On July 1, 2020, the Board of Zoning Adjustment (Board) reversed a decision by the Zoning Administrator (ZA) allowing the by-right conversion of an existing dwelling unit into an eight-unit apartment house in the RA-1 zone. The crux of the appeal in BZA Case 20226 concerns the ZA’s interpretation of Subtitle U §§ 401.1 and 421.1 in the Zoning Regulations, which govern multiple dwelling uses in the RA zones. Under Subtitle U § 401.1, multiple dwelling uses are permitted as a matter-of-right in all RA zones except for the RA-1 and RA-6 zones. Whereas, in the RA-1 and RA-6 zones, Subtitle U § 421.1 dictates that special exception relief is required for “all new residential developments, except those comprising…

