Ward 3 Housing Justice appreciates the opportunity to comment on the draft Wisconsin Avenue Development Framework and share our concerns. We reject the Framework as drafted. It should be considerably improved to achieve the city's and community's goals.
The Framework is an outline for development for the huge development that will be allowed to be built within the “planning” area, but it is not a plan. It purports to look at the neighboring areas and set goals for complementary development, but, in the end, all it does is outline the maximum zoning based on the 2021 changes to the Future Land Use Map. The Council's directive was to match the zoning options within a density category to the existing infrastructure, adjacent neighborhoods, and with equitable development, but the “plan” does none of that. It simply rationalizes the maximum heights and densities. It sets some limited admirable goals, but there is nothing in the zoning it proposes (virtually the only tool to achieve any such goals), that would make anything but height and density, and to a limited extent “uses” a certainty.
The proposed framework will bestow an enormous windfall of property value with no commensurate public benefits and no provisions for community needs, like schools, recreation space, and community services. Enacting new zoning that will bring 5,000 or more new residents into this corridor based on an incomplete and inadequate "development framework". What is needed is a plan to manage the most development ever conceived for Rock Creek West and Ward 3. Once all the proposed up-zoning is achieved, the community and other stakeholders will experience a mishmash of development and will question why there are so many missed opportunities.
OP's Framework claims to prioritize affordable housing, but only through Inclusionary Zoning, without specifying goals for total housing needed in the corridor. Recent multi-family development in Ward 3 has delivered less than 10%, mostly at 80% MFI. For example, the Wardman project's 900 luxury apartments will include only 72 IZ units. City Ridge and Upton Place on Wisconsin Ave have only 121 affordable units out of more than 1,300 units. In addition, this plan fails to address affordable housing for residents with MFI below 60%. The Framework will enable developers to expand a luxury, high-end, exclusionary neighborhood that fails to rectify past inequities and fails to achieve the Mayor's goal of a more integrated city.
To ensure that new development results in an inclusive, equitable, and socio-economically diverse community, the Framework should explicitly require that 30% of all new residential development be permanently affordable at the full range of affordability from 30% to 80%, or no more than 50% of residential at market rate. DC will have just this one chance to gain substantial affordable housing in Friendship Heights. The city shouldn't squander the opportunity to specify greater affordable housing requirements
Up-zoning along the corridor is designed to allow matter-of-right development. Replacing the PUD process with MOR development throughout the corridor diminishes the potential for community benefits and amenities that are typically associated with granting greater height and density. The Framework's proposed design review is too vague. Design review should require specific criteria and require public input for each proposed development project. The criteria for design review should be spelled out before the Zoning Commission agrees to up-zoning map amendments.
The Framework defines four new zones, but fails to take advantage of the opportunity to create customized zones that could achieve at least some of the goals. Specifically, at a minimum, new zones should require:
30% of all new residential units be permanently affordable at the full range of affordability;
increased setbacks and step backs;
Design Review with public input for all new building projects based on criteria spelled out in the Framework;
residential at both WMATA sites, coordinated with 2 Sites/1 Plan;
open public spaces and amenities clearly identified in the Framework.
In addition, guidelines for the zones should require adherence to specific defined goals that encourage low-income homeownership as well as rentals; mandate large units for multi-generational families with children; and provide units designed for seniors and disabled residents.
Successful implementation of this massive new development and increased population requires comprehensive, collaborative planning by all city agencies. should be comprehensive and involve all agencies. Increased population will necessitate improvements to infrastructure such as schools and recreation facilities, and demand for more city services such as police and emergency services.
The Framework needs substantial revision before it can gain the public support it needs to be successful and in order to best serve Ward 3, communities along the corridor, and the city as a whole.