The BNCA has developed a set of proposed amendments for the DC Office of Planning to consider as it undertakes an update to the DC Comprehensive Plan. Our formal comments are provided here:
BNCA comments on and proposes amendments to the DC Comprehensive Plan
6/21/17
At our January 17, 2017 general meeting, we solicited member feedback on the “Principles” that BNCA should communicate to the City regarding the elements of the Comprehensive Plan that relate to the Brookland community (meeting minutes). The main ideas we heard are presented in the bullets below organized around key topics.
More information about the Comprehensive Plan update process is available at PlanDC.dc.gov. There you can find the current Plan that is to be updated. An overview of how the Plan is organized is here. Brookland is in the Upper Northeast Element, one of 10 Area Elements of the Plan. Also particularly relevant to our comments is the Implementation Element, which contains action items related to Brookland.
And here is a link to the 2007 Brookland Small Area Plan, which was incorporated into the Comprehensive Plan in 2011.
During this amendment cycle, the City is emphasizing the concept of Resilience.
Finally, if you disagree with how an area is currently designated on either the General Policy Map or the Future Land Use Map, which accompany the Comprehensive Plan, you can make suggestions to change these designations as well (e.g., recommend that a “high-density residential area” be changed to a “moderate-density residential area”).
All of these materials are potentially subject to amendment by the City – especially if we draw attention to ways in which we believe they can be improved! Please share your thoughts!
BNCA Membership “Principles” from January 17, 2017 general meeting:
General
- Preserve and strengthen current language in the Plan that recognizes Brookland as a stable, residential, historical neighborhood that should largely be conserved in existing character. Brookland is not at all an acceptable location for high-density, high-rise infill.
- Incorporate the concept of “carrying capacity” into neighborhood planning. How much traffic, how many residents, how much infrastructure can reasonably be accommodated while preserving quality of life for all residents? The City should be investigating this more comprehensively.
- Inclusivity and diversity are important to Brookland – economic, racial, and cultural diversity. Gentrification without ameliorating policies is a threat to the community.
- Private developers are essentially uncontrolled by OP, BZA, or DCRA in Brookland. They have enormous discretion and projects are almost always approved, regardless of neighborhood input. Residents have had to seek relief from the courts, and the courts have agreed with residents that the City is not upholding its own planning laws. (See 901 Monroe and McMillan litigation). This lack of law or accountability needs to be remedied.
Green Space / Open Space
- Preserve, enhance, and increase accessible public green space, including on institutional properties
- Protect and enhance the Brookland Green, as the City has committed to do
- The urban tree canopy should be maximized and extended. Old trees should be protected. New native trees should be planted wherever appropriate.
Development
- The rapid level of construction of new residential in-fill near stations is overwhelming residents and degrading quality of life.
- Developments should be consistent with existing character
- Need for new development based on population projections seems uncertain. City should validate and “show its work” for its population projections – how were they arrived at, and how certain is the City that they are reliable?
- There should be no net loss of greenspace with any development.
- Developers should be required to provide traffic and environmental plans for each development. Existing planning and zoning requirements allow the developers to do whatever they want without restriction.
Housing
- Protect and increase affordable housing – real affordable housing, not just a % of AMI that does not reflect real incomes of residents.
- Preserve existing levels
- Provide incentives to protect and increase affordable housing stock
- Existing residents should be protected
- Aging population and senior housing should be protected
- Exclusive developments, such as the use of homeowners associations to enforce private rules of access, or gated communities, are completely inappropriate for this community.
- Reduce use of cookie-cutter “curb-to-curb” townhouse/condo design;
Historical Preservation
- Historical sites and properties should be appropriately protected
- The character of 12th Street is mixed; while existing facades and character are generally preferred to any sweeping change, a more consistent, “boutique” character to the corridor from RI Avenue to Michigan Avenue should be pursued with an emphasis on bringing in local business.
- Require greater integration of new buildings with existing architectural elements.
Industrial lands/Environmental
- Heavy industry is not appropriate within, or anywhere adjacent to Brookland. Heavy industrial uses should be relocated.
- The City should investigate and provide a comprehensive assessment of environmental risks associated with living in Brookland, with an emphasis on air pollution exposure from diesel truck traffic, industrial facilities such as the recycled asphalt plant along MBT
- More information on remediation activities should be made available to the public.
- City should be more active in determining whether development is appropriate on certain contaminated sites, and rigorously pursue cleanup of those sites.
- Hazmat transport on roads and railway has not been addressed, despite language in current Plan. City is building more housing very close to the railroad. This is a recipe for disaster. City must establish a prohibition on transport of Hazmat with CSX.
- Our water supply is at risk of contamination. City should protect groundwater, enhance stormwater retention requirements, and enhance and expand permeable surfaces, especially through use of native ecological restoration.
- Emergency evacuations should be better planned and explained to the public.
