Can DC build a better Comp Plan process? An Office of Planning report hints at “yes.”

Within the Comp Plan package that DC Mayor Muriel Bowser recently sent to the DC council is a report from Office of Planning staff. It contains some interesting tidbits about what’s come out of OP’s outreach efforts over the past year, as well as some remarks on how our comprehensive planning process, and documents, could work better.

While it’s true that the Comp Plan “establishes a context and sets broad goals to inform public decision-making and fine-grained planning efforts” (pg. 1), the most recent edition, which was released in 2006, runs over with florid language that glorifies some parts of the city, and is quite contemptuous of others.

I’ve also found DC’s Comp Plan to be very editorial, very detailed, and very subject to discretion and individual interpretation. Compared to other comprehensive planning documents used by other jurisdictions, the definitions of certain land-use categories and descriptions of density are inconsistent or unclear. This leads to muddled interpretations, both by the public and by agencies like the zoning commission that are supposed to take direction from the document.

In OP’s staff report, there’s a short section on the history of comprehensive planning in the District that offers the most reasonable explanation I’ve seen for why this is so. The District’s first federally dictated Comp Plan was instituted in 1950; the first post-Home Rule Comp Plan was written in 1984. After that, new sections, like the land use element and ward-level plans, were added sporadically. By the time 2006 rolled around, the District — which had finally crawled out of a long slog of population decline and onerous federal oversight — was ready to go comp-plan crazy.

We’re still disorganized in our comp-planning cycles. Minneapolis’ recent comprehensive plan overhaul, which legalized triplexes citywide, is deserving of all the accolades that it received. But behind that impressive policy change is a longstanding regional practice of regular comprehensive planning: The regional governing body there, the Metropolitan Council, requires cities, townships, and counties in its seven-county area to routinely submit comp plans, per its Metropolitan Land Planning Act.

As a result, Minneapolis planners, politicians, and residents know what to expect when comp-plan-revision season rolls around, and have greater fluency in what comp plans can and can’t do. Closer to home, Virginia mandates the contents of county comp plans, giving greater guidance for what should or shouldn’t be included.

The OP staff report hints that DC’s scattershot comp planning is unmoored from any sort of timeline and doesn’t come with a clear scope. The process that started in 2016 was an amendment cycle that was ostensibly intended to bring the 2006 Comp Plan, which was lightly edited in 2011 for “technical corrections and a limited number of policy updates” (pg. 2), in line with contemporary planning standards, and update it with data that correctly accounted for 2016 DC, not 2006 DC.

But the Comp Plan ended up spurring so much discourse about the state of the city, about whether it was affordable, and about whether longtime residents felt at home as visible markers of DC’s population growth — large-scale redevelopments like the Wharf, and businesses that seemed tailored to young newcomers with disposable incomes — emerged.

OP accepted an enormous amount of public feedback, and by the time the council took up the administration’s amendments (to only the Framework element, not even the full plan!) in 2019, the various factions that emerged, including GGWash, treated the Comp Plan as a referendum on the city’s identity rather than a straightforward planning document.

I think this is in part because — despite a popular narrative of government overreach, giveaways to developers, and fates forced upon neighborhoods — most cities, including DC, don’t really have much centralized planning happening at all. The Comp Plan was a big, obvious process in which people could get involved, and it became a battle.

Lots of people, rightfully, felt like they had something to fight for, or fight to preserve. Ultimately, most of us who participated in the Comp Plan process, from long-time public meeting attendees to people who emailed their ANC for the first time, experienced it as a full rewrite, even though it was just an amendment cycle.

The staff report hints at ways in which comprehensive planning could be smoothed out in the future (p. 8):

• Scope the plan with accessibility and inclusivity. Consider reducing the detail and length to make the document more accessible to a broader audience.

• Consider the optimal process to both facilitate long-term planning while allowing for much-needed, more nimble updating.

• Evaluate the maps needed, including the granularity of FLUM and GPM to distinguish them from parcel-level zoning maps.

A proposed 2025 Comp Plan gives DC time to envision a new way to do things

It also says that the next Comprehensive Plan rewrite should be completed by 2025, which…yikes? But, actually, not yikes!

There is a huge opportunity to standardize how the District does comp planning, starting with the fact that there is literally no mandate for the next Comp Plan to be completed by 2025, but it probably should be done by then anyway, because a whole bunch more stuff is going to change by then!!!!!

I’ve been keeping a wishlist of Comp Plan administrative reforms that I think would give the process some anchors and make it more predictable, such as:

• Mandate that the city fully rewrite the Comp Plan every 10 years
• Mandate that outreach for the Comp Plan not exceed certain time periods, such as 12 months
• Mandate that the council pass the Comp Plan within a certain time period of receiving a legislative package from OP, such as 90 days
• Mandate that the zoning code be updated within a certain time period following the passage of a rewritten Comp Plan, such as two years
• Mandate an amendment cycle, or time frames at which the Comp Plan can be amended, or actions that would trigger a Comp Plan text or map amendment
• More flexibly incorporate amendments to area elements

Office of Planning could just conform to these things by setting its own internal standards, but that’s not a legal mandate, and may not survive an administrative turnover. I don’t think it’s necessary to amend the Home Rule Act for this, either. The council is probably the most effective body for attaching these sorts of requirements to comp planning, and it would be prudent of councilmembers to include reforms around how comprehensive planning is conducted in the District when they vote to pass this version.

Of course, even with a council mandate for OP to conduct planning in this fashion, there’s no guarantee that it will actually happen. Better still would be to include in any such legislation a reduction or hold on OP’s budget allocation unless it successfully stays on schedule.

It would also be great to see the council acknowledge what OP has in its third recommendation: that the FLUM is not a zoning map. It’s really easy to conflate the two, and conflate their purposes, which is bad! We’ve written a lot about why the FLUM can and should function differently from a zoning map, but, tl;dr, the FLUM should illustrate the potential future density and use categories of broad areas of the city, while the zoning map should provide guidance for what individual parcels can be. If the FLUM functions more like a zoning map, it’s doing a bad job. And it’s redundant.

Other dazzling details

There’s some more fun stuff in the staff report:

• Following OP’s draft amendments to the rest of the Comp Plan, released on Oct. 15, 2019, over 1,000 public comments and 33 official ANC resolutions, with around 1,500 comments, were submitted (p. 7); about 3,100 residents and stakeholders engaged with the “DC Values” outreach campaign OP held throughout the city (p. 3)
• OP provided “88 days for the public and 123 days for ANCs. This time frame represents the longest period of feedback provided for a draft Comprehensive Plan” (p. 4)
• “Overall, 78% of the feedback was integrated, supported, or acknowledged in the Mayor’s proposal. (p.7)
• “The updates to the Future Land Use Map between the Oct. 15 draft and the Mayor’s proposal created an additional 2.3% of land use capacity on less than 1% of land area (535 acres)” (p. 7)
• A nod to statehood: “Finally, the updated GPM incorporates the boundary for the Proposed State of Washington, Douglass Commonwealth, which encompasses all of the District of Columbia, except an area around the Monumental Core that will remain a federal government enclave” (p. 6)

Overall, there’s a lot of potential for making the Comp Plan more accessible and easier to deal with. The most effective way to ensure that this actually happens would be for the council to require the city to more routinely overhaul the document, so that residents — and ANCs, whose feedback was considered with great weight—know what to expect, and when. And a greater public understanding of what comp plans are generally, and what they can do for the District specifically, might lead to a more proactive culture of planning and, subsequently, more constructive input.

There’s an obvious appetite for more centralized planning that’s sensitive toward redistribution. The most exciting thing in the staff report, to me, is that 78% of people wrote in to say that they generally supported Office of Planning’s vision. That’s impressive starting point, and bodes well for both more types of housing in neighborhoods where residents have historically resisted them, and a better culture of regular, organized, evidence-based planning.