For the last several months, with the approval of our chapter's steering committee, a number of Metro DC DSA activists have been attending city-wide meetings in which a variety of grassroots community organizations have been preparing for participation in this year's amendment of the DC Comprehensive Plan.
The meetings began primarily under the auspices of Empower DC, a group advocating against the displacement of lower-income African Americans through redevelopment and gentrification in the District. However, out of the early organizing efforts of Empower DC and several allied organizations, a new and expanded group has come into existence, the DC Grassroots Planning Coalition, which plans to hold monthly meetings on zoning, development and Comp Plan issues until the process of amending the Plan is concluded.
Through our participation with other organizations in the planning process, Metro DC DSA members have formulated a total of 15 proposed amendments to the Comprehensive Plan, including several written up by members of other organizations but subsequently adopted as official policy by DSA's local Steering Committee.
The detailed wording of the amendments, which in many cases modify existing language in the Comp Plan, can be tedious to read, but essentially DSA has proposed to amend the Plan to ensure (1) that DC government gives priority to providing truly affordable housing, (2) that major steps are taken to prevent the displacement of low-income Washingtonians from their neighborhoods, and (3) that District government adopts the pursuit of social, economic and environmental equity as one of a half-dozen major guiding principles to the Comp Plan.
Among the proposed amendments to the Plan that DSA has submitted to the DC Office of Planning (OP) is a proposed change in the formula by which "affordable housing" is measured when zoning officials decide whether proposed development projects meet the requirements of the Comp Plan and the District's inclusionary zoning law.
Currently, the affordability of new housing units in the District is evaluated in reference to the Area Median Income (AMI) for our region in accordance with U.S. Housing and Urban Development (HUD) regulations. However, using AMI figures to determine whether housing is affordable in this area leads to absurd results, because for HUD's purposes, the District is included in a metropolitan area that also contains several of the richest counties in the country. They include among others Fairfax County, Loudoun County and Arlington County in Virginia and Montgomery County in Maryland.
Consequently, the AMI for a family of four in the District â€“ based on HUD's regional definition -- is currently defined at more than $108,000 annually. Housing is considered affordable for "low income" households in the District if it can be afforded by households making up to 60 percent of AMI, or roughly $65,000 for a family of four. In fact, some new housing units proposed by developers may still be considered "affordable" if they can be afforded by households making up to 80% of AMI. Yet thousands of District families have incomes far lower than these levels.
It follows that development projects ostensibly designed to include "affordable" housing units are often economically out of reach for lower-income and even working class Washingtonians, leading to their economic displacement from gentrifying neighborhoods and the city as a whole.
To address the District's affordable housing crisis, Metro DC DSA has proposed that the definitions of affordable housing be changed. The amended Comp Plan will still need to refer to the old definition to comply with HUD requirements, but in setting planning objectives for affordable housing, Metro DC DSA proposes that the District should use "Community Median Income" (CMI) levels within individual DC census tracts.
In 2010, the U.S. Census Bureau listed some 179 different census tracts in the District, with average family incomes ranging from less than $50,000 in some of the poorest tracts to more than $350,000 in the richest. Median family incomes in the District as a whole also are significantly lower from those in the wealthier suburbs. DSA believes that our proposed definitions based on census tracts will help Washingtonians in lower-income neighborhoods avoid being displaced from existing low-cost housing and seeing it replaced by "affordable" units in new developments that are not actually affordable.
Metro DC DSA also has submitted 14 other proposed amendments to the Comprehensive Plan, including one that would make the promotion of equity, via the pursuit of social, economic and environmental justice, a sixth framework principle of the Plan.
Another broad amendment would encourage DC planning officials to use Social Impacts Assessments as well as Environmental Impacts Assessments when considering the likely impacts of proposed developments, as is suggested but not required by the National Environmental Policy Act (NEPA).
Other DSA amendments are intended to promote racial integration in the District via the planning and development process, protect existing residents of distressed low-income and public housing from displacement when such housing is redeveloped, keep existing public housing and public lands under the control of public entities and community land trusts rather than transferring it to private investors, address the prevention and cleanup of industrial pollution in less advantaged neighborhoods, and mandate greater attention by District government to problems with lead contamination in low-income housing and public schools.
DSA's 15 proposed amendments were submitted in late June to the Office of Planning along with approximately 3,000 other proposed amendments. The OP stated in a recent letter to stakeholders that these changes have been proposed by "a broad range of stakeholders across all eight Wards, including Advisory Neighborhood Commissions, civic associations, advocacy organizations and individual residents," as well as several DC government agencies.
When the Plan was last amended in 2010, OP notes, only 200 proposed amendments were submitted by the public. Accordingly, it may be some time before OP publishes a report on the proposed amendments, which under law will be followed by a 60-day public comment period before the District Council can vote on amending the plan. The Council's recommendations will then go to Mayor Bowser for adoption, and her recommendations will then be subject -- probably sometime early next year -- to further review by the National Capital Area Planning Commission.
It's impossible to predict whether the Office of Planning will report favorably on DSA's proposed amendments, not to mention the proposed amendments of other organizations and individuals taking part in the Grassroots Planning Coalition. One knowledgeable advocate for the homeless told the Washington Socialist that he fears the OP will ignore the input of community groups and only adopt amendments proposed by developers. On the other hand, DSA housing activists note that our proposals to make "affordable" housing truly affordable, and to help protect low-income Washingtonians from displacement through gentrification, fit squarely within the goal of promoting an "inclusionary city" that the OP has said will be central to its recommendations on amending the Plan.
In any case, the mandatory 60-day public comment period that follows the OP's report provides DSA and other advocates for affordable housing with an additional opportunity to rally public sentiment in the District in favor of more equitable planning principles. The lobbying and testimony that will then precede the District Council's vote on the OP's recommendations should provide DSA and allied organizations with another political opportunity to make the case for better planning language. The review of the District Government's recommendations by the National Capital Area Planning Commission, which won't occur until early in 2018, may provide still more opportunity for public education and political agitation.
DSA activists involved in the Comp Plan amendment process belong to our chapter's Economic Justice, Racial Justice and Climate Change and Environmental Justice committees. However, as our campaign over the Comp Plan amendment process continues, we hope it will serve as the basis for more extensive involvement in housing and anti-gentrification activism by many other DSA members. We also hope it can be a basis for building relationships between DSA and other organizations that can lay the foundations for continuing activism around local housing conditions.
DCDSA members David Poms, Elizabeth Stafford, Doug Farley and Andy Feeney were involved in writing DSA's proposed amendments to the Comp Plan. DSA also adopted as our own several key amendments proposed by social justice advocate and urban planning consultant Claudia Barragan, as well as others written by Lori Leibowitz of the Neighborhood Legal Services Program. DSA members Ernest Bailey and Stuart Karaffa assisted in the amendment writing effort, and we also received guidance from Chris Otten of DC for Reasonable Development.
David Poms has aggregated these resources for further information on the DC Comprehensive Plan revision: DC Housing Plan Resource, Greater Greater Washington Comp Plan Amendment Package
And a few new articles that are relevant to the Comp Plan: a favorable Vox write up on the GGW/Smart Growth "YIMBY" Coalition, a Jacobin article on the shortcomings of YIMBY politics when it comes to addressing adequate affordable housing, and this recent "Delete your Account" podcast episode interviewing the author of "How to Kill a City", a new book from a DSA member on gentrification.