Why People Are Arguing Over D.C.'s Comprehensive Plan Again Officials have spent four years gathering public feedback on the Comp Plan. But what is it, and why is it back in the news again?
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Why People Are Arguing Over D.C.'s Comprehensive Plan Again

The crown jewel of D.C.'s Comprehensive Plan is the Future Land Use Map, which Mayor Bowser's administration wants to revise to make room for more housing, among other changes. Courtesy of/D.C. Office of Planning hide caption

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Courtesy of/D.C. Office of Planning

In March 2018, around 300 D.C. activists, urbanists, affordable housing advocates, developers and concerned citizens crowded into a Wilson Building hearing room to testify on a document that many residents have never even heard of: D.C.'s Comprehensive Plan.

The Comprehensive Plan — no relation (that we know of) to a local conspiracy theory known as The Plan — is a roadmap to the city's future development. Required by D.C.'s Home Rule Act, it establishes the parameters for what growth and change should look like across a variety of sectors, including transportation, historic preservation, and environmental protection.

Importantly, it also informs decisions about how much housing developers can build and where they can build it. While the plan offers strategic guidance about how to approach growth, it does not change existing zoning or height laws that constrict development, and the document itself doesn't carry the same weight as legislation.

City officials are supposed to overhaul the plan every 20 years, but Mayor Muriel Bowser's administration maintains that its current iteration needs a medium-term update since the document, which was written in 2006 and amended in 2011, doesn't reflect recent and changing demands on infrastructure and housing supply. Consequently, D.C.'s Office of Planning has spent the last four years updating the tome with extensive feedback from residents, and has baked in proposed updates that support Bowser's goal of building 36,000 new units of housing in D.C. by 2025.

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After that big hearing in 2018, the D.C. Council approved updates to the plan's "Framework Element" — an overall statement of priorities that guides the rest of the plan — the following year. Bowser's administration submitted further changes in April to the Council, with the hope that Chairman Phil Mendelson would schedule a vote on them this year.

But despite years of deliberations, it doesn't look like those proposed updates to the Comp Plan will see a vote this year. Debate over proposed amendments to the plan's remaining 24 chapters continued to rage last week over two days of hearings in the Council, and Mendelson says lawmakers need more time to review the plan's 1,500 pages, pushing the vote to February. (The public can submit comments on the latest amendments until Dec. 3.)

While residents, developers and officials await legislative action on the remainder of the plan, here's a primer on the document and why it's attracted controversy.

Why does the Comprehensive Plan matter?

Land use decisions in the District must conform to the Comprehensive Plan or they're vulnerable to challenges in court. This is a big reason the current plan has become a thorn in the side of the Bowser administration, real-estate interests, and those who want more housing and transit-adjacent development in the city.

For years, activists and residents who oppose various development projects have seized upon language in the plan to challenge those projects in the Court of Appeals. (Does the term "McMillan Sand Filtration Site" ring a bell?) Right now, the construction of roughly 1,000 housing units is on hold while the Zoning Commission awaits a Council decision on the Comprehensive Plan, much to the chagrin of some developers. The document also helps guide things like the city's capital improvements budget and how D.C. adapts to climate change, and having an updated plan in hand would help speed those decisions along.

What do the new amendments propose?

The Office of Planning focused its amendments on five categories: COVID-19, housing, equity, resilience, and public resources. The housing piece is especially important, because proposed language in the plan and its all-important Future Land Use Map support the mayor's goal to produce 36,000 additional housing units by 2025, with a third of them affordable to low- and moderate-income residents. The document's "Housing Element" now contains more explicit references to promoting housing affordability, which can be used to inform future zoning decisions.

The revisions also eliminate rigid language that can be used against development projects in court, like mandates that developments "must" or "shall" include certain features. They also scrub phrases such as "protect neighborhood character," wording often deployed by residents seeking to block new construction in their neighborhoods that can be a dog whistle for perpetuating racial and economic segregation. Overall, the changes proposed by the Office of Planning generally flow from the Framework Element, which the Council approved in 2019.

What's controversial about the city's proposed Comprehensive Plan amendments?

Progressive activists, preservationists, and development skeptics are chiefly concerned about the extent to which the amended plan could open up the city to more high-rise, luxury-priced housing. The approved Framework Element revision already dealt a blow to residents who use the document to mount legal challenges against development projects. Now, proposed changes to the Future Land Use Map would incentivize more housing density, providing 15% more housing capacity around transit stations, the Coalition for Smarter Growth estimates. That's one reason many residents are concerned about the plan allowing unwanted density and congestion.

Some progressive activists also worry the updated plan could usher in even more gentrification. The plan "does not do enough to address displacement [and] low-income housing, nor to promote community-led equitable development," Empower D.C. Executive Director Parisa Norouzi testified last week, echoing similar statements made by fellow affiliates of the D.C. Grassroots Planning Coalition, a vocal critic of the city's proposed plan updates. Norouzi said the plan lacks an "enforceable policy" to build housing for the District's most vulnerable residents and stop displacement of Black Washingtonians, in particular.

The D.C. Grassroots Planning Coalition has also drawn attention to the plan's focus on population growth, which they believe the city is overestimating to justify more housing development. D.C.'s population growth has actually slowed down in recent years, and some predict it will slow even more in the wake of the pandemic, raising questions about whether the plan needs to make room for thousands more housing units. "The Council should assess whether, in a post-coronavirus world, net out-migration is a real possibility," says a Washington Post op-ed by Kirby Vining, a leading opponent of the Bowser administration's Comprehensive Plan priorities.

But Andrew Trueblood, Director of the Office of Planning, says concerns like this reflect a misunderstanding of what the Comprehensive Plan does.

"The plan is not a document that prescribes growth. It talks about how we grow. When we grow is not really controlled by us," he says. "There are things we can do to slow growth or speed it up on the margins, but [the timing of growth] depends not only on who's moving in, but how many babies are being born. There are a whole host of factors that the Comp Plan does not really deal with. It's really meant to be a framework that allows us to grapple with whatever may happen."

How could COVID-19 affect updates to the Comprehensive Plan?

Right now, it appears that the pandemic won't derail the revisions in any significant way. When the Office of Planning delivered its latest amendments to the Council in April, Trueblood wrote that they stand up "to many of the changes we are experiencing" during the pandemic and "will continue to serve as a critical guide for responding and recovering from this dual public health and economic crisis." Only time will tell if he's correct.

What happens next?

While the Bowser administration and various stakeholders really want the Council to pass all the latest amendments this year, D.C. Council Chairman Phil Mendelson has been firm that lawmakers won't get around to voting until early 2021. So, the public waits.

But longer term, expect even more updates, more hearings, more outreach and more debate — because believe it or not, this latest round of changes isn't even considered a full rewrite of the Comprehensive Plan. A proper rewrite is expected to happen in 2026, at which point it will fall to either a third-term Bowser administration or a new administration entirely to decide what the Comprehensive Plan should look like for the following 20 years. Buckle up!

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