Room to Grow
The Parker bills are a great start. Here's how we can level up the impact.
The Gap
We scored 6 cities on transit-oriented zoning strength. Philadelphia ranks last.
Every peer city that has adopted transit-oriented zoning goes further than the Parker bill on parking, height, density, and geographic coverage. Philadelphia’s new law covers fewer stations, offers a smaller FAR bonus, and retains parking minimums that no other city still requires near transit.
| City | Parking | Height | FAR/Density | Coverage |
|---|---|---|---|---|
| Seattle, WA | No minimums citywide | Unlimited in urban centers | 75% density bonus w/ affordability | Citywide (all frequent transit) |
| Chicago, IL | No minimums near transit | No TOD-specific caps | 50% FAR bonus | ½ mile around all CTA stations |
| Austin, TX | No minimums citywide | 60 ft near transit | Compatibility standards relaxed | ¼ mile around transit stops |
| Baltimore, MD | No minimums in TOD zones | 65 ft in transit zones | Density doubled in TOD | ½ mile around rail stations |
| Prince George's Co., MD | 50% reduction near transit | 150 ft in activity centers | Up to 8.0 FAR in activity centers | ½ mile around Metro stations |
| Philadelphia (Parker) | 50% reduction (not elimination) | 45 ft (CMX-1/2, RM-1 only) | 30% FAR bonus | ¼ mile, 13 MFL stations only |
Fix the Bonus
The 30% FAR bonus brings buildings to 9 stories — the range the construction cost study flags as least efficient.
A landmark study by Eriksen & Orlando (Real Estate Economics, 2022) shows that in 24 of the 50 largest US cities, unconstrained developers build exactly 7 stories. At 8 stories, construction costs jump 32% due to the shift from wood-frame to steel/concrete. The 30% bonus (500% × 1.3 = 650% FAR) adds about two floors, bringing buildings to 9 stories — the range the study identifies as least cost-efficient.
Construction Cost / sqft
Four Massing Scenarios
Base Zoning
Current Code
Current CMX-3 zoning allows 500% FAR with 75% lot coverage. This maxes out at 7 stories — the sweet spot for Type III/IV wood-frame construction. Most efficient construction type with lowest per-unit costs.
Parker TOC Bill
Bill 260517
The 30% bonus is calculated on the base FAR (500% × 1.3 = 650%), adding +150% FAR — about two floors — to reach 9 stories. The cost study finds 8-9 stories is where returns are weakest: it requires Type I (steel/concrete) construction and its ~32% higher cost, while adding only modest floor area, so the added capacity is hard to build economically.
Transit Improvements Bonus
Bill 260518Bill 260518 doubles the transit-improvements bonus (§14-702(8)) for CMX-3 within /TOC from 100% to 200%, reaching 700% FAR (~10 stories) — rising past the steepest part of the cost cliff. This is an earned bonus: a developer claims it by spending a set share of hard costs on transit improvements. It adds no by-right capacity, and at 700% it's still short of the ~800% where Type I steel/concrete typically becomes economical on its own.
Cumulative Bonus Stacking
Recommended
Stacking the doubled transit-improvements bonus (200%, Bill 260518) and the mixed-income bonus (250%, §14-702(7)) on the 500% base reaches 950% FAR. At 12+ stories with 80% lot coverage, the building clears the cost cliff and becomes economical again — but only if the developer earns both contingent bonuses. The by-right path stops short of that.
The Cost Cliff
At 650% FAR, buildings reach 9 stories, which requires Type I steel/concrete construction — about 32% more per square foot — while adding only about two floors over the 7-story wood-frame optimum. The economics are strongest either at 7 stories (wood frame) or at 12+ stories, where added floor area offsets the higher cost. The 8-9 story range in between is where the cost study finds the weakest returns.
Add More Stations
The new law covers 13 Market-Frankford Line stations. Philadelphia has 85 more rail stations the bill reserves for later designation.
Around the 13 designated stations, the /TOC bonuses allow about 3,509 more homes on underused lots. Designating all 98 Broad Street Line, Market-Frankford Line, and Regional Rail stations would allow about 33,352, or 9.5 times as many.
The Stations We Want Added
We are asking each District Council Member to introduce amendments designating the stations in their district. Each card shows the line’s housing potential and its individual stations.
Broad Street Line
23 stations- 15th St/City Hall+6,010
- Walnut-Locust+4,225
- Race-Vine+1,827
- Chinatown+1,330
- Erie+1,225
- Broad-Spring Garden+1,127
- Susquehanna-Dauphin+932
- Fairmount+857
- North Philadelphia+803
- Broad-Girard+707
- Lombard-South+662
- Hunting Park+585
- Ellsworth-Federal+555
- Wyoming+548
- Broad-Allegheny+535
- Cecil B. Moore+376
- Logan+343
- Snyder+300
- Olney Transit Center+274
- Oregon+170
- Fern Rock Transit Center+99
- Tasker-Morris+59
- NRG Station—
Rest of the Market-Frankford Line
13 stations- MFL 11th St+4,155
- MFL 15th St+3,887
- MFL 8th St+3,842
- MFL 13th St+3,176
- Front-Girard+1,075
- MFL 5th St+886
- MFL 2nd St+782
- Church+745
- Drexel Station at 30th St+261
- Arrott Transit Center+231
- York-Dauphin+63
- 34th St—
- 40th St—
Regional Rail
49 stations- Jefferson+4,186
- Suburban+4,130
- North Broad+961
- Chelten Av+792
- North Philadelphia Septa+625
- Germantown+598
- Temple University+575
- East Falls+482
- Chestnut Hill West+477
- Gray 30th St Station+328
- Wayne Junction+234
- Chestnut Hill East+223
- Stenton+219
- Torresdale+194
- Manayunk+176
- Richard Allen Ln+166
- Bridesburg+156
- Ryers+147
- Gravers+143
- Overbrook+143
- Wissahickon+138
- Angora+124
- Wister+123
- Mount Airy+106
- Olney+92
- Washington Ln+82
- Allegheny+78
- Carpenter+54
- Tacony+42
- Queen Ln+40
- Wynnefield Av+35
- Tulpehocken+21
- Sedgwick+20
- Penn Medicine Station+15
- 49th St+14
- Cheltenham+10
- Upsal+3
- Fox Chase+2
- Airport Terminal A—
- Airport Terminal B—
- Airport Terminals E & F—
- Eastwick—
- Forest Hills—
- Highland—
- Holmesburg Junction—
- Ivy Ridge—
- Somerton—
- St. Martins—
- Wyndmoor—
New homes the /TOC bonuses would allow on underused lots with eligible zoning within a quarter mile of each station. Neighboring stations share lots, so station figures can add up to more than the line total, which counts each lot once. Girard Avenue and other trolley stops are not included: they must also meet a separate eligibility test that we have not modeled yet. See every lot on the TOC Scenario Map.
Designated Stations Alone vs. All Stations
The MIN Gate
At the 13 designated stations, 59% of the homes today's zoning allows on underused lots sit behind an affordability requirement that carries no subsidy.
The Mixed Income Neighborhoods (/MIN) overlay requires projects of 10 or more homes to make 20% of them affordable at 40% of area median income, with no subsidy attached. It also bars the /TOC floor-area bonus. Every analysis we have run, and the City’s own reporting, says that combination does not pencil without a subsidy.
The Market-Frankford Line, station by station
All 26 Market-Frankford stations in Philadelphia: the homes today’s zoning allows on underused lots within a quarter mile, how many of those sit behind /MIN, and the new homes /TOC would allow.
| Station | Designated | Homes allowed today | Behind /MIN | % behind /MIN | New homes with /TOC |
|---|---|---|---|---|---|
| MFL 11th St | — | 12,873 | 0 | 0% | 4,155 |
| MFL 8th St | — | 11,755 | 0 | 0% | 3,842 |
| MFL 15th St | — | 11,349 | 0 | 0% | 3,887 |
| MFL 13th St | — | 9,271 | 0 | 0% | 3,176 |
| Drexel Station at 30th St | — | 7,729 | 6,860 | 89% | 261 |
| 40th St | — | 4,658 | 4,658 | 100% | 0 |
| 56th St | Yes | 3,984 | 3,652 | 92% | 122 |
| Erie-Torresdale | Yes | 3,962 | 587 | 15% | 1,086 |
| 46th St | Yes | 3,527 | 3,527 | 100% | 0 |
| Front-Girard | — | 3,137 | 0 | 0% | 1,075 |
| Spring Garden | Yes | 3,005 | 0 | 0% | 970 |
| MFL 5th St | — | 2,602 | 0 | 0% | 886 |
| MFL 2nd St | — | 2,349 | 0 | 0% | 782 |
| Arrott Transit Center | — | 2,128 | 1,503 | 71% | 231 |
| Frankford Transit Center | Yes | 1,981 | 1,860 | 94% | 42 |
| Church | — | 1,855 | 0 | 0% | 745 |
| Kensington-Allegheny | Yes | 1,652 | 817 | 49% | 301 |
| 52nd St | Yes | 1,436 | 1,412 | 98% | 9 |
| 60th St | Yes | 1,329 | 735 | 55% | 301 |
| York-Dauphin | — | 1,126 | 951 | 84% | 63 |
| Somerset | Yes | 1,039 | 487 | 47% | 142 |
| Berks | Yes | 1,016 | 907 | 89% | 37 |
| Tioga | Yes | 951 | 272 | 29% | 247 |
| 63rd St | Yes | 870 | 339 | 39% | 266 |
| Huntingdon | Yes | 602 | 332 | 55% | 89 |
| 34th St | — | 541 | 541 | 100% | 0 |
Downtown stations are a few blocks apart, so their areas overlap and the rows cannot be added together. Counting each lot once, the line holds 73,078 homes of capacity on underused lots, of which 28,897 (40%) sit behind /MIN. Inside /MIN the /TOC figures leave out the 50% unit bonus: those homes would carry the /MIN requirement, so they are not counted.
Three parts of the line, three different situations
West Philadelphia (30th Street through 63rd) is where /MIN and the line overlap most. At 40th and 46th Streets, all of the capacity on underused lots is behind /MIN.
Center City (2nd through 15th, plus Spring Garden, Front-Girard, and Church) has no /MIN and holds the most capacity on the line. Only Spring Garden is designated.
Kensington and the Northeast (Berks to Frankford) is mixed, from 15% behind /MIN at Erie-Torresdale to 94% at Frankford Transit Center.
What we are not claiming
We do not estimate how many homes /MIN has cost transit-oriented development specifically. BPN’s MIN study finds the overlay as a whole is associated with roughly 1,000–1,400 fewer homes against a market-strength-matched control. Splitting that across the transit areas would be a modeling assumption, not a measurement, so we report the gated capacity instead. Full MIN analysis.
Eliminate Parking Minimums
Parking requirements consume floor area within a fixed height envelope, killing housing units.
In a 38-foot building — the maximum in most residential districts — requiring ground-floor parking eliminates an entire residential floor. Each parking space consumes roughly 350 sqft including drive aisles. Across all TOC-eligible parcels, current parking minimums destroy 10,545 housing units that could otherwise be built.
Units Lost to Parking by Scenario
Parking Rates by District (Zoning Code \u00a714-804)
1 space/unit: RM-3, RM-4, RSA-1, RSA-2, RSA-3, RTA-1
0.5 space/unit: RM-2
0.3 space/unit: CMX-3
No requirement: RM-1, CMX-1, CMX-2, CMX-2.5, CMX-4, CMX-5
The Parker bill reduces these by 50% but does not eliminate them. A 10-unit building in RSA-3 would still need 5 parking spaces — consuming 1,750 sqft that could hold 2 additional units.
Pass CMX-1 Reform. Add the Stations. End the Parking Minimums.
The TOC law is a credible start. Council can make it meaningful by passing CMX-1 reform, designating the remaining rail stations, and eliminating parking minimums in the TOC overlay.
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