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Mr. HARSHA. If it becomes necessary, if it did, to destroy one of these 38 new major installations, to provide adequate parking spaces in the immediate area where it is needed, would you advocate that? Mr. BURGUNDER. You say if it became necessary?

Mr. HARSHA. Would you advocate that, to do that?

Mr. BURGUNDER. You see, what I advocate would be an authority which, in turn, would plan a parking system, and, if, in the plan of the parking system, it became necessary for the public good to take that given building for the good of the whole area to be served, I would have to say "Yes, sir".

Mr. HARSHA. Thank you.

Mr. NELSEN. Would you yield?

Mr. HARSHA. Yes.

Mr. NELSEN. These developments that are referred to now, if parking is not available because there was not adequate planning when they were developed, would be due to the developers not taking it into account; is that not true?

Mr. BURGUNDER. The overall problem, yes.

Mr. NELSEN. What you are seeking to do is to look to the future to prevent the possibility that same situation is not aggravated so that as the city continues to grow and you plan, you are also planning parking along with the development of the total city, and wherever possible, where parking facilities are available, to help out in the problem as it does exist now?

Mr. BURGUNDER. Exactly, sir.

Mr. Dowdy. This goes back to a question that I raised about planners, whether they are infallible, as some people think. The Southwest Urban Renewal was totally in the hands of the planners-absolutely in the hands of the planners-and they are woefully short of parking spaces, and you cannot blame anybody but the planners for that.

Mr. BURGUNDER. I must say that they are fallible. The question is whether we are better off with planners who are fallible or with no planners at all.

Mr. Dowdy. You say that any kind of a planner is better than private enterprise; is that what you are saying?

Mr. BURGUNDER. I said that a planner, who is a human being and fallible, is, I feel, better than having no plan whatsoever.

Mr. DowDY. In other words, private enterprise cannot make a plan? Mr. BURGUNDER. Private enterprise, per se, cannot make an overall plan for a city, yes, sir-cannot make an overall plan for a city and execute that plan. They can make it on a piece-by-piece, block-byblock, building-by-building basis.

Mr. Dowdy. Are your people willing to contribute money to these things, as in these places where they locate businesses and have parking facilities?

Mr. BURGUNDER. They contribute money to let the private business in, for the parking.

Mr. DowDY. That is right-like they do in the parking areas in the shopping centers?

Mr. BURGUNDER. Like in the downtown parking shopping, they pay for it?

Mr. DowDY. You want to set up a commission, to build some parking spaces. The people that you represent, are they going to pay for

that or are they going to have the taxpayers in Maryland and in Virginia and in California and in Texas pay for it?

Mr. BURGUNDER. It will be self-sustaining. It would not be the taxpayers. Bonds would be issued by the authority, which bonds would be self-liquidating. Therefore, it is not a burden on the taxpayers— that is, per se. Whether the businesses, the individuals will contribute to their patrons, their customers, for parking in their lots, I think would be dependent on each individual business. Right now, the downtown parking have those who do not participate and some who do. My answer to that, sir, would have to be whatever the individual business decides. I imagine it could go either way. I do have some concern where the taxpayers are concerned, that the parking authority look into that.

Mr. DowDY. No more questions. Mr. Nelsen.

Mr. NELSEN. Could the building code provide that a new building that is to be erected would also provide parking for the employees? Could that not be done? Could the City Council or the Zoning Commission do that?

Mr. BURGUNDER. That would be part of the building regulations. I should think that they could.

Mr. NELSEN. Even if the building code does not specifically provide, is there not some zoning code to the effect that when a building is erected it has to meet certain parking standards?

Mr. BURGUNDER. I do not think so. I am not an expert on that. I think that in other areas of the city, what you say is true. I do not think that it is true downtown.

Mr. Dowdy. Do you not think that they would require that in the building, require them to put in the parking?

Mr. BURGUNDER. I think Mr. Ailes comment on that, when he was testifying, would be that there would be a lot of drawbacks in the structure; it would not necessarily be in accordance with the situation that it would really hurt the traffic pattern. You would not want three or four hundred trucks going along a street, going into a parking lot. Certain sized lots are too small to actually be able to get parking on those lots. You are, in effect, hurting the person with a small lot.

Mr. Dowdy. Is that any worse than the right of eminent domain, taking the property away from that person with a small lot?

Mr. BURGUNDER. First of all, it is according to the plan; it is for the overall good of the community, and there is compensation involved in this. Therefore, I, personally, have been subject to eminent domain. Mr. Dowdy. Did you like it?"

Mr. BURGUNDER. Do you like it? No, sir.

Mr. Dowdy. I do not think that many people do.

Mr. BURGUNDER. But it built the Rayburn Office Building.

Mr. DOWDY. Mr. Sisk?

Mr. SISK. If I could-I am not going to take the time of the Committee, but there are many things I could discuss with Mr. Burgunder. I appreciate the opportunity to have him here. I know that Mr. Burgunder is well versed on this subject. I have known him over some years, and as a prominent official of a prominent concern down town, I know that he is very much for private enterprise. I think that we want to commend him for his efforts and the work he has done over the years in contributing his time, his effort and energy in trying to come up with some solutions to this whole parking problem.

Thank you.

Mr. BURGUNDER. Thank you, sir.

Mr. DOWDY. We have several other witnesses here yet to be heard. I wonder how many of you can file your statements?

Is Mrs. Thelma N. Dawson, the Executive Director of the Washington Building Congress, present? Her statement may be filed in the

record.

STATEMENT OF THE WASHINGTON BUILDING CONGRESS

The Washington Building Congress represents some 1600 members composed of architects, engineers, contractors, labor representatives, officials of government, public utilities companies and investment firms. Their prime interest is in helping build a better, more felicitous Washington. Representing that segment of our private enterprise concerned with construction and development, the Washington Building Congress is concerned with Zoning, Transportation, and Parking as they affect the welfare of the city. It in this spirit that we are here today. H.R. 15083 addresses itself to two major problems confronting the city: Congressional building height limitation and parking. We would like to address each of these items separately.

I. MODIFICATION OF THE ACT OF 1910 TO REGULATE THE HEIGHT OF BUILDINGS IN THE DISTRICT OF COLUMBIA

The Washington Building Congress favors an extension of the present Congressional height limitations in order to afford an opportunity to design buildings of a given floor area ratio with greater architectural design freedom in massing, ceiling height, and exterior treatment which will enhance the urban environment of our rapidly growing city.

The Washington Building Congress supports, as a matter of its policy, the modification or repeal of the Act of 1910 to Regulate the Height of Buildings in order that the Zoning Commission of D.C. may make such adjustments in height and F.A.R. as it may deem advisable at some future time, and in order to develop simpler and more workable Zoning Regulations.

In view of our position on these matters we generally view with favor the intent of H.R. 15083. However, we wish to make the following specific reservations:

(1) We do not believe that the Act of 1910 concerning height of buildings, an Act which is already confusing and difficult to administer because of many previous detailed amendments, should be further amended and made still more confusing. This Act was passed more than 10 years before we had any zoning legislation in the District of Columbia and more than 6 years before the first zoning legislation anywhere in the country. The detailed provisions which it contains have, for many years, been obsolete and should have been repealed and incorporated in the first zoning legislation for the District of Columbia. It would, of course, be appropriate for the Congress to establish an overall maximum height for buildings in the District of Columbia but this could be done in the form of a single sentence. (2) The Act of 1910 also contains a number of items which are, in effect, building code regulations and these should be repealed and made a part of the Building Code for the District of Columbia.

(3) We believe that the proposed maximum height limit of 230 feet is reasonable provided it is understood that (a) it is inclusive of all roof structures such as pent-houses and (b) the locations selected for height limits greater than those now permitted would be determined by the Zoning Commission or an appropriate agency of the Government of the District of Columbia.

(4) In our opinion H.R. 15083 would not be effective in providing the needed height relief. The Act of 1910 specifically controls the height of buildings in relation to the width of the street on which they front. These provisions must also be either amended or repealed in order that any extension of the maximum height limitations may be effective.

(5) H.R. 15083 also makes reference to maximum F.A.R. of 20. This would be the first instance of Congressional involvement in controlling the F.A.R. of buildings which we feel should continue under the control of the Zoning Commission of the District of Columbia.

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(6) We feel that the matter of building height regulation, being as complex as it is and being as germaine to our urban aesthetic and local real estate economy as it is, deserves specific attention by the Congress. Since before 1964, the Washington Building Congress has been developing a proposal for the amendment of the Acts of June 1, 1910, December 30, 1910 and May 20, 1912, relative to Height of Buildings. It represents the best thinking of those in the Washington Building Congress who are deeply concerned and highly knowledgeable about the matter. We offer as an attachment hereto our proposal for such an amendment.

(7) At this time the District of Columbia zoning authorities are undertaking a complete review of the Zoning Regulations. Various civic and professional bodies such as the local chapter of the A.I.A and the Washington Building Congress have offered them all possible assistance. We believe this effort will be immeasurably aided if the Act of 1910 is amended but would suggest that the provisions of the amendment be made effective at the time the restudy of the Zoning Regulations are adopted by the D.C. Zoning Commission or no more than one year after the passage of the

measure.

II. PARKING FACILITIES

First, it is appropriate to mention that the Washington Building Congress is on record as supporting Senator Tydings bill S. 944 which relates to the establishment of parking facilities in the District of Columbia. We recognize H.R. 5274 introduced by Congressman Sisk to be the companion bill on the House side. Our response to the parking provisions of H.R. 15083 are brief. We would make these observations:

(1) The need for dependable and permanently located parking facilities, well related to traffic arteries and centers of commerce is obvious.

(2) We recommend that these facilities should be established under some appropriate authority having power of eminent domain and the mandate to study the parking problem throughout the District of Columbia, inclusive of Federal properties.

(3) It would seem to us that framers of this bill, H.R. 5274 and H.R. 12463, introduced by Mr. Broyhill, could combine the best aspects of their respective proposals to produce a greatly needed and truly viable parking facilities program for the District of Columbia.

We wish to thank you for the opportunity to appear before this distinguished body.

PROPOSAL 1

The Washington Building Congress endorses and requests your support for the following proposed Act of Congress:

Amendment of the Acts of June 1, 1910, December 30, 1910, and May 20, 1912, Height of Buildings.

In order to permit a more effective administration of the zoning regulations of the District of Columbia, the following Acts or portions of Acts with respect to regulations concerning "Zoning and Height of Buildings" as referenced in Title 5, Chapter 4 of the District of Columbia Code, 1961 edition, namely the Acts of:

June 1, 1910, 36 Stat. 452, 453, 454, 455, ch. 263 paragraphs 1, 2, 3, 4, 5, 6, 7, 8, 9.

December 30, 1910, 36 Stat. 891, ch. 8.

May 20, 1912, 37 stat. 114, chapter 124, including later amendments thereto, are hereby repealed and the following substituted therefor:

"The Commissioners of the District of Columbia are hereby directed to incorporate in the Building Code of the District of Columbia on the basis of good current engineering and safety practice, any of the provisions of the above acts that are, in effect, building regulations.

The Zoning Commission of the District of Columbia is hereby directed to prepare, approve and enforce regulations governing height of buildings in the District of Columbia subject only to an overall limitation of 220 ft. in height inclusive of all penthouses and roof structures of any kind, such height to be measured as required by the zoning regulations; provided, however, that the Zoning Commission may make a special exception for increased height above the 220 ft. limit for church towers, domes, minarets, and radio or television towers.

The effective date of the repeal of the Acts or portions of Acts listed herein shall be one year after the passage of this Act and this same date shall also be

the effective date for the enforcement of the modifications of the Building Code and of the Zoning Regulations referred to in the preceding two paragraphs."

(As submitted to the D.C. Commissioners on September 15, 1964)

Mr. DowDY. Next is the American Security and Trust Company by Mr. S. T. Castleman, Senior Vice President.

Do you have a statement that you could file?

Mr. CASTLEMAN. Yes, Mr. Chairman, and members of the Subcommittee. I would like to file it, and if I can tell you just one thing, I shall appreciate it.

Mr. DowDY. Your statement will be made a part of the record.

STATEMENT OF S. T. CASTLEMAN, SENIOR VICE PRESIDENT, AMERICAN SECURITY AND TRUST COMPANY

Mr. CASTLEMAN. I am S. T. Castleman, Senior Vice President of the American Security and Trust Company. I thank you for the opportunity of letting me speak on this subject and to express our deep concern for parking in the downtown Washington area.

I have filed the statement with the Committee, and I will not proceed to read it.

(The statement submitted by Mr. Castleman follows:)

STATEMENT BY SAMUEL T. CASTLEMAN, SENIOR VICE PRESIDENT, AMERICAN SECURITY AND TRUST COMPANY

I am Samuel T. Castleman, Senior Vice President of the American Security and Trust Company. I am grateful for the opportunity to appear here today before this committee to express the deep concern of my organization about the parking situation in Downtown Washington.

We don't believe that there presently exists in the District of Columbia an adequate system for providing sufficient parking spaces to meet the needs of our business, and I understand that this problem exists for all banks in the District of Columbia.

In the first place, it is not possible at our Main Office at 15th and Pennsylvania Avenue, N.W., to provide sufficient parking space for our customers and employees. Furthermore, the privately run parking facilities located in this area are expensive to use, provide slow service in handling cars, and are generally all filled up by 11:00 A.M., each day.

Although some of our customers who work nearby in Downtown can walk to the bank, and lack of adequate parking facilities is a major problem for many of our customers who are not close by and who cannot conveniently use public transit. These customers must come in person to use the special services which are available, of necessity, only at our Main Office. These include: our complete trust and investment services; foreign exchange and international activities, construction and mortgage lending; and large government bond transactions. In addition, 75% of our business consultations and commercial loans are carried out at the Main Office. This office also contains the bulk of our safe deposit facilities for commercial establishments.

In addition to the difficulties experienced by our customers, the lack of adequate parking also is extremely inconvenient for many of our employees. Although a significant percentage use public transportation to get to and from work, some must drive regularly and others occasionally find it necessary to bring a car. The parking problems affect our operation in the following manner :

1. It is difficult to schedule meetings and start on time because those who must drive generally are unable to find a parking space within convenient walking distance. This is particularly true when branch personnel must come to the Main Office after mid-morning.

2. It is difficult to conduct meetings in the late afternoon because many people must leave in order to make connections with their car pools.

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