What the Application Proposes

The zoning application for 78/88 Howard Street NE seeks to rezone 0.66 acres from R-4A (single-family residential, which permits 3 to 4 homes) to PD-H (Planned Development, Housing) for a 47-unit multifamily building. The application describes the project as affordable senior housing with an age restriction of 62+.

Each unit would be approximately 250 to 275 square feet. The site plan includes 6 parking spaces for 47 residents plus staff and service providers.

The Classification Question

The rezoning application states the proposed facility "will not be a supportive housing facility" as defined under the Atlanta zoning ordinance. However, the project was consistently described as "Permanent Supportive Housing" in communications with at least three city entities between March and August 2025, and a $25,000 city loan was secured under that designation.

The operational controls listed in the application are also consistent with PSH facility standards rather than conventional senior housing:

The developer has stated that funding will be pursued from sources typically available only for Permanent Supportive Housing, and that the final resident mix will not be determined until after rezoning is approved. This means the zoning decision is being made without a clear picture of how the facility will actually operate.

Zoning Analysis

The current R-4A zoning permits 3 to 4 single-family homes on this parcel. The proposed PD-H rezoning would allow 47 units, a density increase of approximately 1,200% to 1,500% on a single parcel located in the interior of a residential neighborhood, not at a transition zone or commercial corridor.

Previous rezonings in the Kirkwood area that were found to be appropriate share common characteristics: they were located at the periphery near commercial zones, involved modest density increases of 2 to 3 times the existing zoning, included mixed-use or mixed-income character, and were consistent with comprehensive plan goals for the corridor.

This proposal differs from those precedents in every respect. The density increase, the 100% single-use institutional character, and the interior residential location raise the question of whether this constitutes spot zoning: a rezoning that benefits a single property owner without a planning justification for the departure from surrounding land use.

What Housing Research and State Policy Indicate

Rise ATL supports Permanent Supportive Housing as an evidence-based approach to addressing homelessness. The question is not whether PSH should exist, but whether this specific proposal follows the standards that make PSH successful.

Georgia Department of Community Affairs Limits

Georgia DCA limits the entire state to 2 single-site PSH projects per year through its Qualified Allocation Plan. A 47-unit development would consume 50% of Georgia's annual statewide PSH allocation in one neighborhood. The state imposes this limit because housing policy experts recognize the operational challenges of large, concentrated single-site PSH facilities.

Federal and Research-Based Standards

National housing research consistently finds that smaller, mixed-income models produce better outcomes for PSH residents. The Minnesota Housing Finance Agency found that tenants in mixed-income properties with fewer than 50% PSH units had 65% higher odds of housing retention compared to majority-PSH developments. Federal and state agencies now recommend a maximum of 25 units per PSH development with mixed-income integration.

What We Asked the Developer to Consider

Rise ATL and community members have presented alternative approaches to the developer and Turner Monumental AME Church, including smaller scale development (20 to 30 units), mixed-income integration rather than 100% concentration, identified operators with demonstrated PSH experience, and published service and staffing plans. These requests align with HUD best practices and Georgia DCA guidance. The developer has not committed to adopting these standards.

A Note on YIGBY

YIGBY (Yes In God's Backyard) is a national movement of churches building affordable housing on underutilized property for families, seniors, and working people. Rise ATL supports this movement. Churches can be powerful partners in addressing housing needs.

The YIGBY model is characterized by general affordable housing for diverse community members, appropriate scale relative to the surrounding neighborhood, and mixed-income integration. The Howard Street proposal differs from this model in that it proposes a 100% single-population facility at a density that is 12 to 15 times the current zoning, with operational characteristics consistent with institutional PSH rather than community-integrated affordable housing.