Comprehensive Plan Revision Process is too accelerated and a deficient product will result

All along, people have been complaining that the process for revising and creating a finished product for the Comprehensive Plan for the City of Washington has been circumscribed and accelerated. That the amount of work that had to be produced in this time frame is greater that can be done and be done well.

Today and tonight there are the final "Mayor's hearings" on the plan:

Mayor's Public Hearing
Tuesday, June 13 -- The Whole City
441 4th Street, NW
Old Council Chambers
-- 1:00-3:00PM
-- 5:00-8:00PM
Call 202/442-8812 to sign up to testify.

Then, unbelievably, the Comp Plan draft is to be submitted to the City Council for action within the next three weeks.

The Comp Plan document is hundreds of pages long.

There are 8 "area elements" and 17(!) sections of the document related to "citywide elements."

It was released last month.

There is no question that the people involved in the project are dedicated and have produced a great deal of work in a relatively limited and constrained timeframe.

But clearly, it is a first draft.

If it were a graduate school thesis or dissertation, I don't think it would qualify as final work. Although average and under-average students might consider it to be finished. It needs a great deal of revision. At best, in its current condition, it would get a C or a C- grade.

Is that the kind of grade you'd be satisfied with? The kind of paper you'd want to turn in with your name on it? The kind of document that you'd want to guide planning and development for the nation's capital, a "world class" city?

The draft as published seems to have avoided a number of questions. And in a number of areas, it is clear that best practices were not considered in developing sections or land use guidance (or that there wasn't time to consider broader issues).

Some of the elements are excellent (Historic Preservation, Urban Design), but even so they need work, deserving only B grades at present.

Some of the elements I've read are really weak, surprisingly including the Transportation element, which as written is a lot weaker than our transportation infrastructure and the quality of the agency that executes this element. Importantly, some fundamental questions are ignored. A C- grade at best.

The Arts & Culture element is puff and says little of substance. A D grade. And it's embarassing to me personally because I lobbied hard for the creation of this element, and the development of an overarching cultural development and management plan for the city.

You know the old Chinese saying, "be careful what you wish for, because you might get it"...

I do feel like many of the things I've written or said in public meetings are reflected in the plan. My comment that most Comprehensive Plans don't have elements on "building a local economy" seems to have influenced the "Economic Development" element. It's pretty good (but I haven't read it all yet, so I can't grade this element).

Given the length of the document and the time required to go through it carefully, plus, the need to compare the draft revision to the original Comprehensive Plan, and to then read and consider the "Federal Element" (Comprehensive Plan for the National Capital: Federal Elements) in the context of the draft revision, there is no way that you turn around such a document in 6-7 weeks, which is what is going on here.

The time required for solid and careful review is considerable, and then to write up the comments in a readable cogent fashion is lengthy as well. Easily a 50-70 hour project at a minimum--and I read and write pretty quickly. And even for a wonk like me, it gets to be a slog after awhile. Plus, I will say, it seems like a lot to ask of the average citizen... There should have been a technical review committee (maybe there was) doing this kind of response and analysis.

Another problem with the draft as written is that there are contradictory policies.

For example that neighborhood integrity should be maintained, but within 1/4 mile of subway stations, categorically, density should be increased. I understand this at the relatively undeveloped Fort Totten or the west side of the New York Avenue station, or parts of the area around the Brookland station, but does that mean you demolish the eligible for historic designation residential buildings to the east of New York Avenue or Brookland stations?

Plus, I would reorder the elements to better reflect their importance as guiding planning and development decisions in the city. For example, I am in a "tussle" with a colleague--she thinks that the Land Use element should be listed first, I think that the Urban Design element should be first. I can accept Urban Design being listed second, but not 14th.

DC is defined by urban design, and that needs to be reflected through and through the Comprehensive plan.

Note the first sentence in the header of this blog:

A community’s physical form, rather than its land uses, is its most intrinsic and enduring characteristic.

(The source for this quote is the report Getting To Smart Growth 2.)

Yesterday's Wall Street Journal has a column on B1 about Management and Leadership, entitled "Executives Who Build Truth-Telling Cultures Learn Fast What Works, " which opens with this:

The higher executives climb, the easier it is for them to distance themselves from problems. Top company officials are often surrounded by yes people who filter out bad news. They then convince themselves their strategies are working, even when they aren't.

At the citizen summit in 2003, Mayor Williams talked about the need to "build an inclusive city." For a time, a video of this presentation was online on the city website. But it's been unavailable for as much as 18 months. I remember that he talked about how DC never really made its own land use plans before and how doing so now is important and necessary, and how it is important and necessary to define our values--building an inclusive city--in doing so.

As citizens, we shouldn't be satisfied with sub-standard work. It should be unacceptable. We should want and expect the best for ourselves and our city, today and for our future.

Certainly, sub-standard work shouldn't be guiding land use and government planning for a city that is:

(1) the national capital with an unparalleled planning tradition;
(2) the number one real estate development market in the United States and the number two real estate development market in the world;
(3) visited by upwards of 17-20 million people each year; and
(4) the place that 600,000 or more people call home.

I made a similar point at April's City Council budget hearing for the Office of Planning. I said something like this:

According to the website of the DC Marketing Center, one of the city's Economic Development arms, "Washington has a development dynamic best illustrated by $13 billion worth of projects completed since 2001 and the $7 billion currently under construction." Likely there is at least $7 billion of projects in development. How can we not fund adequately the Office of Planning? How can we not provide the City Government with adequate tools and funding so that we have the ability to manage and oversee this development? Otheerwise, we cannot ensure that we are truly building an inclusive and beautiful city.

Well, it starts with the Comprehensive Plan. According to the Office of Planning website:

The Home Rule Act requires the District government to develop a Comprehensive Plan. This plan is a general policy document that provides overall guidance for future planning and development of the city. The first Comprehensive Plan was adopted in 1984 and 1985. The plan is updated periodically, most recently in 1998 and 1999. The Office of Planning is in the process of updating the current Comprehensive Plan.

How can we allow an unfinished and problematic Comprehensive Plan to be enacted into law, to guide the city's planning and development?

Some colleagues think that having the whole summer to review, revise, and extend the plan will provide enough time to polish the document. While I don't think that's enough time, having that extra time would make a big difference.

That will be the subject of my testimony tonight.

Index Keywords: comprehensive-plan; urban-design-placemaking