Letter to the Council on Comprehensive Plan Changes
Dear Ward 5 Councilmember McDuffie, Chairman Mendelson, Councilmembers, and 5C Advisory Neighborhood Commissioners,
The undersigned Brookland Manor/Brentwood Village residents and allies ask the Council to oppose the Comprehensive Plan changes proposed by the Mayor for the following reasons:
1. The proposed UpFLUMing** at Brookland Manor is an attempt to work around further community input and developer accountability.
Among the hundreds of proposed amendments, we see that the Mayor has proposed to UpFLUM Brookland Manor’s property in a spot-zoning gift to the developers. The existing PUD already upzones the parcels, so we are concerned because there is no practical purpose for upFLUMing other than potentially extinguishing the existing PUD to build matter-of-right. This means any of the developers’ promises, agreements, and obligations of the already highly controversial PUD project at Brookland Manor could be discarded and the already expected displacement of Brookland Manor families would be accelerated and done so without any required zoning or planning accountability at all. This will harm Black families.
2. The Mayor’s proposed changes lack substantiation and analysis required by the law.
The Comprehensive Plan itself requires progress reporting, impact assessments, and supporting data to show that any proposed amendments are fundamentally sound, based on real planning analysis, & will help and not harm DC residents. However, the proposed amendments were presented without any of this legally required analysis. When residents testified about the law and regulations that show progress reports and impacts studies are required with any amendments to the Plan, we have been ignored or worse. Mr. Trueblood must realize his decisions and that of his staff deeply affect the lives of Brookland Manor residents and vulnerable families across this city. We want the law followed, period.
3. The Mayor’s amendments seek to weaken a Plan that should be made stronger.
The Mayor wants to weaken language in the Plan, making directives discretionary using words like should or encourage instead of shall and require. The recent Court decision regarding the PUD at Brookland Manor shows that if the Zoning Commission has the opportunity to use flimsy policies and rules to benefit the developers bottom-line, they will. The Court affirmed the Commission’s flawed reasoning that the displacement of many Black families may be outweighed by a project they subjectively deem as a “public benefit.” The Commission has been allowed to waive away the future of existing residents for the sake of profit. This is why we ask the legislature to strengthen, not weaken, the language in the Plan.
4. If the racial equity analysis of the Mayor’s proposed changes show failures to address the harm on Black residents, we want the Comp Plan amendments rejected whole cloth.
We understand that the Council Office on Racial Equity is evaluating the DC Office of Planning’s Comprehensive Plan amendments now. We expect to see their report soon and if it makes critical findings that the Plan narratives and amendments harm us, we want the Mayor’s proposed changes rejected and deferred until the Office of Planning actually does the work of planning required by the law and the requirements of the ethics and oath that these certified planners take and make for our city.
**FLUM= Future Land Use Map; upFLUMing essentially means increasing the intensity of land use allowed at a given location (e.g., from low-density residential to a mix of high-density residential and commercial).
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