It’s been almost seven months since the epic spring hearing on the DC Comprehensive Plan, a planning and land use document that guides how the city will grow for years to come. Yesterday, October 16 the DC Office of Planning (OP) released an “additional assessment” of the bill under consideration and offers new suggested language to the DC Council.
That new language adds a detailed analysis of the shortage of affordable housing in the District, and the patterns of displacement that has caused. It also gives new guidance for Planned Unit Developments (PUDs) that says the resulting community benefits packages should prioritize “new affordable housing” and the “prevention of displacement.”
Many anticipate that the DC Council will bring the Comp Plan legislation forward for a hearing within a month. We think the council should add these changes to the text, and you can ask your councilmember to do the same (along with any other comments you have) here.
Remind me, what’s the Comp Plan again?
For those who didn’t spend more than 13+ hours discussing this document at the marathon hearing last March, let’s review. The 1,000+-page Comprehensive Plan articulates the goals and direction for the city from economic development, to arts and culture, to the future of particular neighborhoods. It's particularly important when it comes to land use because it lays out the policies and future patterns of development for the city, and guides how the city can be zoned.
The Comp Plan has come under a lot of scrutiny in the last few years because the recent flood of lawsuits over large development projects in the District all revolve around the Comprehensive Plan, which zoning decisions must be “compatible” with.
This was a main topic of debate at the March hearing: What is the role of the Comp Plan, and in particular its two central maps? OP has so far only released changes to the Framework Element, which sets the outline for the rest of the Comp Plan, and definitions and descriptions for these important maps. Some of the court cases, like the first major one, Durant, have turned on language in the Framework.
OP adds focus on affordable housing
At the hearing, GGWash and our allies, as well as others, called for more language prioritizing affordable housing and clearer rules to protect residents from displacement.
While most important language around these issues will be in the Housing Element, the Framework Element needs to also address them. Out of the 60 pages of OP’s amendments from earlier this year, there were literally only two sentences that discuss displacement (205.6).
In the staff report released yesterday, the Office of Planning addresses these criticisms, saying “various stakeholders expressed concerns that the Framework Element does not adequately address rising housing costs in the District and the displacement pressures that many residents experience as a result.” The rest of the report then offers additional language that would remedy this.
First, the report offers two new long and detailed narrative sections. The narrative portions of the Framework Element are supposed to paint a picture of how DC has changed over the years, and how they anticipate future challenges and opportunities. While these sections don’t carry the weight of policy, they do articulate issues that the rest of the Comp Plan will later address, so it is important that they be thorough and meaningful.
The bulk of OP’s additions fall under a new section, “(205a. HOUSING COST CHANGES.” Two pages of detailed analysis and data describe how DC slowly lost affordable housing over the last decade, how residents’ wages have stagnated and many low-income folks have been displaced, and then points to resulting patterns of segregation.
There’s a lot here. The report discusses how “in 2016, more than 48,000 households were severely burdened by rental housing costs, while another 30,000 rental households were burdened by housing costs consuming 30 to 50 percent of their income.” Earlier it describes the massive influx of rental housing in the District since 2006, but that “most of these new units were higher-cost apartments affordable to households earning near and above median income.”
From 2006-2016, DC added 41,500 rental homes that are affordable for middle and upper income folks (60% MFI and above). In contrast, for lower income folks (50% MFI and below), the supply of available affordable rental homes actually dropped by 11,800 units.
This of course has made many residents, especially residents of color, experience “housing insecurity and displacement.”
As so many pointed out in March’s hearing, having a Framework Element that was so muted on the two preeminent land use challenges of our time (affordable housing and displacement) was the wrong way to start off our new Comp Plan. This new language looks much, much better, and would set up future sections of the Comp Plan to seriously tackle these issues.
New guidance for PUDs: prioritize affordable housing and anti-displacement
While much of the Framework Element is narrative, sections are closer to policy, in particular around the land use maps and Planned Unit Developments (PUDs). PUDs allow for larger buildings and often more homes in exchange for community benefits like improved parks, transit or bike infrastructure, or additional affordable housing. Every recent PUDs has been appealed, in part because of recent court rulings about the Comp Plan.
To address this head on, earlier this year OP proposed adding a brand new section to the Framework Element specifically about PUDs (Section 227). In this newest report, OP suggests adding a few more sentences to this section (emphasis mine):
Specific public benefits are determined through each PUD application and should respond to critical issues facing the District as identified in the Comprehensive Plan and through the PUD process itself. In light of the acute need to preserve and build affordable housing described in Section 205a, the production of new affordable housing units [above and beyond existing legal requirements] and the prevention of displacement of on-site residents should be considered as high-priority public benefits in the evaluation of residential PUDs.
This addition is a big deal. The essential idea behind PUDs is that because an owner is getting to build bigger than the base zoning allows, they also should provide a piece of the benefit back to the public. However, many times those community benefits have taken the form of payouts to local organizations, buying schools computers, or other impermanent items.
The proposed language signals a shift — now PUD benefit packages should think first about providing additional affordable housing and should also help prevent direct displacement.
There are current PUD cases where this could have made a big difference, like Brookland Manor. While the story there is very, very complex, at first OP asked the owners to downsize their original PUD plans, perhaps reacting to concerned neighbors. What if, instead, OP had held its ground on supporting a taller building, and had advocated that a portion of that value help replace all of the previously low-cost units on site?
DC is not building enough homes
Another section discusses DC’s capacity to house its growing population. It starts by saying that “there is room for growth under current zoning within the District through 2045,” when the agency projects a population of nearly 1 million residents.
This might suggest that nothing needs to change in the Comp Plan to meet the housing need. But OP then explains that’s actually not true. Instead, a set of “land use patterns … tend to restrict the pace of adding new housing and to narrow the range of available housing prices, which ultimately affects the District’s ability to grow in an inclusive manner.”
One cited example of these restrictive patterns are owners choosing “to build as-of-right, building less housing than they could due to the increasing risk of the entitlements process.” By this, OP is alluding to the documented cases of developers avoiding PUDs because of the lawsuits. Other examples given: “unbuilt capacity often exists above one- and two-story retail buildings along commercial corridors,” or vacant land in weaker markets that aren’t being built on.
This is a really important analysis. First and foremost, we need a Comp Plan that makes room for everyone that wants to live here. Second, if, as OP says, we technically have the room for 1 million people under current zoning, but in reality we are not building out to that capacity, we have a problem that needs to be addressed. A housing shortage is a housing shortage, even if our current zoning gives us room to get out of that housing shortage.
Help make sure the DC Council is paying attention
Sometime in the next month, we expect Chairman Phil Mendelson to release edits to the Framework Element, and then the DC Council will vote. OP’s report has a lot of good ideas and definitely improves upon the draft the agency released in January. It would be a major improvement to the Comp Plan to add these amendments concerning affordable housing and displacement. Our land use policy is long overdue for this kind of language, and we need to take these issues seriously in our long term plans for growth.
The DC Council has a lot going on right now, and you can help us make sure they see this report and the helpful proposals within it. Click the button below to send a note to your DC councilmember and encourage them to support adding the good stuff here in the coming debates.