The first 60 pages of amendments to DC’s Comp Plan are out. Here’s a first look.

After months of anticipation, the DC Office of Planning (OP) recently released its first set of amendments to the DC Comprehensive Plan, which is the central planning document for the city. While many of the amendments are factual updates to data and forecasts, there are a few important policy changes you should pay attention to.

The Comp Plan describes the planning challenges the city faces, pointing forward towards future solutions and policies, and guiding the actions and decisions of district agencies. It is of particular importance for land use and development. In recent years, it has taken on an increasingly high profile as it has been used successfully in a growing body of court cases challenging development projects across the city.

OP’s recent release only includes amendments to the Framework Element of the Comp Plan, which essentially acts as the introduction of the entire 1,000+ page document. In a letter, OP Director Eric Shaw says the agency needs more time to analyze and prepare all of its amendments to the rest of the Comp Plan, including amendments to the maps rather than just the definitions of them. We should see the full set of amendments later in 2018.

The DC Council has scheduled a hearing for this initial package in March, at which point the public and councilmembers will discuss OP's proposals and possible amendments to them.

So what exactly is in the Framework Element?

As noted by Shaw in his public letter, the Framework Element,

“accomplishes three objectives key to shaping an inclusive city:

• Establishing a current and data-driven context for city decision-making;
• Providing new information on forces that impact growth and development; and
• Clarifying our land-use designations and their relationship to zoning reviews, to ensure the District can strengthen affordable housing and other critical community objectives.”

If you flip through it, you’ll see the Framework Element has three general sections:

• A narrative section that describes the growth and development of the city over the last few decades, with data and forecasts indicating how those pressures will continue to impact the District
• A set of guiding principles for the entire Comprehensive Plan
• Descriptions and definitions of two key maps in the Comp Plan — the Future Land Use Map and Generalized Policy Map — both of which are influential in land use and development decisions

The planning office’s 60 pages of proposals amend both the narrative section and the map definitions, but do not amend the guiding principles (which it has repeatedly said it would not amend) nor the actual maps themselves (which will be amended at a later date along with the rest of the Comp Plan).

Here’s what looks good so far

Many of the amendments OP propose involve updating data and planning forecasts — remember this was all originally written in 2006. However, there are a few changes that would influence city policy in a good way.

• Clarifies legal issues facing Planned Unit Developments (PUDs): PUDs have been a useful tool, used by both for- and non-profit developers, to get zoning relief (read: build bigger) in exchange for community benefits like additional affordable housing, infrastructure improvements, or green space. Right now there are around 6,500 new homes and affordable homes caught up in the courts because of an increasing trend of challenging PUD projects in court.
  
  The Comp Plan has been used in many of those cases, and OP’s amendments create an entire new section in the Framework Element (section 227 here) to clarify the goals of PUDs and the role of the Comp Plan in influencing them.
  
• Removes problematic, exclusive language: As we have noted previously, the Comp Plan currently has problematic language that goes against its stated goal of “an inclusive city.” It couples phrases like “stable” neighborhoods or “protecting the character of the neighborhood” with policies that ultimately help wealthier, “stable” neighborhoods push away new homes and affordable homes. This combination funnels all growth and change into “emerging,” “transitioning” or “distressed” neighborhoods (guess where those are).
  
  This language could be much better and instead invite inclusion in all areas of the city. OP’s proposals take some steps to reword this problematic language, though there is more to do here to truly push back on patterns of segregation and exclusion.
  
• Supports better (and more) development near transit: In a similar way, the current Comp Plan does not support building densely and affordably near transit corridors as much as it could, instead opting for defensive or weaker language. The recently-released draft improves a lot of this language.

What needs to change

Arguably one of the biggest planning challenges facing DC right now is our housing and affordable housing shortage. While the Framework Element is not the Housing Element (another chapter in the Comp Plan), it does set the tone and direction for the entire Comp Plan. Therefore, it needs to do a better job addressing these fundamental issues.

• Directly address the affordable housing shortage: OP updated a lot of the narrative pieces of the Framework Element, but did not include significant data, analysis, or discussion of affordable housing. It also did not prioritize affordable housing in any of the new sections describing PUDs, though it did encourage additional affordable homes in a small section about repurposing industrial land. Detailed analysis and policy on affordable housing can wait for the Housing Element, but not including much of anything on the subject in the Framework Element is deeply problematic.
  
• Directly address concerns about displacement: Hand in hand with the issue of providing enough homes and affordable homes is the issue of displacement. The previous 2006 draft of the Framework Element spends barely more than a sentence on the issue (205.6), saying that displacement is a “threat that has become more real in the District as land values have increased” and that it is an issue that affects businesses and “District residents — particularly those of lower income[s].”
  
  OP’s recent proposals don’t add significant additional analysis or data to this meager description, and it easily could. If the Framework Element is meant to provide direction and data for the city’s preeminent planning challenges, more is needed in discussing the threat of displacement in the city.
  
• Update the guiding principles: OP amended everything in the Framework Element EXCEPT the guiding principles. Some of these principles are fine, while others are really out of step with the DC of 2018. There are 36 guiding principles and about 15 relate to housing and land use. Of those 15, three focus on preserving “the character of the neighborhood,” “stable” neighborhoods, and historic preservation. One directly mentions the demand for affordable housing, while zero discuss displacement.
  
  These priorities are out of whack. As mentioned before, OP has said from the beginning that these principles were not on the table to amend, but it’s unclear why, especially if there are opportunities to update and amend problematic ones.

Over the coming weeks, I will write more about the specifics of OP’s current proposal. I’ll note that GGWash has been part of a diverse coalition of housing and development stakeholders who have been drafting and advocating for amendments to the Comprehensive Plan. This post is not an official statement of that group, but rather GGWash’s own analysis.

The coalition’s priorities have been consistent through this entire process, and as a group we will continue to analyze OP’s findings and advocate to ensure the new Comprehensive Plan adequately addresses our three-pronged approach: meet the city’s need for more homes, build and preserve more affordable homes, and increase protections against displacement.