Comprehensive Plan Written Testimony

The last few months have been a true laboratory of civic participation as groups, activists and individuals shared their ideas about the pending update to the city’s Comprehensive Plan for future development.  While it is no secret that I oppose our local civic association’s position on the Comp Plan, it has been exciting to engage in civil debate and test ideas against neighbors and people from around town.

Below, I have posted my own written testimony to the Council regarding the Comprehensive Plan and Shepherd Park Citizens Association President Mark Pattison’s submission.  The D.C. Council is still a long way from the finish line on this important issue and they will need guidance from all points of view to make this Plan the best that it can be.

You can find many videos that I curated from the live testimony in this previous post.

April 2, 2018

Council of the District of Columbia
1350 Pennsylvania Avenue, NW
Washington, DC 20004

Honorable D.C. Councilmembers:

I am a resident of the Shepherd Park neighborhood of Ward 4 and I am in favor of the Office of Planning’s 2018 update to the city’s Comprehensive Plan. Though there is certainly room for improvement, the changes presented in the Framework Element so far are vital to protecting the
city’s goal of maintaining inclusiveness and diversity throughout our city.

The members of the Council and their staffs are to be commended for enduring more than 13 hours of public testimony and reading through reams of written testimony. This surge in civic participation illustrates how important the matter that lies before Council truly is. The decision you
make here on the Comprehensive Plan will shape our city for years to come. Here are my comments and suggestions:


After decades of decline and stagnation, American cities are back in demand. Changes initiated by previous administrations have made Washington, DC one of the most popular destinations in the country for a vibrant and growing population.

Unfortunately, our housing stock hasn’t kept up with the pace. Every student of economics knows that sharply increasing the demand for a good or service while only moderately increasing the supply will cause the price of that item to increase. We see that here in D.C. with the skyrocketing
cost of residential real estate and apartment rental prices.

Contrary to the calls from housing activists opposed to the Comprehensive Plan updates, slowing down or stopping the pace of home building in the city will only cause the cost of living to go up MORE and force additional and unnecessary displacement on our longtime residents.

The Council should do all that it can to encourage the private sector to build more housing units in the city, and especially units with three or more bedrooms to accommodate families. In addition, the final Comprehensive Plan update should include provisions to generate more housing that is affordable to residents living at 80%, 50% and 30% of the Area Median Income AND distribute that housing equitably across all eight wards of the city. Our major transit corridors, including Wisconsin, Connecticut and Georgia Avenues, have enough capacity to house many more current
and future D.C. families.


We may never know why the D.C. Court of Appeals decided to get into the business of interpreting land use maps. Nevertheless, it has, while at the same time ignoring the entire purpose of Planned Unit Developments (PUD), which is to offer bonus development density to developers in exchange
for negotiated community benefits.

Many changes in the Comprehensive Plan’s Framework Element are clearly an attempt by the Office of Planning to simplify and streamline city regulations so that the Court will not substitute its own judgement over that of the locally- and Federally-appointed Zoning Commission. This is a
crucial point because, as of now, the PUD process in the District is DEAD.

Aggressive lawyers and community groups have skipped over the negotiation process and have proceeded to sue over a dozen separate projects to a halt. As Councilmember Anita Bonds and Chairman Graham learned during the live testimony, leaders of some of these groups extract large financial settlements from developers in exchange for dropping these lawsuits yet refuse to disclose what they do with the funds or even how many settlements they have received. Worst of all, many developers have simply abandoned the PUD process altogether and have resorted to building projects “by-right” where the community has little say over the ultimate outcome.

Thousands of units of housing rest in the balance until the Council clarifies its vision for our city’s future. The Council must provide guidance to the Zoning Commission and the Court on how we want our city to grow.


During the live testimony, Councilmembers Robert White, Brianne Nadeau and Elissa Silverman engaged in a sincere and fascinating debate with several witnesses over how to weigh the competing priorities of  “maintaining neighborhood character” and building additional affordable housing.  While several smart-growth oriented witnesses were quick to choose affordable housing as a higher priority, opponents of the Comp Plan update were much more hesitant and suggested that neighborhood character should take precedence.

Both sides of the debate acknowledge the need to preserve and create additional affordable housing, but opponents of the Plan are generally silent on how to do so or where to put it.  The fact of the matter is that many of our Northwest D.C. neighborhoods have good schools, retail and access to job centers, but relatively little affordable housing when compared to areas east of the Anacostia River.   An equitable housing policy cannot continue to concentrate all of the city’s affordable housing in one area while wealthier neighborhoods “preserve their character” and accrue all of the benefits of our city’s renaissance.

A wise housing plan would clarify and streamline the Planned Unit Development process so that neighborhoods like mine can attract more market rate and affordable housing units in vacant or underutilized mixed-used areas.  If the Council will provide a clear and predictable roadmap, the marketplace will certainly respond to the opportunity.


Christopher Alexander

SPCA testimony to the D.C. Council on the Comprehensive Plan

April 2, 2018

To the members of the D.C. Council:

For the record, the Shepherd Park Citizens Association opposes B22-663. Still, a great debt of thanks is due to you for slogging through not only the proposed Framework Element of the Comprehensive Plan, but through the half-day-plus hearing to listen to District residents’ concerns about it. It was likely because the Office of Planning had wiped away the 60-day comment period once the Framework Element had been revised — rather than amended — that you had to endure listening to comments that could far more easily could have expressed in emails.

Since we can’t go back in time, though, we have to deal with the Framework Element as it has been presented. The Shepherd Park Citizens Association, of which I am president, has grave reservations about the proposed Framework Element. Here is, believe it or not, a short list — and I’m sure you heard these concerns repeatedly over the course of the March 20-21 hearing:

Intentionally imprecise language. The word “shall” is conspicuously missing, replaced by “should.” (“Should” is to “shall” what “someday” is to “when are you going to pay me back?”) Definitions are missing from the Framework Element, replaced by descriptions. Other double-speak terms to be found include “soft-edged” and “not intended to be strictly followed.” This removes the predictability that has historically been expected of the Comprehensive Plan and how it may be amended or altered. It also severely weakens future legal challenges to questionable decisions by the Zoning Commission since it would be next to impossible for a court to determine that a decision is, to use another double-speak phrase, “consistent with the Comprehensive Plan on balance.”

Displacement. The Office of Planning’s inappropriate use of revisionist history explains the decline in D.C.’s black population, as follows: “Many blacks left the city for the suburbs, or migrated to other parts of the country because of family ties, increased opportunities and lower cost of living.” The new proposed language in the Framework Element of the Comprehensive Plan denies the most damaging impact of development: displacement of longtime black residents. Between 1980 and 2000, the city’s black population declined by nearly 100,000; the hemorrhaging continued during the next decade, when nearly 40,000 more black residents left the city. While the reasons for this are many and varied, we know that thousands of lower-income residents did not leave of their own volition, but were pushed out by gentrification. Studies on this are well known and easily accessible. As residents in one of the first historic communities that intentionally and peacefully integrated, we of the SPCA believe this language should be corrected to accurately reflect the drastic change in our city’s demographics, and concrete steps taken to curb displacement.

Equity. “Equity” is an important guiding principle that was rejected by the Office of Planning but must be added in this amendment cycle. As discussed numerous times during the March hearing, the current proposed draft of the Framework Element espouses an “inclusive city” but DOES NOT provide a foundation to ensure equity. Until “equity” is a guiding principle, we will continue to have disparities across the city in educational opportunities, housing, transportation options, city services and facilities, healthcare, race, gender, age, and jobs and economic development, which, if not addressed head-on, will be counterproductive to implementing the vision, goals, and policies of the Comprehensive Plan. In addition, equity expands the choices and opportunities for everyone and places value on ensuring that the needs of disadvantaged groups or persons are met. Moreover, equity is an important principle in basic planning that is deemed critical by the American Planning Association as has been implemented in several other jurisdictions. Put simply, you cannot have inclusion without equity.

Citizen Participation. The SPCA submitted an amendment to the Framework Element to include “citizen participation” as a guiding principle. This is also included in the D.C. Code § 1-306.04. The premise behind the submission was based on other best practices that we researched in other jurisdictions and integrated with several other policies in the 2006 Comprehensive Plan that speak to working with surrounding community, ANCs, and citizen/civic groups. Everyone in Washington deserves a seat at the table to make decisions regarding their neighborhoods. To give better context, Berkeley, California, has an entire element on citizen participation in its Comprehensive Plan.

Density changes. Stories (or floors), a term lay people understand, is deleted and number of feet substituted in its place. Medium density residential currently limits mid-rise apartment buildings to 4-7 stories; the Framework Element deletes the 4-7 story limit and there is no height maximum. High density is currently is a max of 8 stories for apartment buildings; the Framework Element deletes the limit on stories and no height limit is specified. The list of zone districts that are compatible with medium density include zones permitting heights of 90 feet as in the high density residential designation. For commercial zones, the number of stories has been replaced with building heights in feet by stating that Planned Unit Developments can be taller, a move that will insulate the Zoning Commission from appeals based on excessive height. Further, the language “other districts may apply when approved as described in Section 225.1” is inappropriate and gives far too much authority to the Zoning Commission. During a Feb. 23 meeting the between SPCA representatives and Office of Planning leaders, OP’s Jennifer Steingasser acknowledged that this is not common practice and that other jurisdictions concretely define density by zone district or either include concrete ranges with no flexibility.

Affordable housing gets short shrift. Many D.C. residents legitimately wonder whether they could afford to live in their neighborhood if they had to buy or rent their dwelling today. There is no additional language in the Framework Element that bolsters affordable housing, let alone offers language that defines what affordability is – which can include food and transportation costs — and to whom it should be made affordable. Since the Framework Element is the foundational chapter for the rest of the Comprehensive Plan, and since we have not seen any further chapters of the plan (nor can the Office of Planning specify when they may be ready), this does not bode well. Given that the current version before the Council lacks substantial language which requires decent affordable housing that provides stability for families and improves opportunities for education and career advancement while reducing the District’s homelessness problems, it should be rejected.

Neighborhood Conservation Areas that aren’t conserved. One of the District’s major assets its tree-lined residential neighborhoods similar to Shepherd Park, Colonial Village, and North Portal Estates. Row-house neighborhoods (Shepherd Park contains row-house blocks on a few of its streets) and small apartment complexes designated moderate density and above on the Future Land Use Map will see new development and reuse changes, which could include commercial uses in residential areas and taller and denser development than what is allowed today. In terms of “commercial uses,” are we talking about day-care centers (home-based centers currently can operate in the District), restaurants or bed-and-breakfasts in dwellings too big to support the typical D.C. household – or are we talking about Airbnb-style complexes devoid of appointments and character and anything else save a convenient walk to the subway? The Office of Planning’s vision is not included in the Framework Element.

We can see how the Framework Element as currently written could have deleterious impacts on the community within the SPCA’s boundaries, but we can also see how it would negatively affect virtually every other neighborhood in D.C. – not just Shepherd Park but Manor Park, LeDroit Park and Kingman Park, not just Dupont Circle but Fort Dupont.

District law requires an amending of the Comprehensive Plan, but not the wholesale revision we’ve seen here. The city claims it is already adding about 1,000 new residents every month without these harmful proposed changes to it. While these are gross gains, we have yet to see information on net gains. Based on the gross gains alone, we’d hit 1 million by 2043 – two years ahead of the proposed Framework Element’s projection. Changes to the Comprehensive Plan should not disregard the 700,000 or so people currently living in the District in a quest to get to a magic number of 1 million. That is simply the tail wagging the dog.

These are the SPCA’s recommendations as to how the Council should proceed.

First and foremost, do not — repeat, do NOT — give the Comprehensive Plan back to the Office of Planning to fix. There is no guarantee they’d come up with a Framework Element that is substantively better. Based on the oral and written testimony related to the hearing, the Committee of the Whole and its staff should amend the document.

The Council can share its proposed revisions with the Office of Planning, but it should also wait to approve an amended Framework Element until the Office of Planning submits all other elements and related components to the Comprehensive Plan. As I noted earlier, the Framework Element is key to the rest of the document, and there should be no contradictory language in the Comprehensive Plan. The best way to assure that is to wait until the full Comprehensive Plan can be approved in one fell swoop. If that means waiting until 2019 to do so, then so be it.

During the amendment process, the Council should examine how other cities developed their own Comprehensive Plans, and be unafraid to plug in portions relevant to D.C. There is precedence for this. In 2002 under PR14-0604, the Council set up a task force to, among other things, look at best practices. The link to the Council’s resolution can be found here: I know this may seem dodgy after the Michelle Rhee-led D.C. Public Schools lifted entire swaths of its educational strategy from the public-school system in Charlotte-Mecklenburg County, N.C., without attribution, but the Framework Element has so few footnotes it is truly disturbing. When I asked Tanya Stern, an Office of Planning associate director, which cities they looked at for approaches and best practices at Councilmember Todd’s Ward 4 ANC and civic leaders meeting March 10, she gave a long, rambling answer that mentioned no other city. At all.

The SPCA went through the proposed Comprehensive Plan last fall with the proverbial fine-toothed comb, with its Planning, Zoning and Economic Development Committee conducting a series of “Comp-Plan-Palooza” workshops to go through the entire document, which included a review of other cities’ Comprehensive Plans. After all of that, the SPCA board of directors approved 150-plus amendments for forwarding to the Office of Planning — more than any other neighborhood organization in D.C. — so it is fair to say we have acquired a certain expertise with the Comprehensive Plan. We stand ready to offer our assistance in how it can be authentically improved. Feel free to reach out to me weekdays at 202-xxx-xxxx, and I can get you in touch with the members of our association who can provide direction on how to improve the Comprehensive Plan and, as a result, our city.

Best wishes,

Mark Pattison, president

Shepherd Park Citizens Association

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