Comments from 2/12 DC Council Oversight Hearing for the Office of Planning and the Office of Zoning

On February 12, the Board of the Cleveland Park Historical Society (CPHS) provided testimony at the DC Council’s Oversight Hearing regarding the Office of Planning and the Office of Zoning. Our remarks addressed recent zoning decisions affecting Cleveland Park, particularly the proposed rezoning of the commercial corridor within the historic district. CPHS strongly supports housing growth and the expansion of affordable housing. At the same time, we raised concerns about process, transparency, alignment with the Comprehensive Plan, and the need for clear, enforceable zoning standards that ensure appropriate transitions and protect neighborhood character. To keep the community informed, we are sharing our full comments below:

CPHS strongly supports housing growth and expanding affordable housing in the neighborhood. But the Office of Planning’s (OP) proposed rezoning package for Cleveland Park raises serious issues of process, transparency, and consistency with the Comprehensive Plan. First, the Comprehensive Plan Framework Element makes clear that the most intense zoning should not automatically be selected, and that zoning decisions must consider prevailing neighborhood character and surrounding uses. In terms of its proposal for the Cleveland Park Historic District’s commercial strip, OP’s zoning approach exceeds the residential range typically associated with “medium density residential,” and proposes an additional increase in the zone’s standard height—seven stories, plus penthouse. That seems to us to be a deliberate choice to maximize development capacity, not an inevitable outcome of the FLUM designation. Second, OP’s proposal fails to include basic zoning tools that are commonly used throughout the District to ensure predictable transitions between larger development and lower-scale neighborhoods. During OP’s engagement process, the community was shown illustrations of setbacks and stepdowns that indicated these would be part of the zoning framework. OP’s proposal does not include these protections. Instead, OP suggests that HPRB should address compatibility issues later through project-by-project review. That is not an adequate substitute. Zoning standards are enforceable and predictable; they apply equally to all projects. HPRB review is important, but it is not zoning, and it cannot replace clear bulk and transition requirements, especially next to a historic district. Third, we have heard that this out-of-scale rezoning package is necessary to gain affordable housing. But let’s consider the numbers: Ward 3 has already exceeded the Mayor’s housing production goals, with more than 3,600 units built since 2015. Yet the affordable housing yield from private development has been limited—only 482 affordable units from completed projects. And so, we urge the Council to use its oversight authority to require OP to publicly quantify what the rezoning is expected to deliver—how many affordable units, at what income levels, and on what timeline—and to evaluate alternative zoning approaches that better align neighborhood impacts with measurable results. CPHS has also tried to be constructive. Years ago, we developed and submitted design guidelines for the Cleveland Park commercial strip to help accommodate growth while protecting the integrity of the historic district. During the December 1 hearing, we reminded the Commission that these were available on HPO’s website and ours: https://www.clevelandparkhistoricalsociety.org/guides/cleveland-parks-design-guidelines-aug-2023.pdf Finally, we must again express our dissatisfaction with the Zoning Commission’s decision to close the public record on the Cleveland Park rezoning case before the record was complete—despite knowing that OP would be submitting significant additional information. Last December, we wrote to you, Matt Frumin, Anita Cozart, and Anthony Hood, asking that the record be reopened. The Chair has the authority to reopen the record, and we strongly believe the public should have the opportunity to comment on whatever OP submits. Decisions about the future of Cleveland Park should not be left to a closed dialogue between OP and the Zoning Commission. CPHS respectfully asks the Council to require OP to revise its proposal so it aligns with the FLUM designation, Comprehensive Plan guidance, and the District’s commitment to protecting historic districts. Board of the Cleveland Park Historical Society