I never did put up my testimony about the Comprehensive Plan

The "smart" growth forces are doing a strong lobbying campaign for the Comp Plan. It is troubling, because I think the plan isn't ready. (I pissed someone off at the Coalition for Smarter Growth table at last weekend's Green Festival when I called the pro-Comp Plan effort that they are helping to lobby for "Intellectually bankrupt.")

In my opinion, the two most important things that should be in the Comp Plan are a focus on urban design as the primary organizing element, as well as transportation demand management/transit first policies/mode shift from cars as the organizing philosophy of the transportation element.

Neither are handled in the plan draft in a manner in which you could argue that they are proscriptive policies.

The response of the SG folks is "well, it's better than what we have. It has affordable housing requirements, and it can be changed."

To my way of thinking, urban design and TDM are not in the current plan or in the proposed new plan. Since these two things impact my ability to do what I do the absolute most, and they are in neither plan, a delay doesn't hurt us.

Better we produce something excellent--just as excellent as the tradition of planning excellence laid out from the beginning by L'Enfant, and followed by the McMillan Commission in the early part of last century.

Below is my written testimony about this from the last hearing. My verbal testimony was extemporaneous, and more provocative.

There is another hearing next week. I haven't decided if I will testify again.
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Mayor's Hearing, Revision of the DC Comprehensive Plan
Before the City Council of the District of Columbia
September 26, 2006

Testimony: The Citizens Planning Coalition Says the Comp Plan is not ready to
become law

"We shape our buildings. Thereafter they shape us." -- Winston Churchill

Influenced by the designs of several European cities and 18th century gardens such as France's Palace of Versailles, the plan of Washington, DC was symbolic and innovative for the new nation. Only limited changes were made to the historic city-bounded by Florida Avenue on the north and the waterways on the east, west and south-until after the Civil War. The foremost manipulation of L'Enfant's plan began in the 19th century, and was codified in 1901 when the McMillan Commission directed urban improvements that resulted in the most elegant example of City Beautiful tenets in the nation. L'Enfant's plan was magnified and expanded during the early decades of the 20th century with the reclamation of land for waterfront parks, parkways, an improved Mall and new monuments and vistas. Two hundred years since its design, the integrity of the plan of Washington is largely unimpaired-boasting a legal enforced height restriction, landscaped parks, wide avenues, and open space allowing intended vistas. Constant vigilance is needed by the agencies responsible for design review, it is their charge to continue the vision of L'Enfant.

-- National Park Service website
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Thank you, Chairman Cropp and Councilmembers for the opportunity to speak before you today. I am Richard Layman, and for the past several years I have been involved in a variety of neighborhood and city-wide urban revitalization activities, in particular commercial district revitalization, historic preservation, and the development of cultural resources. I testify today on behalf of the Citizens Planning Coalition (CPC).

The Citizens Planning Coalition was founded as a grassroots response to the very first DC-resident-based Comprehensive Plan exercise in the late 1970s, which followed the granting of the Home Rule Charter, and the City of Washington's assumption of the various functions of government, including planning, that had been conducted previously by the federal government. The creation of Ward Plans as part of the city's Comprehensive Planning Process was an early CPC achievement.

Today, we are addressing the revision of the Comprehensive Plan, a process that has been underway for a number of years, under the rubric of Creating an Inclusive City. A tremendous amount of work has been conducted over the course of this process, with hundreds of meetings, and thousands of residents and other stakeholders having been involved in meetings and comment stages, in person, in writing, and online.

Because of the efforts expended, many advocacy groups, particularly the Smart Growth contingent, are calling for the approval of the Plan, as is. Many others, especially neighborhood groups, are concerned that the Plan needs an additional round of improvement, that the Plan is a great first (or by now third) draft, but isn't quite ready to become law. (And some of these groups may disagree with the CPC that the Comprehensive Plan as submitted is a great document, albeit needing more work.)

Besides being the federal city, Washington, DC is also distinguished amongst American cities for its tradition of planning excellence, beginning with the initial effort of planning the City of Washington, commonly referred to as the L'Enfant Plan, under the direction of President George Washington, who is memorialized in the name of our great city.

Let's assess where we are shall we?--215 years after Pierre L'Enfant.

It is not news to anyone in this room that the dominant planning and land use paradigm in the United States is automobile-centric and suburban, one of separated, deconcentrated, and low scale uses, connected for the most part by freeways and other high-capacity roadways. (We call this "sprawl.") By way of example, the average suburban household conducts 15 separate out-of-home trips daily, most by cars, usually peopled by only one occupant. Most suburban households have two cars, a significant number have at least three cars, and the number of cars per suburban household is increasing still.

By contrast, the average urban household resident combines tasks and errands into far fewer trips. DC residents have commute times at or under national averages, spend less money on transportation overall, and almost 40% of households do not own cars. DC has a higher rate of walking and bicycle trips than all but a couple other cities nationally.

With the 2000 Census, a majority of the nation's Congressional Districts are now suburban, and for the most part, this is reflected in the activities and concerns of the Legislative and Executive Branches of the Federal Government. Cities, even the "Federal City," aren't that important to the Federal Government.

These demographics and characteristics are important to consider in the light of the seeming and real success of the city's transformation over the past few years. DC is attracting new residents and new businesses. DC is the number one commercial real estate market in North America, and the second in the world, after London.

The DC real estate market is one of national and international, not just local, actors. Billions of dollars of new buildings have been constructed over the past 7 years, and billions more is underway. Many thousands of new apartment and condominium units are attracting new residents to the city--in every Ward! Buildings vacant for decades are being rehabilitated and coming back into productive use.

Despite this great success, the region and the nation continues to suburbanize. Washington is an anomaly. As legislators and involved citizens, it is essential for us to understand why this is so. Why is Washington an attractive place to live, a great place to locate a business, one of the most popular visitor destinations in the United States, a center for arts, cultural, and entertainment?

It is easy to forget that in 2002, many of us doubted that our various neighborhoods--especially those of us in the Northeast and Southeast quadrants--would ever improve. That WMATA abandoned plans for expansion, plans that would have aided the District greatly, instead laying off 250 workers in their construction and engineering division--over 90%--because of the then poor economy!

Over the past few years, most of my testimonies before City Council make the same point over and over and over. The City's competitive advantages center upon:

- (historic) architecture;
- human-scaled and people-centric urban design;
- history and authenticity;
- a rich set of transit assets allowing cost- and time-efficient mobility that isn't reliant upon the automobile.

(Note that there is a fifth competitive advantage, one that we have less influence over--the strong steady unstopping employment engine of the federal government.)

This can be summed up in fifteen words:

Washington is a real city, with history, designed for and around people, not the car.

Our efforts as legislators, appointed officials, and civic leaders must be focused on supporting, strengthening and extending these competitive advantages. And the Comprehensive Plan should be leading the way, serving as:

- the ultimate policy and business planning document for the City generally;
- for all agencies individually;
- focusing and prioritizing our efforts and resources;
- at both the city-wide and neighborhood levels.

It doesn't matter that DC is vastly more successful than other center cities such as Philadelphia or Baltimore or Cleveland.

Economically, we compete with Alexandria, Arlington, Fairfax, Prince William, and Loudoun Counties in Virginia, and Montgomery, Prince George's, Howard, and Anne Arundel Counties in Maryland, and increasingly counties even further from the heart of the region in Virginia, Maryland, West Virginia, and Pennsylvania.

Subdivisions in Pennsylvania are being advertised as being within commuting distance of our city! The City of Alexandria markets itself as "The Fun Side of the Potomac," meaning that the District of Columbia is "unfun" by comparison. Counties in Maryland advertise their proximity to DC with slogans such as "DC Days, Maryland Nights."

To stay the same is to fall behind, because our competitors continue to move forward. Look around places like Arlington, Bethesda, New Carrollton, Silver Spring, Alexandria, Rockville Pike, I-270, in the Dulles Corridor, Tysons, if you don't believe me. The National Harbor across the border, in Prince George's County, is already impacting convention and hotel business in Washington, DC proper.

Yet at the same time, our success as a city is inextricably intertwined with these jurisdictions and their success.

Many people argue that the Comprehensive Plan revision, as is, is a major step forward and the best that can be achieved given all the conflicting stakeholders and the tremendous pressures involved in the process.

I too have been lobbied to testify in favor of the plan. And in working through the reasoning on which way to fall, yea or nay, I had to stop and think about my own core competence, being uncompromising about demanding quality in all that we do when it comes to involvement in planning and land use matters in the District of Columbia.

I merely ask one question, remembering that incrementalism and compromise are too often the allies of mediocrity -- and irrelevance:

As submitted to City Council, does the Comprehensive Plan revision adequately maintain, support, and extend those qualities that make the City of Washington one of the greatest cities in North America?

My answer is: no.

Rather than provide voluminous and detailed testimony about the various gaps and underdevelopment of the various sections--some of which are quite good, and others (Arts and Culture especially) very weak, I will offer comments on three sections that demonstrate the overall problem.

1. Winston Churchill's quote at the outset of this testimony recognizes that the city's physical form, rather than land use, is its most intrinsic and enduring characteristic--walkability, a city designed for the pedestrian, not the car, historic architecture--those are the elements that define the city. But the Comprehensive Plan defines Land Use as the most important element. Rather than being listed ninth, Urban Design should be deemed the leading Element.

(Urban Design should be first, Land Use second, Transportation third, Economic Development fourth, and Housing fifth. If you don't get the how of the city as an urban, rather than suburban, place, make it easy to get around, with a thriving local economy, there is no point in living here--which is why we suggest that Housing follow the other, more "building block" elements.)

Virtually all of the matters that I have testified about in the past, ranging from the necessity of architectural design review and the protection of historic and cultural resources flows from the recognition of the primacy of urban (not suburban) design in the conduct of planning and land use matters in the City of Washington.

Most District Government policies acquiesce to the insistent and demanding lobbying of motorists≈and most developers are still focused on and most comfortable with the suburban paradigm. Zoning laws and regulations focusing on lot line and Euclidean requirements within have little relevance to the site's context and connection with the world outside of the lot and the people who live, work, and play in and around these buildings. (Note that the Office of Zoning strategic plan planning process makes no mention of the impact of their actions on the quality of life of the District's residents.)

Aggressively suburbanizing the city by focusing on the car destroys all the characteristics that make the city great. Put Urban Design first (and augment the Element).

2. Efficient mobility and transportation is at the heart of why and where cities developed in the first place--it is about the transit of goods, and people coming together, for commerce and trade.

Simple mathematics demonstrates that a focus on the car as the primary mode of transportation is inefficient and unsustainable. An average street lane of one mile in length has a throughput of 900 cars/hour in urban settings, and 2,000 cars/hour on freeways. Even the least efficient transit mode moves 6,000 people or more in the same space/hour, and heavy rail up to five times that number!

Therefore, transportation demand management (TDM) and the reduction of single occupancy vehicle trips should be guiding force for the entire Transportation Element.

Yet the Transportation Element is a major disappointment (which I have detailed elsewhere) for many reasons (its unexplained halving of the number of proposed streetcar lines is one, and the failure to lay out a broader transit agenda--the District is dependent on a great regional transit system, and should advocate for such, first, foremost, and always--is another).

The proposed TDM requirements are so weak as to be meaningless*, calling for TDM requirements in PUD matters, when TDM should be required as a matter of course, for all new and extant development in the city--all public and private institutional uses; commercial buildings; multiunit housing; guidelines for residents for single dwelling units (i.e., after one car per household, registration and parking permit fees should be significantly higher); and deliveries to businesses.

(*Arlington County does way more and the State of Virginia doesn't even have enabling legislation allowing for mandatory TDM. Everything Arlington does is voluntary. DC doesn't have the same constraints, and can learn from all their experience, rather than trial and error. As the Chancellor of Germany, Otto Bismarck, was fond of saying: "Fools learn from experience. I prefer to profit from the experience of others."

Many of the land use battles around the city, which developers and others often call nimbyism (not in my backyard) are often, at the core, about mobility and the perceived impact on traffic.

Whereas advocates with city-wide and regional perspectives might not always agree with residents and with what I sometimes call the tyranny of neighborhood parochialism, TDM would provide the guidance needed and necessary to work through these matters, ranging from locating denser development around transit, to inappropriate siting of institutional uses in places that are inadequately connected to the transit infrastructure, to dealing with the always contentious church parking issue (require that churches and neighborhoods jointly create transportation demand management plans and as elected officials, you no longer have to get involved), etc.

3. Categorically, the definition of each of the Area Elements is weak, incredibly so. Not one Area Element, as submitted, is equal to any of the Ward Plans as currently in force.

Substantive, not overly constrained and accelerated, efforts need to be conducted to improve each of the Area Elements, with a neighborhood-centric process.

Conclusion

The Comprehensive Plan Revision, as submitted to the DC City Council in 2006, in many respects, is not quite "Comprehensive" and is underfocused on maintaining and strengthening the City of Washington's competitive advantages:

1. (historic) architecture;
2. human-scaled and people-centric urban design;
3. history and authenticity;
4. a rich set of transit assets allowing cost- and time-efficient mobility that isn't reliant upon the automobile.

Therefore, the Citizens Planning Coalition recommends that the City Council table consideration of the Comprehensive Plan as submitted, mandating an additional round of revisions to the document, to be resubmitted and reconsidered as part of the Council agenda in the Spring-early Summer of 2007.

Washington has a tradition of excellence in urban planning, beginning with the City's founding 215 years ago. We are the stewards of that legacy. Let us be equally demanding today, in the tradition of Pierre L'Enfant, George Washington, Senator McMillan, Daniel Burnham, and all the subsequent planning efforts that we are the fortunate beneficiaries of today.

Index Keywords: urban-design-placemaking; mobility