CPSG Supports FLUM Amendment 2123

Today the Steering Committee of Cleveland Park Smart Growth approved the following letter of support for the proposed density increased for the Cleveland Park commercial area on Connecticut Avenue between Porter and Macomb Streets.

We encourage our members to reach out to ANC 3C (all@anc3c.org), ANC 3F (commissioners@anc3f.us), the Office of Planning (plandc@dc.gov), Ward 3 Council Member Mary Cheh (mcheh@dccouncil.us ), Council Chairman Phil Mendelson (pmendelson@dccouncil.us), and At-Large Council Members Anita Bonds (abonds@dccouncil.us), David Grosso (dgrosso@dccouncil.us), Elissa Silverman (esilverman@dccouncil.us), and Robert C. White, Jr. (rwhite@dccouncil.us).    Emails should be a personal note from you to the policymakers indicating what you are asking for (support OP’s proposed increase in density on the Future Land Use Map for the Cleveland Park commercial area on Connecticut Avenue), and why you support it.


 

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Letter on FLUM Amendment 2123
January 2, 2020

The steering committee of Cleveland Park Smart Growth endorses the proposal by the Office of Planning to increase the density of the commercial area on Connecticut Avenue between Porter and Macomb Streets on the Future Land Use Map from Low Density Commercial to a mix of Moderate Density Commercial and High Density Residential (amendment 2123), and asks ANC 3C and 3F to pass a resolution to that effect, asks the Office of Planning to keep this amendment in the package it will send to the Council, and asks for the Council to approve the change to the Comprehensive Plan.  Background on this proposal and our rationale are outlined below.

Background
In response to the open call for amendments to the City’s Comprehensive Plan, ANC commissioners Emma Hersh (3C05) and Beau Finley (3C04), along with residents Susan Taylor and Bob Ward, solicited feedback from the community to a proposal to change the designation on the Future Land Use Map for the commercial area on Connecticut Avenue between Porter and Macomb Streets.  The proposal was to change from Low Density Commercial to Moderate Density Commercial, with the intent being the allowance of upzoning the area to attract development of additional commercial and residential space. The amendment, which would become #2123, was submitted in June 2017 along with a petition supporting it signed by 324 people. This group was the start of what would become Cleveland Park Smart Growth in March 2018.

In October 2019, the Office of Planning recommended amendment 2123 for Council approval with modification, adding High Density Residential to the Moderate Density Commercial designation.

FLUM 2123.JPG

Cleveland Park Smart Growth surveyed its membership in mid-November 2019, explaining the change in the OP proposal, and asking whether people supported or opposed it.  Of the 494 members, 96 members responded to the survey during the week it was open and virtually all (97%) supported the new higher density proposal.

There are many reasons why allowing the potential of high density residential in the Cleveland Park commercial area is a public policy we all should support.  We have outlined several of these below.

Revitalization
A benefit that is self-evident is the positive economic impact a greater density of residents at the commercial area would have.  As noted in the submission of amendment 2123, “The density that would once have sustained a vibrant neighborhood serving commercial corridor no longer carries the same economic throughput for our brick and mortar stores.”  It was also noted that businesses that closed in 2017, like Ripple and NamViet, said that customer traffic to their stores was down substantially. Adding more customers is not a cure-all to the neighborhood’s retail slump, but when coupled with the opportunity new development gives to place making and the new managed Main Street, the potential for revitalization increases significantly.

Sustainability
High density boosts our efforts to combat climate change.  Transportation is the single greatest contributor to carbon emissions in the United States.  Adding housing virtually anywhere in D.C. for someone who works in D.C. or in nearby Metro-accessible areas, at any price point, is green.  Living close to work, rather than in the suburbs, reduces vehicle miles traveled. Putting housing at a transit nexus like the Cleveland Park commercial area is extremely green.  Locating housing where people can live car-free or car-lite is the best public policy, as people can walk to transit, shopping and entertainment. 

Equity in Growth
There is an equity benefit in adding more housing here.  Adding high density residential anywhere in Ward 3 will make up for the lack of development in Ward 3 compared to other parts of the city where housing construction has been more intense over the past decade, adding pressure of displacement on low-income residents. Adding housing in Cleveland Park is an issue of equity.  Growth brings change, much good, but also challenges that require management and in some cases to just be endured. Ward 3, Cleveland Park included, has a responsibility to share in the growth of our inclusive city.

Affordability and Incentive-Driven Community Benefits
These aforementioned benefits accrue from any added housing, even if all of it is market rate.  The community, however, has additional priorities for any growth that comes to our neighborhood.  Chief among these is providing housing for a range of incomes, and a range of unit sizes, including more multi-bedroom or “family-sized” homes.  Inclusionary zoning will provide a small amount of affordable housing (8-10%) for any project in excess of 10 added units. However, to get meaningful levels of affordable housing and more family-sized units, incentives will be required, and that is where high density FLUM becomes community capital.

Through the Planned Unit Development (PUD) process, communities negotiate with developers to receive community benefits in exchange for added height and density.  If the community does not have bonus density to offer, developers will either build elsewhere, or build matter-of-right. The City Ridge development at 3900 Wisconsin Avenue is an example of a project that lacked community capital, as the by-right zoning (MU-5a) for the site was at capacity of the potential density afforded by the FLUM designation (Low Density Commercial).  There was no incentive for the developer to build anything other than matter-of-right. As a result, the approximately 700 units built there will yield no more than 10% of the required IZ.

The ideal position for the Cleveland Park community is to have future land use of maximum potential density and actual zoning that is less dense than is allowed.  This creates the opposite situation of City Ridge, providing an incentive for developers to work with the community to get as much height and density as possible, in exchange for providing community benefits.  Those benefits could include affordable housing, including deeply affordable, more family-sized homes, subsidized retail rent for local independent businesses, underground parking — whatever the community at the time prioritizes.

Design Review
The entirety of the commercial area is included in the Cleveland Park Historic District.  That will continue to be the case if the change to the FLUM is approved by the Council. The DC Historic Preservation Act requires any substantial physical changes, be they alterations or additions to contributing resources, or infill development, be reviewed by the Historic Preservation Review Board for design compatibility with the commercial area of the historic district. Developments proposed in 2019 at 3432 and 3400 Connecticut Ave are among the first significant commercial area changes since the historic district was formed over thirty years ago. Both were subjected to review and revision by the Historic Preservation office and HPRB, as would any future development.

Zoning
The current zoning for the commercial area is NC-3, which allows for low density commercial and moderate density residential, with height limits of 45 feet with Inclusionary Zoning plus penthouse.  It also has restrictions on PUDs. Updating the FLUM does not change the zoning. The matter-of-right height and FAR do not change. In the NC-3 zone, only a map-amendment can change the zoning of the area which requires a very public and deliberative process with the ANC representing the community.

Conclusion
Changing the FLUM designation for the commercial area does not give any property owner a right to develop to maximum potential.  To do so would require significant community discussion and approval by both the Zoning Commission and the HPRB. What the up-FLUM does is open the door to consider future development with significant community benefits for a well designed and negotiated project.  Not changing the FLUM designation assures us the potential benefits of growth will elude us. Let us not shut the door for another 20 years on the potential for positive change. Instead, let us prop that door open and invite investment in our community. We ask you support amendment 2123 as modified by the Office of Planning for its inclusion in the Comprehensive Plan’s Future Land Use Map.

Respectfully, 

Cleveland Park Smart Growth Steering Committee

Liza Collery
Megan Draheim
Ellen Herr
Nina Shiffrin
Glenn Stanley
Bob Ward
Laura Watson

About CPSG
CP Smart Growth is a community association of nearly 500 Cleveland Park area residents who share an interest in promoting, sharing and discussing urbanist and smart growth issues in Washington D.C. with an emphasis on Cleveland Park.  Our mission is to advance smart growth policies in Cleveland Park to ensure an economically vibrant, environmentally sustainable, and socially inclusive neighborhood. We do this through educating, organizing and advocating.

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