Expanding Equitable TOD and TDM in Chicago

As New Urbanists, we work to undo the legacy of past urban design and planning choices that have created a wide array of chronic challenges for built spaces. From car-oriented development to environmental racism, the unfortunate effects of poor decisions continue to threaten the sustainability and well-being of our communities.

But as we advance this work, we must be prepared to recognize when our efforts need to be revised and updated to ensure our plans and policies maximize the opportunity to build a better urban environment. Recent work out of Chicago illustrates what we gain when we go back to earlier plans and strengthen them to be more responsive to community needs and to address a wider array of challenges.

In July 2022, Chicago City Council passed the Connected Communities Ordinance to strengthen and expand the City’s existing equitable Transit Oriented Development (eTOD) policy throughout the City. While Chicago has had a TOD ordinance in place since 2013, much of the development that has been stimulated by that ordinance has occurred in the wealthier and predominantly white northside neighborhoods.

The Connected Communities Ordinance is designed to increase ridership on transit, improve the safety of streets and sidewalks near transit, stimulate development in areas proximate to transit service, and, most significantly, create greater equity in the distribution of TOD and its attendant benefits throughout the City. The new ordinance is a direct response to the lack of development occurring in the southern and western Chicago neighborhoods, which have higher concentrations of low-income and minority residents.

Under the previous TOD ordinances, incentives such as lower parking requirements and higher density maximums were limited to within a ¼-mile radius of Chicago Transit Authority (heavy rail) and Metra (commuter rail) stations. Under the Connected Communities Ordinance, these incentives have been expanded to cover a ½-mile radius of these stations as well as high-frequency bus routes. This has greatly expanded the amount of land subject to these incentives, as shown in the graphic below:

Source: City of Chicago

The Connected Communities Ordinance also establishes a parking maximum for new residential developments at 1 space per 2 units (although developers can obtain an administrative adjustment to increase this to 1 spot per 1 unit) and eliminates on-site parking requirements for affordable housing developments. These changes represent a significant commitment to reducing the addition of new parking in TOD projects.

Importantly, the Ordinance also limits the “deconversion” of multi-unit housing, including the two-to four-flat buildings that have been a cornerstone of affordable housing in Chicago neighborhoods, into single-unit housing. This limit has been put in place to reduce the risk of displacement and the loss of Missing-Middle Housing in areas that are gentrifying. Additionally, developments that receive TOD density bonuses are required to build a greater number of affordable units than under the previous eTOD ordinance.

As part of its implementation, the Chicago Department of Transportation (CDOT) released a new set of Transportation Demand Management (TDM) rules for new developments in eTOD areas in June 2023. These TDM rules provide guidance for developers who are now required to conduct a Travel Demand Study and develop a TDM Plan for CDOT approval as part of the new development process.

The Travel Demand Study and TDM Plan are both designed to build on the Traffic Impact Study (TIS) that CDOT already requires for many types of developments. The TIS is designed to estimate expected traffic volumes at a new development and illustrate their impact on adjacent roadways, including roadway capacity and safety. If impacts are significant, the developer is required to identify mitigation measures for the development that offset the impacts of the traffic increase, such as turn lanes or traffic signal improvements. However, these mitigation measures have historically focused on reducing delays or improving safety for drivers.

Where CDOT’s TDM approach extends beyond traffic mitigation is in its explicit emphasis on reducing the number of single occupancy motor vehicle trips and incentivizing the use of alternative modes of transportation. The Department presents two main categories of strategies that developers can adopt to meet their TDM Plan requirements:

· Programmatic: Policies, programs, and service offerings that reduce single-occupancy trips by adjusting behavior. Options include transit pass subsidies, establishing a shared-vehicle program, unbundling parking costs from other building costs, and installing on-site childcare facilities.

· Design and infrastructure: Physical components installed on-site or adjacent to the development to make alternative modes of transportation safer and more efficient. Options include on-site bike amenities, bicycle, and pedestrian infrastructure, and transit stop installation or improvement.

While this combination of programmatic and design/infrastructure options gives developers significant flexibility and encourages a multi-pronged approach to advancing TDM goals, the use of an “either/or” approach in the current regulations creates the risk of failing to change the built environment in ways to meaningfully improve safety or accessibility. Policies that focus on incentivizing alternative modes of transportation may fail to change that behavior if people still feel that the physical infrastructure of the development or its surroundings incentivizes them to drive.

Despite this risk inherent in the structure of the TDM strategies, the Connected Communities Ordinance represents a significant effort to return to the drawing board and make tangible improvements. The Ordinance strengthens the policy reforms that support denser, more walkable communities and corrects for the lack of attention given to geographic equity and housing justice in previous efforts. Chicago is demonstrating that innovation requires iteration in order to create a better, more just built environment for all.

Author Bio:

Baird Bream is a Senior Associate with Cambridge Systematics in Chicago, IL. Baird has worked with city and state departments of transportation around the country on long-range transportation planning efforts that are designed to improve safety and accessibility for all users. Baird has a particular interest in addressing barriers to accessibility for people with mobility challenges and creating more just transportation systems that meet the needs of people of all ages and abilities.