TOC Impact Analysis
A parcel-by-parcel look at Mayor Parker's transit-oriented housing bills — what they cover, where the housing can go, and what's getting in the way.
Build Philly Now · March 2026
Download PDF →Executive Summary
Mayor Parker’s HOME II bill would expand transit-oriented zoning around 13 Market-Frankford Line stations, giving commercially-zoned properties the green light to build more housing. We analyzed every eligible parcel using city property data and Philadelphia’s zoning code to answer a simple question: how many homes could this actually produce?
The headline figure includes dimensional restrictions from /FNE, /VDO, /WST, and /PCH overlays, the CMX-3 cost cliff, and the MIN overlay (~2,575 additional units blocked in Districts 3 & 7, detailed in Section 5).
Two problems hold the bill back. First, a construction cost “cliff” makes the FAR bonus for CMX-3 districts economically unviable, costing an estimated 1,483 units. Second, the Mixed-Income Neighborhoods (MIN) overlay in Districts 3 and 7 is estimated to cost ~2,575 additional units — 8.6% of the Mayor’s 30,000-home goal.
1. What the Bill Covers
The expansion reaches further from stations — but the vast majority of affected land is single-family and receives zero changes.
Eligible Parcels: Before vs. After
What’s Inside the Expanded Radius?
The bill expands the TOC overlay from 500 feet to 1,320 feet (one-quarter mile) around station entrances. This increases eligible parcels by 5.5x — but even at the wider radius, only 1.7% of Philadelphia’s 551,412 parcels are affected. The other 9,437 parcels in the radius are single-family homes, townhouses, and other categories that receive no zoning changes whatsoever.
| Current (500 ft) | Expanded (1,320 ft) | Change | |
|---|---|---|---|
| Total parcels in radius | 3,254 | 18,644 | +15,390 |
| Eligible for TOC bonuses | 1,685 | 9,207 | +7,522 |
| Share of all city parcels | 0.3% | 1.7% | — |
Eligible Parcels by Zoning District
RM-1 (multi-family residential) accounts for 80.9% of eligible parcels. Density-bonus zones (RM-1, CMX-1, CMX-2, CMX-2.5) receive a 50% dwelling unit bonus. FAR-bonus zones (CMX-3, CMX-4) receive a 30% FAR bonus.
2. Where Will New Housing Actually Go?
Of the 9,207 eligible parcels, we identified 1,482 where new development is most realistic — places that are vacant, underused, or economically ripe for change.
A fully-built rowhouse isn’t going to be torn down for a slightly larger building. To focus on parcels where development is actually likely, we classified every eligible property into “opportunity site” categories based on what’s currently on the ground:
Why This Matters
These 1,482 opportunity sites represent the realistic near-term pipeline — where market conditions, land economics, and physical conditions all point toward redevelopment. The remaining 7,725 eligible parcels have existing buildings that are well-utilized and unlikely to change in the near term, though they retain long-term capacity.
3. How Many Homes?
We estimate housing capacity at three levels — from the theoretical maximum down to a conservative, real-world projection.
Our zoning rules engine calculates the maximum building size each parcel could support under the zoning code, then converts that floor area into dwelling units (using a conservative 750 sqft average). We then apply two reality checks: first, narrowing to opportunity sites only; second, subtracting units lost to the construction cost cliff (explained below).
| Tier | What It Means | Additional Units |
|---|---|---|
| Maximum possible | Every eligible parcel built to full zoned capacity | +30,242 |
| Opportunity sites (gross) | 1,482 vacant, underbuilt, and economically ripe parcels at full capacity | +11,803 |
| Lost to cost cliff | CMX-3 parcels where the bonus pushes into unviable 8-story construction | −1,483 |
| Realistic (before MIN) | Opportunity sites after the construction cost cliff | +10,320 |
| Lost to MIN FAR block | 30% FAR bonus blocked by law in CMX-3/4/5 within MIN (§14-513(5)(a)(.2)) | −1,361 |
| Lost to MIN deterrent | Density-bonus projects ≥10 units deterred in MIN (0.54 difference-in-differences rate) | −1,214 |
| Realistic (with MIN) | The headline figure — after the cost cliff and the full MIN overlay effect | +7,745 |
Yield by Zoning District
| Zone | Parcels | Opportunity Sites | If All Built to Max | Realistic (before MIN) | Realistic (with MIN) |
|---|---|---|---|---|---|
| RM-1 | 7,449 | 960 | +16,407 | +3,929 | +3,669 |
| CMX-3 | 235 | 178 | +6,690 | +3,486 | +2,158 |
| CMX-2 | 1,066 | 240 | +5,267 | +2,244 | +1,545 |
| CMX-2.5 | 346 | 68 | +1,614 | +624 | +369 |
| CMX-4 | 20 | 13 | +228 | +33 | +0 |
| CMX-1 | 57 | 10 | +36 | +4 | +4 |
Yield by Station
| District | Station | Parcels | Realistic (before MIN) | Lost to MIN | Realistic (with MIN) |
|---|---|---|---|---|---|
| D1 (Squilla) | Spring Garden | 139 | +2,323 | — | +2,323 |
| D3 (Gauthier) | 46th Street | 89 | +1,493 | −1,135 | +358 |
| D3 (Gauthier) * | 60th Street | 72 | +896 | — | +896 |
| D3 (Gauthier) * | 63rd Street | 233 | +845 | — | +845 |
| D3 (Gauthier) | 52nd Street | 89 | +674 | −296 | +378 |
| D4 (Jones) * | 56th Street | 74 | +337 | −26 | +311 |
| D6 (Driscoll) | Frankford TC | 66 | +1,148 | −827 | +321 |
| D7 (Lozada) | Berks | 203 | +939 | −18 | +921 |
| D7 (Lozada) * | Huntingdon | 106 | +739 | −195 | +544 |
| D7 (Lozada) * | Somerset | 142 | +290 | −78 | +212 |
| D7 (Lozada) | Allegheny | 134 | +252 | — | +252 |
| D7 (Lozada) * | Tioga | 118 | +237 | — | +237 |
| D7 (Lozada) * | Erie-Torresdale | 17 | +147 | — | +147 |
4. The Construction Cost Cliff
The 30% FAR bonus for CMX-3 districts backfires — pushing buildings into a more expensive construction type without enough capacity to justify the cost. An estimated 1,483 units are lost.
Buildings up to 7 stories can use wood-frame construction ($171/sqft in Philadelphia). At 8 stories, building codes require steel and concrete — a 32% cost jump to $216+/sqft.
The Parker bill’s 30% FAR bonus is calculated on the base FAR (500% × 1.3 = 650% FAR), adding +150% FAR — about two floors — and pushing typical buildings from 7 stories to 9. But 9 stories still requires Type I steel/concrete, and 650% FAR doesn’t generate enough floor area to make that cost jump profitable. The result: developers will build 7 stories and leave the bonus on the table.
Impact on CMX-3 Districts
This affects all 235 CMX-3 parcels in the expanded radius. On the 178 near-term opportunity sites, an estimated 1,482 housing units are unlikely to be built because the bonus creates capacity that doesn’t pencil economically. One path forward: either increase the FAR bonus to 800%+ (so developers can justify 12-story steel/concrete), or redesign the bonus to maximize density within 7-story wood-frame construction.
Bill 260518 (introduced May 14, 2026, Gauthier for Council President Johnson) moves in this direction: it doubles the §14-702(8) Transit Improvement Bonus, raising the CMX-3 ceiling from 100% to 200% FAR. Stacked on the base, that lifts a building toward — and a full bonus stack clears — the cost cliff. One consideration: the Transit Improvement Bonus is earned, not by-right. A developer claims it only by spending a set share of hard costs on transit improvements, so it adds no automatic capacity. By-right, the flat 30% bonus still leaves projects at 9 stories. To reliably carry development past the cost cliff, the by-right FAR bonus itself would need to clear 800%+.
5. The MIN Overlay Problem
On near-term opportunity sites alone, the MIN overlay costs an estimated 2,575 TOC bonus units — 25% of the near-term yield.
The MIN overlay, adopted in July 2022, requires projects with 10 or more units to set aside 20% as affordable (at 40% AMI) with no public subsidy. It applies only in Council Districts 3 and 7. Since MIN took effect, large-project housing delivery in those districts has dropped 86%. MIN either blocks the TOC FAR bonus entirely (in CMX-3/4/5 zones) or deters large projects in other zones.
TOC Housing Yield: With vs. Without MIN
| District 3 | District 7 | Combined | |
|---|---|---|---|
| TOC bonus units (no MIN) | 4,245 | 3,752 | 7,997 |
| With MIN deterrent | 2,788 | 2,634 | 5,422 |
| Bonus units lost | 1,457 | 1,118 | 2,575 |
| Near-term sites in MIN | 207 | 136 | 343 |
6. Other Overlay Restrictions
Beyond MIN, 5,543 parcels in the TOC zone are subject to additional overlay rules.
| Overlay | Parcels | What It Does | Units Lost |
|---|---|---|---|
| /MIN (Mixed-Income) | 1,759 | Blocks FAR bonus in CMX-3/4/5; deters 10+ unit projects via unfunded affordability mandate. | 2,575 |
| /VDO (Village District) | 606 | Caps CMX-2 density to 2–3 units per lot — limits the TOC density bonus on 606 CMX-2 parcels. | Already in yield |
The /VDO density cap is already reflected in the realistic yield figures above, so it is shown here as context rather than an additional loss on top of the 2,575 MIN total.
7. What Should Council Do?
The 30% bonus creates capacity that is hard to build economically under the cost study. Either increase it to 800%+ (so the economics of steel/concrete work) or redesign the bonus to maximize housing within 7-story wood-frame construction — more units per floor, not more floors.
The unfunded 20% affordability mandate has coincided with an 86% collapse in large-project delivery and is estimated to deter ~2,575 TOC housing units. A funded inclusionary zoning program — like Portland's, which pairs mandates with tax exemptions — would likely produce far more affordable housing without discouraging market-rate construction.
The bill covers only one of Philadelphia's six transit modes. Adding the Broad Street Line, trolley routes, and Regional Rail would ensure every Council district benefits from transit-oriented zoning — not just those along the MFL.
The overlay affects just 1.7% of city parcels. Single-family neighborhoods are explicitly protected. The scope is targeted and modest — the bonuses should match the ambition.
8. The Stations We Want Added
Six corridors, 38 stations. Together with the bill's existing 13 MFL stations, these corridors cover every high-potential transit-oriented site in the city — and would more than triple the bill's realistic housing yield.
Our second core ask is for District Council Members to introduce companion amendments adding the stations in their districts. The six corridors below were identified by running the same parcel-level yield analysis used on the 13 MFL stations against every BSL, trolley, and Regional Rail station in Philadelphia. The cards show each corridor’s realistic near-term housing yield and the individual stations within it (sorted by station-level yield).
Girard Ave (Rt 15 Trolley + BSL)
11 stations- Girard & Front St+565
- Girard & 2nd St+1,364
- Girard & 5th St+2,136
- Girard & 8th St+747
- Girard BSL+464
- Girard & 16th St+748
- Girard & 17th St+605
- Girard & 33rd St+87
- Girard & 39th St+171
- Girard & 51st St+675
- Girard & 52nd St+324
North Broad BSL
11 stations- Temple University BSL+332
- Cecil B Moore BSL+26
- Susquehanna-Dauphin BSL+811
- North Philadelphia Amtrak+2,529
- Erie BSL+935
- Hunting Park BSL+446
- Wayne Junction RR+213
- Logan BSL+281
- Wyoming BSL+1,578
- Olney TC BSL+48
- Fern Rock TC BSL—
Complete MFL (Fill Gaps)
5 stations- Girard MFL+2,004
- York-Dauphin+1,203
- Church+435
- Margaret-Orthodox+452
- Arrott TC+664
South Broad BSL
6 stations- Ellsworth-Federal BSL+937
- Tasker-Morris BSL+91
- Snyder BSL+193
- Oregon BSL+265
- AT&T Station BSL+50
- NRG Station BSL—
West Philadelphia RR
3 stations- 30th Street Station+244
- 49th Street RR+153
- Overbrook RR+1,124
Chelten/Germantown RR
2 stations- Chelten Avenue RR—
- Germantown RR+231
How to read these numbers
“Realistic units” applies the same conservative filter used for the Parker bill stations: opportunity sites only, overlay caps applied, CMX-3 cost cliff subtracted. Stations showing “—” have no eligible-zoned parcels within range (typically because they sit in single-family-only neighborhoods or industrial districts that the TOC bonuses don’t touch).
Methodology & Data Sources
Parcel data: Philadelphia Office of Property Assessment (OPA) via CARTO. 551,412 parcels citywide.
Zoning capacity: BPN’s zoning rules engine implements the Philadelphia Zoning Code (Title 14) dimensional standards. GFA-based unit estimates use coverage × stories × lot area for density-bonus zones and lot area × FAR for commercial zones. Average unit size: 750 sqft.
Construction costs: Eriksen & Orlando, “Returns to Scale in Residential Construction,” Real Estate Economics (2022). Philadelphia costs: $166/sqft (1-3 stories), $171/sqft (4-7), $216/sqft (8+).
Opportunity sites: Seven categories based on OPA property descriptions, assessed values, and utilization ratios. High and medium tiers included in near-term estimates.
Overlay analysis: Spatial join with Zoning Overlays shapefile (OpenDataPhilly). MIN has two effects: a legal FAR-bonus block in CMX-3/4/5/RMX-3 per §14-513(5)(a)(.2) (1,361 units, a statutory exclusion) and a behavioral deterrent on 10+ unit density-bonus projects (1,214 units), estimated via a 0.54 within-district difference-in-differences rate (new-construction permits ≥10 units, CD3 + CD7, pre- vs post-MIN). A broader all-permit-types rate (0.36–0.44) would lower the behavioral component to ~800–960 units; the legal FAR block is unaffected by the rate. /VDO’s CMX-2 density cap is already reflected in the realistic yield, not an added loss.
Transit proximity: 500 ft and 1,320 ft buffers around MFL station entrances via BPN pipeline.
Downloads
BPN’s zoning rules engine is open source. For questions, contact jon@buildphillynow.org.
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