Office of Planning proposed exempting interior alterations that produce little or no external change from Green Area Ratio review, except where GAR already does not apply (R and RF zones). OP said the current GAR trigger sometimes requires a lengthy review for projects that do not change a building's exterior and imposes unnecessary cost and delay for interior renovations that frequently produce housing conversions.

Joel Lawson (OP) told the commission: "Having to go through this process, for those kinds of buildings can create a lengthy and expensive administrative process and burdens for applicants and review staff." OP said it has coordinated with the Department of Energy & Environment (DOEE) and Department of Buildings (DOB) on technical refinements, including how GAR is calculated on split lots and updates to the list of certified landscape professionals.

Support and concerns: Building-industry representatives supported the change as a way to reduce unnecessary regulatory friction on conversions to housing. OP said it found no material opposition in the record to this particular proposal as of the staff review time, though several stakeholders suggested technical clarifications that OP has incorporated or will continue to refine with DOEE.

Next steps: The commission left the item in the hearing record; OP will place DOEE technical guidance and updated draft language in the record for later consideration. The item remains part of the omnibus case 25-12 and will be revisited in subsequent hearing nights and in proposed rulemaking language if the commission moves forward.