Proposed DC Comprehensive Plan Amendments

-- Vision for Growing an Inclusive City and Vision Policy Papers
-- 2006 Comprehensive Plan
-- Comprehensive Plan Amendment Process

I didn't write super exhaustive policy papers because at one level I am resentful of having to write such proposals "for free." It's a lot of work, and the Office of Planning has spent hundreds and hundreds of thousands of dollars on consultants for both the creation of the Comprehensive Plan as well as the Planning Processes Study and yet there are massive gaps in the final products. Amendments were due today, by 5pm.

I realized while reading through the plan that I suppose I could have submitted at least one dozen more amendments to strengthen or clarify various sections, but it was enough as it was.

So, what did I propose? Some "simple" stuff and some more complicated philosophical-theoretical constructs...

Simple Stuff

1. Add two words to a section on industrial land use, to extend to the CM (not just the M) category greater protections for industrial uses.

Non-industrial users, especially schools (charter schools) and churches, can outbid industrial users on noneconomic considerations. Only 1% of the city's total land is zoned industrial, and the CM category allows typical commercial use (retail, office, even housing), while the M use only allows industrial use, not any other commercial or civic use. By not discouraging competing uses in the CM category, which is the dominant industrial zoning category, real industrial users (production, distribution, repair) still get outbid.

An alternative suggestion was requiring 50% to 100% of ground floor use remain industrial on a lot. That would allow for nonindustrial users, but only if they utilize air rights.

2. I proposed changing the language in the Transportation Demand Management section of the Transportation Element to specifically require transportation demand management--especially a shift away from automobile use, for neighborhoods, districts (which I did not define), institutions (which I did not fully define -- think schools, universities, churches, hospitals, etc.), commercial enterprises of a certain size and/or type, and multiunit residential buildings.

While you can read the section as it currently exists and think that TDM is required, it's not clear, and in any case, the Office of Planning and the Department of Transportation assert that they can't impose TDM planning requirements, other than for new "planned unit development" actions--something that I got required in the Comp. Plan in the 2006 revision process (even at the first draft of the plan it was suggested not required).

Hence the suggested change.

3. Another "simple" change was suggesting that the entire section of the Land Use Element on "Transit Oriented Development and Corridors" be rewritten to de-emphasize the sole focus on development around transit stations and focus instead on targeting land uses to those places best able to meet the transportation demand they are likely to generate through extant transportation infrastructure, with transit being the foremost preference, but also considering the street network.

In short, many institutional uses are considered "matter of right" in an entire zoning district, but the reality is that depending on the transportation demand generated by the use, locating such uses anywhere in a zone, without considering the street network or the quality and type of transit service, disserves residents.

The method for measuring this is laid out in this paper, "Utrecht: 'ABC' Planning as a planning instrument in urban transport policy" and the method uses the following classification system:

A localities are places with excellent public transport and poor car accessibility. These localities are typically suitable for offices with a large number of employees and many visitors. The sites have to be within 600 m of a national or regional railway interchange or within 400 m of a high quality tram or bus stop; not more than 10 minutes ride from a national railway station and a good connection to park & ride facilities at the outskirts of the city has to be available. Within this category is a further distinction between AI and AII locations. An AI location has to have be directly adjacent to a railway station whereas an AII location does not.

B localities are places with a good public transport as well as good car accessibility. These locations are characteristically chosen for offices and institutions with a large number of employees which depend partly on car journeys for professional reasons. Such sites are within 400 m of a high quality tram or bus stop and no more than 5 minutes ride from a regional railway station. In addition, they have to be within 400 m of a main road connected to a national highway. BI, BII, and BIII locaities have to be defined according to needs of organisations in the area (e.g. parking facilities are attuned to encourage minimum use of cars).

C localities are places with poor public transport and excellent car accessibility. In particular, such sites are suitable for car-dependent companies like hauliers, couriers or other industries. These sites are within 1000 m of a direct connection to a national highway. C locations are normally situated in the outskirts of metropolitan areas.

4. I also proposed taking out the section on Tourism promotion from the Economic Development element, and instead making this its own separate, albeit linked, element in the Comp. Plan. These elements are under-addressed in the current system.

For example, last week I wrote about why it matters that the director of the DC Convention and Visitors Bureau (which is called DestinationDC) said that it was ok that Disney is building a hotel in Prince George's County, that the city needs to have an accommodations development plan, and yet, such a provision is listed in the Economic Development element. But it doesn't seem to be important. Therefore, let's separate out this entire section. and set up a development and management infrastructure for tourism that puts the city first and foremost in the context of the regional tourism environment.

Theoretical proposals

1. Creating what I call Leading elements. While the Framework element outlines the vision behind the Comprehensive Plan, technically all the elements are considered equal, and the Land Use element is first among equals.

But, because, as the introduction to the blog states:

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

instead I suggest that the Framework, Urban Design, Transportation, and Economic Development elements should be designated the guiding or leading elements of the Comprehensive Plan, because in toto the overall urban form (morphology) and context is more important than the land use specifically, that if we have the right urban design, transportation, and economic policies in place, they shape land use, rather than land use shaping those elements.

Land use does shape urban design currently, but not in ways that we should be happy about.

2. Alternatively, I proposed something different, the creation of a new framework for the Comprehensive Plan, designed to recognize the fact that the Comprehensive Land Use plan is the closest thing DC has to a vision-mission statement and a business plan, and to reorganize the plan accordingly along these lines:

- Leading Elements;
- Citywide Elements (the rest of the elements as currently in the plan, minus the newly designated leading elements);
- Public Finance, Capital Assets and Budget, and Agency Management Elements, to better link finance and capital improvements policies and funding to the Vision and Mission of the city, and to get agencies to begin to act as if they are part of a larger whole; and
- Area Elements (as exist currently, no change);
(Plus the Federal Elements which the National Capital Planning Commission is responsible for).

3. But separately I then had to write about the need to create these elements: Public Finance, Capital Assets and Budget, and Agency Management Elements.

4. And I also suggested that a new element on Civic Engagement be added to the City-wide elements, to better link the polity and its constituent parts: the citizens both as leaders and as the governed; elected officials; and the various agencies of the government.

I needed to write a big thought paper on that, but I didn't have the energy. I came across this paper though which you might find interesting, "Democracy and city life."


It will be very interesting to see how they react to these suggestions. Obviously the change in the theoretical construct of the Comp Plan isn't likely to happen as part of this amendment process.

But maybe the TDM and ABC and industrial land amendments will go through. And the rest of these ideas will sit out there and hopefully begin to shape people's thinking on these issues.

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Still, it's worth sitting down and reading all the many hundreds of pages of at least the Citywide Elements. It's written pretty well, even if there are tons of gaps and the sections of the plan and the sections of the elements are often not congruent and reciprocal. (As I say, all the elements should be consistent with the goals and vision, and each of the policies and actions of the elements should "cascade" from the goals.)

-- Volume 1: Acknowledgements, Introduction and Citywide Elements

But I can't say it isn't somewhat of a chore.