incomplete. Many of these areas are along future or existing high-capaCity transit lines, but not all areas along those routes are designated for growth, greatly restricting the potential to properly match land use around transit investments.
That said, we agree with the City’s goal of converting existing low-density lots to high-density lots within that area, even if we think it’s a bit too small.
Reduce Minimum Lot Size Requirements
This is generally a good policy that couples nicely with the general elimination of exclusively single-family zoning rules within the City. Reducing land required to create a housing unit can make that unit of housing cheaper, and the generally increased density can lead to higher economic productivity for the area.
Distribute Dedicated Affordable Housing More Equitably
The City of Atlanta is proposing an interesting system of targeting the number of affordable housing units based on school zones and growth areas. 50% of housing units would be equally distributed across high school clusters, while the remaining 50% would be allocated within those same high school clusters based on the percent of growth area within the cluster. This has the extra benefit of spreading affordable housing efforts into wealthy neighborhoods who have resisted income mixing, which exacerbates already prevalent racial and income segregation.
Expand the Urban Enterprise Zone Program
This proposal would be to expand the Urban Enterprise Zone program, which is a tax abatement program allowing 10-years tax reduction for a wide variety of development types as long as that development comes with 20% of any housing units being affordable housing for the period of the abatement.
The program has not been particularly well used, and is generally concentrated in extremely low-income areas of the City. To help spur additional affordable housing development, the City is looking at expanding the UEZ program to all of the growth areas.
Generally speaking, we prefer to end property tax abatements, or other tax-cuts, particularly on individual project bases, and instead directly fund affordable housing programs from tax revenue. However, if such a program is to exist, it makes sense to expand it to growth areas for the purpose of more evenly distributing new affordable housing.
Create Affordability Districts Near Major Public Investment Projects
Essentially the City would create or otherwise expand Inclusionary Zoning requirements to areas around large public investments, like the BeltLine, and Westside Park. There could also be an affordable for-sale requirement as well, mimicking Inclusionary Zoning with purchased housing units, rather than only for rental units.
Generally speaking, we prefer to directly fund housing affordability programs. Inclusionary zoning, and any form of development by development affordability requirements, places an undue financial burden on those persons not within the affordable units since their housing prices must go up to offset the lower prices of other units. This is regardless of the actual income or financial position of the person renting that higher unit, which can contribute to housing burdens if all of the affordable units are filled first.
This is compared to, for example, a tax that spreads financial burdens of affordable units across all residents, including those new ones, reducing the per-person burden and allowing for potentially tuning for ability to pay the tax itself.
Leverage Publicly Owned Vacant Land
The City would use much of its currently owned vacant land to install affordable housing of a variety of types. We fully support this effort, and only wish it would happen sooner, and on a larger scale. We are encouraged to see the city proposing innovative solutions for some of its ‘odd lots’, such as unused road right of way to create small-scale housing that, though not fancy, would be quite affordable for people needing it.
Expand the Housing Innovation Lab
Here the City is proposing to expand efforts much like its Atlanta City Studio, which has a focus on studying, and creating proposals for new projects ranging from more benign streetscape rebuilds to innovative concepts like city-spanning greenways and nature trails.
The Housing Innovation Lab would focus, specifically, on creating new housing patterns that could fit into odd-shaped lots, preserve existing trees, and generally allow affordable infill housing throughout the City through unique design proposals.
Lessons for Cobb
There is a lot of good material in here for Cobb County and its cities to mimic and mirror. From generally eliminating single-family exclusivity, to increasing density around transit lines, to removing parking minimums, to increasing investment in affordable housing. Whether or not we’re 100% satisfied with the specific efforts the City is taking, we recognize the importance of the progress their proposals represent, and hope to see Cobb County, as well as the rest of the metro, follow the City of Atlanta’s lead to right the wrongs of past decisions.