DC’s Comprehensive Plan needs to treat displacement as a serious problem

A growing Washington, DC is a good thing, but that growth done poorly can lead to painful changes for lower-income people who have made the city their home through boom and bust. The Comprehensive Plan could manage growth in a way that doesn't pit the needs of our burgeoning population and the needs of more vulnerable residents against one another.

As DC continues to grow, many affordable communities are being considered for redevelopment, either because repairs are desperately needed or because the owner's commitments or leases are expiring. In some cases these sites represent opportunities to not only renovate buildings in disrepair, but also add more homes to the community. The fear and risk is that this same redevelopment means losing existing cheaper housing that many must have if they're going to stay in the community.

GGWash contributor Pete Rodrigue covered one such development, Brookland Manor, in depth. At that particular site, the owner is proposing to redevelop an aging complex of subsidized affordable and market-rate affordable homes into a mixed-income community with much greater density.

While the owners have agreed to keep many of the subsidized homes there, advocates and community members have rallied against the project because current plans would not replace every single unit of low-cost housing that's currently there.

I’ve heard from these advocates and others about their deep anger and frustrations about this process. They feel that when the development comes under review, there are not enough tools to fight against displacement.

The current Comprehensive Plan, a land use document that guides city wide policy and individual zoning cases, describes the problem of displacement but offers little in terms of clear actions to prevent it. Here is the one and only policy in the Housing Element of the Comp Plan that directly addresses displacement:

Policy H-2.1.3: Avoiding Displacement

Maintain programs to minimize displacement resulting from the conversion or renovation of affordable rental housing to more costly forms of housing. Rental housing comprises almost 60 percent of the housing stock and is the main housing option for those just entering the workforce and those without the initial resources to purchase a home. These programs should include financial, technical, and counseling assistance to lower income households and the strengthening of the rights of existing tenants to purchase rental units if they are being converted to ownership units.

Like I said, lots of description about the problem, but no clear benchmarks, policies, or goals.

As a result, when tenants or advocates testify before the DC Zoning Commission to ask for something like one-for-one replacement of existing affordable units, they are met with sympathy rather than action. Commissioners have held that because their job is to uphold and interpret the Comp Plan, they can’t do much beyond what's in it.

And that’s the problem: the Comp Plan just does not make such a demand.

This is out of sync with other DC efforts

Last fall, the city’s Housing Preservation Strike Force (made up of District agency leadership, councilmembers, and private sector and advocate leaders) called for the “the ambitious goal of preserving the affordability of 100 percent of the District’s existing federally- and city-assisted affordable rental homes.” It went even further to include “preserving the city’s unassisted affordable homes, what the Strike Force came to call ‘naturally affordable’” homes, in its policy recommendations.

So in one corner you have the Mayor and a host of the top people in DC’s housing sector calling for a hard line on the preservation of affordable housing, and in the other corner, you have the muted language of the Comp Plan. You can see why many are upset.

If we’re going to take preservation seriously, we need to fund it

Greater Greater Washington recently submitted a Comp Plan amendment package that was formed with the input of a broad set of housing stakeholders. As we worked on this amendment package with our many partners, it became clear that preserving the affordable housing that is left in DC is an essential part of the strategy to maintain a diverse housing stock that is affordable to people of all incomes. One of the challenges, of course, is funding this work.

DC does more than many other cities by putting $100 million in its Housing Production Trust Fund, which is used to provide gap financing for many projects that include affordable homes in the District. But that is simply not enough. Beyond the repairs and revitalization needed for many of these cheaper units, the cost of long-term subsidy and maintenance is big, and with rising rents, only going to get bigger.

That’s why as part of our package, we included language that holds the line with preservation but also points to funding opportunities to make it happen. Here’s an example:

When redevelopment occurs on properties with housing made affordable through subsidy, covenant, or rent control, the District, Zoning Commission, and neighborhoods should work with landowners to create redevelopment plans that preserve such units or replace any lost ones with similar units either on-site or nearby. These entities should provide the necessary density and/or potential funding to ensure it is financially feasible to reinvest in the property with no net loss of affordable units.

If we’re going to make sure there's money to preserve homes, we need to have all the funding options on the table. That might mean allowing zoning flexibility to build a taller building, using some of the profit generated from those extra units to subsidize in-house lower-cost units. That might mean expanding voucher programs like DC’s Low Rent Subsidy Program (LRSP), to help meet the gap between what families can afford and what it costs to build a low-cost home.

In the end, replacing affordable units during necessary redevelopment needs to be taken seriously, and so do the funding mechanisms for it.

It takes more than replacing affordable units

Unfortunately, even in redevelopments where affordable homes have been replaced one-for-one, there are other problems that can lead to the ultimate displacement of the original residents.

An example is the Ellen Wilson Dwellings near Barracks Row, which were redeveloped through the DC Housing Authority and are now the remarkable mixed income community called Townhomes on Capitol Hill. While the resulting community is a fascinating model of mixed-income ownership and equity building, out of the original 129 low income families that lived at the Ellen Wilson Dwellings, only 11 came back to live in the new community.

Part of the problem was that the new development did not replace all of the affordable units one-for-one. But beyond that, it also took over 10 years for the redevelopment to occur, and by that time many of the displaced families had left or found alternatives. What is more, here and elsewhere many returning residents needed to reapply for the new replacement homes. This process can lead to original residents losing the opportunity to come back if the requirements are now suddenly different for the new community.

There are fixes for these kinds of things, such as utilizing a build-first policy or fairer reapplication requirements, but these fixes don't get consistent attention in District policies and they're even less of a priority in the Comp Plan. The amendments we helped propose call for these kinds of policies in a feasible way.

The goals of redeveloping affordable homes, building more homes overall, and maintaining a clear path for original residents to return do not have to be at odds. In fact, these three goals can complement each other and should. That’s what we need to take both inclusivity and growth seriously.