New and Revised Comprehensive Plan Policies for Rock Creek West
Updated: Jul 4, 2022
Ward 3 Housing Justice's work began with the Comprehensive Plan. We proposed the changes below to the Office of Planning's amended Rock Creek West Area Element to the D.C. Comprehensive Plan. Anchored by the Housing Justice Priorities of the DC Grassroots Planning Coalition, the proposals were intended to strengthen affordable housing policies in Ward 3 with the goal being to produce significant amounts of deeply affordable housing in a variety of ways while ensuring good planning principles.
• New policies or reframed policies are in red.
• Current policies with OP amendments are bulleted with titles in italics.
• Parts that OP has deleted are in italics and underlined.
• Parts that OP has added are in bold.
• A discussion of why the change we might suggest is appropriate follows each policy.
I. NEW POLICIES
#1: NEW/RCW-000: Affordable Housing. Require that any new housing or conversion to housing provide at least 2/3 affordable units and that half of those units provide at least 3 and 4 bedrooms to accommodate families. Affordable means that renters will not spend more than 30% of income on rent and utilities. The target incomes for affordable housing may vary by program, but the goal is to create an inventory of deeply affordable housing units to meet demand while also recognizing that households can be housing burdened at the low and moderate income levels and that they also need affordable housing.
Reason: RCW or Ward 3 has the third most children in the District. It is a safe, family-oriented area with well-regarded public schools, an abundance of grocery stores and other retail options, parks, jobs, and reasonable transit options. It is an area that is attractive to families with children but the cost of housing with multiple bedrooms is high. The need is for family housing that is affordable. The lowest cost housing is in shorter supply than moderate priced housing so the emphasis should be on building the inventory of housing affordable to the lowest income families.
#2: NEW/RCW-001: Public Housing. As federal and District governments reinvest in public housing, ensure that land is provided through District programs, such as PADD, to be the site for new public housing to meet the need. Leverage large site redevelopment to include new public housing units.
Reason: Public housing development was clustered in low income neighborhoods. As a result, there are not as many public housing units in RCW as in some other parts of the District. There will always be a need for public housing that serves older adults, the disabled and extremely low-income working households. Public housing should be integrated into neighborhoods where services and amenities can serve everyone. Since RCW is built out the District government needs to acquire land for public use, such as public housing. Financing tools that will offer opportunities for public housing residents to achieve equity should be employed.
#3: NEW/RCW-002: Land Trusts and Equity Co-ops. Develop programs to reduce or separate land costs from housing costs in order to reduce the price of housing, including single family, for households earning up to 60% MFI. With non-profit housing developers, develop housing on these sites to maximize homeownership options. Since building equity is a benefit of purchasing a home, continue in perpetuity the affordability of new homes.
Reason: The cost of land has been estimated as 40% of the total cost of buying a house. The land costs reduce the number of households who can afford to buy a house and begin building equity and generational wealth. Even if a household can buy a house, they may quickly find that District property taxes are an uncontrollable housing cost. Removing land costs, including as a proportion of property tax assessments, can increase the number of households who can afford to buy a house. This would result in more lower income households buying homes in RCW.
II. EXISTING RCW POLICIES AMENDED BY OFFICE. OF PLANNING
#4: Policy RCW-1.1.4: Infill Development. Recognize the opportunity for infill development within the areas designated for commercial land use on the Future Land Use Map. When such development is proposed, work with ANCs, residents, and community organizations to encourage mixed-use projects that combine housing, including affordable housing, neighborhood-serving retail, and commercial uses. rather than projects that contain single uses. Heights and densities for such development should be appropriate to the scale and character of Neighborhood retail along Connecticut Avenue adjoining communities. Buffers should be adequate to protect existing residential areas from noise, odors, shadows, and other impacts. Design transitions between large- and small-scale development to ameliorate the appearance of overwhelming scale and to relate to context of lower-scale surrounding neighborhoods. 2308.5
NEW LANGUAGE: Infill development in mixed use areas shall provide a majority of affordable housing units for households up to 50% MFI. Family sized units with at least 3 and 4 bedrooms will be included in every development and there will be no exemptions based on the number of total units provided. Retail in mixed use areas should be neighborhood-serving. Physical buffers, including open space, trees, fences, etc., shall be provided except when the density level between adjoining mixed use and residential uses is the same.
Reason: The OP language would continue the production of mostly market rate housing units, which are plentiful in the District and which are expensive and out of reach from most residents both from a unit size and cost perspective. Public policy should prioritize the housing that is needed and guarantee that the households most in need of affordable family-sized housing have priority access. Long standing planning policies that protect built neighborhoods from the impacts of growth and development should be maintained. These are aesthetic considerations that underpin the District’s emphasis on neighborhoods no matter the income level of the residents.
#5: Policy RCW-1.1.6: Metro Station Areas. Recognize the importance of the area’s five Metrorail Metro stations to the land use pattern and transportation network of Northwest Washington and Washington, DC as a whole the entire District of Columbia. Each station should be treated as a unique place and an integral part of the neighborhood around it. The Mixed-use redevelopment of large office buildings at the area’s Metro stations should be discouraged. The preference is to use available and underutilized sites for prioritize the production of affordable and moderate income housing and retail uses in a manner consistent with the Future Land Use Map, the Generalized PoliciesPolicy Map, and the policies of the Comprehensive Plan. Careful transitions Design context-specific transitions to be more aesthetically pleasing from development along the avenues to nearby low-scale neighborhoods must be provided. 2308.7
NEW LANGUAGE: Each metro station is located in commercial or mixed use zones, but the surrounding areas are different and the appropriate type and level of development must be based on the whole areas development context. Determine how neighborhood-serving retail uses will mix with residential uses when infill or redevelopment opportunities arise through community-led planning. The priority housing shall be affordable and family-sized housing units. Physical buffers as described in RCW-1.1.4 above shall be provided.
Reason: The OP language does not match their language regarding housing in the Infill Development policy. The language about housing should be the same and should be prescriptive. This is an example where policies could have been consolidated, but at a minimum they should be consistent. The mentioning of the maps in some policies and not others is confusing and all references to the maps should be removed since the maps are defined and explained in the Framework Element. The statement about buffers contrasts with long-standing policy; the language about buffers should be consistent from policy to policy.
#6: Policy RCW-1.1.7: Housing for Seniors and Disabled Residents Older Adults and Persons with Disabilities. Maintain and increase housing for elderly and disabled residents older adults and persons with disabilities, especially along the major transportation and commercial corridors of Wisconsin and Connecticut Avenues, NW. 2308.8
NEW LANGUAGE: Recognize that older adults and persons with disabilities are often on fixed incomes and confront housing burdens. As public housing is developed, recognize the large population of older adults in RCW and the needs of persons with disabilities by providing housing for these populations throughout the area. Maintain and expand the more than 12,000 rent control housing units in RCW as a major source of housing for households that may not be eligible for public subsidies but who cannot afford market rate housing units.
Reason: The current policy is inadequate since it does not explain the different housing resources for older adults and persons with disabilities. The proposed new language cites the two prominent sources of housing for these groups, with rent control being a significant source in RCW. The new language also recognizes the very large number of older adults in RCW - much larger percentage than citywide – so that the relevance of this policy in RCW is clear.
#7: Policy RCW-1.2.7: Fire and EMS Services. Renovate and enlarge fire stations while remaining sensitive to their historic architectural qualities. and avoiding the loss of adjacent open space. Ensure that there are a sufficient The number of fire stations should be sufficient to serve the needs of area residents and businesses. 2309.8
RESTORE EXISTING LANGUAGE
Reason: There really should be no debate about restoring the policy that ensured the safety of residents with Fire and EMS capacity. That the District would have a policy that “it would be nice” to have the resources, but “we can’t guarantee it” is unsupportable. In RCW, this would mean that families and older adults, which predominate in RCW, could be vulnerable to harm without resources to intervene. I have not seen a comparable policy in the other area elements I have studied.
#8: Policy RCW-1.2.8: Schools and Libraries. Place a very high priority on the expansion, renovation, and improvement of schools and libraries. The fact that a majority of the schools in this Planning Area are operating at or above capacity should be considered in DC Public Schools (DCPS) facility planning., and in the approval of any residential development that could further exacerbate school overcrowding. Changes to school service boundaries, and the expansion of existing school facilities, and/or development of additional school facilities should be aggressively pursued to ensure so that school overcrowding is proactively addressed. 2309.9
NEW LANGUAGE: Prioritize the expansion, renovation, or improvement of public schools and libraries recognizing that some are on small parcels of land and some are historically landmarked or in historic districts. The large and growing number of children in RCW, and the interest in expanding the opportunities for families to live in RCW, requires that DCPS facility planning and the District 6-year capital budget identify reliable plans to meet the increasing demand and reverse the overcrowding at a majority of RCW public schools. The overcrowding conditions and plans to provide more classroom space should be a consideration in the planning and approval of residential developments with family-sized units.
Reason: RCW schools seem to be an afterthought in the 6-year capital budget. Planning has not kept up with the growth of families in RCW or the interest in using RCW public schools. There is also the fact that many RCW schools provide out-of-boundary places for children from other parts of the District that may increase diversity and equitable opportunity. Recently, the funds to purchase a private school building in RCW were approved in order to address the critical need for more classroom space at nearly every school in this area. The Comp Plan policy needs to be more urgent and more descriptive of the significant need. It also is bad planning to encourage more families to locate in RCW while ignoring the effect it will have on schools, which are one of the assets that attract families to RCW. Recognizing the cause and effect of development and school capacity issues is essential and could provide leverage to enhance schools.
#9: Policy RCW-2.1.2: Infill Development. Recognize the opportunity for additional housing
including new affordable and moderate-income units, with some retail and limited office space along the Connecticut Avenue corridor NW corridor. Any development along the corridor should be consistent with the designations of these areas on the Future Land Use Map, zoning overlay requirements, and the scale of adjoining uses. 2311.86
NEW LANGUAGE: Recognize the opportunity for new affordable and more rent control housing units along Connecticut Avenue, NW. Prioritize preservation of housing and create family-sized units in new construction. Provide retail and limited office space if a need is identified through a community driven planning process. Provide physical buffers per RCW 1.1.4.
Reason: There are a lot of large-scale apartment buildings on Connecticut Avenue, many of them providing rent control housing units and other newer housing with much higher rents. There is a dearth of lower income housing on the avenue. Because there are very limited opportunities for infill given that the area is built out and the existing housing should be preserved, the priority should be to produce affordable housing.
#10: Action RCW-2.1.AB: Large Hotel Sites. Carefully monitor fFuture proposals for the Omni- Shoreham and Marriott Wardman Park hotels should include analysis of impacts on adjacent residential and commercial areas, prepared by property owners. to ensure compliance with the Zone regulations and prevent adverse effects on the adjacent residential community. Proactively address ongoing issues at the hotels, such as tour bus motor coach and visitor parking. 2311.12
NEW LANGUAGE: Recognize the significant opportunity for housing large numbers of extremely low, very low, and low-income households, particularly families, on large sites, such as former hotels. Ensure that public purchase of, and public investment in, these sites considers innovative land valuation alternatives and equity building options for new residents and fully takes into account the need for additional parks and open space for passive and active recreation in this area, as well as other infrastructure needs.
Reason: The Mayor has established a goal of creating 1,990 new affordable housing units in RCW by 2025. This is an impossible goal to meet with new construction because there isn’t much vacant land in RCW and rent control buildings and viable homes should not be demolished. Rather than allowing another very expensive and very large housing development in RCW, the District should invest in one or both of the hotel properties for the purpose of a non-profit redevelopment that would prioritize housing for the lowest income bands and provide missing neighborhood amenities at the same time. These sites could also be incubators for innovative programs to provide equity for low income households.
#11: Policy RCW-2.2.1: Housing Opportunities. Recognize Pursue the opportunity for additional housing, including affordable and moderate-income housing, with some retail and limited office space on the east side of Wisconsin Avenue between Albemarle and Brandywine Streets, on the Lord and Taylor parking lot, on the Metro (WMATA) bus garage and underdeveloped sites west of the Friendship Heights metroMetro station, and on underutilized commercially zoned sites on Wisconsin Avenue. Any development in these areas should be compatible with the existing residential neighborhoods. 2312.87
NEW LANGUAGE: Recognize that large market rate housing and mixed-use developments have been built or are being built south of Van Ness Street. Promote infill development on underutilized sites to the north that would provide more affordable housing and be in scale with adjoining neighborhoods. In particular, the Lord and Taylor site and WMATA bus garage provide larger site opportunities for affordable housing, including family housing. Leverage opportunities to invest in land for public use, including public housing and infrastructure needs, such as schools, recreation centers, and services for older adults.
Reason: The current policy focused on Friendship Heights because it is a policy focus area and this policy is in that section of the area element. The amendment no longer targets this area where the most intense redevelopment opportunities exist. The inference is that OP may have other plans for these sites and thus, it doesn’t want any policies that might conflict with their plans. Whether that is true or not, it is basic planning to account for how these large sites should be redeveloped. There are map amendments that propose high density uses and no doubt there have been discussions about what developers want here.
#12: Policy RCW-2.2.2: Tenleytown and Friendships Heights Metrorail Station Areas. Support coordinated planning for Wisconsin Avenue’s to Stimulate a well-planned economic activity center at the Tenleytown and Friendship Heights Metro station areas, generally defined as the area bounded by extending north from Van Ness to the Maryland state line at Western Avenue. Albemarle, Brandywine, Fort Drive, and 42nd Street. This center should Planning considerations for the corridor include should:
Utilizing Use the public transit infrastructure and maximize Metrorail Metro and bus access
Enabling Enable merchants to upgrade existing businesses, attract new customers and new business establishments, and provide neighborhood give residents needed services;
Providing Provide for the development of new housing for a mix of incomes;
Protect and preserve Conserving Conserve existing low-density residences in the vicinity, and the surrounding institutions and local public facilities, by mitigating from the adverse effects of development; and
Maintain heights and densities at appropriate levels, with architectural Site Ensure that planning and building design should be is that is sensitive to the area’s topography, existing architectural assets, street layout, and pedestrian circulation patterns; relative to the District
Promote safe and comfortable pedestrian and bicycle circulation to parks, schools, transit, and shopping, as outlined in the Rock Creek West II Livability Study;
Enhance a robust public life on the corridor, with key public spaces that function as places where neighbors and visitors want to stay, linger, and enjoy; and
Partner and collaborate with public and private institutional and educational facilities along the corridor. 2312.98
NEW LANGUAGE: Maintain language through the second bullet.
Provide for the development of a mix of housing to meet the needs of the lowest income residents up to moderate income residents.
Protect and preserve existing low-density residences in the vicinity, and surrounding institutions and local public facilities from the adverse effects of development.
Create physical buffers between lower density structures or neighborhoods and new construction that is denser. Plan these areas to enhance the area’s topography, existing architectural assets, street layout, traffic and pedestrian circulation patterns.
Ensure that public resources, including fire and EMS services, schools, libraries, recreation centers, and parks and open space are expanded as new housing is built in order to meet an increased demand for services.
Assess the infrastructure to anticipate where improvements may be necessary to avoid congestion, parking issues, truck traffic and loading, and other issues associated with an increase in intensity of use and density.
Reason: This is a more expansive policy whereas it formerly was limited to Tenleytown. Since this involves a large low-density commercial area that was developed adjacent to residential neighborhoods and now it is proposed to have significant increase in density the planning should be prescriptive. It’s important not only to ensure affordable, family-size housing, but also to anticipate the many impacts these proposed changes could visit on the surrounding neighborhoods that provide some of the more affordable homes in the area. An action calling for a small area plan follows below.
#13: Policy RCW-2.2.5: Land Use Compatibility Along Wisconsin Avenue NW. Ensure that future Future development along Wisconsin Avenue NW should be is physically compatible with and architecturally sensitive to adjoining residential neighborhoods and is appropriately scaled given the lot depths, widths, and parcel shapes. Use a variety of means to improve the interface between commercial mixed-use districts and lower-scale residential uses, such as architectural design, the stepping down of building heights away from the avenue, landscaping and screening, and additional green space improvements. 2312.1211
NEW LANGUAGE: Ensure that future infill development or redevelopment along Wisconsin Avenue is in scale with its surroundings and that denser development stepdown toward lower density areas. Require physical buffers, including open space, trees, and fences, to protect existing residential areas from noise, odors, and other conditions associated with more intense commercial or mixed uses.
Reason: The amendments strike protections communities negotiated in previous Comp Plans to help ensure that their neighborhoods would not be overwhelmed by development. Now as more intense development than was allowed when these protections were approved is proposed, OP wants to strip the neighborhoods of these protections. These are reasonable planning tools used universally to address the predictable tensions between non-residential uses and residential uses and high-rise development next to low rise development. If, as it appears, these communities will no longer be able to ask for sensitivity to their concerns, it is incumbent that the Comp Plan require that these nominal protections be included.
#14: Action RCW-2.2.C: Wisconsin Avenue NW Planning. Craft a coordinated vision with the District and community to better understand the realities of change along northern Wisconsin Avenue NW to inform future development and manage growth on the Wisconsin Avenue corridor at the Tenleytown and Friendship Heights Metro station areas. A plan will identify opportunities for urban design, commerce, housing, mobility, culture, public space, and community facilities to preserve a high-standard urban quality of life and advance District policies promoting inclusive prosperity. 2312.15
NEW LANGUAGE: Prepare a community driven small area plan for the Tenleytown Metrorail Station from Albemarle Street up to and incorporating the Friendship Heights Metrorail Station. Recognize that there are different permitted uses, intensities of use, and densities along Wisconsin Ave. and in the surrounding areas. Engage fully with the community in a participatory and community-led process to plan for infill development or redevelopment at the Metro stations that will maximize opportunities for deeply affordable housing, ensure adequate public services and infrastructure, meet the challenge of bridging the lower density areas between the two Metro stations with solutions that are innovative, bring jobs, upgrade retail, maintain utility capacities, and reflect the character of each area.
Reason: There isn’t another amendment proposed by OP that uses language like “better understand the realities of change” or “advance District policies promoting inclusive prosperity.” This area is not underserved and not a drag on the local economy. RCW sustained and grew its population in the 80’s and 90’s when many areas in the city lost large numbers of residents. This area has the third most children in the city, among the most elderly and a growing population of Hispanics. It provides more jobs than any area outside Central Washington except for the newly developed Waterfront and Navy Yard. It has little or no vacant land. It is unreasonable for OP to use the language they propose in this new action. It would be appropriate to clearly call for a small area plan to organize the significant density increases OP is proposing at the Metro stations and in low density areas between them. The FLUM changes should not be approved until this community-led planning occurs.
The aspiration for inclusive prosperity is a worthy goal that is not highlighted in the Comp Plan amendments and should be. The language changes we recommend would improve the chances of realizing the goal of creating more inclusion but there must be changes to policies throughout the Comp Plan on homeownership, maximizing and defining affordable housing, job creation, equity of opportunity and investment to move toward “inclusive prosperity.”
#15: Policy RCW-2.3.4: Commercial Opportunities in Van Ness. New building construction and major renovation projects should produce high-quality retail space that engages with the sidewalk and increases housing near the Metro station where possible. 2313.8
NEW LANGUAGE: New building construction and major renovation projects shall create local jobs and affordable housing, with the majority of units providing housing for the District’s lowest income residents. High quality, contextual architecture and engagement with the sidewalk shall characterize new and rehabilitated multi-neighborhood retail space.
Reason: None of the new policies in the Van Ness policy focus section mention affordable housing. This is the only policy that even mentions housing. It is an unsupportable gap. There is also no mention of jobs. This is the home of UDC and a future hub for job creation. Marrying jobs, transit, and affordable housing is often a dream, but here all that is missing is affordable housing.