Sunrise over the city by Erin used with permission.

When DC Mayor Muriel Bowser and Office of Planning (OP) Director Andrew Trueblood released citywide targets for affordable housing production by neighborhood planning area, they also made public amendments to the rest of the Comprehensive Plan—all 24 chapters of it. The Comp Plan is important because it guides how the city will grow in the years to come.

On October 8, the council passed the Framework element, the intro which charts the direction for the plan. This is our first look at OP’s proposed updates to the rest of the document. GGWash will be paying particular attention to the land use, housing, and historic preservation sections, as well as the area elements of the Comp Plan as it’s revised.

We’re working through the amendments to each section. Here are four things we found notable in our first pass at the historic preservation text amendments.

What changed regarding historic preservation?

Throughout the chapter, OP’s amendments more clearly present the nuts and bolts of preservation in DC.

1. Clarification of roles and responsibilities: What’s most interesting is that the interplay between historic preservation and growth, particularly as growth concerns housing, is reflected throughout OP’s amendments to the chapter. On the first page, “The Element recognizes historic preservation as an important local government responsibility” is changed to “The Element recognizes historic preservation as a valuable planning tool” (page 1 of 65).

This is also a more honest description of where preservation is situated in the city’s governance: under planning, rather than an independent arm. Making this clear is an important set-up for the rest of the section, which states that “Welcoming new growth in the city, while protecting its historic character” and “Expanding the reuse of historic buildings for affordable housing,” among other additions to Section 1000.2, are critical historic preservation issues facing the District (page 1 of 65).

The changes also better explain the role of various agents, like the State Historic Preservation Officer and Commission of Fine Arts.

2. A more forward-looking vision: Some sections seem rewritten with the aforementioned framing in mind. This includes Section 1000.6, which now says, “The District’s recent growth by 100,000 residents in a single decade parallels earlier booms during wartime and the Great Depression, when newcomers flocked to the city seeking jobs and opportunity. Each of these spurts led to innovation and expansion, but also the burden of providing adequate housing and services for new residents.”

While statements that effectively amount to, “DC grew once, and it will grow again, and there will be challenges,” aren’t earth-shattering admissions, it’s much more useful for the preservation element to present a forward-looking vision. The 2006 Comp Plan has a lot of treacly language describing the city’s then-current state, which isn’t helpful or, really, relevant to a document that’s supposed to provide guidance for future growth. For example, the District’s “mosaic” of neighborhoods is described in the current Comp Plan as:

“Some filled with turreted Victorian rowhouses, some with modest bungalows intermixed with apartments, and others lined block after block with broad turn-of-the-century front porches. Washington’s architecture is an eclectic mix that belies the dignified uniformity of the tourist postcards. And much of the historic city is still intact. This is a prime source of the city’s charm and an inheritance that should make all Washingtonians proud.” (page 30 of 65)

Further, language like “Affirm the importance of local cultural identity and traditions, and recognize the role that cultural recognition plays in supporting civic engagement and community enrichment. Recognize a diversity of culture and identity to support a more equitable understanding of the District’s heritage,” can be read as a direct nod to the rising interest in a kind of cultural conservation—most notably surfaced by the Don’t Mute DC protests—that isn’t entirely, or at all, based in physical structures.

3. Acknowledgement of tension between preservation and growth: Statements like, “Preservation standards should be reasonable, and flexible enough in their application to accommodate different circumstances and community needs” and “With thoughtful planning and development, needed growth can occur without degrading historic character” (page 7 of 65), speak to a long-simmering tension between preservation and development. Advocates tend to fall on sides—preserve neighborhood character, or build!—and hold scarcity mindsets that drive them further into conflict with each other.

It’s reasonable to say that DC’s preservation regime is much more aggressive than that of many cities, and that it has negatively impacted housing affordability. Many, many anti-development fights have involved at least a nod to historic preservation, perhaps because the process to nominate a building or a neighborhood as historically significant is relatively publicly accessible. Most Advisory Neighborhood Commissioners (ANCs), and hyper-involved residents, can figure it out how to engage with it.

Debates over preservation might loom large at the neighborhood level, rightfully, but they are handily engulfed by projections for DC’s, and the region’s, job and population growth. So it’s appropriate that OP’s amendments locks together these two oppositional stances, rather than deferring to one or the other. Lots of new language embodies this dynamic:

Preservation of existing affordable housing is among the District’s highest priorities, and many of these units are located in the city’s older housing stock, including historic buildings. Historic preservation can help to retain and enhance this building stock as an important resource for the city. At the same time, as older neighborhoods become more attractive to new residents and developers, values rise, generating increases in property taxes. Maintenance and upkeep of these older buildings is necessary, and both taxes and repair costs affect lower income residents most severely. Appropriate flexibility in the application of preservation standards within historic districts can mitigate this problem, but financial assistance programs and incentives are also necessary to keep as much as possible of this building supply affordable” (page 59 of 65).

“While historic preservation has supported the revitalization and enhancement of downtown and many neighborhoods in recent decades, currently the District faces a new challenge of providing adequate housing for a population that has has soared by more than 100,000 people since the 2010 Census. Some of this housing will need to be provided in the city’s historic districts, whether existing or new. More study of the relationship between gentrification, historic preservation, and the cost and availability of housing is needed to support an understanding and consensus about how these new needs can best be managed” (page 60 of 65).

4. A mandate to see how historic preservation impacts housing: There’s a great deal of respect granted to the long legacy of preservation in DC, which is a complex and messy thing that, in my experience, works differently here than anywhere else in the country.

When discussing preservation, we should be honest with ourselves, and acknowledge that the legal strings of preservation policies typically look much like economic development. The stated purpose of preservation in the District—much like preservation at the federal level—is to “retain and enhance” historic assets and areas. The output of this is preserving buildings, yes. But the actual process of doing so often depends on the infusion of tax credits to redevelop ailing properties into viable commodities.

Further, preservation in DC, specifically, often acts as a restrictive land-use regulation, given that it’s a small city-state. By limiting what can happen by-right in areas designated historic, preservation looks not dissimilar to exclusionary zoning. Fundamentally, our preservation laws and regulations are, literally, not designed to preserve affordable housing, keep people in their homes, or bulwark neighborhoods against gentrification.

The coda to all this is another new section, which says, “Examine the effects of historic preservation on housing affordability, as documented in existing studies and through analysis of available District data. Consider the findings of these studies and investigate how to manage preservation tools in ways that support housing affordability” (page 61 of 65). That’s as explicit of a mandate as any comprehensive plan can give to move something, like a study, forward.

How do I look at all of this stuff?

Everything lives on plandc.dc.gov. Scroll down: The links to most of what is relevant are in the bottom left-hand corner.

The full PDF of the amended 2006 Comp Plan—so, the document in which you can see OP’s redlines, which are amendments—is here. Summaries of OP’s changes to each section are here. The current and proposed Future Land Use Maps and Generalized Policy Maps are here.

You can see OP’s recommendations on amendments submitted during the 2017 open call here. The Housing Equity report with affordable housing targets, which isn’t part of the Comp Plan, is here.

And how can I get involved?

The public has until December 15 to review what OP put out, and you can email your thoughts to planning@dc.gov. Advisory Neighborhood Commissions have until January 31 to submit resolutions.

Keep in mind that whatever you, or your ANC, submits to Office of Planning will be reviewed by the Office of Planning. But, just like the Framework, the rest of the Comp Plan is a piece of legislation that’s voted on the by the council. So next year the council will take it up, though we don’t yet know when. There will be a public hearing, then a first and second reading; second reading doubles as the final vote.

Alex Baca is the DC Policy Director at GGWash. Previously the engagement director of the Coalition for Smarter Growth and the general manager of Cuyahoga County's bikesharing system, she has also worked in journalism, bike advocacy, architecture, construction, and transportation in DC, San Francisco, and Cleveland. She has written about all of the above for CityLab, Slate, Vox, Washington City Paper, and other publications.