Planning Commission Staff Report
Overview
Case: Project Plan PJT2025-00020 - BLVD Lofts
Location: 198 East Montgomery Avenue
Staff: Chris Davis, Senior Planner
Community Planning and Development Services
240.314.8201
cdavis@rockvillemd.gov <mailto:cdavis@rockvillemd.gov>
Applicant: Comstock 33 Monroe, LC
Filing Date: January 28, 2024
Planning
Commission
Date: July 23, 2025
Background
Comstock 33 Monroe, LC (the “Applicant”) has filed a Project Plan application to convert 13,011 square feet of existing vacant street-level commercial space into 13 residential dwelling units. In order to allow this project as proposed, an amendment to the Rockville Center Inc. Planned Development (“PD”) is required pursuant to Section 25.14.07 of the Zoning Ordinance. The PD was initially established by the Planning Commission on April 27, 1994, with approval of Preliminary Development Plan PDP94-00001 for Rockville Center Inc., and allowed redevelopment of the former Rockville Mall property into a phased, multiple-building, mixed-use development known as Rockville Center on 5 record lots (originally subdivided as Parcels 2-F, 2-G, 2-H, 2-J and 2-K within the Rockville Town Center subdivision), located at the southwest corner of Rockville Pike (MD 355) and East Middle Lane intersection.
The PD originally established a new five (5)-block mixed use development including office, retail and residential uses totaling approximately 1.4 million square feet. The subject property was specified as Lot 2 that was approved for approximately 500,000 square feet of office and retail uses. In 2005, the Mayor and Council adopted Resolution No. 10-05 (PDP1994-0001E) which amended the PDP to revise the mix of uses on Lots 2 and 3 to remove the office uses and allow a mix of retail, commercial and residential uses, including 255 residential units on the subject property. In 2014, the Mayor and Council further amended the PD with adoption of Resolution No. 21-14 which increased residential uses on Lot 2, including an increase from 255 to 400 residential units.
PD amendments require the filing of a Project Plan application, and the application may be approved only if the Mayor and Council find that approval of the application will not:
a. Adversely affect the health or safety of persons residing or working in the neighborhood of the proposed project;
b. Be in conflict with the Plan;
c. Overburden existing and programmed public facilities as set forth in Article 20 of the Zoning Ordinance and as provided in the adopted Adequate Public Facilities Standards (APFS);
d. Constitute a violation of any provision of the Zoning Ordinance or other applicable law; or
e. Adversely affect the natural resources or environment of the City or surrounding areas.
In accordance with Section 25.07.07 of the Zoning Ordinance, the Mayor and Council and Planning Commission were previously briefed on this Project Plan application. The Planning Commission will now consider the request and make a recommendation to the Mayor and Council on the application. At future meetings, the Mayor and Council will hold a public hearing and consider a resolution to amend the PD and approve the Project Plan application. Should the Mayor and Council ultimately approve the amendment to the PD, and thereby approve the Project Plan, the Planning Commission will consider a site plan for the development project.
end
Site Description
Location: 198 East Montgomery Avenue
Planning Area: Planning Area 1 - Town Center
Land Use
Designation: CRM - Commercial Residential Mix
Zoning District: PD-RCI (Planned Development - Rockville Center, Inc.) with MXTD (Mixed-Use Transit District) Equivalent Zone
Existing Use: Mixed-Use Building (including 22,200sf of commercial space and 400 dwelling
units)
Proposed Use: Mixed-Use Building (including 8,000sf of commercial space and 413 dwelling
units)
Site Area: 1.41 acres (61,469 square feet)
Building Height: 173 feet
Surrounding Land Use and Zoning
|
|
Zoning |
Planned Land Use |
Existing Use |
|
North |
PD-MC (Planned Development - Metro Center) |
O (Office) |
Commercial |
|
East |
PD-RCI (Planned Development - Rockville Center, Inc.) |
OCRM (Office Commercial Residential Mix) |
Commercial |
|
South |
PD-RCI (Planned Development - Rockville Center, Inc.) |
OCRM (Office Commercial Residential Mix) |
Commercial |
|
West |
PD-RCI (Planned Development - Rockville Center, Inc.) |
CRM (Commercial Residential Mix) |
Residential/Commercial |
The Project Plan site is identified as Parcel 2-L of the Rockville Town Center and is approximately 1.41 acres (61,469 square feet). The property is generally square in shape and is bounded by East Middle Lane to the north, Monroe Street to the east, East Montgomery Avenue to the south, and Helen Heneghan Way to the west. The site is relatively flat, with a slightly downward slope from East Montgomery Avenue towards East Middle Lane. The property is improved with an 18-story mixed-use building with commercial spaces concentrated on the ground floor and residential uses on the remaining floors above. At the street level, the building is surrounded by expanded sidewalks, street trees, and furniture to enhance the pedestrian realm around the building. The property is within the PD-RCI (Planned Development - Rockville Center, Inc.) Zone, and has an equivalent zone of MXTD (Mixed-Use Transit District), and is subject to the Rockville Center, Inc. PD governing documents.
Project Description
title
The Applicant proposes to convert 13,011 square feet of existing vacant street-level commercial space into 13 residential dwelling units, known as the BLVD Lofts. The dwelling units will be designed as two-level lofts and will include (1) 1-bedroom unit, (11) 2-bedroom units, and (1) 3-bedroom units. Most of the proposed dwelling units will be located along East Middle Lane with several others located on Helen Heneghan Way and Monroe Street.
Figure 1: Site/interior floor plan depicting the proposed unit bedroom types. (Plan provided by applicant, markup by staff)
According to the Applicant, the 6,500 square feet of existing commercial space along East Montgomery Avenue will remain as approved for retail use. The 17 parking spaces required for the proposed residential units will be provided within the existing on-site non-reserved structured parking garage. The Applicant is not proposing any MPDUs for the proposed 13 converted units as the existing building currently provides MPDUs for 32% of the building’s total units. The subject project has been reviewed and found to be in compliance with all necessary code requirements, as further detailed in the “Findings” section of this report.
The new residential uses will have access to several amenities. According to the Applicant, a mail and package room will be provided within the lobby of the building for the benefit of future residents near the Monroe Street entrance. Additionally, the Applicant has indicated that residents of the proposed BLVD Lofts will also have access to the existing residential amenities in other areas of the building including an upper-level clubroom, open courtyard with pool, outdoor dining and gathering spaces, fitness center, business center and co-working spaces and a secure bicycle room with maintenance and repair facilities. The façades of the residential units will utilize materials and details that will communicate an urban frontage that will include two-story window walls. Most of the units will have direct access to the adjacent sidewalks of the building.
Project Analysis
Master Plan
The project is located within Planning Area 1 (Town Center) of the City of Rockville’s Comprehensive Plan, Rockville 2040 (“Plan”), and the Land Use designation applied to the site is CRM (Commercial Residential Mix). The CRM designation focuses on, “retaining and introducing commercial uses in specific locations mixed with multiple unit residential and/or residential attached types. The mix can be horizontal, with stand-alone commercial next to apartment buildings on a site; or the mix can be vertical, with commercial on the ground floor and apartments above.” Additional details on compliance with the Plan and other requirements are provided in the “Findings” section of this report.
Public Notification and Engagement
Notifications of the Project Plan application were made consistent with City Code requirements. The Applicant held a virtual pre-application area meeting on December 9, 2021. The Applicant also held a virtual post-application area meeting on February 25, 2025.
As of the date of this report, staff has received 4 emails from members of the public providing comments of support and opposition on the proposed project (See “Public Testimony” attachment). Additional public engagement opportunities will be scheduled later as described in the ‘Next Steps’ section of the staff report.
Boards and Commission Review
In accordance with Section 25.07.07.6 of the Zoning Ordinance, the Planning Commission was briefed on this project at their March 12, 2025 meeting, and the Mayor and Council were briefed on April 7, 2025. At the briefings, the Planning Commission and Mayor and Council asked questions and offered suggestions concerning the development proposal.
Both the Commission and the Mayor and Council’s feedback was generally positive on the project, but both bodies did express a desire to see some form of landscape buffer or physical transition from the private front entries of the residential units to the public sidewalks abutting the building to enhance privacy for the units. The Applicant has responded to these comments by updating their plans with additional elements to distinguish and buffer the front entries of the units from the sidewalk, including the addition of entry shade canopies and planter boxes for additional landscaping. The Mayor and Council also inquired about the history of MPDUs with this project, and the Applicant responded that while no new MPDUs were proposed with this amendment, the building would continue to provide 32% of its units as MPDUs, exceeding the 15% requirements, as was established in previous approvals.
Next Steps
Following the Commission’s review, the Project Plan application will be scheduled for a public hearing by the Mayor and Council. Upon hearing information and feedback from the public hearing, the Mayor and Council will render a final decision on the proposed Project Plan as an amendment to the Planned Development via adoption of a resolution, incorporating the findings as required by Section 25.07.01.b.2 of the Zoning Ordinance. If the application is approved, the Mayor and Council will establish a period within which construction of the approved Project Plan must commence. Following Project Plan approval, the Applicant must obtain approval of a Level 2 Site Plan.
Findings
In accordance with Section 25.14.07.e.2, any proposal to amend the Planned Development Governing Documents must comply and be processed in accordance with the requirements for a Project Plan as set forth in Article 7. Pursuant to Section 25.07.01.b.2, a Project Plan may be approved only if the Mayor and Council find that the approval of the application will not:
(i) Adversely affect the health or safety of persons residing or working in the neighborhood of the proposed project:
The Applicant’s proposed design seeks to produce additional housing units within the envelope of the existing building by utilizing existing ground-floor commercial space that has been vacant since 2021. The proposed conversion into 13 residential units would mostly involve interior alterations to the building and minor modifications to the building’s exterior façade. These improvements will add new housing options to Town Center to assist in supporting the surrounding business district and will enhance the safety of the surrounding area by adding use and activity to the street-level of the building. The project will be required to abide by all applicable building and construction requirements to ensure public health and safety are maintained during and after the construction phase of the project. Therefore, the proposed conversion is not anticipated to adversely affect the health or safety of persons residing or working in the neighborhood of the project.
(ii) The Project Plan will not be in conflict with the Plan.
The project is not in conflict with the Rockville 2040 Comprehensive Plan. This project falls within Planning Area 1 of the Plan. On January 27, 2025, the Rockville Mayor and Council adopted the 2025 Rockville Town Center Master Plan as an amendment to the Comprehensive Plan, originally adopted in August 2021. Adoption of this updated plan repeals and replaces the Planning Area 1 chapter of the Plan and the 2001 Town Center Master Plan. With the exception of several specific properties, the 2025 Town Center Master Plan (TCMP) retains the existing land use policy established in the Plan for most properties in the Town Center. The 2025 Plan does not provide specific recommendations for the subject property. However, staff finds the following compatibilities outlined in the Town Center Master Plan:
• Goal 1, Land Use: “Target appropriate areas for higher density residential developments to reach 3,000 new residential units by 2040. Provide a variety of development types to adapt to marketplace demands and to address missing middle housing” (page 41). In response to changing market demands, the Applicant is proposing additional residential units in Town Center where additional residential density is encouraged by the TCMP.
• Action 1.1, Land Use: “There should be no requirement for ground floor retail, although street-facing, active ground floor uses, including residential or quasi-retail uses should be encouraged” (page 42). The Applicant is proposing a conversion from vacant ground floor retail space to residences as anticipated and encouraged by the TCMP.
• Housing Chapter: “The city encourages the development of a wide variety of unit types - this refers to different housing typologies (such as townhomes and multifamily apartment buildings) but also provides a mix of units within those typologies (studios, 1-bedroom units, 2-bedroom units, etc.). The city encourages unit mixes in development projects to contain the full range of unit types that the market can support of different sizes and layouts to accommodate the greatest variety of households” (page 60). The Applicant proposes 13 new residential units within the existing building that will include 1, 2 and 3-bedroom units to appeal to a variety of family sizes.
• Policy 12.1, Sustainability: “Encourage the adaptive reuse of buildings and coordinate with property owners to increase efficiency within existing buildings” (page 91). The Applicant proposes to adaptively reuse a ground-floor commercial space that has been vacant since 2021 by converting such space into 13 residential units, that will allow the property owner to more efficiently use such space within the existing building, consistent with this policy.
(iii) Overburden existing and programmed public facilities as set forth in Article 20 of the Zoning Ordinance and as provided in the adopted Adequate Public Facilities Standards;
The Project will not overburden existing and programmed public facilities as set forth in Article 20 of the Zoning Ordinance and as provided in the adopted adequate public facilities standards.
Schools
The property is served by the Richard Montgomery Cluster Area (Beall Elementary School, Julius West Middle School, and Richard Montgomery High School), and is located within a Infill School Impact Area. Using the corresponding Montgomery County FY2025-20230 Student Generation Rates, the proposed development will generate the following number of students:
• 1 student at the elementary school grade level;
• 0 students at the middle school grade level; and,
• 0 students at the high school grade level
The current school test standards of the APFS utilize a seat deficit and capacity percentage calculation to determine adequacy. The maximum permitted capacity level is 120% and no more than a 110-seat capacity deficit in elementary schools and 180-seat capacity deficit in middle schools. The proposed development meets these standards at all three grade levels as shown in the table below.
|
School Test: Seat Deficit > 110 Seats (Elem.) or > 180 (Middle) and Percent Utilization >120% (Elem., Middle, and HS) = Moratorium |
|
School Type (Richard Montgomery Cluster) |
Projected 2029-30 Enrollment |
Students Generated by Proposed Development |
100% MCPS Program Capacity 2029-30 |
Enrollment Including Proposed Development |
School Percent Utilization in 2029-2030 |
School Percent Utilization in 2029-30 with Proposed Development |
|
Beall ES |
440 |
1 |
663 |
441 |
66.4% |
66.5% |
|
Julius West MS |
1,404 |
0 |
1,432 |
1,404 |
98.0% |
98.0% |
|
Richard Montgomery HS |
2,604 |
0 |
2,236 |
2,604 |
116.5% |
116.5% |
Traffic and Transportation
With no changes proposed to the existing and built transportation and access infrastructure, and considering the proposed changes are resulting in fewer AM and PM vehicle trips, the approval of the proposed plan will have no impact to the existing and planned transportation infrastructure serving the site.
Access and Circulation:
1. Passenger Vehicle:
The development vehicular access will be provided to East Middle Lane to the north and East Montgomery Avenue to the south via existing service and parking driveways on Monroe Street and Helen Heneghan Way. These roadways are classified as Business District roadways, and as such existing buffered sidewalks are provided along the site frontage on East Middle Lane, Monroe Street, Helen Heneghan Way and East Montgomery Avenue. Truck (loading and trash) access to the site will continue to be along the service driveway, with an entrance on Helen Heneghan Way and exiting onto Monroe Street. The loading area will accommodate head-in and head-out turning maneuvers without impacting the public right-of-way. The property is located within the designated Rockville Metrorail Transit Oriented Area, as defined by the CTR guidelines.
2. Pedestrian Access:
No changes to existing pedestrian access to existing sidewalks are proposed.
3. Transit Access:
The Rockville Metrorail/ MARC commuter train and Amtrack reginal train station, is located approximately 0.2 miles from the site. The WMATA Metrorail Red Line runs from the Shady Grove station in Rockville to Glenmont in Silver Spring by way of downtown Washington, DC. There are two (2) bus stops near the site, located on East Middle Lane at its intersection with Monroe Street. The bus stop serves one (1) WMATA bus route (T2) and three (3) Montgomery County Ride-On Bus routes (45, 55, 301).
Trip Generation
Using the approved trip generation rates outlined in the Institute of Transportation Engineers (ITE) Trip Generation Manual, 11th Edition, the proposed changes in use will generate 28 fewer trips in the morning peak hour (18 fewer inbound & 10 fewer outbound) and 64 fewer trips in the afternoon peak hour (32 fewer inbound & 32 fewer outbound)
Water and Sewer
In a letter dated July 2, 2025 (see “Water and Sewer Authorization Letter” attachment) the proposed development received Water and Sewer Authorization approval from the Department of Public Works (DPW) for connection to the City’s water and sanitary sewer systems. The Water and Sewer Authorization Approval Letter lists project specific conditions of approval.
(iv) Constitute a violation of any provision of the Zoning Ordinance or the applicable law;
Staff has reviewed the proposed development for compliance with the Zoning Ordinance and finds that the development proposal is consistent with the Zoning Ordinance requirements. The project complies with the applicable development standards and design regulations of the governing PD-RCI documents and the equivalent MXTD zone. The scope of the project is focused toward interior alterations to transform the existing vacant ground-floor retail space into 13 new residential units; exterior modifications will be limited to minor façade updates to create new residential frontages. In addition to authorizing the change in uses on the site, the project also meets the corresponding parking requirements for both automobiles and bicycle vehicles for the change in use. Beyond the proposed project scope, the overall building and site will continue to comply with the requirements as established by the PD-RCI governing documents and the equivalent MXTD zone as was approved with the previous Project Plan PJT2014-00003. As previously mentioned, the 2014 Project Plan approval designated the site to provide 32% of its units as MPDUs, exceeding the 15% minimum required. Under the current proposal, the site will continue to exceed the minimum requirements and no additional MPDUs are required with the current proposal.
No changes to bicycle access are proposed, and the project will meet the bicycle parking requirements required under City Code as noted later in this report. The existing access points along the Monroe Street frontage, allow for easy access to bicycle lanes along East Middle Lane and the signed shared roadway along Monroe Street which connect the site to an existing network of bike lanes and signed shared roadways near the site and provide access to Rockville Metrorail station (Red Line). A bi-directional Shared Use Path is also planned by the city along the Monroe Street frontage as part of the Fleet Street and Monroe Street Complete Streets project.
Pedestrian elements within the right-of-way shall be fully accessible and comply with the criteria for accessible routes in the 2010 ADA Standards for Accessible Design. Where the running slope of a sidewalk exceeds 1:20, such sidewalk or portion thereof shall comply with the requirements for ramps found in §405 of the 2010 ADA Standards for Accessible Design. Conformance with other requirements, including but not limited to other zoning requirements, city codes, and the building code, will be confirmed through the site plan, permit review, or other applicable process.
(v) Adversely affect the natural resources or environment of the City or surrounding areas.
Stormwater Management
Stormwater Management (SWM) for this project will be provided by a monetary contribution in lieu of providing water quality volume, channel protection volume and water quantity management for the minimal new and replaced impervious areas associated with retrofitting the existing building.
Forestry
Forest Conservation
The subject property is subject to an existing forest conservation plan under FTP2006-00019. That plan met the required forest conservation requirements for the entirety of the subject property. There are no anticipated changes to the existing forest conservation plan, which will remain in effect.
Significant Trees
The NRI/FSD (see “Approved NRI Plan” attachment), 2025-22-NRI, that was approved by CPDS on March 3rd, 2025, identified nineteen (19) street trees on the subject property. These trees are not proposed for removal and will be preserved throughout the project.
Street Trees and Lot Trees
The proposed application does not involve subdivision, and as a result the subdivision regulations are not applicable. However, street trees were previously provided in association with the development of the property and are in existence on the subject property. This was confirmed through a recent NRI/FSD.
Historic Resources
The property is not within a historic district and has no potential historic resources on site.
Recommendation
Staff recommends that the Planning Commission forward to the Mayor and Council a recommendation to approve Project Plan application PJT2025-00020, a proposed amendment to the Rockville Center Inc. PD initially approved with Preliminary Development Plan PDP94-00001, as amended and the subsequent Project Plan PJT2014-00003, subject to the findings and conditions identified in this report.
The Planning Commission must review the Project Plan application and provide an opportunity for public comment. After its review, the Commission shall prepare and transmit its comments and recommendation on the application to the Mayor and Council.
Conditions
Staff recommends approval of the application subject to the following conditions, to be incorporated into a Resolution for Mayor and Council consideration:
Planning and Zoning
1. The proposed development will be designed and constructed in a manner consistent with the concept design, graphic conceptual representation, and all associated development tables included in the project plan set.
DPW - Engineering
2. The applicant shall comply with the conditions of DPW’s Water & Sewer Authorization Approval Letter dated July 2, 2025.