Brookland Manor. Image by the author.

This the final post in a series about Brookland Manor, a controversial development project just east of the Rhode Island Metro station that epitomizes the complex dynamics of building housing—especially affordable housing—in DC.

Last week, DC’s Zoning Commission approved property owner MidCity Financial’s plan to redevelop the first of eight blocks at Brookland Manor. MidCity staff left the hearing “thrilled,” while members of the Brookland Manor residents’ association gathered outside, their lawyer pledging to “take things to the street and put political pressure” on the mayor and other public officials to “change the reality of housing in Washington.” That raises two questions: How should DC regulate development, and what obligation does it have to care for low-income residents?

Here’s the situation at Brookland Manor

Over the past three years, the future of the 20-acre apartment complex has slowly started to come into focus. Initially, MidCity wanted to replace the existing 535 apartments with 2,235 apartments and townhouses. But in early 2015 both DC’s Zoning Commission and its Office of Planning said that plan was incongruent with the District’s Comprehensive Plan because the buildings would have been too tall. Rather than try to change the Comp Plan, MidCity downsized its proposal to have fewer affordable housing units and 20% fewer total units.

Most of the current tenants have low or modest incomes, and this reduction in affordable units has heightened their fears of being displaced. Contrary to MidCity’s plans, they’re pushing for 535 affordable apartments in the redevelopment, and say that should be a condition for DC government’s approval of MidCity’s plans. Some also allege that management has been trying to push them out so that it doesn’t have to re-house them as part of the redevelopment (an allegation MidCity denies).

Currently, an agreement between MidCity and the federal government keeps 373 of the apartments affordable to low-income residents; that agreement ends this year, but MidCity says it’ll renew it. The company has no hard plans to dedicate the remaining roughly 150 units to affordable housing.

MidCity has a green light for the first part of its plan, more or less

In broad strokes, a big reason there’s so much debate about whether MidCity is building enough affordable housing is because the company is asking, via the Planned Unit Development process, to build more than what base zoning laws currently allow. In return for getting to build taller buildings and more units, MidCity is supposed to give the public something extra in return.

DC’s Zoning Commissioners decide whether MidCity’s offering of public benefits— like more affordable housing than inclusionary zoning would require— is sufficient to grant a waiver from the base zoning. That’s where tenants, advocates, and the general public have weighed in.

The future stages of MidCity’s PUD application still have to pass the Zoning Commission, and the fate of Brookland Manor and its residents is still partly in flux. But on Monday, May 22, the Commission approved the company’s plan to redevelop the southwest block of the complex with two new four-story buildings, one with 200 units and one with 131 units. That’s 331 units of the 1,760 total that MidCity wants to build. The Commission also approved MidCity’s plan to make 200 of the 373 deeply affordable units almost all one-bedrooms for seniors only.

The Commission vowed to tighten the requirements surrounding the “right of existing tenants to return” in its detailed approval order, which it will publish in two months (tenant leaders said they weren’t holding their breath).

The redevelopment will likely continue to change shape, poked and prodded by the Office of Planning, zoning commissioners, tenants, neighborhood organizers, housing lawyers, MidCity’s leadership, and public opinion. MidCity will have to submit several more of these detailed PUD applications in order to redevelop the remaining seven blocks of the complex.

Dorothy Davis (right), with friends from Brookland Manor. She’s lived in DC for 30 years, and at Brookland Manor for almost 13. She lives with her oldest daughter; other family (she has four daughters, 11 grandkids, and 11 great-grandkids) live in nearby apartments.  Image by the author.

Are residents demanding too much? That’s a question of values.

Much of the tension at Brookland Manor, and other large redevelopments, revolves around the nature of the city’s responsibility to low-income residents.

Do we, as a city, believe housing is a right we should secure for all residents? If it is, how much should the city enroll the private sector in pursuit of that goal, and how? Part of the reason this PUD process has been tumultuous is that city officials don’t seem to have formulated a coherent set of answers to those questions.

This must be frustrating to developers, and terrifying for low-income tenants. The former must wait years to learn what’ll become of their projects, and the latter, their homes and neighborhoods.

There’s also a question here about whether the current PUD process is an effective and efficient way to achieve the city’s affordable housing goals.

A lot of this series has focused on building heights, occupancy counts, and legal minutiae. I’ve done my best to impartially describe the the facts facing each party at Brookland Manor. If I failed to do that, I hope at least all the relevant facts are there for you to piece things together.

But now that you’ve got the facts, here’s a parting editorial thought. As I see it, focusing purely on existing laws and proceedings imparts its own bias. If you become too focused on how the world is, you can lose sight of what it might become.

MidCity might be able, legally, to tear down Brookland Manor, build a handful of affordable apartments, and rake in a fortune. And it might be able to build fewer than 535 affordable apartments.

But why would DC government allow either of those outcomes when some of its members, like those who work in the Office of Planning, say they want to secure more affordable housing? Given the depth of our housing crisis and our supposed collective concern for middle- and low-income families, you’d think our public officials would be doing more here.

Why, for example, are we shelling out millions in taxpayer money to build soccer and baseball stadiums when we have the highest rate of homelessness in the nation? When men made homeless in middle age are dying on park benches in January?

Why don’t we let more people build and occupy finished garages, tiny homes, duplexes, rowhouses, or apartment buildings? Why do we prevent that with byzantine rules only an on-the-clock lawyer could love? One of the biggest reasons the city even has leverage in PUDs is because regionally, we’ve disallowed so much housing and driven up rents and home prices.

And why, at Brookland Manor, does the Zoning Commission agonize over the architect’s choice of brick color while saying issues of displacement don’t fall within its purview? Why do we wring developers and residents through this absurd process when there are almost certainly less onerous ways to induce the private sector to provide affordable housing?

Right now, there's no explicit, legal “1-for-1 replacement of affordable housing” rule. (MidCity says it’s doing that now, but the company’s definition of “affordable housing” excludes market affordable units). Developers might not like such a rule, for understandable economic reasons. But if there were such a rule, at least they would know what the PUD rules were from the outset, and could plan accordingly. Maybe then the PUD process would at least be quicker and less costly for them. Heck, if we just told developers ahead of time what we wanted from them maybe we wouldn’t even need a Zoning Commission. Maybe the default could be “replace the affordable housing,” and the Commission would be a place to ask for special exemptions.

The city touts the “flexible” nature of the PUD process. In some ways, the process isn’t flexible enough: even after OP said it thought MidCity’s original plan was a good one, the Comp Plan’s height restrictions basically killed it.

In other ways, if you value affordable housing, the process is too flexible. If it clearly prioritized affordable housing, then negotiations might have started with how to preserve all the affordable units, rather than whether to do so. But now, some PUDs devolve into these melees. Tenants, afraid of being displaced, plead their case before the Commissioners, who might then intervene on their behalf like a set of feudal magistrates. Developers, aware they're losing money with each plan revision and delayed decision, weigh the cost of continuing debate against the cost of agreeing to the Commission’s demands. Which is wasteful in terms of developer dollars, and harmful in terms of tenants’ physical and social wellbeing.

So is keeping 535 affordable apartments too much to expect? After writing this series, my answer is “no.” But you should formulate your own answer, and then tell your political leaders. Maybe they’ll think of a way to make redevelopment in DC saner and more humane.

Weigh in with your thoughts on Brookland Manor in the comments section. Also, you can contact Ward 5 Councilmember Kenyan McDuffie (@kenyanmcduffie;, the Zoning Commission (@ahoodahood,, or Mayor Muriel Bowser (@MayorBowser;