
Tag: dc comp plan
CSG Comments on DC Comp Plan Amendments
January 10, 2020
Director Andrew Trueblood
DC Office of Planning
1100 4th Street, SW, Suite 650 East
Washington, DC 20024
Via: plandc@dc.gov
RE: Coalition for Smarter Growth Comments on DC Comp Plan October 2019 Draft
ENCL: Detailed CSG comments on the Comprehensive Plan October 2019 draft
Dear Director Trueblood:
Please accept these comments on behalf of the Coalition for Smarter Growth, the leading organization in the Washington, DC region dedicated to making the case for smart growth. Our mission is to promote walkable, inclusive, and transit-oriented communities, and the land use and transportation policies and investments needed to make those communities flourish.
Summary statement: We wish to express our support for the Comprehensive Plan amendments, including the map amendments. We believe that these changes are a major step forward for the District, as it seeks to fulfill its new mandate from the Framework Element to build a more inclusive, equitable, and sustainable city.
We strongly support the housing goals to increase housing opportunities throughout the city and provide more affordable homes, especially in parts of the city where there are few today. We commend the refocusing of defensive language to “enhancing” and “respecting” neighborhoods while ensuring they help address our housing needs. We also support the continued focus on transit-oriented development. We recommend going further in rethinking the role of vehicle parking in our future as parking requirements are a government anachronism in a rapidly changing transportation and environmental context. We recommend eliminating government regulations for minimum parking requirements and focusing on improving multimodal access and transportation demand management.
A mix of housing types with access to better transit will build a stronger city and better neighborhoods for all. It is also a legal obligation under the Fair Housing Act to affirmatively further fair housing. We applaud the District’s specific production goals to create 36,000 homes, with 12,000 of them affordable by 2025, and we support the allocation of these production goals by planning area. We agree that this is a helpful approach to building a truly equitable city and directly addressing the need to undo a legacy of racial discrimination and segregation.
We support the Future Land Use Map (FLUM) changes in general. A highlight are FLUM changes for new housing capacity in Rock Creek West, the area with the smallest share of affordable housing, at just one percent today. The next two areas lagging in affordable housing opportunities are Capitol Hill and Near Northwest. We urge the District to designate more housing capacity in these areas to achieve the
minimum 15 percent affordable homes in each planning area. We value quality affordable homes to meet the needs of DC households in all planning areas, but we especially urge the city to use land use policy to help lagging areas catch up to their affordable housing production goals of 15 percent.
DC’s many compact, walkable, transit-served neighborhoods make it the most sustainable place to live in the region. We should make it easier for more people, of all incomes to live in the city, which offers lower transportation costs, and helps reduce regional vehicle miles traveled and greenhouse gas emissions. The Comprehensive Plan and the District’s increased housing production goals play a major role in facilitating our region’s increased sustainability and social equity. The District faces many challenges, but our most pressing need as we manage the benefits of rising prosperity is to ensure that our low-income residents, especially people of color, have access to safe and affordable housing and transportation, along with quality nearby schools and services. Therefore, we commend the District’s efforts to ensure equitable access to quality housing and neighborhoods across the city.
We have enclosed our detailed comments on the Comprehensive Plan and maps. These comments are supplemented by our joint statement with affordable housing groups submitted on December 16, 2019. In addition, we want to associate ourselves with the comments of Ward 3 Vision and the 21st Century School Fund.
Thank you for the good work of the Office of Planning and sister agencies in putting together this excellent draft. We look forward to supporting the quick adoption of the new plan.
Sincerely,
Cheryl Cort, Policy Director

Housing Priorities Coalition DC Comp Plan comments
December, 16, 2019: A coalition of affordable housing advocates and producers released comments today in support of the DC Comprehensive Plan draft amendments.

Support DC’s Comp Plan. Join Nov-Dec 2019 Meetings
Attend one of the DC Office of Planning meetings in your community to help ensure increased affordable housing is implemented
CSG in the News: Study: DC rent is 3rd highest in the country
Study: DC rent is 3rd highest in the country; Here’s how much income you need to afford it
WASHINGTON (ABC7) — The D.C. Council unanimously voted on the first step of the city’s Comprehensive Plan for development last week.
A spokesperson for Mayor Bowser’s office said she will likely unveil the remaining elements of the comprehensive plans as well as area housing targets and maps on October 15.
The comprehensive plan includes proposed solutions to the city’s affordable housing shortage – an issue that elected officials and advocates are coming together to try to fix.
The plan will go through review by the National Capital Planning Commission and Congress before it gets to the mayor’s desk for signing, the mayor’s spokesperson said….
Numbers from the National Low Income Housing Coalition estimate that over 50 percent of residents living in the D.C. metro area are renters.
According to NLIHC, the median family income for both renters and buyers is $121,000. This means families can afford to pay $3,000 a month for rent without being cost-burdened.
HUDs estimate of a fair market rent that recent movers paid for a modest two-bedroom apartment in D.C. was $1665, but 60 percent of rents are currently higher according to the NLIHC.
For those in the fortieth percentile, in order to afford $1665 without being “cost-burdened” an individual would have to earn $66,000 a year, or $5500 monthly, the NLIHC estimates.
Assuming a 40-hour workweek, 52 weeks per year, this level of income translates into $32.02 an hour. Working at the minimum wage of $14.00 an hour in D.C. each week an individual would have to work 90 hours weekly at two jobs to afford a modest apartment.
Cheryl Cort, policy director for Coalition for Smarter Growth, an organization dedicated to bettering the district believes lack of affordable housing is one of the greatest challenges D.C. faces.
“Housing insecurity worsens other conditions in a person’s life. Many DC residents face daunting challenges — lack of access to quality education and training, violent neighborhoods, poor health status, low wage jobs and unstable employment. Lack of access to stable, quality housing compounds all these problems, and is also one of the solutions to a number of these problems,” Cort said.
Cort said the CSG stands behind the mayor’s housing strategy. In May, the mayor signed an order directing District agencies to identify new policies, tools, and initiatives that would start moving toward the goal of creating 36,000 new housing units, 12,000 of them affordable, by 2025….
Regardless of how the numbers add up, whether you’re renting or buying, one thing is clear – officials and advocates think housing in D.C. is too expensive.“Bold action to address housing affordability requires the entire city’s input and energy,” Cort said.
View the full story by WJLA here.
CSG in the News: D.C. Council Approves Measure To Curb Wave Of Development Appeals Washington DC
The ongoing process to amend D.C.’s Comprehensive Plan received a key approval vote Tuesday after Council Chairman Phil Mendelson removed language that had caused concerns among planners and housing advocates.
CSG in the News: Phil Mendelson added important affordable housing language to the Comp Plan, but some are trying to undo it
Phil Mendelson added important affordable housing language to the Comp Plan, but some are trying to undo it
…On October 2, Chairman Phil Mendelson’s latest draft of the plan’s Framework Element added language similar to those principles, especially around building and preserving affordable housing and protecting tenants in affordable housing when their properties undergo redevelopment. The chairman’s draft also centers the importance of, as DC grows, building in racial and economic equity, a credit to interventions by Councilmember Kenyan McDuffie (Ward 5) and Councilmember Trayon White (Ward 8).
The final vote on the Framework bill is on Tuesday, October 8, and last week, some opponents emerged to fight this language. We’re pushing for it to remain….
The Comp Plan Framework now borrows much of this language
Chairman Phil Mendelson’s latest draft of the Framework has…a lot of what the Housing Priorities Coalition proposed! (The final version will be released on Monday.)
Notably, it reflects an amendment introduced by Councilmember Brianne Nadeau (Ward 1) at the bill’s first reading. Advocacy by many of affordable housing groups who were part of the original coalition, like, DC Fiscal Policy Center, Housing Association of Nonprofit Developers, Enterprise Community Partners, Coalition for Nonprofit Housing and Economic Development, and Coalition for Smarter Growth emphasized the necessity of this sort of language, so it’s a win that Mendelson added more beyond what he had included in the version voted on at first reading.
Not everyone is happy with the new community benefits language. Attorney David Goldblatt of Goldblatt Martin Pozen LLP, which does lobbying and real estate transactions for large companies, wrote a letter on behalf of the DC Building Industry Association (DCBIA) asking to water down this language. Goldblatt said the changes were in the interests of the DC Housing Authority, though his letter says he’s not speaking for DCHA, just DCBIA.
It’s worth repeating that this language is only about benefits given in exchange for zoning flexibility as part of a PUD, like more density. It doesn’t impose any kind of unfunded requirement on property owners. What it does is say is that in exchange for more affordable housing or anti-displacement measures, you can build taller or bigger in proportion.
Affordable housing is really necessary. It’s also expensive. With more floors or larger buildings, it can become economically feasible to offer one-for-one replacement, “build first,” and other features that the city’s residents deserve when their homes are redeveloped.
Not all developers are supportive of this concept, but a lot are. Many think it’s a great idea to build more affordable housing and avoid displacing anyone, as long as they can design a project which does so and actually works economically. Sure, if people could build higher and didn’t have to build affordable units, that would be even more profitable, but public policy can ensure we get affordable housing, while projects still “pencil out.”
Right now, DC’s acute limits on new buildings directly prevent developers from paying for more affordable housing to avoid displacement. Some people from the development community, at least, would like to be part of the solution, and the proposed rule would let them.
The proposed Framework language takes a big step toward achieving what the Housing Priorities Coalition recommended. It’s not everything, because this language just applies to PUD benefits. There will be other opportunities to enact these and the rest of the coalition’s 10 principles in the rest of the Comp Plan. The Office of Planning will release its amendments to the rest of the document October 15, along with housing targets and map changes.
Read the full post here.
RELEASE: Affordable Housing Groups Praise Council Chairman’s Comprehensive Plan Bill
Press Release
DC HOUSING PRIORITIES COALITION
CONTACT
Cheryl Cort, Coalition for Smarter Growth: 202-251-7516; cheryl@smartergrowth.net
Courtney Battle, HAND: 202-384-3764; cbattle@handhousing.org
Affordable Housing Groups Praise Council Chairman’s Comprehensive Plan Bill
Washington, D.C. – October 3, 2019 – Today a coalition of affordable housing stakeholders applaud critical revisions to the draft Comprehensive Plan released by DC Council Chairman Phil Mendelson. This transformative update incorporates three of the coalition’s priorities: ensuring the creation of affordable housing, preventing displacement, and addressing racial equity. The bill will get its final votes by the full Council next Tuesday, October 8.
“We are gratified that the Comprehensive Plan bill offers the guidance our city needs to make affordable housing and preventing displacement top priorities. The bill also provides clarity to the development approval process, clearing the way for increasing affordable housing and other public benefits, along with community input as part of the negotiated process,” said Cheryl Cort, Coalition for Smarter Growth, a member of the DC Housing Priorities Coalition.
The group pressed for the DC Council to amend its bill after the first vote on July 10, urging the body to adopt stronger language on how affordable housing would be prioritized in land use decisions. It appealed to zoning experts and the DC Office of Planning to work with the DC Council to ensure the development approval process (i.e. Planned Unit Developments), would achieve greater levels of housing affordability, tenant protections, and increased certainty. The group’s goal was to achieve more affordable housing and prevent displacement of existing residents, while reestablishing a more fruitful development review process.
“We talk about the Framework elements as a “bill of rights” for District residents and communities,” said Melissa Bondi, Mid-Atlantic State & Local Policy Director for Enterprise Community Partners. “It is important that the current language reflects our values, including prioritizing resident protections, emphasizing greater housing affordability, and evolving our approaches to achieve a truly inclusive, equitable city.”
“We thank Chairman Mendelson for amending the Comprehensive Plan bill to prioritize the creation of affordable housing and prevention of displacement, while also providing needed clarity to the development review process. We particularly appreciate that the administration, the Council, and advocates were able to find common ground to facilitate a more equitable development process for the District,” said Steve Glaude, President and CEO of the Coalition for Nonprofit Housing and Economic Development (CNHED).
“The revised language provided by Chairman Mendelson will accomplish the goals we set – to elevate affordable housing and racial equity, and fix the broken project review process, said Heather Raspberry, Executive Director of the Housing Association of Nonprofit Developers (HAND). “Creating and preserving more affordable housing throughout the District is the cornerstone to building an inclusive city where all of our neighbors have an opportunity to thrive. We appreciate the Chairman and Council’s thoughtful review of the Plan which will serve the city and surrounding region well.”
“Prioritizing affordable housing and the prevention of displacement in the Comprehensive Plan are two necessary steps our city must take in charting a path toward a more equitable future,” said Adam Kent, Senior Program Officer at the Local Initiatives Support Corporation (LISC). “We look forward to working with the DC Council on the remaining elements of the Comprehensive Plan to ensure these priorities are maintained throughout.”
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DC Housing Priorities Coalition
Who We Are
The DC Housing Priorities Coalition includes: Enterprise Community Partners, DC Fiscal Policy Institute, Coalition for Nonprofit Housing and Economic Development (CNHED), Somerset Development Company, Coalition for Smarter Growth, Greater Greater Washington, United Planning Organization (UPO), Local Initiatives Support Corporation (LISC) and the Housing Association of Nonprofit Developers (HAND).
Why We Formed
The Housing Priorities Coalition formed three years ago to help update the DC Comprehensive Plan, the land use policy that guides development decisions in the District. (Learn more from DC Office of Planning on the DC Comprehensive Plan amendment process here). See the full Housing Priorities Coalition amendment package here. The Housing Priorities Coalition’s guiding principles for amending the DC Comprehensive Plan are:
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- Meet the housing demand
- Equitably distribute housing
- Best utilize areas near transit
- Include families: ensure homes for people of all income levels and of all household sizes, including families.
- Prioritize affordable housing as a community benefit
- Preserve existing affordable housing
- Protect tenants
- Support neighborhood commercial corridors
- Clarify zoning authority
- Improve data collection and transparency
Why These Priorities:
Lack of affordable housing and risk of displacement are among the greatest challenges DC faces to achieving racial equity, quality of life for residents, and economic sustainability for all.
Low-income District residents, particularly residents of color, do not currently enjoy equal access to affordable housing connected to communities of opportunity, perpetuating a gaping racial equity gap.
The Planned Unit Development (PUD) process, which is an important way to produce new housing with substantial affordability, is now held up in constant court challenges resulting in thousands of stalled homes, including hundreds of affordable homes. Court challenges and rulings have relied heavily on narrow interpretations of the Comp Plan, so the proposed amendments help to clarify how the Zoning Commission should judge and prioritize PUDs. Such clarification is critical, because even the risk of lawsuits has dramatically reduced the use of PUDs for affordable and market-rate housing (ex: Park Morton public housing blocked due to Bruce Monroe PUD lawsuit). View the list of stalled projects published by Washington Business Journal here.
CSG in the News: D.C. Council advances key comp plan changes in bid to ease activists’ concerns
Final changes to the first section of the D.C. comprehensive plan are taking shape, and it seems District lawmakers have acquiesced to the demands of activists and some city leaders who worried a previous draft was seriously flawed.
D.C. Council Chairman Phil Mendelson is circulating a draft of amendments to the plan’s “framework element.” Crucially, Mendelson and his staffers have rewritten a section of the bill that a coalition of housing advocates and developers feared would open the door to a flood of new legal challenges to large new developments.
The chairman had hoped to pass this legislation by now, as changes to this section of the comp plan are broadly seen by the development community as being essential to beating back future lawsuits seeking to hold up planned-unit developments. But he chose to delay consideration while this debate over the language played out.
With issue seemingly resolved, it should set the table for the council to, at last, finalize the amendments to the framework element by Oct. 8.
“We think the language in the revised bill addresses our concerns about fixing the broken PUD process and elevating affordable housing,” said Cheryl Cort, policy director for the Coalition for Smarter Growth and a lead organizer of a campaign to raise awareness about potential problems with the old language. “The chairman really listened carefully and considered all the issues here.”
Cort and many of her colleagues in the housing advocacy world worried that changes to one section of the framework could “generate a tremendous amount of uncertainty in the PUD approval process or would open up PUD approvals to litigation in a brand new way.” A member of the D.C. Zoning Commission voiced similar concerns, as did Planning Director Andrew Trueblood.
View the full story in the Washington Business Journal here.