League of Women Voters of the District of Columbia
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Washington, DC 20005-4504

THE 1998 AMENDMENTS TO THE COMPREHENSIVE PLAN AS THEY MAY AFFECT ECONOMIC DEVELOPMENT

While many of the 1998 Comprehensive Plan amendments have significant economic development implications, the Plan is not self-implementing. Policy changes with no clear implementation mechanism are typically not effective in bringing about real change. There are, however, a limited number of new policies with an economic thrust that will probably be implemented, generally through zoning. These have been summarized and grouped below into five areas:

• Downtown Housing. There were a few Downtown housing amendments in the last minute that got significant press coverage and had the effect of diminishing housing potential numbers in Downtown. Housing potential was effectively lost adjacent to the new convention center, on the Asbury Church square and on the large triangular square north of the Wax Museum housing site. There were also minor gains, with residential use to be permitted in Woodies and to be required on-site at the DOES site. The problem with numbers is that they represent housing that may never be built. Thus, perhaps the most important amendment was a fairly obscure policy encouraging housing in the Mount Vernon sub area. This has led to a zoning change in the works to allow the use of bonus TDRs to subsidize new housing built along and within the northern boundary of Downtown.
• Convention Center-Related Development. The Comprehensive Plan was amended to encourage, both by broad policy and by specific land use recommendations, convention center-related development around the new convention center, where heretofore the construction of hotels was either not permitted or would have been discouraged with a housing requirement. The City's investment in the new convention center makes this kind of development critical.
• Redevelopment of the Existing Convention Center. One important amendment speaks to permitting additional commercial zoning density on the site of the existing convention center, without a housing requirement, to increase the City's flexibility in the redevelopment of that site in the future for uses which will provide both the greatest benefit for Downtown and the highest return on our investment in that site to date.
• PUD Time Limits. There is currently no limit on the length of time that a Planned Unit Development (PUD) approval can be extended and remain valid without construction of the project. Some have tied up potential development sites for years, with no real expectation of actual construction in the foreseeable future. In response to this issue, and in hopes that a clean slate will lead to a more developable project or one more consistent with current land use policies for the area, one amendment would have the Zoning Commission limit approval of an unbuilt PUD for a total of 12 years. The Council added reasonable exceptions at the last minute for tolling of time while an approval or extension is under appeal and for projects that have provided substantial amenities in advance of construction.
• Neighborhoods (Outside of Downtown). A number of Plan amendments would encourage community-related development, for the most part by directing that the commercial zoning density be increased or expanded. These include the Tivoli Theater site on 14th Street, NW, the Camp Simms site in Ward 8 and a number of commercial strips on Capitol Hill. In addition, one amendment expands the Central Employment Area in five locations to enable GSA leases, one such location being along MLK, Jr., Avenue in Southeast.

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The Comprehensive Plan for the District of Columbia (District Element)

Urban planning, which has occurred since at least 5,000 BC, has shaped the form and nature of cities throughout the world. In Washington, DC, planning dates back to 1791 and L’Enfant’s plan for the original city. Modified by Ellicott, that plan was followed by a highway plan in 1898, the Macmillan Plan which laid out elements of the current monumental core in 1902, and various “comprehensive” plans by NCPC from the 1920s to 1970. Following World War II, urban renewal plans and programs changed the face of many central area neighborhoods. In 1973, the Home Rule Act made the Mayor responsible for municipal planning in the District. As the “chief planner” of the city, the Mayor prepares the District elements of the Comprehensive Plan, with NCPC preparing the Federal elements. The first District elements of the Comprehensive Plan were adopted in 1984 and 1985, amended subsequently in 1989 and 1994 and 1998.

The District Elements of the Comprehensive Plan

The eleven citywide District elements of the Comprehensive Plan, a 20-year policy plan and generalized land use map, form the first tier of the District's “3-tier” planning structure. The eight ward plans, providing more focused policies, are included in the Comprehensive Plan and form the second tier. The third tier is made up of small area plans which are the most detailed of the city's plans, providing specific planning and development initiatives and implementation strategies. The District elements include General Provisions, Economic Development, Housing, Environmental Protection, Transportation, Public Facilities, Urban Design, Preservation and Historic Features, Downtown (the most detailed element), Human Services, Land Use and the eight ward plans.

The Comprehensive Plan provides general policy guidance to decision-makers. It must be considered in its entirety, because individual goals and policies often appear to conflict when considered in isolation from others. Also, because of its general policy nature, the Plan provides little direct priority direction. Most importantly, the Plan is not self-implementing. Implementation of the land use portion comes largely through zoning (the Home Rule Charter requires that zoning not be inconsistent with the Comprehensive Plan). Because the Council has not direct control over the Zoning Regulations, unlike the situation in other jurisdictions, it passes a relatively detailed Comprehensive Plan to give it some control over zoning and, thus, over land use and development. The other unique aspect of the District's Comprehensive Plan is that it is prepared without direction from an appointed planning commission.

Amending the Comprehensive Plan

The Comprehensive Plan can only be initiated by the Mayor (it is adopted by the Council), and is currently required on a four-year cycle. The Mayor, however, can initiate the process at any time for a particular purpose, although he has been advised to do so only under the most urgent circumstances because he then also opens up the process for any Council initiated amendments without there being the context of a full community outreach process. Recommended amendments to the Downtown element of the Comprehensive Plan resulting from the current Downtown planning effort would likely constitute the kind of urgent situation which would justify the Mayor's initiation of an amendment.