At over 600 pages, the DC Comprehensive Plan is massive document, and few people actually read through the text. It has two maps, though, that are very easy to understand. They are, arguably, the pieces of the Comp Plan that are most often cited in decisions about development, and it’s important that you know about them.
What is the Comp Plan again?
DC has a giant planning document called the Comprehensive Plan. Most of it is super dense and complicated, but its goal is to lay the foundation for many city-wide decisions, in particular decisions on land use.
Shown below, the FLUM is intended to guide land use decisions for the District. It colors blocks or parts of blocks with various broad land use categories, like “moderate density residential,” “high density commercial,” “federal government,” etc. Each of those categories are given specific descriptions in the legend, even as specific as including numbers of stories.
Does this sound like a zoning map? I can see why you’d think so, but in fact the language in the Comp Plan clearly states that this is NOT a zoning map. Instead, it is supposed to translate the land use policies in the Comp Plan text to a map, and act as a guiding document for the zoning commission when zoning changes are proposed.
The colors represent a combination of what land use currently exists on the ground, and what planners predict for the future. In the end, when a governing body in DC is asked to interpret policies embedded in the various chapters of the Comp Plan, that body is supposed to refer back to the FLUM to clarify and guide their interpretation.
This map is cited often at the Zoning Commission and was at the center of a recent court case limiting development near a Metro station.
The Generalized Policy Map
This map is similar to the FLUM in its purpose and scope. Rather than designate land use by color and description, the Generalized Policy Map is supposed to guide neighborhood policy decisions by highlighting a few general strategies. For example, it colors certain corridors of the city as “Main Street Mixed Use Corridors,” signaling a certain policy framework that encourages said growth along that street.
The map’s stated purpose is “to categorize how different parts of the District may change between 2005 and 2025,” managing that change using the categories in the legend.
There are some reasons you should be worried about these maps
There’s one big issue with both of these maps: they tend to preserve the status quo— more specifically, the status quo of 2006, which is when the Comp Plan was created.
For example, If you look at the Generalized Policy Map, a vast majority of the District is marked as “Neighborhood Conservation Areas,” which do not forbid but do generally discourage new development from taking place. What that means is that in 2006, planners sectioned off a huge majority of the city as “let’s leave it be” sections. If you look at the map closely, the most obvious concentrations of “Neighborhood Enhancement Areas” (where change is encouraged and expected to take place) are in Wards 7 and 8.
The FLUM is not much better, and truly acts more like a “Current Land Use Map.” Look at your neighborhood; you’ll notice that most of the land use designations match what exist today, and in many cases aren’t too different from what existed in 2006. The map and Comp Plan in general are supposed to last until 2020.
If used more intentionally to plan for and accommodate the growth happening in the city, both maps COULD be great tools to help guide where residents and the city want to incorporate growth. Unfortunately, neither functions that way right now.
Recent events have made these conservative maps more powerful
I’ve looked at these maps a lot, and even now as I read some of the language in the FLUM I’m struck: the text sounds like a zoning map even though the FLUM says it is not a zoning map. Each color in the legend gives ranges of stories (like 4-7 stories) for each of the land use categories. That really sounds like zoning. This makes it easy to interpret the map (incorrectly) to say that development in those areas should strictly fall within that range.
Many groups use such arguments when they go before the zoning commission, and now those arguments carry significantly more legal weight. The recent court case at 901 Monroe Street in Brookland created a legal precedent that the numbers of stories in the legends of these maps can be used to restrict new projects.
There’s an opportunity to make changes to these maps
As we have been writing about, the Office of Planning is organizing an effort to amend and update the Comprehensive Plan. As a part of that update, groups are allowed to submit recommendations for what they’d like to see changed in the Comp Plan. This includes the maps.
Take a look at your neighborhood on these two maps. What suggestions do you have? If your neighborhood was to incorporate more residents, retail and jobs, how would you do it?