Amendments to the Comprehensive Plan

I have been regularly engaged in this process since last year’s hearing on the Framework Bill, and have drafted my own recommended changes to what the Office of Planning presented to the Council. Those recommendations are below. I’m pleased to see that much of this language made it into the Chairman’s draft in some form, which pushes the District towards a more inclusive and equitable model of growth. However, I am concerned that the current draft significantly scales back on the tools by which we would be able to do important things like building a significant amount of affordable housing and reducing segregation so that the effects of growth don’t only flow to the neighborhoods where residents are most at risk of displacement. Below is a summary of some of the more significant changes I have been pushing for, and will continue to push for, as the Framework Element moves through the Council’s legislative process. We need to acknowledge that our affordable housing crisis is just that – a crisis – and not be willing to accept incremental changes or even the status quo in our most important citywide document.


You can find Chairman Mendelson’s committee draft here.


My Priorities

  • Incorporating all recommendations from OP’s August 24th, 2018 memo
  • Specific, enforceable language on primary displacement
  • Clarifying housing affordability as the highest-priority community benefit
  • Emphasizing the reversal of residential segregation and to advocate for Affirmatively Furthering Fair Housing
    • The Council has the authority to amend the guiding principles, despite OP categorically excluding any such changes from their amendment process. I recommend doing so, particularly in order to remove exclusionary language and encourage the reduction of segregation.
  • Clarifying the original purpose of the Future Land Use Map to continue to allow for community-negotiated development, and the prioritization of affordable housing on city-owned properties.
  • Allow for the creation of more missing-middle housing (e.g. duplexes, triplexes, smaller multifamily buildings) and by-right affordable projects
  • Incorporating the District’s already-set sustainability and transportation mode share targets


Summary of Significant Changes

The changes below are in addition to the inclusion of new passages and sections from the August 24th OP memo, which are not included below.


Page of Redline Document

Addition or Change



Recent migration patterns of those leaving the District suggest conditions cause the city to lose certain types of households. While those moving to DC tended be young adult white individuals either with or seeking higher education, those moving out tended to be parents and their children, older adults, and blacks. The single largest destination for those leaving the city was Prince Georges County and the next was Montgomery County, Maryland. Even with the higher rates of out migration of parents with children, older adults, and blacks; the population of all three groups in the District is one again growing in the District. However, this overall trend may mask much more significant demographic changes happening on a neighborhood level, as these populations are pushed out of some areas of the District without much opportunity of returning.

While it is important to highlight that black, elderly, and child populations are on the rise, this falls into a kind of ecological fallacy: just because those populations are increasing doesn’t mean that it’s the same people returning; additionally, this ignores sizable demographic shifts on a neighborhood or ward level, particularly in areas historically and culturally important to the District’s (and the country’s) Black heritage.



Some estimates suggest that between 2011 and 2016 the cost of purchasing a home rose by almost 50 percent, while the cost of renting rose 18 percent. The absolute number of low-cost market-rate rental units (less than $800 a month) declined by nearly half between 2002 and 2013, while rental housing at higher costs has steadily increased. Units with rents of $1000 or less made up 59 percent of the total rental stock in 2002; in 2013 those units comprised 34 percent of the total stock.  Housing costs are perhaps the central challenge toward maintaining and growing an inclusive city.

Important to quantify the problem and frame the issue as a total decline in affordable units, to focus efforts on both preservation and production of affordability.



Fitting such development into the fabric of a mature city creates a number of challenges. One is primary displacement, which occurs through multiple levers: rent or property tax increases, evictions, redevelopments, and buy-outs among them. The a threat of eviction that has become more real in the District as land values have increased due to rising demand that has not been met with a proportional increase in supply.

Including a more fully operationalized definition of primary displacement.


The District’s Sustainable DC goals have set targets to reduce the share of commuter trips made by car to 25 percent by 2032, while increasing transit mode share to 50 percent and walking and cycling to 25 percent. To further these goals, additional investments will have to be made in high-capacity transit improvements like dedicated bus lanes and light rail, as well as an expanded network of low-stress bicycle and pedestrian infrastructure. These changes may need to be made by reallocating road and curb space.

Acknowledging the goals already set by the District and crafting language on transportation that is more forward-looking and proactive, while acknowledging the reality of what it will take to meet our mode share goals.



Redevelopment and infill opportunities along corridors and near transit stations will be an important component of reinvigorating and enhancing our neighborhoods. Development on such sites must not compromise the integrity of stable neighborhoods and must be designed to respect the broader community context. Because low-income households are often more transit-dependent, such development should account for the affordability and amenity needs of low-income households.  Adequate infrastructure capacity should be ensured as growth occurs.

Incorporating a suggested amendment that was rejected by OP (Tracking number 1084)


44 The recent housing boom has triggered a crisis of affordability in the city, creating a hardship for many district residents and changing the character of neighborhoods. The preservation of existing affordable housing and the production of new affordable housing are essential to avoid a deepening of racial and economic divides in the city, and must occur city-wide to achieve fair housing objectives. Affordable renter-and owner-occupied housing production and preservation is central to the idea of growing more inclusively. In the pursuit of that inclusive growth, public housing, community land trusts, limited-equity cooperatives, and other non-market-based strategies shall be considered as important tools.  Identifying the importance of tools that proactively work against housing speculation. 


The residential character of neighborhoods must be protected, maintained and improved. Many District neighborhoods possess social, economic, historic, and physical qualities that make them unique and desirable places in which to live. These qualities can lead to development and redevelopment pressures that threaten As the District continues to grow, more residents and those of more varied socio-economic backgrounds should be accommodated in these amenity-rich neighborhoods while enhancing the very qualities that make the those neighborhoods attractive. These pressures must be controlled through zoning and other means to ensure that neighborhood character is preserved and enhanced. The zoning code and zoning designations shall be crafted to maintain compliance with the Fair Housing Act and Affirmatively Further Fair Housing, and to require that all areas and zones designated for residential use permit more than one non-accessory dwelling unit on an individual lot. Residential neighborhoods should be planned and crafted to fully satisfy the District’s housing needs, including the allowance of more varied residential building typologies, the reduction of segregation, and the production and preservation of affordable housing at all income levels in all areas of the District.

This amendment reorients the first guiding principle under “Creating Successful Neighborhoods.” The existing language perpetuates patterns of neighborhood exclusion and does not allow for the District to meet its housing needs. It also would leave the District behind many other cities that are scaling back or eliminating exclusive single-family zoning and allowing for a more inclusive variety of unit types within a neighborhood’s context.



Each neighborhood is an integral part of a diverse larger community that contributes to the District’s identity. Growing an inclusive city means that all neighborhoods should share in the overall social responsibilities of the community, including accommodating the overall growth in new residents, housing the homeless, feeding the hungry, and accommodating the disabled.

Without language encouraging more equitable growth across the District, pressures of new development will continue to travel the path of least resistance and disproportionately affect lower-income neighborhoods.



Transportation facilities, including streets, bridges, transit, sidewalks, and paths, provide access to land and they provide mobility for residents and others. Investments in the transportation network should be equitably distributed across the District, should prioritize sustainable transportation such as walking, bicycling, and public transit, and should emphasize safety and access over motor vehicle speed. must be balanced to serve local access needs for pedestrians, bicyclists, transit users, autos and delivery trucks as well as the needs of residents and others to move around and through the city.

Incorporating a suggested amendment that was rejected by OP (Tracking Number 2119)


Neighborhood Conservation Areas

Neighborhood Conservation areas have very little vacant or underutilized land. Some new development and reuse opportunities are anticipated. New development and localized land use changes are predicted to occur in Neighborhood Conservation areas when not inconsistent with the Future Land Use Map (FLUM), or when identified as part of an approved small area plan and are in furtherance of the policies of the citywide or area elements. Conservation of neighborhood character can be achieved in conjunction with or through new development. In Neighborhood Conservation Areas that are designated Low Density Residential on the FLUM, maintenance of existing land uses and community character is anticipated over the next 20 years and where change occurs, it will typically be modest in scale and will consist primarily of public facilities, institutional uses, and an increase in housing density through scattered site infill housing and through the addition of Accessory Dwelling Units.



Allows for neighborhoods in amenity-rich areas of the District to accommodate new residents and not remain static in time, while maintaining aesthetic and community characteristics.



The guiding philosophy in Neighborhood Conservation Areas is to encourage the conservation and enhancement of existing neighborhood character but not to preclude new development, redevelopment, or alteration.

Strategies for managing growth in Neighborhood Conservation Areas may be very different based on an area’s history and current socio-economic makeup. In high-income, high-opportunity neighborhoods, steps should be taken to allow for context-sensitive increases in residential density and the reversal of historic patterns of segregation by race and income by accommodating more varied residential unit types and more levels of housing affordability. 


In other parts of the District designated as Neighborhood Conservation Areas, existing residents may be more at risk of housing cost increases and displacement as described in sections 203.4 and 203.21. In these neighborhoods, other policies may be needed to mitigate threats to lower income households.

Altering and incorporating a suggested amendment that was rejected (Tracking number 1326).


Context-sensitive growth in more exclusive and higher-income neighborhoods is essential to mitigating adverse impacts of development on lower-income communities and reversing the legacy of segregation.


In light of the acute need to preserve and build affordable housing described in Section 205a, the production of new affordable housing units above and beyond existing legal requirements and the prevention of displacement of on-site residents should be considered as highest-priority public benefits in the evaluation of residential PUDs.


While providing for greater flexibility in planning and design than may be possible under matter of right zoning procedures, the PUD process shall not be used to circumvent the intent and purposes of the Zoning Regulations, nor to result in action that is inconsistent with the Comprehensive Plan. In cases where redevelopment occurs on properties with housing made affordable through subsidy, covenant, or rent control, such units should be preserved or replaced with similar sized units either on-site or nearby. The necessary density may be provided to: enable reinvestment in the property with no net loss of affordable units or affordability levels; when feasible, facilitate a net increase in affordable units on-site or nearby; and minimize unnecessary off-site relocation by enabling construction of new units before demolition of existing occupied ones.

Set out clear guidance to prioritize affordable housing in Planned Unit Developments and gives the Zoning Commission clearer authority when dealing with cases of primary displacement.



(NEW) 227.9 In addition to the prioritization of affordable housing and a PUD benefit as described in 227.6, the Zoning Commission should establish a new mater-of-right process that permits the full PUD density bonus of a zone be given to a building that meaningfully and substantially exceeds Inclusionary Zoning requirements.

This would establish a new means by which a building could achieve a density bonus – essentially an optional “Extra IZ.” This would allow for a density bonus within a zone similar to PUD density but stops short of the rezoning and additional flexibility PUDs allow for.


This would lower the barriers to projects that deliver a significant amount of affordable housing (though the exactly amount would be established by the Zoning Commission).


The Utility Disconnection Protection Act of 202 would apply protections from May 15 through September 15, and from November 1 through February 29, an expansion of the current temperature-based protections required by law.
"When we create an exemption here, we open the door to an exemption there and another one and another one. This exemption from TOPA is a line that, once crossed, cannot be undone."

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