
Subject
title
Level 2 Site Plan Application STP2025-00503, to Permit Conversion of 13,011 Square Feet of Previously Approved Street-level Retail into 13 Residential Units at 198 East Montgomery Avenue.
end

Department
CPDS - Development Review

Recommendation
Staff recommends approval of the Level 2 Site Plan STP2025-00503, based on the findings and conditions of approval contained in this report.

Discussion

Case: Level 2 Site Plan STP2025-00503 - 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, 2025
Meeting
Date: October 8, 2025

Executive Summary
Comstock 33 Monroe, LC (the “Applicant”) has filed a Level 2 Site Plan application to convert 13,011 square feet of existing vacant street-level commercial space into 13 residential dwelling units at 198 East Montgomery Avenue (the “Property”). The Planning Commission’s role is to conduct a review of the application at a public meeting and decide on the proposed site plan, as outlined in Section 25.07.01.a.3(a) of the Zoning Ordinance (the “Ordinance”).
After a comprehensive review of the application, staff has found that the application complies with all relevant City codes and policies. Based on the review, and as described in the proposed findings and recommended conditions, staff recommends approval of the site plan.
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) |
OCRM (Office Commercial Residential Mix) |
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.) |
OCRM (Office Commercial Residential Mix) |
Residential/Commercial |
The subject 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).

Project Description
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 unit. 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.

Previous Related Actions
On September 15, 2025, Mayor and Council conditionally approved Project Plan Application PJT2025-20, an amendment Rockville Center Inc., Planned Development, to permit conversion of 13,011 Square Feet of previously approved street-level retail into 13 residential units at 198 East Montgomery Avenue.
Pursuant to Section 25.07.07.21 of the Ordinance, the Applicant is required to file this Level 2 Site Plan application to implement the September 2025 Project Plan approval.

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.”
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.

Community Outreach
Notifications for this Level 2 Site Plan application have been 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). Since the approval of the Project Plan application, and as of the date of this report, staff has not received any additional communication on this application from any members of the public.

Findings
In accordance with Section 25.07.01.a.3(b) of the Ordinance, a site plan that implements all or a portion of an approved project plan is deemed to meet the findings of approval so long as the site plan complies with conditions and requirements of the approved project plan and where the application will not:
1. Be detrimental to the public welfare or injurious to property or improvements in the neighborhood;
The proposed project will not be detrimental to the public welfare nor injurious to property in the surrounding neighborhood. 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 and welfare 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 welfare and safety are maintained during and after the construction phase of the project.
2. Constitute a violation of any provision of the Zoning Ordinance or other applicable law;
Staff has reviewed the proposed development for compliance with the Ordinance and finds it to be consistent with the requirements. The Mayor and Council, having approved a Project Plan amendment for the Property, authorized the proposed residential conversion within the existing building. Given that the project will encompass mostly interior alterations and minimal exterior improvements beyond minor grading and façade improvements, the subject site will continue to function under the approved development standards of the previous approvals for the site. The building will maintain the height, setbacks, public use space and other and development requirements previously approved for the site. The Zoning Ordinance requires 19 parking spaces for the new 13 residential units. Accounting for previously approved parking reductions and the new proposed allocation of uses on the site, adequate parking will continue to be provided on-site within the building’s parking garage. The project will also continue to provide adequate bicycle facilities, provide a surplus of short-term and long-term bicycle parking spaces. With all applicable development requirements met, the project will not violate the Ordinance.
3. Be incompatible with the surrounding uses or properties.
The project will provide complementary uses to surrounding properties and will therefore not be incompatible with the neighborhood. The Property is located in Town Center, characterized by a variety of uses and buildings intensities amongst an urban grid street network. The combination of residential and commercial uses within the same building is a common occurrence within this area. With the addition of 13 residential uses, the building will continue to provide both residential and commercial uses, consistent with neighboring properties. The project will also complement the area by bringing additional residents to the neighborhood, providing additional opportunities to support existing businesses while bolstering the city’s adopted policies to provide more housing in Town Center. Furthermore, the project will replace vacant commercial space with active residential ground floor uses along prominent street frontages in Town Center to further augment and revitalize street activity. The project also provides the opportunity to focus retail uses to its established presence around the existing Town Square while also providing a customer base in the form of new residents to support such amenities and services.

Conditions
Staff recommends approval of Level 2 Site Plan STP2025-00503, based on the above findings and following conditions of approval:
Planning and Zoning
1. The Applicant must fully comply with the conditions of approval for Project Plan PJT2025-00020 as outlined in the adopted Resolution No. 15-25.
2. The Applicant shall sign and return the approval letter prior to finalizing the site plan signature set. The approval letter shall be included in the stamped approved signature set.
3. 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 approved Level 2 site plan signature set.
DPW - Engineering
4. A Public Works permit (PWK) shall be required per Chapter 21 of the Rockville City Code to construct, excavate, drill, connect to, install, or plant any public improvement of a permanent or temporary nature in the City right-of-way or easement.
5. Provide Stormwater Management (SWM) for all new and replacement impervious area as required by Chapter 19 of the Rockville City Code, entitled "Sediment Control and Stormwater Management" if the development creates or replaces 250 square feet or more of impervious area, or if the project involves 5,000 square feet or more of disturbed area. Applicant must submit a SWM application, minimum plan review fee and a sketch delineating and quantifying the new and replacement impervious area within the project's limit of disturbance. Monetary Contributions must be paid prior to issuance of building permit.
CMO - Publicly Accessible Art in Private Development
6. The applicant elected to make a monetary contribution to fulfill the AIPD requirement, and the AIPD application for this option was approved. The following is required of the applicant, per the AIPD Implementation Manual:
a. If making a monetary donation to an Eligible Arts Organization: An Eligible Arts Organization is defined as an organization that has met the following five (5) criteria for at least twenty-four (24) consecutive months immediately preceding a proposed donation of money, arts space, or arts-based infrastructure:
i. Has as its primary mission the exhibition, presentation, production or performance of, and/or education in the arts and/or the humanities;
ii. Holds current status under IRS code 501(c)3 or is a specifically defined arts organizations within a larger 501(c)3 organization;
iii. Has its primary office in the City of Rockville;
iv. Is governed by an independent, legally liable board of directors operating under a mission statement for the organization and an operating budget specific to the organization; and
v. Offers more than half of its programs and services in the city and they are open to the public, with or without charge.
b. Written confirmation the donation has been made must be given by the developer, and written confirmation of the donation receipt given by the recipient, to the Arts and Culture Program Manager before Permit Issuance.
c. If the applicant makes a monetary contribution to the city’s Art in Public Places Program, the contribution can be designated for a public art project in the area of the development with credit given to the applicant. For information about upcoming public art projects in the development area, contact Anne O’Dell, Arts and Culture Program Manager, at (aodell@rockvillemd.gov).