Letter to OP: Upzoning proposals will embed inequity

February 6, 2026 

Anita Cozart, Director

Office of Planning

899 North Capitol St., NE

Suite 7100

Washington, DC 20002

Dear Anita,

We are writing on behalf of Ward 3 Housing Justice (W3HJ) and NW Opportunity Partners CDC in response to your invitation in Greater Greater Washington to submit comments on the zoning proposals for Connecticut Ave. (ZC25-09) and Wisconsin Ave. (ZC25-13).

You have asserted that rezonings will lead to more racially and economically inclusive neighborhoods with housing that families can afford. Where is the evidence for this claim? The rezoning proposals will not accomplish this result for three reasons.

First, the only affordable housing provision in the rezoning is Inclusionary Zoning (IZ 

and IZ+) that requires a set aside of a small number of rental units affordable to middle income households. IZ has failed to make an appreciable dent in the affordable housing crisis in Rock Creek West. Of 2,618 new units built in Ward 3 at Wardman Park, City Ridge, Upton Place and Residences at Mazza, only 233 apartments are part of the IZ program for middle income households. Clearly, increased supply has done very little to promote affordability.

Second, OP’s own data shows that IZ units exclude the majority of Black households and others earning below $75,000/year who work in Ward 3 but can’t afford to live here. There is no provision for new housing in these exclusive zones for the daycare worker, home health care aide, or grocery store clerk who work full time 40 hours a week, earning $18/hour (slightly less than $37,500 yearly).

Third, equity would require that the IZ increase be proportional to the full extent of density increases, with no ceiling of 125% increased density as your office has recommended. Theoretically, IZ+ set-asides increase with zoning increases in density. However, the current proposed requirement stops at 125% of increased density. The proposed new zones greatly exceed that with some parcels in Friendship Heights including more than 200% increased density. Equity would require that IZ increase proportionally to the full extent of density increases, with no ceiling at 125%. Since the Zoning Commission seems poised to authorize huge increases in matter-of-right development, the increased building envelope should be subject to 30% IZ as is required in disposition of other public assets.

Increased supply will not produce housing affordable for low-income households in Ward 3 without targeted intervention. Affordable housing has been built in other wards through the Housing Production Trust Fund (HPTF). Ward 3 had never received any of that funding until a recent loan to assist building 93 units of senior housing. Are the District’s housing and planning programs so siloed that they are incapable of coming together and really planning a neighborhood for all?

Finally, OP has given little attention to the fact that IZ is not structured to create affordable housing in meaningful numbers, to cut into the dearth of housing affordable to half the DC population, or to create inclusive communities. OP has consistently missed opportunities to improve the requirement by fighting against extending IZ to downtown during both the housing boom and the office-to-residential conversions, and opposing lowering the minimum income threshold for IZ applicants or increasing the affordable housing set aside on public land in rezoning cases.

At the end of the December hearings on ZC 25-09 and ZC 25-13, the ZC asked your office for further information. Then, it closed the record, slamming the door on further public comment. Now you have invited people to contact your office with comments. We strongly urge you to include these comments in OP’s supplemental report to ZC. Much is at stake, for if the ZC accepts OP’s plan, all redevelopment in these zones will be matter-of-right, and the public will be permanently silenced. Even ANC’s will have no voice in a project’s design. 

Much recent attention has focused on Ward 3’s history of exclusionary zoning through forced displacements, redlining, and exclusionary covenants. Approving the proposed new zones without targeted intervention for low-income households and without repairing the intentional policy of limiting IZ+ set-asides to households living on moderate incomes will, one day, count as another exclusionary land use strategy because it bakes in inequity for decades to come.

Thank you for this opportunity to submit additional comments.

Sincerely,

Margaret Dwyer, Convenor, Ward 3 Housing Justice

Meg Maguire, Chair, NW Opportunity Partners CDC