The Comp Plan is about to be baaaack. Here’s what’s happening.

On Tuesday, July 9, the DC Council will take the first of two votes on the Framework Element of the Comprehensive Plan. This is the first chapter of DC’s massive Comp Plan and the subject of the epic 13-hour hearing all the way back in March… of 2018.

The Comprehensive Plan is a 600-page document that supposedly guides all of DC’s growth and change, from housing to education to trash pickup. It’s most important on land use, since it sets policies that zoning boards must follow.

It’s now up to Chairman Phil Mendelson to bring to the council a revision to what the DC Office of Planning submitted a year and a half ago, for members to potentially amend further and vote on.

We have no idea what the revised bill will say. Mendelson has said publicly he’s not simply going to advance what the DC Office of Planning (OP) proposed. But he hasn’t said much more about how much he’ll amend or in what way.

Mendelson has faced criticism in the past for releasing massive changes to bills, including the DC budget, the night before a big vote (as did some chairs before him). His staff have said they hope to release a draft of the Framework Element on July 2, which would give people some time to digest it before the vote, if they meet that deadline.

The debate is sure to be lively on July 9. But it won’t be the last one. The council has to take two votes on bills, and July 9 is just before the summer recess. The council will return in September and at some point take a second vote. If councilmembers raise a lot of concerns about Mendelson’s revisions, there could be significant further rewrites over the summer.

During the public “open call” for comp plan amendments, which ran from 2016 to 2018, former GGWash housing organizer David Whitehead convened advocacy organizations, faith groups, tenants’ advocates, affordable housing developers, market-rate developers, and lots of others to write and submit amendments to the Comp Plan. We’ve continued to collaborate and check in with many of these partners.

We’ll be taking a close look at the draft of the framework element bill as soon as it comes out, and let you know what we think as soon as we can. Here’s what we’ll be looking for:

Does the Framework prioritize affordable housing?

The current Framework Element does not definitively or clearly state anywhere—in the plan’s guiding principles, maps, or anywhere else—that affordable housing is the, or even a, top planning priority. The words “affordable housing” appear in the Framework just two times.

In August 2018, responding to requests from groups including GGWash, OP asked for changes to the Framework that would center the importance of affordable housing and anti-displacement policies. That includes a statement that affordable housing is a top priority.

We’d like the council to include these changes, and actually say that affordable housing is the top priority, not just one.

Does the Framework allow for more housing?

DC needs more homes to meet the needs of people who already live here and the people who are going to move in. The Council of Governments and OP have estimated that DC needs 36,000 new homes, including about a third affordable, a third “workforce” or middle-income, and a third at higher prices.

The Comp Plan is complicated. It has a set of maps, which mostly show the city as it was in 2006 with a few changes. It also has a lot of text, some of which talks about the need to add new homes even in places the maps don’t explicitly show as okay for development. The plan is contradictory.

You can read the plan to say that anything not consistent with any single chapter must be prohibited. Or, you can read it to say that the DC Zoning Commission, which decides on development issues, can strike a balance. It might decide in favor of building homes, or against, or a compromise.

Under the first interpretation, the plan doesn’t allow for the 36,000 new homes, and especially not in an equitably distributed way (see below). If so, it needs to be changed. Or, it needs to be clarified to elevate the second interpretation.

Does the Framework try to fix Planned Unit Developments?

Planned Unit Developments allow a property owner to negotiate zoning exceptions in exchange for community benefits that wouldn’t otherwise be required. For example, they might get more height and density in exchange for more affordable housing, or community space, or extra landscaping in public space. DC’s Zoning Commission, which decides PUDs, is often reconciling the contradictory elements of the plan. Disputes over that have led to lawsuits that have made PUDs much more rare in DC.

Those lawsuits have blocked many new homes. A few are affordable, usually under DC’s Inclusionary Zoning rules, which require about 8-10% of units in developments over 10 units to be below market rate. Some PUDs include more affordable housing than IZ requires. Some, like the Park Morton public housing redevelopment, have much more. However, most units in the held-up PUDs are market-rate.

DC needs both market-rate and affordable housing. With PUDs broken, it’s getting less of both.

Rules for PUDs are part of the Framework, and so OP tried to clarify the second interpretation discussed in the previous section. Critics of PUDs said this would make the Comp Plan toothless.

There are plenty of legitimate criticisms of the PUD process. But it’s broken down, and the council needs to decide if it wants to leave it broken or fix it. If it chooses the latter, there could be reforms to make the PUD process more effective, clear, and inclusive.

Does the Framework affirmatively further fair housing?

Development in DC, even when it brings much-needed new housing, is located unevenly and unfairly. This is no accident.

The existing Framework Element—which was written in 2006—assumed that it’s desirable to protect already-advantaged neighborhoods and push development away from them, because they’re “built out.” But “there is no such thing as a city that has run out of room.”

This has shaken out just as the existing plan says: Parts of the city, like west of Rock Creek Park, have not seen as much development, while areas with more vacant lots, like Wards 5 and 6, saw lots of development. It also so happened this policy was less bothersome to the homeowners who are more likely to show up in protest.

The words “fair housing” or “segregation,” appear in the Framework zero times, while “character” appears 26 times. “Character” is often “a euphemism for … exclusion.” Even when the preservation of a certain vibe or feeling in a given neighborhood is well-intentioned, it’s a privilege most often granted to majority-white and wealthy spaces, and thus has the effect of perpetuating legally sanctioned patterns of racial segregation over affordable housing.

Our coalition proposed many amendments to clarify the importance of fighting racial and economic segregation and affirmatively furthering fair housing.

We’ll be taking a close look at the draft as soon as it comes out, and let you know what we think. While you wait, you can:

• Watch two lengthy (approximately 20-minute) debates David Alpert had with Mendelson about the Comp Plan during oversight hearings (start at 2:47:30) and budget hearings (start at 4:22:45 or so) this spring
• Take the Office of Planning’s survey about the possible citywide values that the Comp Plan should reflect
• Read our previous posts about the Comp Plan
• Just read the whole Framework and the other 13 citywide chapters (especially the Land Use and Housing chapters, the next two after the Framework) and the 10 neighborhood chapters Because if and when the council gets through the Framework Element, there’s still the rest of the document to go!