Op-Ed: Comp Plan Amendments: What Now?

By Fredrica Kramer, ANC 6D05 and Vice Chair, ANC 6D

The District’s Comprehensive Plan, adopted in 2006, is a 20-year guide to future growth and development. The Plan was amended in 2011, the Framework chapter was amended in 2020, and the full Plan is now being amended again. 

The Office of Planning’s (OP) 2019 draft met with stiff resistance, including a perceived weakening of the language that might provide stronger directives and legal authority to redress the consequences of rapid growth and increased density. In response, the DC Council charged the ANCs with collecting and submitting comments of their own and their constituents. ANC 6D submitted detailed comments to OP in February 2020 on Chapter 19 on the Lower Anacostia/Near Southwest, with additional reference to Chapter 4 on Housing, and testified with extended comments to the Council in November and December 2020. 

With the Council’s May 18, 2021 final vote, including their own amendments to the OP draft, we should take the time between now and the full rewrite beginning January 2025, to consider some critical issues that can and should be addressed outside of the Comp Plan to shape the community we strive for. 

Whether Southwest can remain an “exemplar of equity and inclusion,” as our Small Area Plan (SAP) memorialized, can be shaped by legislative and policy changes outside of the Plan. While the principal vehicle for addressing housing affordability has been increasing density and infill, we will continue to lose the social diversity that Southwest values without additional ways to create varied and affordable housing stock as aggressive redevelopment continues.

• Changing our Inclusionary Zoning (IZ) law can be a target now to cover more projects and to make more units available to those who cannot afford market rate rents or purchase prices.  
  • Current IZ rules typically require only 8% below market rate units in the new buildings to which IZ applies – as we increase density with more tall buildings, affordable housing will become an increasingly smaller slice of the whole. 
  • The Amendments propose 40% of new affordable (below market rate) units be capped at 30% of our region’s Median Family Income (MFI), and the rest split between 30-60% and 60-80% of MFI (80% of MFI is nearly $70,000 for one person and nearly $101,000 for a family of 4, while 30% of MFI is $37,800 for a family of 4). Capping 40% at deep affordability is a good target, but still leaves most developments stuck at providing only about 8% of the total units below market rate and many buildings not subject to IZ at all. 

• Public housing is the last assurance for deep affordability, but essential maintenance is not properly funded and most public housing is disappearing through replacement projects. 
  • We must ensure that our commitment to Build First for Greenleaf is realized – one-for-one replacement and one move from current to new unit within our community. 
  • The Amendments include a tenant’s right of return and a full relocation plan, but absent the strict application of Build First above, redevelopment has scattered public housing residents, breaking community ties and services and making future return largely unrealistic.  

• Publicly owned parcels destined to be surplused or repurposed, and public subsidies in other redevelopment parcels, are opportunities to lead equitable development. 
  • The Council’s Amendments prioritize deeply affordable housing for city-owned land, and we should press the District to harvest these parcels, including the DMV facilities in Southwest as long as we remain a redevelopment hotspot for private developers; by DC law, if converted to residential use, it could produce 20-30% below market rate housing. 
  • Benefits from public subsidies (e.g., tax relief in Opportunity Zones and otherwise, long-term leases, deep price reductions on sales of publicly owned properties) also ought to play prominently in discussions as redevelopment projects are vetted. 

• The dictates for review of development proposals by ANCs and others is extremely variable, and not all communities have Small Area Plans to articulate community values and objectives and apply them to development. Southwest has an SAP, but its recommendations are often not well reflected in development plans, and may not have primacy when they overlap with other planning directives (e.g., the Capitol Gateway Project).
  • Except for Planned Unit Developments (PUDs), many projects are subject to only limited review, comments may be due only to the OP rather than the Zoning Commission – with the potential to become part of a Final Order, or may have no mandated community review at all. A full review of the review process itself could strengthen the ANC’s and community’s ability to influence development decisions.
  • We should also require social impact assessments, as we do environmental impact assessments, as part of local planning and as a tool to take stock of the short- and long-term consequences of a proposed new development in relation to the SAP and other critical community effects.  

• Historic preservation can be a means to retain the cultural fabric of a community and to preserve affordable housing. Thoughtful consideration of how the historic character can be preserved, inventorying important structures, creative integration of historic structures with new development, and more subtle recognition of how social interaction works in a community and can be protected, should be part of the process as new projects are reviewed. 

• As new residential buildings move common spaces to the interior, we are losing open space, both green space and the physical ground that nurtured social interaction across demographic divides. Whether creative design can regain some of that space is a challenge and merits consideration.

• We agonize over the scarcity of neighborhood-serving businesses but need to find new tools to support small businesses – including smaller spaces, and lease and ownership arrangements to control costs and support neighborhood services. 

• Transportation planning focuses on a dramatic reduction in automobile use, expanded use of smaller motorized vehicles and bikes, and more support for walkers. An equitable transportation policy must minimize competition between all motorized vehicles and others to maximize safety. 
  • It must also account for realistic public transit availability, especially for those who rely on it to get to work at odd hours. Automobiles are necessary to get to areas not well served by public transit, and when age or disability requires auto use, planning must account realistically for available parking and garage space for those who need it.
  • Details of an equitable transportation plan must accompany all new development, which they too often do not. 

These are not abstract issues or long-term goals but govern our ability to realize the dictates in our own Small Area Plan and can provide a blueprint for needed reform now.