DC Comprehensive Land Use Plan revision
There is an op-ed, "D.C.’s growth is tied to the amended Comprehensive Plan," in the Washington Post by the director of the Downtown DC BID, who was at one time the city's Deputy Mayor for Planning and Development under Adrian Fenty, that the city needs to approve a new comp plan because the city needs to be able to address defects in the existing planning process.
From the article:
It would be in the best interests of D.C. residents and businesses for the D.C. Council to approve the amended Comprehensive Plan — and soon.
The Comprehensive Plan amendments will help D.C. grow equitably and inclusively. The amended plan will allow for greater density, which will lead to additional affordable housing through planned unit developments or expanded inclusionary zoning for map amendments. The Comprehensive Plan amendments will also help grow tax revenue to fund the District’s progressive social agenda, including preventing evictions and building affordable housing, without the need to raise tax rates (which would make D.C. less competitive with Northern Virginia and suburban Maryland).
It happens that while I agree with that point, at the same time, I think the current Comprehensive Plan revision process is completely flawed, because the Comp Plan was on a revision cycle, which mostly involves online solicitation of recommended changes, and then at the end of the process, they submitted major revisions to the City Council, called it a new version of the plan, without having had a robust public planning process--although there were some planning meetings but only for a couple hours--which was opposite of how the 2005-2006 process for the current Comprehensive Plan was handled, which started out with "vision papers" and had hundreds of meetings and opportunities for community review and input.
Albert's opinion piece does not acknowledge this, stating:
The amendment process has been extremely open, inclusive and transparent. No new issues were raised during the D.C. Council’s recent extensive hearings that warrant either substantive amendments or delaying approval.
although in part he is referring to calls to delay the revision because of the pandemic, which he argues isn't particularly relevant and again, I happen to agree with that narrow point.
City Council had some really long hearings and argued that sufficed for public input.
But I always thought it was grossly inadequate and was more about bulldozing through changes, even though necessary.
Key problems with the DC planning process are longstanding and I have written many times about them.
1. Legally, plans are advisory documents. First, the basic problem with any "plan" is that legally it is "precatory" law, meaning it reads as "should" not "shall." It's just guidance.
As a result it means that people can read the same sections and have vastly different interpretations of what it means, either pro-development or anti-development.
2. Local jurisdictions have multiple goals to achieve, residents only care about their neighborhood. Second, I have always argued that planning is set up to fail from the outset, because planners have to accomplish two sets of goals, around both city/county needs (more residents, more revenue, economic development) while residents/citizens tend to only be concerned about their neighborhood, and warding off change.
The thing is that city planners tend to inadequately lay out that there are two sets of goals, and work towards a common understanding of how to accomplish that.
3. After the comp plan was approved, there needed to be a massive public engagement process to create consensus about the meaning of the plan and the needs of the city and the residents. Third, so the biggest point I made after the approval of the Comp Plan was rather than jump into a zoning rewrite process (which took about 10 years!!!!) instead there should have been a two year "road show" where city officials, residents, and other stakeholders could have developed a consensus about what the plan meant, why growth was important, developing a better way to accomplish city-wide and neighborhood goals simultaneously, understanding the costs and revenues of different types of development, creating a public capital budgeting process, etc.
NOT DOING THIS is the primary reason why there is all kinds of opposition to development, a belief that real estate developers are the only beneficiaries from development, and there are many lawsuits against projects, "bad" court rulings--because the plan is precatory it has contradictory sections promoting growth and stasis simultaneously, and inadequately defining what density is--what people think is very dense in DC is not particularly dense at all, etc.
4. Plans inadequately communicate where change is targeted, and that residential areas are mostly left unchanged. Fourth, I think the planning approach is flawed, because it doesn't define proposed change in a way that residents can understand.
I suggested that the city use the framework laid out in the Nashville Community Character Manual (""Right size" development protest sign, Takoma Metro," 2014), where they define three intents for all planning guidance: preserve; enhance; and/or create.
Preserve and enhance is to improve existing areas with little fundamental change or new development. Create adds new development.
Nashville uses the New Urbanism transect approach, but modify it slightly, by recognizing different land use types (i.e., commercial districts, commercial corridors, and open spaces) within each transect zone, which is not how the New Urbanists do it.
In DC, single family districts in the outer city are T4, rowhouse districts are T5, and the downtown core is T6. The transect ends at T6, but I think it could go to T7 or T8, to account for center cities that are even denser.
The NCCM approach understands differences in density within zones for different types of uses (single family versus multifamily, commercial buildings, etc.).
Right sizing density by land uses.is is important because the reality is that in a mostly developed place like DC, residentially zoned land from a planning perspective is set up to mostly "preserve" and "enhance" while new development --"create" -- targets commercial and institutional lands, and transit station zones.
However, because Nashville and Davidson County don't have the same array of transit assets as DC such as heavy rail, streetcar, and passenger railroad services, the categories for land use elements laid out in their planning document aren't fully applicable.
Transit districts should allow for higher density too, especially out a few blocks. By contrast, in the neighborhood row over development of the Takoma Metrorail Station, some people argue that the height of the 1.5 story bungalows across the street should set the scale for the height of development around the transit station.
-- "Takoma's Brookland moment: some opposition to apartment development on the WMATA station site," 2013
-- "The Takoma Metro Development Proposal and its illustration of gaps in planning and participation processes," 2014
-- "Design of the apartment building at the Takoma Metro: offering better design cues," 2014
It turns out the Office of Planning considered my recommendation about adopting the NCCM approach, but rejected it, saying that it was too big a leap from how things were already done.
Instead, they said that each neighborhood if they had the means and social capital to do so, could create their own zoning sub-category, which was ridiculous.
5. Other planning inadequacies. Other problems in DC's planning regime include the following, but this lack wouldn't have been addressed by a road show, although these are items for which a consensus for the need to change remains. These are off the top of my head, not a comprehensive list.
(a) a failure to have a public capital improvements planning process, which means DC wastes tons of money on overbuilding and unnecessary projects ("Another example of the need for more formal and open capital budgeting planning practices (in DC)");
(b) lack of a more innovative approach to large or complex projects, where different parties should address projects simultaneously instead of sequentially;
(c) a failure to prioritize sustainable mobility (despite the talk), or at least the acknowledgement of the need to extend Metrorail service within the city ("If DC had visionary elected officials and planners it could use the new WMATA "BOS" study to push through the development of a separated Silver Line in DC (and Northern Virginia)")
(d) lack of visionary approaches ("Why can't the "Bilbao Effect" be reproduced? | Bilbao as an example of Transformational Projects Action Planning,")
(e) a failure to think more broadly about the role of elementary schools as building blocks of successful neighborhoods ("The bilingual Key Elementary School in Arlington County as another example of the "upsidedownness" of community planning")
(f) equity planning -- they have an initiative for it, but I am not particularly impressed ("Equity planning: an update")
(g) failure to develop consensus social and development policies at the neighborhood scale ("Community benefits agreements" and "1% for arts: what about 1% for community?: An idea")
Conclusion. Not having a consensus about what the plan means, nor a consensus about why new development is important and how existing residents do benefit in significant ways, and coming up with better ways to mitigate potential negatives means that land use matters are always contentious.
Rather than build conflict into processes, why not work conflict out of processes, by developing, if not a consensus approach, at least a more informed and educated approach to urban planning with a forthright discussion about conflicts, constraints, and compromises?