DC is amending its Comprehensive Plan, a land use and policy document that will guide the growth and development of the city for decades to come. Recently, the Office of Planning (OP) released its proposed amendments to the first chapter of the Comp Plan, and among those changes were small language adjustments that could result in a shift in how and where we add new homes to the city.
The current Comp Plan directs growth to some neighborhoods and not to others
OP’s amendments so far solely focus on the Framework Element of the Comp Plan. This chapter acts as the introduction for the whole document, describing the past and present planning challenges of the city. It also lays out guiding principles for the entire Comp Plan, and defines two very important maps that many say are its central tools: the Generalized Policy Map and Future Land Use Map (FLUM).
One of those, the Generalized Policy Map categorizes different areas of the city into four main groups: Neighborhood Conservation Areas, Neighborhood Enhancement Areas, Land Use Change Areas, and Commercial/Mixed Use Areas. These categories are supposed to define the general pattern of future development for each area.
Neighborhood Conservation areas, as you might guess, encourage little to no change in “existing land uses and community character... over the next 20 years.” As for Neighborhood Enhancement Areas, the Framework Element explains:
“[the] main difference between Neighborhood Enhancement and Neighborhood Conservation Areas is the large amount of vacant land that exists in the Enhancement Areas. Neighborhood Enhancement Areas often contain many acres of undeveloped lots, whereas Neighborhood Conservation Areas appear to be mostly ‘built out.’”
The other two are pretty self explanatory. The Commercial/Mixed Use Areas category is for areas that are anticipated to be just that. Land Use Change Areas are for areas where big changes are expected. For example, the 2006 Comp Plan labeled all of what is now NoMa as a Land Use Change Area, because at that point the neighborhood was already beginning its conversion from an industrial area to the more dense residential and commercial area it is today.
If you actually look at the Generalized Policy Map, you’ll see that the vast majority of the city is designated as Neighborhood Conservation Areas. Nearly all of the Neighborhood Enhancement Areas are east of the Anacostia River, and the Land Use Change Areas are on scattered large sites across the city, places like Poplar Point, the area around RFK Stadium, and Walter Reed.
We know that DC has a still-growing population even as we approach the 700,000-resident mark. Looking at all of this through the lens of “we need to build enough homes so everyone can live here,” you can see why there is reason for concern. The overarching message of the current map and its categories seems to be: “Build where it is currently vacant, leave the rest alone.”
This is both an ineffective and inequitable strategy. Forcing all growth into a few neighborhoods with vacant space (which often are lower-income neighborhoods) exposes those who are often the most vulnerable residents of the city to all of the pressures of neighborhood change — and exempts those who could best absorb those pressures.
OP’s proposals create more opportunity for “missing middle” housing
In January, OP released its amendments to the Framework Element, and some of the changes signal a different strategy in growth management. At the very beginning of the Generalized Policy Map definitions, OP adds this sentence:
“Although each of these areas have specific characteristics, they all provide opportunities for future development that advance District goals and policies.”
That’s an important shift that shows up throughout the section. This de-emphasizes the idea of “just build where it’s vacant.” Now, “there are opportunities to build everywhere within the context of the neighborhood.” That’s not to say established neighborhoods will have willy-nilly development, but neither should they have absolutely zero.
There are lots of small changes that support this in the new text, such as this rewrite here:
This message carries through even into other sections. For example, in the part describing commercial areas OP added multiple new references clearly stating that commercial development should incorporate resident development (223.13-223.21). Theoretically, these changes mean that in the future, proposed infill and mixed use developments would find more support in the Comp Plan when they are brought before the Zoning Commission.
Infill development (building in non-vacant areas) can be done in a responsive way that enhances a neighborhood and does not “threaten” the existing neighborhood. In fact, that kind of infill development is often the “missing middle” types of homes that cities like ours are wanting.
Within an expensive and tight housing market like ours, forcing all new homes into largely vacant areas creates enormous pressure to build big, often big and expensive, and dense. That means prevailing new development ends up being either low density single family homes (because that’s all the prevailing zoning allows for), or high density apartments and condos that maximize whatever zoning allows for. The missing in-between buildings can be 1) more affordable, especially for middle-income folks looking for a starter home, and 2) not such a dramatic architectural departure from the surrounding neighborhood.
The changes proposed here seem to support more of this “missing middle” kind of development. OP seems to recognize that the city needs new homes everywhere, not just in “vacant” areas. Without meeting the overall need for homes, there is simply not going to be enough room for everyone and those with the least are going to get pushed out in that cruel game of musical chairs.
While for a lot of urbanists this sounds pretty good, there are some significant problems with OP’s proposals as well; I will write more about those soon. The DC Council hearing for these changes is March 20th, and the council can make amendments to this chapter of the Comp Plan before it is finalized.
GGWash has been following this process closely along with a diverse coalition of partners from across the housing and development spectrum (Note: this post reflects my own opinions, and is not an official statement of the coalition). As this all moves forward, the coalition will continue to advocate for our three overarching priorities for the Framework Element of the Comp Plan: plan for enough housing, plan for enough affordable housing, and protect residents from displacement.