topic index



There are few documents potentially more germane to NARPAC's raison d'etre than the Comprehensive Plan for the National Capital. This chapter summarizes the new draft of the Federal Elements half of the plan made available for comment in April, 2004. NARPAC then provides its own extensive analysis of what it found, both positive and negative. In conclusion, it provides its earlier summary and comments on the older DC Elements half of The Plan Where possible, this section provides actual quotes from the draft to protect the character of the document from NARPAC's not inconsiderable biases. It is important to understand from the outset that there are two separate and presumably equal parts of this plan:

The Comprehensive Plan for the National Capital is actually comprised of two parts the Federal Elements and the District of Columbia Elements. The Federal Elements address matters related to federal properties and federal interests in the District and the region. The DC Elements address citywide issues such as land use, human services, housing and economic development.

The Federal Elements Plan has nine chapters, followed by three sets of NARPAC comments:

o Introduction
o Federal Workplace, Location, Impact, and the Community
o Foreign Missions and International Organizations
o Transportation
o Parks and Open Spaces
o Federal Environment
o Preservation and Historic Features
o Visitors
o The Action Plan

o NARPAC Detailed Comments
o NARPAC General Comments
o NARPAC Comments on DC's 'Topographic Bowl'

The older DC Elements Plan has eleven chapters, also followed by NARPAC's commentary:

DC Elements of the Comprehensive Plan


The draft begins with some broad statements that make it clear that the nation's capital is a special place, but it is somewhat ambiguous about what "the capital" includes area-wise, as well as what constitutes its image:


National capital cities have distinct planning and development needs that distinguish them from other cities. While they share many traits of other major cities, by virtue of their national constituency they have unique qualities and requirements that must be accounted for in their planning. The Federal Element (this plan) is based on the premise that the nation's capital is more than a concentration of federal employees and facilities. Washington, DC is the symbolic heart of the nation. It provides a sense of permanence and centrality that extends well beyond the National Capital Region (NCR) and our national borders. It represents national power and promotes the country's shared history and traditions. Through its architecture and physical design, it symbolizes national ideals and values.

The nation's capital has a long and distinguished planning history, resulting in a civic and monumental architecture and art arrayed in a rationally planned landscaped setting that is both efficiently modern and classically beautiful. A green setting, open spaces, and parks also figure prominently in the identity of the NCR a testament to the vision and determination of the city's earliest leaders. The result is a city and a region that comprise one of the world's most recognizable and appealing capitals.

federal impact on the region

It provides some interesting "gee-whiz" statistics on its importance to the region:

o There are more than 230 memorials and museums in DC and surrounding environs. In 2001, the region attracted approximately 20 million visitors stimulating over $4 billion in regional economic activity....

o In 2002, there were 169 foreign diplomatic missions and 28 officially recognized international organizations in NCR.....and they contribute to the city's cosmopolitan flair....

o Although the federal share of total regional employment has declined over the past quarter century, the federal government continues to be the largest employer in the region....In 2000, approximately 370,000 federal employees 15% of the total regional workforce worked in the NCR.

o The value of federal procurement contracts in the NCR more than doubled between 1990 and 2000, reaching $28.4 billion....and accounting for 21% of the Washington area's gross regional product.

o Federal leased space in the NCR amounted to 55 million square feet in 2003.....(while) federal owned space amounted to 155 million (74% of the total)...of the total space, 43% is in DC, 30% in Maryland, and 27% in Virginia (site maps are included).

o ....The federal government has jurisdiction of 321 square miles, or 13% of the region's 2412 square miles.

o Washington, DC devotes 19.3% of its land area to parkland, ranking well above the average of 8.8% among 55 cities rated. At $155 per resident, the city ranks fourth in the amount of park spending per resident among 48 cities ranked well above the average of $80 per resident.

(NARPAC aside:) As NARPAC never tires of reminding its readers, the National Capital Region (NCR) is seriously skewed to the West by ignoring the more eastern Maryland counties of Howard, Anne Arundel (seat of Maryland's attractive capital, Annapolis), Calvert and Charles. This results in slowing the development of Prince George's County, and of DC itself, East of the Anacostia River).

NCPC role and responsibility

There are awkward divisions of planning responsibilities between the federal government, and the independent-minded local DC politicos, but they are hardly evident here:

"The significance of the federal presence in the region demands expert planning and coordination. As the central planning agency for the federal government in the NCR, the NCPC is charged with planning for the appropriate and orderly development of the national capital and the conservation of its important natural and historic features.

The Commission coordinates all federal planning activities in the region, and has three principal functions: comprehensive planning; master planning, project planning, and program review; and multi-year federal capital improvements planning

. Section 4 of the National Capital Planning Act of 1952 requires that NCPC prepare and adopt a "comprehensive, consistent, and coordinated plan for the National Capital". The Comprehensive Plan for the National Capital is the blueprint for the long-term development of the national capital and is the decision-making framework for Commission actions on plans and proposals submitted for its review. The Act requires that federal agency plans and projects and DC governmental actions "not be inconsistent" with the Comprehensive Plan."

planning framework: vision, goals, guiding principles

The plan goes on to describe the three century-long planning legacies of the L'Enfant Plan, the McMillan Commission Plan, and more recently the "Extending the Legacy Plan for 21st Century, and then turns to a summary of its overall vision and principles:


"A vibrant world capital that accommodates the needs of our federal government, enriches the lives of the region's residents, workers, and visitors, and embodies an urban form and character that reflects the enduring values of the American people."

a. accommodate federal and national capital activities
b. reinforce smart growth and sustainable development planning principles
c. support local and regional planning and development objectives

planning program: federal elements

The introduction concludes with the identification of the seven major planning elements (down from eleven in the 1984 Comprehensive plan). It should be understood that these sections that follow are almost entirely summary platitudes and policy statements to the effect that "the federal government should" do this or that. 32 specific "action plans" come at the end of the document. "Bulletized" versions of each facet are included in easy-to-read "boxes". As some indication of emphasis, NARPAC has duly counted the pages devoted to each of the topics, as well as the total included "policy bullets". For whatever it's worth; foreign ministries, international organization, and visitors get 28 pages and 52 policy bullets, while parks and open space, federal environment, and preservation and historic sites together get 59 pages and 179 policy bullets. The two sections of most interest to NARPAC concerning the federal workplace and its ramifications plus transportation, get 56 pages and 112 policy bullets.

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(38 pages, 62 policy bullets)


These opening statements are worth repeating:

"From its beginning, the nation's capital has been planned for the special purpose of serving as the seat of the federal government. Conceived as a capital of a great nation, it was not intended to be completed in the life of one administration, or one generation, but to be built over time. As it developed, facilities to house the permanent offices of the government have been built to promote the efficient conduct of governmental functions. These buildings were also meant to serve as a source of national pride, providing testimony to the dignity, enterprise, vigor, and stability of our system of government. These facilities have, through their location, guided much of the way the NCR has developed......"

"......Through its growing purchases of goods and services to support its operations, the federal government has become the region's major customer for private sector activities. This activity has become a significant factor in the economic development and health of the region and its communities. But this activity has made the federal government highly dependent on a strong and economically vibrant region to maintain and enhance its operational efficiency and productivity. This relationship results in common social and economic interests between the federal government and the various jurisdictions within the region, with important implications on how federal workplaces and their communities develop in the future....."

Federal agencies also need consider how their workplaces relate to their community. Do their activities fit with the development plans of the community? Its economy? Do they have the potential for community-desired spin-offs, including new residents or business activities. How do their security requirements impact the vitality and visual character of their communities? Are there opportunities to enhance and beautify the community's public realm through security installations?..."

"Policies in this section....encourage federal agencies and communities to work together to improve operational efficiency and productivity of federally owned and leased workplaces and the economic health and livability of communities within the region."

This opening section goes on to discuss the relationships between federal workplaces and a vibrant region, including federal procurements, employment, and facilities and their total regional impacts; current locations and needs of federal workplaces and their continued development in the NCR; and some general location considerations concerning use of existing resources, alternative modes of transportation, and meeting common goals and objectives.


Locating Federal Workplaces

with regard to DC and the Monumental Core:

"....On July 30, 1947, PL80-279 (4 USC $71 et seq.) Reconfirmed the importance of a cohesive national government for government efficiency that "all that part of the territory of the US included within the present limits of DC shall be the permanent seat of government of the US" and that "all offices attached to the seat of government shall be exercised in DC and not elsewhere, except as otherwise expressly provided by law".

As the metropolitan area has grown beyond the borders of DC, Congress recognized that the planning of federal facilities within the region should be coordinated and contribute towards solutions of community development problems of the region on a unified metropolitan basis, while still maintaining DC as the seat of government.

Within PL 109-185 ((40 USC $8302 (2003)), Congress declared that, "because the District which is the seat of the government of the US and has now become the urban center of a rapidly expanding Washington metropolitan region, the necessity for the continued and effective performance of the functions of the Government of the US at the seat of said Government in DC, the general welfare of the DC and the health and living standards of the people residing or working therein require that the development of DC and the management of its public affairs shall, to the fullest extent practicable be coordinated with the development of the other areas of the Washington metropolitan region....

In 1968 a policy was adopted as part of the Federal Element of the Comprehensive Plan which stated that 60% of the region's federal employees should work in DC and 40 percent should be located elsewhere in the Region. ...This policy remains today."

This section goes on to discuss existing facilities and resources, and the regional distribution of federal workplaces, complete with tables and diagrams.

Development of Workplaces with Communities

Coordination with the Community

"When leveraging federal investments to benefit the surrounding community, federal agencies should incorporate into federal workplaces uses that would be valuable to the community. Federal agencies should consider the addition of publicly accessible mixed uses; including shopping, dining, entertainment, and residential within their workplaces. The Public Buildings Cooperative Use Act of 1976 (40 USC $490) supports the leasing of space in public buildings for these types of uses for cultural, educational, or recreational activities."

Business Development

"Placing new federal workplaces in distressed areas can promote the revitalization of communities in which few employment opportunities or services exist. If economic incentives are necessary to help business development within a neighborhood, federal agencies should use existing federal programs when valuable, such as the Empowerment Zone/Enterprise Community programs....."

and continues with policies re building and development codes and energy efficiency.

Excess Property

" When disposing of excess land, agencies should work with the community to undertake plans for economic development and/or to use the property or facilities for other public (including open space) and private spaces. The disposal of excess federally owned property should result in minimal adverse economic impacts on affected communities. Its future use should contribute towards solving existing community development problems. Guidance on the disposal of federally owned property can be found in......"

and concludes with lengthy policies for the working environment, and physical security.

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(19 pages, 32 policy bullets)


This section begins with an interesting analysis of the economics and fiscal impact of foreign missions, noting that they employ about 10,000 workers in DC, with an annual payroll of about $300M. The missions produce consumer spending about $32M, and non-payroll spending about $258M. They attract business/visitors who spend about $183M and DC collects $24M from taxes generated by leased space, rented homes. It goes on the describe historic sites as well as future building requirements, which may be substantial.


There are extensive guideline for chanceries, both programmatic, location and siting, and about urban design, historic preservation, access, and open space and parkland. These are followed by policies for ambassadors' residences and for international organizations (very few!). The most interesting policy to NARPAC is the concept of promoting new chancery areas in high density "foreign mission centers".

(NARPAC Aside:) NARPAC retains its high interest in developing much larger resources for DC by encouraging foreign missions to participate in a federally-sponsored "International Mall" to match the National Mall. It would include permanent displays by major countries, as well as residential accommodations for foreign visitors and students: the equivalent of a permanent "world's fair" setting to significantly increase tourist visits and stay-time.

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(19 pages, 57 policy bullets)


"It is the goal of the federal government to develop and maintain a multi-modal transportation system that meets the travel needs of residents, workers, and visitors, while improving regional mobility and air quality through expanded transportation alternatives and transit-oriented development".


Commuter Rail, Rail Transit, and Bus Transit

the federal government should support:
* capacity and service expansion of regional Metrorail and Metrobus....
* expanded levels of commuter rail...
* increased use of passenger rail service, conventional and "maglev"....
* exclusive transit row's to all regional airports, with TOD at stations along route...
* design/implement innovative transit systems: Circulator, Busway, BRT, light rail, trolley
* help jurisdictions supplement Metrorail with light rail
* developing intermodal transit centers...


the federal government should:
* provide only for fed employees with no other choice;
* give priority to carpools and vanpools;
* provide for disabled persons;
* provide for official vehicles;
* emphasize park in structures, preferably below ground;
* avoid obstructing access by bikers, walkers;
* try to use nearby commercial space at market rates;

Parking Ratios

the federaql government should provide no more than: * 1 space per 5 employees within (downtown) CEA;
* 1 for 4 outside CEA, inside Historic DC;
* 1 for 3 at suburban federal facilities near Metro stations; and
* variable at suburban federal facilities away from Metro stations.

This section goes on to discuss policies for transportation management plans and demand management, shuttles and circulators, other infrastructure and transportation services, and includes exhaustive guidelines for bicycle facilities. Here there are policies for travel lanes on major roads, secure racks, lockers/showers in federal buildings, safe entry to garages, usage promotion, continuous trails from beyond beltway, and lockers/racks for stations and buses.

Investment Priorities

The section concludes with six investment priorities summarized as follows:

o fix it first, maintain existing facilities;
o increase capacity of regional transit;
* improve transit, roadway access in dense areas;
* extend transit to under-served areas;
* deploy new "intelligent transportation" technologies for better roadway use; and
* integrate transit services

(NARPAC Aside:)we believe this is the only instance in the entire comprehensive plan in which investment priorities are mentioned or ranked.

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(28 pages, 83 policy bullets)


It is the goal of the federal government to conserve the park and open space of the NCR, ensure that adequate resources are available for future generations, and promote an appropriate balance between open space resources and the built environment.


General Policies include a) expansion and enhancement, which includes planning for new parks as part of the park system in the region, acquiring parks and open space as necessary, and acquiring land for parks and open space by easement, donation, purchase, exchange, or other means; and b) preservation and maintenance, which includes conserving portions of military reservations that add significantly to the inventory of park, open space, and natural areas and should, to the extent possible, be used by the public for recreation. Examples include Andrews Air Force Base, Fort Belvoir, US Soldiers' and Airmen's Home, Fort Meade, and Marine Corps Base, Quantico, and c) efforts to assure access and connectivity.

Parks and Landscape Policies include monumental and designed landscape parks as well as natural, waterfront and historic parks as important legacies of national, historic, architectural, and landscape significance, including.....Fort Circle Parks.....Manassas National Battlefield Park......C&O Canal National Historic Park......Mount Vernon National Historic Site....etc.

Terrain Features Policies include general policies, as well 46 policy bullets dealing with palisades and gorges, greenways and greenbelts, rivers and waterways, trails, gateways and parkways. Of special interest to NARPAC, there is also an educational section, largely unchanged from the 1984 Plan, describing and proscribing:

DC's Topographic Bowl

From L'Enfant's time onward, topography has defined and characterized the capital, resulting in thoughtful relationships between urbanized areas and natural terrain. (Therefore:)

Maintain the prominence of the topographic bowl formed by lowland and rim features of the L'Enfant City and environs by controlling the urban and natural skylines in the Anacostia, Florida Ave, and Arlington County portions of the bowl as follows:

o preserve the green setting of the Anacostia hills, and integrate building masses with and subordinated to the natural topography;
o maintain the Florida Avenue escarpment's natural definition of the L'Enfant Plan boundaries by retaining developments that are fitted to the landforms and by promoting low-rise developments that are fitted to the land forms and by promoting low-rise development that can be distinguished from the greater height of the L'Enfant City's core areas;
o Within the western portion of the bowl, retain a horizontal skyline by relating building heights to the natural slope and rim areas of Arlington Ridge as viewed from the Capitol, the Mall, and other riverside outlooks;
o In the background areas of the Mall vista, as viewed from the west terrace of the US Capitol, the urban skyline within the basic building height limits specified by Arlington County in an agreement with the Commission for the Rosslyn-Ballston corridor, exceptional, or "bonus" heights should be avoided.

(NARPAC Aside:)NARPAC, appalled by its own corporate ignorance of the existence of this major (?) topographic feature of the nation's capital, sees this on the one hand as an extraordinary constraint on the future economic development of the nation's capital city, but on the other hand as a natural limit to the arbitrary imposition of development constraints "beyond the rim". This is discussed further below

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(18 pages, 55 policy bullets)


It is the goal of the federal government to conduct its activities and manage its property in a manner that promotes the NCR as a leader in environmental stewardship and preserves, protects, and enhances the quality of the region's natural resources, providing a setting that befits the local community, provides a model for the country, and is worthy of the nation's capital.

(NARPAC Aside:) It is to NARPAC's keen disappointment that there is no equivalent statement in this Comprehensive Plan setting forth the same goals for the quality of life of many residents of the nation's capital.


There follow here 55 policy bullets concerning general policies; air quality; water resources, including water quality and supply; land resources, including floodplains, wetlands, soils, vegetation and wildlife habitats; and human activities which are limited to environmental justice, solid waste management, hazardous materials management, noise, and radio frequency radiation and electromagnetic fields return to the top of the page PRESERVATION AND HISTORIC FEATURES
(13 pages, 41 policy bullets)


It is the goal of the federal government to preserve and enhance the image and identity of the NCR through design and development respectful of the guiding principals of the L'Enfant and McMillan Plans, the enduring value of historic buildings and places, and the symbolic character of the capital's setting.

"As the capital city, Washington represents the nation. The visual image of Washington is experienced by residents and visitors, and transmitted around the nation and world by the media, through familiar historic images even on our currency. This resonating and powerful image is formed in part by individual buildings and monuments, and in part by the overall urban design of the city particularly because central Washington's overall form has been explicitly, and very successfully, designed to create and convey an urban image that symbolically expresses the nation. Now that the federal establishment has grown beyond the original capital city to become a significant presence throughout DC and beyond, the historic resources of the entire region have a role in shaping the image of the capital. ...."


National Capital Image

o express the dignity befitting the image of the federal government in the nationasl capital. Federal development should adhere to the high aesthetic standards already established.....
o plan carefully for appropriate and compatible uses in and near the Monumental Corde to reinforce and enhance existing uses and historic charascter;
o preserve the historic building height limit within DC through enforcement of the 1910 Height of Building Act (36Stat. 452;DC Code, sec.5-401 et seq).
o protect the skyline formed by the region's natural features, particularly the topographic bowl around central Washington, as well as historically significant built features, from intrusions such as antenna towers, water towers, and rooftop equipment;
o protect and enhance the vistas and views, both natural and designed, that are an integral part of the national capital's image;
. o create transportation infrastructure that is consistent with the pedestrian character of L'Enfant City and other historic settings. Bridges across the Potomac and Anacostia Rivers should be integrated with the design character of historic contexts. Highway structures should be removed and replaced with at-grade streets where possible.

The section continues with dozens of policy bullets on the stewardship of historic properties and the historic plan of Washington, DC.

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(9 pages, 20 policy bullets)


It is the goal of the federal government to accommodate visitors in a way that ensures an enjoyable and educational experience, showcases the institutions of American culture and democracy, and supports federal and regional planning goals.


This section sets forth policies concerning federal visitor attractions, programs ans special events, but focuses on:

Visitor Transportation

o encourage federal visitor attractions within walking distance of public transportation.....
o support increased visitor access to federal and local visitor attractions in the Monumental Core through a Downtown Circulator system or other transit alternatives (e.g., light rail)......
o support supplemental forms of transportation, such as shuttle service......
o encourage DC to develop tour bus parking and management strategies in the District to reduce traffic congestion.....
o improve information dissemination....
o increase visitor awareness about long-term parking.....
o encourage increased use of bicycles to access attractions.....
o encourage local governments to promote water transportation...and .
o promote a pedestrian friendly monumental core.....

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(19 pages, 32 action plans)

In an interesting attempt to cross reference the seven federal elements with more general goals, the NCPC planners have adapted four seemingly more general themes against which to array their specific "action plans". This seems, in fact, to be the only few pages of this 200 page document that relates to planned actions, presumably by their own staff members in conjunction with other appropriate federal agencies. The four overarching themes are described by quotes from the report, and the 32 planned actions are distributed between each, both in terms of the involved planning element and in terms of their 16-each short- (*) or long- (o) term nature.

Theme 1: Image of the National Capital Region

" The Commission has been a strong advocate in maintaining the Nation's Capital and Region as one of the most beautiful capitals in the world. The symbolism and image that Washington conveys are immediately recognizable and unequaled. The Commission's work......speaks to its continued commitment to hold the Nation's Capital in high esteem....and to protect the city's character....."

Action Plans:

* Parks and Open Spaces: update 1976 master plan of National Mall
* Visitors: assess appropriateness of various means to assure availability of monument sites
* Federal Workplace: facilitate implementation of NC urban design and security plan
* Parks and Open Spaces: conduct viewshed analysis of MonCore from surrounding bowl sites
* Federal Workplace: improve regional gateways
* Parks and Open Spaces: help develop Anacostia Waterfront Initiative
* Transportation: develop plans to remove/relocate parts of SW/SE Freeway to restore street grid
* Transportation: realign existing railroad that runs south and east of capital

Theme 2: Operational Efficiency of the Federal Government

"A commitment to enhancing the operational efficiency of the federal government is a primary goal of the Plan. Understanding the current conditions of federal activities and the future needs of federal employees is paramount to improving efficiency....."
Action Plans:

* FM/IO: revise DC zoning regulations
* FM/IO: revise Dept of State real property manual
* FGM/IO: identify new FM center sites
* Federal Workplace: assess key federal economic/demographic indicators rel federal presence
* Federal Workplace: develop workforce housing program to help federal agencies
* Visitors: identify viability of potential sites for visitor centers
* Federal Workplace: establish/maintain central resource to collect/analyze fed historic sites
* All elements: streamline NCPC project submission process
* Transportation: develop new TMP submission guidelines
* Federal Workplace: monitor and report on federal procurement activities
* Federal Workplace/Transportation: re-examine Central Employment Area boundaries

Theme 3: Transportation Mobility and Accessibility

"Closely linked to federal operational efficiency is the mobility of the federal workforce. Improving mobility provides advantages to federal workers and the federal government generally, as well as all who reside in or visit the region. Mobility goes well beyond putting more cars on already overflowing roads....."
Action Plans:

* Transportation/Federal Workplace/Visitors: design downtown circulator service
* Transportation: design/construct Kennedy Center plaza
* Transportation/Visitors: design/construct central tour bus parking facility near Nat'l Mall
* Transportation: investigate strategies to increase Metrorail system capacity
* Transportation: help plan extension of transit system to Tyson's Corner/Dulles airport
* Transportation/Federal Workplace: construct bicycle paths/lanes on/near federal installations
* Transportation: plan for future water taxi service

Theme 4. Stewardship of Natural Resources

" The region's beauty is exemplified not only in the stone, marble and granite found in its manmade structures, but also in the natural beauty in its open spaces and parks, its forests, its waterways, its topography and its views and vistas. The federal government has been a vigilant steward in the preservation and enhancement of these natural resources...."
Action Plans:

* Parks/Open Spaces: develop central database for collecting/analyzing parks/open space
* Parks/Open Spaces: pursue protection/acquisition of connected outer ring greenway
* Parks/Open Spaces: enhance fort circle park system
* Parks/Open Spaces: develop Georgetown Waterfront Park link Rock Creek/Potomac Palisades
* Parks/Open Spaces: study potential for non-motorized recreation boating on Potomac and Anacostia Rivers.

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NARPAC was given the opportunity to make brief verbal comments to the NCPC planners and developed the following short, concise lift of specific suggestions:

April 19, 2004

Good afternoon. At NARPAC , we aren't trying to make over the world in our image. We just want to make over DC's global image as a symbol of American prowess.

We seek a thriving metro area that supports a dynamic core city that supports the world's greatest capital. We do not seek a white marble theme park surrounded by camp followers.

We find it shameful to have 1,000 acres of pure greed, and 18,000 acres of pure squalor within 4 miles of the capitol and no local, regional, or federal help in erasing DC's Third World image!

This area has disproportionately high shares of the metro area's poor, unemployed, and incarcerated, its single moms; teen pregnancies, child mortality, homicides; school drop-outs, under-used schools, and "below-basic" scoring kids; plus the area's lowest life expectancy; worst air quality and traffic jams, and least productive local government. Hardly an image to "preserve and enhance".

DC's root problem is simple: too few taxpayers for too many tax-takers living too close together, with too many marginal bureaucrats ministering to their welfare: like many other older US cities.

Your draft document is full of great stuff some of it could have been lifted directly from our web site. Most of the material is necessary, but sadly, not sufficient. For us, the real questions are:

a) could this document really help our capital city's distress? (and it is a city, not a "community")?
b) do the physical actions translate into DC's human, monetary, and bureaucratic needs?
c) will our core city gain ground relative to its expanding suburbs? and
d) are the actions consistent with the stated policies and real-world funding profiles?
Other than the Anacostia Waterfront Initiative, the action plans appear unlikely to relieve DC's nationally and internationally embarrassing image of a lousy urban quality of life.
We intend to submit policy comments and action suggestions keyed to our goals and treated on our web site. Here is a short (very blunt!) summary of our marginal notes to date

The themes are a good idea, but don't really cross-walk matrix-style with the elements:

o You need a theme about federal participation in city, not community, development: and....
o another (or element plan) to stimulate regional cooperation in politics, finances, poverty, etc.;
o Don't limit the "NCR Image" visual (post-card) aspects, include quality of life statistics;
o The Transportation Mobility/Accessibility theme is a fiscally unrealistic hodgepodge;

With a few key exceptions, the policies are much stronger than the action plans:

Federal Workplace: Location, Impact, and the Community:

o No policy to use education to rid poverty: job training, mentor kids, run military high schools;
o No policy for regional developments East of DC: viz., Annapolis, Andrews AFB;
o Wrong policy not to relax archaic building height limits near booming edge cities;
o No plans to give up surplus, under-utilized (mostly military) close-in properties;
o No evident connection to the forthcoming DoD BRAC process (base closures);
o No evident plan to help DC East of the Anacostia (EoA);

Foreign Missions, and International Organizations:

o No policy to press FM/IO to provide substantial tourist/visitor attractions;
o No plan to create a permanent "International Mall" (exposition center) somewhere EoA;


o No policy to beef up Metro in-town: improve commuter rail/busways to the outer suburbs;
o Wrong policy to pry Americans from their cars: generate revenues from their addiction instead;
o Wrong plan to waste billions to remove SW/SE Freeways, RRoW: assimilate them;
o No plan to adopt new vehicle parking, tagging, fee-setting, tracking technologies;
o Too much on bicycles, nothing on commercial trucks, urban trash processing/removal;

Parks and Open Space:

o No plans to "swap" excess in-town parkland for more suburban parkland;
o No plans to make parks more revenue-productive;
o No plans to exploit "dirt rights" such as underground parking (viz.G'town W'front);

Federal Environment:

o No plan for adopting hybrid vehicles for federal agencies, FM/IO and their support contractors;
o No plan to get rid of hundreds of acres of surface parking lots within sight of capitol;

Preservation and Historic (P/H) Features:

o No policy to "de-access" outdated historic features, monuments, etc.;
o No policy for "air-rights" or "dirt-rights" over/under P/H features;


o Wrong policy to farm out important attractions to far suburbs like Dulles and Quantico);
o No plans to accommodate tour buses all around city (under parks/near Metro, etc.)

Thank you for this brief chance to offer some hopefully constructive comments.

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NARPAC was also given the opportunity to submit longer written comments, and did not hesitate to do so. It is using this version to provide references to the various parts of this web site where further exposition can be found.


The more closely NARPAC looks at this draft update of the Federal Elements half of the Comprehensive Plan for the National Capital, the less satisfied we become. While we do not reverse any of the truncated verbal comments provided at your second public hearing, there are several substantive issues that need to be confronted more broadly.. These formal comments are therefore somewhat longer, somewhat more negative, and somewhat more at risk of offending the plan's authors. We try to walk the line between pussyfooting and eye-poking in order to provide constructive comments that will catch your attention.. We strongly believe that good planning is essential to "restoring pride in America's capital": our sole raison d'etre.

The present draft appears to be a smooth conglomeration of platitudes on the one hand, and enthusiastic support for virtually all special interests on the other. At the general long-range end, NARPAC finds the projections for the long-range future of this (and other) metro areas inadequate, and far too focused on federal property development with virtually no attention to the metro area's quality of life and discrepancies therein. At the specific, short-range end, the "action plans" themselves seem rather weak and the four "themes" do not fully accomplish their cross- cutting objective. Here are several very basic issues that we believe need further consideration:

o it is not consistently clear whether NCPC considers "the capital" to be a region, a city, or a cluster of federal properties;

o the frequent references to "the community", apparently meaning everything-but-federal- property-and-workers, can easily be interpreted as condescending if not arrogant. The quality of life in some parts of that community severely tarnishes the national capital image;

o two free-standing component plans are not sufficient to provide a comprehensive regional plan that clearly spells out the common aims and the several major areas of interdependence;

o the NCPC "image" of "the capital" is weighted far too much on the world-class quality of federal property and too little on the capital city's Third World quality of life;

o the plan over-emphasizes historic preservation and green space, while underplaying the American focus on the future and high-mobility, high-speed, high density living;

o to be comprehensive, this long-range plan needs more broad projections of the economic, sociological, and technological trends already changing the role and face of US "core cities" and metro areas. The notion of a single core city with a single downtown may well become obsolete.

o the total absence of cost estimates for the proposed improvements compared to the real-world, but also undefined, limitations on resources, established land uses, and usable volume (3-D space), reduces the plan to a catalogue of unconstrained special interests without priorities;

o from NARPAC's viewpoint, virtually none of the top priority actions needed to improve DC's globally-evident below-par quality of life are included: more unencumbered revenue-producing land area under DC control; and more regional and federal sharing of the growing jurisdictional inequities in wealth, health, poverty, and education that mar the national capital's image;

o there is no apparent correlation between this plan and key federal/congressional legislative time tables. 2004 is a key time in preparing for the infrequent release of under-utilized military properties through the accepted "BRAC" (Base Realignment and Closure?) process. There are well over one thousand acres of extinct airfields and outdated specialty headquarters and laboratories within DC, but no plans to gradually convert them to contribute to the capital image.

What is "the capital"?

NARPAC views our national capital as "a thriving metro area (rapidly becoming the basic American economic subdivision), that supports (doesn't ignore, or compete against) a dynamic core city (a self-sufficient, growing, proud collection of residents, workers, and visitors), that supports the world's greatest capital (the physical and human infrastructure that houses and supports the federal government, and would move if the capitol moved).

While there are some grand statements like "The result is a city and region that comprise one of the world's most recognizable and appealing capitals" (last sentence, Introduction), the rest of the plan is often ambivalent about whether it is referring to a region, a city, or just federal property. One of the most egregious shortcomings of the plan is that it almost never refers to the people that populate those areas. They are apparently subsumed in "the community" (below).

NCPC's Use of the Word "Community"

While this may seem to be an oversensitive detail, NARPAC finds the frequent references to the "communities" surrounding the federal presence to be somewhat trivializing, if not demeaning. It not only underrates the role of the capital city (600,000 people), and the region (2,600,000 people), it appears condescending. To those who refer to the more than 140 "neighborhoods" in DC as communities, the use of that word in its broader, but rarer, sense adds to the suspicions that the federal government looks down on its surrounds. We would prefer greater use of the words "capital city" for DC, and "neighboring jurisdictions" for the rest of the region.

Two Elements Aren't Enough

Recognizing the petty political sensitivities between city and federal government, this plan does not try to minimize them. It is patently silly to expect the city to "address city wide issues such as land use (why first in line?), human services (oh, them), housing and economic development" in a separate "DC Elements" when DC is overwhelmed and constrained not only by the 300-pound (and growing) Federal Gorilla, but also by the indifferent, if not downright exclusionary, policies of the more prosperous, faster growing, uninhibited inner and outer suburbs.

Although giving lip-service to a defined "region", there is no document for "Regional Elements". It would raise basic issues which are properly the domain of regional authorities that do exist (WMATA, MWAA, etc.) or which should exist (viz., regional highway, housing, and health authorities). In fact, the Plan does not acknowledge the existence of a regional Council of Governments (COG), or of the need to give it some teeth and accountability. The National Capital Region (NCR) is smaller in area coverage than either the MSA or the CMSA used by the Census Bureau, and smaller than the official afrea of the COG. Nevertheless, it remains strangely skewed to the west, thereby ignoring valuable, growing areas to the east. This is shown on the chart below by the green areas, thereby biasing development away from Baltimore, Annapolis, or the shores of the Chesapeake, as shown by the additional yellow counties. (Click-up to see county detail):

Whether there are two or preferably three Elements documents, there must be some overarching planning elements that address common (or at least overlapping) city and regional problems, constraints, and inequities. We will never have a first class metro area unless some serious efforts are made to level the quality of life playing field, eliminating inequities that serve as sumps, filters, or magnets for the disadvantaged and the blight that thrives on their concentration.

Lastly, there are certain to be shared or overlapping responsibilities and planning opportunities that need to be jointly addressed. As a few typical examples, why should the major efforts for providing adequate tour bus facilities fall on the District when the vast majority of tourists are visiting federal sites? Why should federal facilities be planned with clearly insufficient parking accommodations, forcing the overflow into city facilities? Why should federal parks and open spaces fail to provide underground facilities (or "dirt rights") of value to the city, and why shouldn't federal highways encourage the exercise of "air rights" for either federal or city use?

NCPC's Capital Image Is Much Too Narrow

NCPC seems to be treating the concept of "world image" as something that fits on a postcard, or even a postage stamp, including little more than the Washington Monument, Lincoln Memorial, White House, and Capitol Building, surrounded by greenery and stuffed with the memorabilia of the past we selective choose to honor. NARPAC exists because its founders had been embarrassed by the sneers of national and international observers who got their information not from postcards but from daily media reports about poverty, ignorance, drug use, homicides, ill health, inefficient, if not dishonest, (local) government, etc. Our web site records a short summary of every Washington Post article about DC over the past six years. It summarizes the clearly visible, widely derided, ugly graffiti on the capital's white marble buildings.

NCPC may well assume that such issues should be treated within the "human services" section of the DC Elements (and/or Regional Elements?) if those authors so desire. But deciding what factors impact on the capital's image should be an NCPC responsibility, and NARPAC feels strongly that it is wrong to separate the quality of federal properties from the quality of city life. In fact, DC's resources both human, physical, and economic are significantly impacted by being under the shadows of, the actions and intentions of, and, at least partially, the thumbs of the federal government and the autonomous regional jurisdictions as well.

In fact, the 1984 DC Elements half of the Comprehensive Plan does have a section on Human Services. It is 10th of 11th sections, and ties with Housing as the shortest. The words "education" and "crime" do not appear in the document, but the third and last objective in this section is "to provide income maintenance and support services where needed to the maximum extent possible and to assist families and individuals to achieve or maintain economic self-support." The first and only relevant policy bullet is to:

"Develop a self-support and self-sufficiency task force (!) to make recommendations and to devise a plan geared toward the improvement and enhancement of service delivery capabilities, in order to foster client self-sufficiency and to promote measures to assist recipients of income assistance in gaining skills necessary for full-time employment;"

Lastly, it is quite conceivable that the highest priority for each of the three planning subdivisions may be set by the related needs of another. For instance, the District sorely needs to be assured of the gradual but steady transfer of under-utilized federal properties (mostly military) for its own revenue-producing purposes. Similarly, DC sorely needs the cooperation of the entire region in alleviating its disproportionately large populations of underprivileged adults and special ed kids. The region, on the other hand, needs strong federal support for alleviating its transportation and affordable housing shortfalls, and the federal government needs DC to eliminate its image- damaging reputation as the murder capital of the world. Such interdependencies make it unwise to compartmentalize federal, city, and regional planning. Those plans are inextricably interrelated.

Unbalanced Emphasis on Historic Preservation and Green Space

NARPAC is somewhat offended by the over-emphasis on historic preservation, environment, and parks and open space, compared to the lack of emphasis on the lagging quality of life. There is no acknowledgment of the abuse of historic preservation for devious purposes such as preventing gentrification and urbanization in progress-resisting neighborhoods (viz., memorializing a gas station or a concrete building). Resource-constrained museums recognize their space and financial limitations and "de-access" memorabilia that no longer seem relevant. But the federal and local governments seem bent on unlimited acquisition regardless of the negative impact on economic growth and quality of life. How can DC, for instance, possibly justify more than one historic relic per acre of total District land, and why would NCPC feel obliged to encourage it?

The same applies to the urge to acquire more and more parkland as an end in itself, and regardless of its impact on the fundamental needs of "the community". The draft plan acknowledges that DC already has almost 2.5 times as much parkland per acre as the average large American city. Why push for more? The District lacks the resources to reduce its residential blight at least in part because it lacks sufficient "high-revenue-producing" acreage. Why not instead generate additional parkland just outside DC's borders in jurisdictions that sustain less than 5% of DC's "poverty per acre"? And, in fact, why not give up or swap away some of DC's excessive parklands which have no genuine historic, cultural, or topographic background (viz., most of Ft. DuPont Park)?

While NCPC appears to worship the past, there are few references to its unwanted characteristics. We note that there are no monuments to the internal combustion engine, whose airborne fumes replaced horse manure on unpaved city streets; to concrete and macadam street paving that replaced mud; to flush toilets, internal plumbing and underground sewers that reduced smell and disease; to elevators, electricity, central heating, air conditioning that made taller buildings practical, and so on. We also note that today's enthusiasts for preservation, environment and green space do not advocate eliminating any of these conveniences. Nevertheless, plan implies that none of these major innovations should impact on 200- or 100-yr old plans. Is it really likely that the L'Enfant (or McMillan Plans) would have been unchanged by all these innovations, and especially by the automobile, Americans' second most prized possession?

A 30-50 Year Plan Without Projecting the Future?

NARPAC is concerned that there are no references to the role of technology in further changing the nature of our society and our urban areas. While NARPAC claims no special crystal ball, it is clear that there are going to be major changes in the way our world lives over the next 30-50 years. Surely the nation's capital region (which, outside the capital city itself, is helping to develop that future) should be particularly configured to nurture and adopt these changes. Surely the American image remains forward-looking, and not inhibited or consumed by its past.

multiple core cities?

To begin with, the basic nature and rationale for cities, particularly inner cities is changing. The central core cities have already ceased to be the focal point for manufacturing, commerce, communications, transportation, or self-defense. It seems evident (and is acknowledged in the region's shaky transportation planning) that metro areas will gradually spawn a number of high density, well-interconnected, "sub-cities" throughout the region. Already well-established in the national capital metro area are Arlington, Alexandria, Bethesda, Gaithersburg, Georgetown, Rockville, Silver Spring, and Tyson's Corner. All but one of them are outside the District of Columbia.

The chart below illustrates the current amount of office space in various centers (and corridors) around the region. While downtown DC, including Capital Hill, and Southwest, is still the largest by a factor of two, it is also true that 42% of the area's total office space is in various centers in the Virginia suburbs, and another 28% is in the Maryland suburbs. Trends favor faster expansion away from the historic "core city".

bureaucratic proximity?

The assumption that "federal workplaces with related activities will benefit from being located near each other, where interactions can occur more easily" is becoming anachronistic. We doubt there is much face-to-face interaction, for instance, between the Pentagon and the IRS, or between either of them and the Department of Agriculture. It is not clear, in fact, that we will long resist out-sourcing many routine government functions to the Third World! National and global connectivity by fiber-optics and satellite has only just begun.

Indeed, federal buildings outside the national capital city are almost invariably more efficient users of space than those handicapped by the city's historic height limitations. One has only to look to the new Patent and Trademark Office headquarters in Alexandria (once part of the District) to find a non-compliant set of buildings (still under construction as "anchor" to a very large new urban development. These buildings, shown below, would have broken all the rules if located within "L'Enfant's topographic bowl . This whole new development, located between two Metro stations, would easily have fit within the wasted space on Bolling Air Force Base, and brought tremendous revenues to DC's needy coffers. (Click image for larger version.)

(Clockwise from upper left: main building with 12-story atrium; view of as yet unfinished south face on Eisenhower Avenue; view f complex from Duke Street approach; colorless view from east side open space)

And in the new era of American world domination and pre-emptive enforcement, the clustering of its vital services is almost certainly more of a vulnerability than a virtue. Moreover, why should the new headquarters for Homeland Security occupy a 30-acre low density campus in the most residentially-productive section of DC? Why does the Navy's odd Bureau of Medicine and Surgery occupy five prime acres between the State Department and the Kennedy Center? Why is military housing or a naval research laboratory the "best use" for two extinct airfields on the banks of the capital's rivers within sight of the capitol? Why doesn't the plan address directly the well-established "BRAC" (base realignment and closing) procedures, and propose an orderly reduction in the military properties within DC?

are virtual tours more realistic?

In a different vein, the presentation of history is also changing significantly. The ubiquity of television, computer screens, life-like animation, interactive information systems, and high- definition wrap-around visual and sound presentations is rapidly making many museums and historic sites largely obsolete. Musty relics in glass cases and static displays behind velvet ropes are no match for the information transferred and retained by visual simulation and 3-D animation. And the advent of digital data storage, transmission, and presentation means that any relic, event, or cultural subject can be viewed by virtually any group anywhere in the world.

There may well be a gradual change from getting all Americans out of their living rooms and into Washington, DC, to getting more of what Washington DC stands for into American living rooms, and living rooms around the world. For instance, why ever should we immortalize the crumbling ruins of DC's first sprawling insane asylum, rather than making an honest and lifelike digital documentary of what really went on at St. Elizabeth's , and using that extraordinarily valuable space to, say, further the rapidly unfolding biotechnology field of mental health?

inevitable transportation growth

Equivalent projections can be made in other primary areas such as transportation, where there is little indication that progress is keeping up with need. As the American population grows, and grows faster in metro areas, and has fewer children or other dependents, and lives healthier, longer, and more independently, the demands for mobility can only will increase. Many jurisdictions now average more than two cars per household, and no one can project how rapidly "personal vehicles" (i.e., "segways") will catch on and usurp sidewalks.

The need to embrace "transit-oriented development" (TOD) throughout the metro area will become far more pronounced. Given the extraordinary cost and difficulty of building new metrorail stations, particularly in already-urbanized areas, the present influence of neighborhood activists in trying to protect their backyards will have to be restrained. If local jurisdictions are unable to stand up to their noisiest constituents for the greater good of the metro area, the control of zoning near those stations may have to be transferred to regional or federal authorities. The District's recent decision to approve relatively low new building height at the Georgia Ave/Petworth Station (as shown below in artist's sketches, courtesy of Donatelli and Klein, Inc.) may well become unacceptable. NARPAC pointed out the desolation around the stations along the Green Line North several years ago.

New tagging systems (viz., "E-Z Pass"), navigation systems (viz., GPS), and surveillance systems (viz., red light cameras) will revolutionize traffic control and enforcement, as well as parking systems , and provide a new source of municipal revenues.. Moving stairs, ramps, and sidewalks will be used more broadly, and surely vehicular and pedestrian traffic will eventually be vertically separated. Meanwhile, heavy trucks for the delivery of new materials and removal of used materials , and the ubiquitous delivery trucks that now replace local stores and post offices, continue to block city travel and parking lanes without penalty and without providing sorely needed urban revenues. None of the above are recognized in the comprehensive plan.

alleviating poverty

The only major area where little progress appears on the horizon is in the crucial business of alleviating poverty. There are no magic cures, and no alluring incentives for the underprivileged to gain the needed skills to work their way up the economic ladder. But even in this area, one powerful new tool may very well substantially reduce the numbers of unwanted (and often imperfect) pregnancies, particularly among unready teenage girls forced thereby to drop out of school. Almost without question, the ratio of kids to adults will continue to decline, and the total need for public schools within the core city will continue to decline, perhaps at a faster rate.

"re-calling" the under-educated

To NARPAC, the more immediate problem is try again to educate school drop-outs of both sexes to the level they can be self-sufficient. It is odd that public education obligations cease whenever the kids leave school and no matter how inadequately educated, and responsibilities immediately shift to public welfare agencies that are obliged only to support, but not to alleviate the life-long deficiencies of these barely adult (and very often incarcerated ) youngsters. As the region's largest single employer, shouldn't the federal government actively assist its communities in "re-calling" these "defective" human products that provide life- long real and present threats to the nation's overall quality of life? For instance, why did federal agencies stop "adopting" DC high schools, and why don't they operate local government employment training centers?

Plans Without Financial and Space Implications Are Just Wish-lists

NARPAC has great difficulty accepting the notion of a "comprehensive plan" unconstrained by absolute or relative costs, or by real world space limits. Such a plan ignores real-world limitations, and avoids the key planning element of prioritizing its visions. Surely there should be some projections of resources and land areas available for public sector use as opposed to private sector use, and some idea of the needs of other claimants on those limited commodities.

It would not be unreasonable for the Federal Government to begin to quantify the burdens placed on the private sector both by its current needs and its future aspirations. This is particularly germane to the federal city and, to a lesser extent, to the region's inner suburbs that are also becoming seriously space- (but not revenue-) limited. Urban areas are as dependent on the "productivity" of their fixed available acreage as are farms in the countryside. And urban problems are magnified by the inability of their governments to control their "cash crops".

For instance, there is little DC can do to increase its available revenue-producing acreage. Perhaps 20% of that acreage is occupied by relatively well-off, home-owning residents stridently opposed to urbanization of their pleasantly suburban neighborhoods. A much larger acreage is occupied with poverty-ridden residents dependent on public or subsidized rented housing, and who, together with their activist civic and religious leaders, are adamantly opposed to the scourge of "gentrification". In the small areas populated by very well-off, apartment- and condo-owning residents, productivity is limited by indiscriminate building height limits. As a result, the 12,000- odd residential acres across DC generate in toto less revenues than they consume in city services. The snapshot below shows the private residence at 2929 Massachusetts Avenue, NW, identified in the 2003 Comprehensive Annual Financial Report (CAFR) as bearing one of the highest residential property assessments in DC. It produces $143,000 in annual property taxes per acre:

DC's commercially- and industrially- zoned land area amounts to less than three thousand acres, but generates considerably more revenues than its consumes in city services. It too is constrained by building height limitations well beyond the sacrosanct downtown area. NARPAC is frustrated to see buildings twice as tall on the Maryland and Virginia sides of DC's borders, predominantly in the vicinity of "the edge cities" that are growing up just beyond DC's revenue reach. The building shown below on 13th Street in downtown DC produces more than 20 times the annual property tax revenues (about $3,400,000) per acre than the best residential acre, and could easily produce twice as much without building height limits.

reality in transportation needs

On the other hand, resources for capital projects are substantially constrained both within the federal city and throughout the metro area. The most egregious example is the failure to expand major transportation systems in proportion to the growth in need. A very real part of the nation's capital image is that it has the second worst traffic jams in the US, and is likely to move into first place. It also has the nation's second busiest subway system, which is now in real danger of not only running out of capital investment funding, but of essential maintenance funding as well. That too will make headlines. Why then, would NCPC advocate tearing down existing freeways or interstate railroad lines for aesthetic purposes? Why not devise means to "assimilate" such arteries and apply limited funds to needed highways, connectors, and DC's first-class Metrorail system? Why should NCPC ordain that modern transportation systems are not an inherent part of modern American cities?

building height limits

It is not unrealistic for NCPC to have an unshakable interest in maintaining the majesty of the federal enclave and that portion of the District included within the original L'Enfant plan, and the barely visible "topographic bowl" (is it really part of DC's image?). However, beyond that elliptical depression, which occupies no more than one-half of the District's land (and water) area, why support outdated legislation restricting building height that denies the federal city's ability to resolve its own marginal financial problems (70% of which support DC's disproportionate share of the region's poor)? Why deny the core city the right to share the benefits of "edge cities" like Friendship Heights? Why legislate against the economic development of some of the city's most squalid areas on the high ground East of the Anacostia?


The stated goal of the "Federal Environment" element of the Comprehensive Plan for the National Capital is that:

"It is the goal of the federal government to conduct its activities and manage its property in a manner that promotes the NCR as a leader in environmental stewardship and preserves, protects, and enhances the quality of the region's natural resources, providing a setting that befits the local community, provides a model for the country, and is worthy of the nation's capital"

But nowhere in the document, explicitly or implicitly, is there an equivalent goal that:

"It is the goal of the federal government to conduct its activities and manage its property in a manner that promotes the NCR as a leader in urban and regional development that preserves, protects, and enhances the quality of life for the region's human resources, providing a setting that befits the local community, provides a model for the country, and is worthy of the nation's capital.

return to the top of the page DC'S HISTORIC TOPOGRAPHIC BOWL

Every once in a while NARPAC's leadership is totally surprised by a fact about the nation's capital city it has blissfully ignored. This time it is to learn of the significance of the NCR's terrain features, which includes everything from the Anacostia, Suitland, and Rock Creek valleys, to the natural floodplain and wetland areas of the Anacostia River. But of particular note is the proclaimed "topographic bowl" formed by lowland and rim features of the L'Enfant City and environs.

The Plan places very significant terrain feature constraints not only on the floor of the bowl, but on its slopes and rims as well. One policy guideline suggests that developments along the "Florida Avenue Escarpment" should be constrained to low-rise buildings in order to distinguish that boundary "from the greater height of the L'Enfant City's core area". Another asserts that "the green background of the Anacostia Hills should be preserved". The poor quality topographic map of the District reproduced below, with a tiny yellow star at the site of the Washington Monument, depicts how the terrain would appear totally stripped of its natural and manmade coverings.

That giant sitzmark on the floodplain between the Potomac and Anacostia Rivers (in the center of the map) will never rank with Crater National Park, and those steep ravines along Rock Creek Parkway are surely no match for the Grand Canyon. In fact, there is no point within DC with an altitude greater than 300 feet, and no marker on its highest hilltop. Major avenues and roads traverse the slopes and rims without requiring trucks to shift to low gear. And smog does not appear to settle in the bowl itself. In fact, those rims provide what could potentially be the most valuable currently under-developed properties in DC.

On the one hand, this modest terrain feature quite clearly explains the otherwise seemingly arbitrary boundaries of L'Enfant City 200 years ago. On the other hand, it could now be used to describe a limited area within the District that can be subjected to economic development constraints, or perhaps become the boundaries of a smaller core capital city. To better describe the impact of these and other constraints, NARPAC has doctored up a chart from the earlier Federal Elements Plan. It combines the limits imposed by the L'Enfant City outline, the slopes and rims of the bowl, the extent of non-military federal properties, and, in red, the major under- utilized military properties.

The yellow area, currently almost entirely residential, represents the major areas that could be used for generating additional municipal revenues, were the residents to suddenly turn cooperative about urbanization. It does, however, include border areas (to the northwest and northeast) where edge cities are currently sprouting just outside the city limits and its building height limits. For greater details on this subject, please refer to NARPAC's analysis in the Upper Wisconsin Avenue Corridor Study.


District laws require that the mayor update the city's "Comprehensive Plan" at regular intervals. Under the pressure of other business, and with an evident lack of interest in long-range planning, this task was neglected during 2002, when the latest version was stipulated to be produced. The city is now undertaking a belated, but orderly process to produce a major revision to this key long-range plan, using outside consultants, and a group of interested experts and stakeholders. As is often the case, NARPAC has taken on a peripheral role in commenting on this process, and presents an informal summary of its analysis to date.

Of particular interest to NARPAC are the basic statements of the city's intentions for its own growth, and the interrelations between various documents, of which there is no shortage. In this case, the Comprehensive Plan, with its several separate detailed sections, the more detailed DC Transportation Plan (now also under review for a major periodic update), and the just-published Washington Metro Area Transportation Authority (WMATA) plan, all deal extensively with DC's future transportation plans and their economic consequences. Pertinent references from all of these documents will be summarized here, noting NARPAC's running comments in italics as appropriate.


In the process of developing the District elements of the Comprehensive Plan ("the Plan") and coordinating the widespread citizens review, the following ten (10) major themes were discerned:

(a) Stabilizing and improving the District's neighborhoods;
(b) Increasing the quantity and quality of employment opportunities in the District;
(c) Developing a living downtown;
(d) Preserving and promoting cultural and natural amenities;
(e) Respecting and improving the physical character of the District;
(f) Preserving and ensuring community input;
(g) Preserving the historic character of the District;
(h) Reaffirming and strengthening the District's role as the economic hub of the National Capital Region;
(i) Promoting enhanced public safety; and
j) Providing for diversity and overall social responsibilities.

NOTE that there is no direct reference to the all-important, permanent presence of the nation's capital; the inseparable linkage to the burgeoning national capital metro area; or the need to ensure the financial viability of the city.

specific sections

The Comprehensive Plan then presents a short section on the following subjects (each summarized loosely by NARPAC in parentheses below):

o Stabilizing and Improving the District's Neighborhoods
(stress importance of neighborhoods)
o Increasing the Quantity and Quality of Employment Opportunities in the District
(stress providing jobs for DC residents)
o Developing a Living Downtown
(a popular current objective of most city planners)
o Preserving and Promoting Cultural and Natural Amenities
(stress expanding national reputation as cultural center)
o Respecting and Improving the Physical Character of the District
(keep city low and green)
o Preserving and Ensuring Community Input
(strong assertion for citizen input throughout)
o Preserving the Historic Character of the District
(continue to nurture historic emphasis)
o Reaffirm and Strengthen the District's Role as the Economic Hub of the National Capital Region
(exploit DC's location as hub of metro area)
o Promoting Enhanced Public Safety
(make city safer)
o Providing for Diversity and Overall Social Responsibilities
(all neighborhoods should share in "social responsibilities")
o Interpretation of the District Elements
(goals of this plan overlap intentionally)
o Comprehensive Plan Amendment Process
o Comprehensive Plan Amendment Cycle
o Comprehensive Plan Review Period
o Comprehensive Plan Amendment Coordination and Review Procedure
o Guidelines for Review of Proposed Amendments to Citywide Elements
o Guidelines for Review of Proposed Amendments to Ward Plans
o Definitions

18 separate chapters

Eighteen chapters follow varying in length from 10 to 40 pages, including:

2. Economic Development
3. Housing
4. Environmental Protection
5. Transportation
6. Public Facilities
7. Urban Design
8. Preservation and Historic Features
9. Downtown Plan
10. Human Services
11. Land Use
12.-19. Individual Wards 1-8

Chapters 2 and 5 are summarized below:


major policies

This 19-page chapter presents a rational approach to the city's future. It appears to have been recently updated in some aspects. It's "declaration of major policies" includes the following excepts:

o The purpose of the economic development policies is to build upon the District's role as the Nation's Capital and the economic center of the National Capital region.
o .... the District remains the vital core and driving force in the region's economy
o The District is the unchallenged center of federal government activities......
o The District compared to other regional jurisdictions, has the most private-sector segments contributing to the health and stability of the region.....
o Despite enormous competition from the individual suburban jurisdictionss, the District's private sector economic growth was especially pronounced in the service industries.....
o The District's overall economic development goals are to generate a high-performance economy, create job opportunities for District residents, expand the revenue base through a strong, growing citizen-business-government partnership.....
o The District government will take a clear leadership role in defining economic objectives and policies and installing effective instruments for economic planning and implementation.
o The District intends to build on its recognized assets...... To do this, the District must organize for effective economic development and achieve an effective working partnership with the private sector.
o The District places a high priority on expanding its role as a leading center for national and international tourism and international business
o Expansion of the District's preeminent role as the location for corporate and other headquarters, including the vast network of membership organizations representing business, labor, professional, social, and religious associations throughout the United States, is another priority
o Also of high priority is the development and implementation of policies and strategies that generate new and productive uses of currently under-used commercially and industrially zoned lands. This includes both the attraction of new industries representative of advanced technologies as well as the support, maintenance, and expansion of existing businesses, including those necessary to service the federal and District governments, the private sector, and the tourism industry
o Economic development outside of the Central Employment Area is of equal importance to the District.....
o The District is fundamentally committed to preparing its labor force with the education and occupational skills to participate effectively in the expansion and diversification of the District's economy
o The generation of sufficient tax revenues to fund the District's budget is a top government priority .Economic development programs that contribute to this goal should be promoted
NARPAC believes that this is one of the very few references anywhere to "generating tax revenues" as a goal!
o Affordable, quality child care is an essential precondition for parents with children under the age of fifteen to enable the parents to work, seek employment, complete school, and participate in job training programs.

specific sections

This chapter then goes on with separate sections on each of the following areas. (Excerpts in parentheses are chosen for their particular interest to NARPAC):

o Economic Development Goals
(It is the goal of the District to retain and expand existing businesses, attract new industries, and create jobs for its residents...)
o Economic Development and Growth
(Implement the National Capital Revitalization Corporation (NCRC) as a citywide economic development organization to enhance economic growth and job opportunities.....)
o District Promotion
(....Promote the District as the national center for international business and financial activity, building on the presence of the World Bank, International Monetary Fund, etc....)
o Stimulating Private Sector Growth
(...Encourage increasing university participation in economic development efforts...)
o Economic Development in Downtown and the Central Employment Area
(....Promote the use of the public transportation system, control traffic and congestion in Downtown, and encourage sufficient parking facilities.....)
o Economic Development Outside the Central Employment Area
(....Support the appropriate development of [various named] corridor areas....)
o Improving Labor Force Job Skills Levels and Employment Opportunities
(....Attract labor-intensive industries which employ, in significant proportions, semi-skilled and unskilled workers...)
There are frequent insertions about the need to find work for unskilled DC workers. NARPAC thinks this is perhaps the most blatant and dubious goal in this document!
o Neighborhood and Multi-Neighborhood Retail and Commercial Centers
(....encourage and actively promote the development of active and effective community development corporations CDCs)....)
o Public Action
(....Seek to target government economic development programs to areas of greatest need, which include older business areas that need revitalization....)
This section goes on for ten pages, delineating in very great detail "strategic" industries, populations, and areas far beyond the detail appropriate for a "Comprehensive Plan" top tier document. NARPAC believes that all of this material (and more from prior sections) should be relegated to a separate second-tier, more frequently dated planning document
o Definitions

Continued NARPAC Commentary

NARPAC find the vast majority of the goals and objectives set out in the first half of this chapter to be "desirable, if not sufficient". Nevertheless, several important elements appear to be missing:

o The economic relationship between the shrinking (relatively) "core city" and its burgeoning suburbs is not developed. How should DC distinguish itself from the suburbs, while still offering attractions which keep it a "vibrant" centerpiece of the national capital metro area?

o There is little if any direct correlation between the attraction of new businesses, the retention of existing businesses; and the city's taxation policies. The current tax policies (and breaks) seem to attract marginal businesses that might not otherwise come into the city, while retaining tax exemptions and breaks on businesses for whom a Washington address is a sine qua non. Shouldn't DC seek to attract businesses willing to pay a premium to locate here, rather than demanding a subsidy?

o There is no attempt to settle the continuing debate over whether one more acre of commercial properties will bring in more net revenues to the city than one more acre of residential properties. NARPAC believes that there should be a conscious trend towards favoring businesses over residents, while city fathers seem to prefer the opposite. Why has the mayor suddenly set forth an objection to pull in 100,000 more residents by 2010, when the average DC household now costs the city more in services than it generates in revenues?

o These various economic development goals are entirely qualitative, and suffer from the lack of general quantitative objectives. How fast would DC like to increase the assessed value of its tax-paying commercial properties? How many additional day-time jobs would DC like to create by 2010?


major policies

In comparison to the economic development chapter (above), the transportation chapter seems to have more words, less substance, and no updates. It follows the same format, beginning with a "declaration of major policies", excerpted below:

o The District's transportation network strives to meet the diverse needs of those who reside in, work in, or visit the District. It consists of a modern transit system with subway and bus service, a highway, street, and alley system, and special services for the elderly and handicapped to move people within the District and throughout the metropolitan area. The District's transportation network also includes transcontinental rail service provided by Amtrak, commuter rail service....provided by Amtrak....VRE...and MARC, ....and three airports.
The development of rail service (and rights of way) is never mentioned again.
o The basic philosophy of the Transportation Element is that by providing for the efficient movement of people and goods within the District and its metropolitan area, the District's transportation network can play a key role in the District's effort to maintain and enhance its function as the economic and cultural hub of the Washington Metropolitan Area....
NARPAC believes that transportation infrastructure should precede and govern economic development.
o Direct land uses for transportation include streets and alleys, maintenance yards, storage yards for stations, impoundment lots, fueling stations, office facilities, and equipment dispatch stations....
An interesting list of ancillary facilities, but leaving out parking facilities!

o Today the District has a transportation system that meets its needs generally. There are aspects of this system, however, that must be improved and enhanced in order to comply with CAAA, ADA, and ISTEA, as well as meet the mobility needs of the elderly and of school age children between school and after school programs....
Surely that is not an up-to-date assessment of the status of DC and metro area transportation conditions!
o The District will also coordinate with the appropriate federal agencies in evaluating the feasibility of providing expanded or new rail service on old (abandoned) tracks.
o The District will work aggressively to implement the state requirements for intermodal transportation planning and coordination that are contained in the federal ISTEA legislation....
o The District will also seek .....better design quality of landscaped areas, and amenities for the safety, comfort and enjoyment of pedestrians, including shared use of the roadways by bicyclists.
o....The District is committed to finding regionally based solutions to problems created by heavy suburban commuter traffic, including a shift in commuter emphasis from the private automobile to mass transit.
o The DC transportation system performs another important role ....relating to the growth and development of the future District. The transportation system must respond to District plans for the future as expressed in the Plan...
o The District is committed to overall goal to develop a transportation system that works well for District residents and others who use it, and one that responds positively to projected growth and development, in addition to satisfying other requirements such as health, safety, and welfare of its users.
NARPAC finds these last two bullets concerning transportation growth to be particularly weak

specific sections

Individual sections bear the following titles, and include subsections excerpted parenthetically below both for substance and lack of it:

o Transportation Goal
(It is the goal of the District to provide appropriate, energy-efficient, cost-effective, and convenient public transportation services within the District and to work with neighboring jurisdictions throughout the Washington Metropolitan Area as a means of enhancing the functions and quality of life for those who live, work, and visit in the District )

o Transportation: General
(The general objectives for transportation are to support District policy to preserve and improve neighborhoods, to facilitate the commerce of the District, and to support District growth and development objectives to expand business and job opportunities. )
(Support land use arrangements that simplify and economize transportation services, including mixed-use zones that permit the co-development of residential and nonresidential uses to promote higher density residential development at strategic locations, particularly near appropriate Metrorail stations)
(Continue the residential parking permit program....stimulate shopping, restaurant, and other retail activities, encourage adequate short-term, on- and off-street parking....establish traffic management strategies to separate local traffic from through-traffic....require off-street loading of merchandise in commercial areas.....encourage existing establishments to provide off-street loading....etc.)

o Use of Mass Transit
(The objectives for use of mass transit are to complete the one hundred three (103) mile adopted regional Metrorail system, promote the increased use of transit, and expand the provision of transportation services for elderly and handicapped persons within DC)

o Private Passenger Automobiles
(...reduce regional dependence on the private passenger automobile in order to improve air quality and reduce congestion)

o Streets and Alleys
(...provide a system of streets and alleys to ensure access to all sections of the District)

o Air Transportation
(....encourage the Metropolitan Washington Airports Authority (MWAA(!) to...improve surface access to Dulles Airport.....keep wide-body jets out of National Airport...reduce adverse noise impacts...add a heliport, etc... )

o Waterfront Transportation
( use of waters for recreation ....and integrate waterways into intermodal transportation plan....)

o Intermodal Transportation Facilities
(...provide improved passenger and freight transfer services between various transportation modes serving DC and the metro area.... )
There is no specific mention of the special problems of city trash transfer responsibilities.

o Public Action
(...provide and maintain an efficient and effective transportation system that will maximize accessibility and movement of people and goods , enhance growth and economic development, support the development of housing,...and provide safe and convenient pedestrian and bicycle circulation within neighborhoods)
o Definitions

Continued NARPAC Commentary

o There is no clear vision that available and efficient transportation drives the economic vitality and growth of the nation's capital city;

o There is (as yet) no mention of the new federal requirements for emergency evacuations;

o There are no quantitative long-term goals for expanding/improving DC's transportation network;

o There is no emphasis on the role of parking facilities, or of fare and parking fee structures, in providing incentives to switch from cars to public transit;

o There is no explicit support for the notion of adding new forms of "signature transportation systems" (as in amusement parks and trolleys?), and certainly no support for adding fixed-guideway systems to already crowded surface rights of way.

o There is virtually no mention of the existence of the Washington Metropolitan Area Transit Authority (WMATA) as there is for MWAA. There is therefore no correlation whatsoever between the WMATA ten-year plan and DC's inputs to it, or outputs from it.

o In all fairness, it appears obvious that this chapter of the Comprehensive Plan, unlike the Economic Development chapter, has received virtually no upgrading since it was written years ago. Nevertheless, in its existing version, it provided little if any basis for the existing Transportation Vision, Strategy and Action Plan (TVSAP).

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This page was updated on Jan 5, 2004



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