ANC 3F RESOLUTION REQUESTING REVISION OF
STRATEGIC FRAMEWORK PLAN AND RESUBMISSION TO THE COMMUNITY AND ANCS FOR REVIEW AND COMMENT
Advisory Neighborhood Commission 3F
North Cleveland Park, Forest Hills, & Tenleytown
4401-A Connecticut Avenue, N.W., Box 244
Washington, D.C. 20008-2322
WHEREAS: In November 2003, the D.C. Office of Planning (OP) issued a draft “Upper Wisconsin Avenue Corridor Study Strategic Framework Plan” (Draft Plan) and will be entertaining comments until February 18, 2004; and
WHEREAS: Much of the Wisconsin Avenue Corridor from the U.S. Post Office south of Upton Street to Brandywine Street -- including Squares 1770, 1778, 1779, 1780, 1782, 1783, 1784, 1785, 1786, 1787, 1825, 1829, and 1831 -- is within the boundary of ANC 3F; and
WHEREAS: ANC 3F commissioners have had an opportunity to hear comments from residents at the charrettte to develop the plan held in February 2003; at focus group meetings in the spring of 2003; at community meetings sponsored by OP on October 27, 2003, and December 8, 2003; at community meetings sponsored by the Tenleytown Neighbors Association on December 4, 2003, and January 8, 2004; at meetings on December 15, 2003, and January 10, 2004, sponsored by ANC 3E and Commissioners Carl Kessler, SMD 3F01, and Cathy Wiss, SMD 3F06; and at public meetings of ANC 3F on December 15, 2003, and January 12, 2004; and have also entertained comments from residents by e-mail and telephone; and
WHEREAS: The Draft Plan was an outgrowth of the Cluster 11 SNAP Plan, developed by the Office of Planning in conjunction with neighborhood residents, who identified as planning priorities for Tenleytown:
- neighborhood traffic management and enforcement;
- commercial and retail development;
- residential development controls, historic preservation, small-town character, and comprehensive planning
(Neighborhood Cluster 11, DC Strategic Neighborhood Action Plan, Summer 2002, 15); and
WHEREAS: The stated objectives of the Draft Plan are:
(1) To guide redevelopment opportunities so they will be in harmony with existing development and surrounding residential neighborhoods, but will allow the corridor to meet its full potential utilizing Transit Oriented Development (TOD) Principles
(2) To preserve existing assets of the corridor and enhance them.
(3) To recommend strategies to encourage a better mix of uses, including neighborhood-serving retailers and housing
(Draft Plan, 1); and
WHEREAS: The Draft Plan, in seeking to guide decisions relating to land use, zoning, and the public realm, states that it proposes “no zoning recommendations . . . . Instead, the plan establishes a framework for maximum building heights along Wisconsin Avenue. In addition, there is no intensification of land use recommended in the neighborhoods surrounding Wisconsin Avenue other than what is permitted by current zoning” (Id., 2); and
WHEREAS: Zoning for the Wisconsin Avenue corridor in ANC 3F was reviewed by the Zoning Commission in the 1980s in response to community concerns that build out under zoning established in 1958 (primarily C-3-A in this area) would produce traffic gridlock; and after considering input from seven ANCs, twenty-six civic organizations, and OP, the Zoning Commission decided to (1) retain C-3-A zoning for the “multi-neighborhood center” around the Tenleytown Metro station as not inconsistent with moderate density commercial and medium density residential land use; (2) downzone portions of Squares 1780, 1783, 1784, and 1785 to C-1 as more consistent with the low density commercial category for this “local neighborhood center”; and (3) apply C-2-A zoning to the commercial portions of Squares 1786, 1825, 1829, and 1831 as not inconsistent with moderate density commercial use (Zoning Order No. 530 (Sept. 15, 1988)); and
WHEREAS: These land use patterns have been incorporated into the DC Comprehensive Plan now in effect, see attached excerpt from the Generalized Land Use Map; moreover, the Draft Plan acknowledges that “[t]he general land use pattern established by the existing zoning is appropriate for typical urban arterial corridors” like this one (Draft Plan., 7); and confirms the designation of the Tenleytown sub-area “as a multi-neighborhood center surrounding the Metro Station” (Id., 29) to be treated with a mixed use approach– a goal supported by residents; and
WHEREAS: The Draft Plan then formulates a Framework Plan for building heights “which are not always consistent with existing zoning” but purportedly based on
1. proximity to metro station;
2. proximity to single family residential;
3. redevelopment potential based upon parcel size and building age/condition; and
4. compatibility and urban context provided by adjacent building.
(Id., 24); and
WHEREAS: Washington, DC has two distinct kinds of
urban arterial corridors, from a planning context, which the Draft Plan with
its scant attention to District of Columbia history fails to notice:
-
Arterials such as Massachusetts
and Connecticut Avenues and 16th and East Capitol Streets were planned and
approved by Congress as spacious extensions of the L'Enfant Plan's downtown
thoroughfares into farmland. Those were planned arterials
designed with mass transit in mind (i.e., trolleys, or "light rail" as we
call them today). Those arterials have wide roadways
and deep building setbacks. Sunshine gets in many
hours of the day. People do not feel cramped.
-
Wisconsin Avenue is a different
kind of arterial, which pre-dates L'Enfant, pre-dates creation of the District
of Columbia, and even pre-dates the independence of the State of Maryland
out of which the District was carved. Wisconsin Avenue
evolved from trails and cow paths into an inter-town road and was re-aligned
here and there after much construction was in place. Trolleys
were added to an existing road.
-
Accordingly, when OP (or its contractor)
proposes to encourage developers to change portions of Wisconsin Avenue,
they should not so lightly compare the dense residential development along
portions of Connecticut Avenue (see Draft Plan, 1) as a goal
for Wisconsin Avenue. Wisconsin Avenue has an ambience
of its own and deserves planning aimed at Wisconsin's own character and potential.
- For example, the Upper Wisconsin Avenue Corridor in and near ANC 3F is rich in open-air sidewalk cafes. Building height changes, particularly on the west side of the Avenue, will alter sun-shade patterns. A serious planning study would include sun-shade diagrams and discuss the losses and gains one should expect from earlier shade in cool weather and hot weather, respectively. The Draft Plan does not do that. Nor does it even measure the widths of the Wisconsin Avenue Corridor (building line to building line) in the study area.
and
WHEREAS: Contrary to the Draft Plan’s claim that “the theoretical build-out likely under the Framework Plan is less than what is allowed under current zoning” (Id., 2), the Framework Plan, in fact, would establish building heights and number of stories far exceeding those allowed by existing zoning (even with a PUD) in most of the corridor within ANC 3F; and
WHEREAS: As a result, the Framework Plan proposes buildings of up to ten stories, estimated at 110 feet, in Square 1770 (Tenleytown, “Site C2”) where such heights are not consistent with a multi-neighborhood center like Tenleytown, but with High Bulk Major Business Centers (C-3-C zone district), the Central Business District (C-4 zone district), or Pennsylvania Avenue (C-5, PAD), and where no building close to ten stories exists, contrary to an assertion on page 9 that there are ten-story buildings on the corridor;[1] and even though at every public meeting since the charrette, residents have expressed strong opposition to buildings of ten stories and even eight stories in Square 1770, reasoning that
1. Such buildings would be out of balance and scale with the tallest buildings on surrounding blocks, all five to six stories high: the Wisconsin Building at 4000 Albemarle Street, the Tenley Point Building at Wisconsin and River Road, and the Sears-Hechinger’s Building (now Best Buy) under construction at Wisconsin and Albemarle;[2] these buildings are expected to remain;
2. Ten story buildings are more appropriate for the Central Employment Area downtown;
3. Even near Metrorail stations in the Central Employment Area like Gallery Place and Dupont Circle, new buildings of six stories or less with interesting and varied frontage are operating quite successfully;
4. Some of the most successful retail in the area – like the Cleveland Park Stop & Shop and Bethesda Row – is in more intimate low-scale buildings, which make shoppers feel comfortable and welcome; shops developed like these would be more appropriate for Tenleytown’s neighborhood shopping district;
5. The topography of this area – the highest point in the City -- would make tall buildings visible for miles around;
6. High buildings would dominate the skyline in the neighborhoods and along the avenue -- currently a balance between schools, mid-rise buildings, trees, church steeples, and brick and stone water towers, which give Tenleytown its small-town, “village” feel despite its urban setting;
7. High density in this block would overburden traffic, which already is congested: in 2000, traffic volume on the surrounding streets was measured at 36,900 vehicles per day on Wisconsin Avenue and on Albemarle Street at 8,300 vehicles per day;[3]
8. Increased heights are unnecessary to achieve the plan’s housing goal of 400 new units in this sub-area because more than 200 units are already under construction and the others could be spread between several lower buildings; and
WHEREAS: The Framework Plan improperly includes portions of Fort Circle National Park in the area for development at four to six stories and also includes these lands in the Tenleytown Housing Opportunity Area; and
WHEREAS: The Framework Plan includes in the area for redevelopment at four to six stories the Wisconsin Avenue Baptist Church -- which is not even on Wisconsin Avenue, but ensconced in the low density neighborhood to be protected, where all structures, including the church, are zoned R-1B and limited to three stories -- and does so despite promises from OP officials in Zoning Case 00-03C that “OP would oppose any encroachment of higher density residential east of Nebraska Avenue in the Tenleytown Neighborhood” where the Baptist Church is located (ZC Case 00-03C, Exhibit No. 52, DC Office of Planning Final Report, Oct. 11, 2000, 15; see also Transcript of November 2, 2000, Zoning Commission Hearing, 99, 119-120, 166-172, 174, and 182): redevelopment of this property at four to six stories would overwhelm adjacent homes on Yuma, Alton, and 39th Streets and lead to destabilization of the neighborhood; and
WHEREAS: The Framework Plan includes other properties around Tenley Circle in the plan for redevelopment at four to six stories, despite the fact that
- Tenleytown’s oldest store building and first Post Office, located at 4425 Wisconsin Avenue, is a historic landmark, and thus limited to it existing two stories;
- Bon Secours Convent is currently pending listing on the DC Inventory of Historic Sites;
- The Draft Plan itself suggests historical and architectural assessment of St. Ann’s Church and the former Immaculata High School[4] (Draft Plan, 19);
- The single family home at 4347 Nebraska Avenue is not on Wisconsin Avenue, but part of a row of early twentieth century houses;
- The substantial residence at 4345 Wisconsin Avenue was constructed in 1922 by Frank Perna, a well-known Tenleytown stonemason and builder;[5]
- All of the properties except the store building at 4425 Wisconsin are zoned R-1B and are adjacent to other R-1B properties limited to three stories;
Even allowing some of the properties around the Circle to be redeveloped at four to six stories would create disagreeable disparities in building heights and diminish its effect as the “town green” that tells the area’s story from the mid-nineteenth to the mid-twentieth century through its architecture; and
WHEREAS: The Framework Plan proposes an increase in the number of stories and potential height from three (maximum 40 feet) to 4-6 stories (estimated at 50 to 75 feet) for C-1 zoned properties in squares 1780, 1783, 1784, and 1785, without evidence that more commercial or housing development in this area is needed or expected; but, if built, the increase in stories would affect the light, air, and privacy of adjacent single family properties, still limited to 3 stories, and could lead to destabilization of the neighborhood, like redevelopment of the R-1B properties around Tenley Circle mentioned above; moreover, this area is eminently suitable for neighborhood-serving retail because
1. Its multiplicity of independently-owned stores on small, irregularly-shaped lots, some less than 75 feet deep, its adjacency to single family homes and the low density neighborhood, and its narrow local streets would make higher density development more difficult and less desirable.
2.
Residents of the adjacent neighborhood
utilize the low-scale retail in the 4200 and 4300 blocks of Wisconsin Avenue,
even as they share retail services with commuters and tradespeople working
in the area.
3.
Stores in these blocks are also
favored by neighborhood children because they sell the snacks and novelties
they like and can afford and because children can walk to them without crossing
any busy streets. Effectively, these stores serve
the function of the “corner store” in other parts of the City.
4.
Abutting property owners appreciate
that parking lots along Wisconsin Avenue keep much of the stores’ traffic
out of the neighborhood.
5.
Low buildings at the rear of properties
shield adjacent homes from noise of the avenue. This
section is especially noisy because of the fire house.
WHEREAS: Buildings of six stories on R-2 zoned property adjacent to single family homes on Van Ness Street in Square 1786 would tower over adjacent single family homes; and
WHEREAS: At the ANC 3F public meeting on January
12, 2004, Tenleytown residents, including several who helped develop the
SNAP Plan, appeared and unanimously expressed their judgment that the Draft
Plan as a whole is flawed, not only because of the excessive building heights
referred to above, but also because it fails to take into account the effect
development will have on the area’s infrastructure:
1. The area’s
infrastructure is already inadequate:
-
The roads are
choked to the point that traffic routinely cuts through the neighborhoods;
-
Parents currently
have to walk their children to school because of the dangerous intersections;
high rise buildings would bring more traffic and make them more dangerous;
-
Enrollment at
Janney Elementary School, which serves the entire corridor, is already way
above building capacity, and under the plan, enrollment can only increase;
-
The Metro is
packed when it reaches the Tenleytown and Van Ness stations; by the time
the trains reach Woodley Park, people are often asked to wait for the next
train; The Washington Post recently reported that the Red
Line will be at capacity in the near future;
-
Taller buildings
will bring more cars to compete for limited on-street parking spaces;
2.
The plan’s reliance
on individual planned unit developments to analyze the impact on infrastructure
and provide mitigation will be insufficient and piecemeal;
3.
Planning for infrastructure must
be done before building new housing, stores, and offices, as the National
Association of Home Builders teaches:
Reducing
traffic congestion, relieving overcrowded classrooms and providing other
public facilities and services are absolutely essential components of any
Smart Growth plan. . . . Appropriate government bodies should adopt capital
improvement plans (with timing, location and funding elements) designed to
fund necessary infrastructure required to support new development.[6]
and
WHEREAS: The Office of Planning has said it would
like to reach consensus on the Plan with the neighborhood before submitting
it to the DC Council;
NOW, THEREFORE BE IT RESOLVED
THAT, ANC 3F opposes the Draft Plan and requests
that it be revised and resubmitted to the community and ANCs for review and
comment before any action is taken to send it to the DC Council, in accordance
with DC Code Section 1-309.10; and
BE IT FURTHER RESOLVED THAT, the following revisions be incorporated in the new draft:
1. To the map
of the Framework Plan on page 24:
·
Change Square 1770
to four-six stories;
·
Remove the following
properties around Tenley Circle from designation for any number of stories,
as has been done for a portion of Fort Circle National Park and the American
University Tenley Campus:
·
All portions of
Fort Circle National Park
·
The Wisconsin Avenue
Baptist Church, St. Ann’s Church, St. Ann’s Academy, Bon Secours Convent (All are important institutions
to the community; all zoned R-1B; none of them is adjacent to commercial
structures, but to other institutions and single family homes zoned R-1B;
and neither the Wisconsin Avenue Baptist Church nor Bon Secours Convent is
even on Wisconsin Avenue.)
·
Single family homes
at 4347 Nebraska Avenue and 4345 Wisconsin Avenue (Both are zoned R-1B, are adjacent to other structures zoned R-1B,
and in the case of 4347 Nebraska Avenue, is not even on Wisconsin Avenue.)
·
the landmarked
store building at 4425 Wisconsin Avenue (Its
historic designation prevents it from being redeveloped beyond its present
two-story form; removing it from the Framework Plan would eliminate confusion.)
·
Designate the neighborhood-serving
retail district zoned C-1 south of Tenley Circle for two-four stories
·
Include a transition
zone of two to four stories between the C-2-A commercial district in Square
1786 and the single family homes in the 3900 and 4000 blocks of Van Ness
Street (Square 1787)
2. Revise
the last paragraph on page 24 to reflect these changes.
3. Redraw
the map of the Tenleytown Housing Opportunity Area on page 26 so as to exclude
the tiny (1,836 sq. ft.) landmarked store at 4425 Wisconsin Avenue and Fort
Circle National Park, which borders the rear
of the commercial buildings in this block. New housing is not really possible
at these locations. Redefine the area
to read: “The Tenleytown Housing Opportunity Area
shall be bound by Ellicott Street on the north; the property line between
Lots 817 and 818, Square 1778, on the south; Fort Circle National Park on
the east; and 42nd Street on the west.”
4. On
page 44, remove “Illustration of Whole Foods from Charrette”. Even this picture would encourage bad development. Eight to ten story buildings along 40th Street
would be visually intrusive and overwhelm the nearby neighborhood. This high wall would act as a psychological barrier between
residents east of Wisconsin Avenue and their shopping district. Redo the description of appropriate urban
form on pages 44-45 after consultation with representatives from the neighborhood
as to how they would like to see Square 1770 built out.
5. On
page 47, for Site D2, Infill Sites south of Tenley Circle, revise the paragraph
on Urban Form to indicate redevelopment at 2 to 4 stories for the section
of the corridor from Veazey Street to just north of Windom Place, and clarify
that redevelopment at 4 to 6 stories refers to the area south of Veazey Street. Delete from this paragraph the reference to a large property
that could be redeveloped at 6 to 8 stories,
as this paragraph obviously does not apply here.
BE IT FURTHER RESOLVED THAT, ANC 3F requests that OP consider the properties
surrounding Tenley Circle for a zoning overlay or historic district; and
BE IT FURTHER RESOLVED THAT, ANC 3F requests that OP
-
Analyze the effect this plan would
have on the schools, transportation system, parking, and other public facilities
and services in the area;
-
Provide and weigh seriously information
about the thousands of students and employees who commute into and out of
the area every day in analyzing density and intensity of use along the Wisconsin
Avenue Corridor, not just residents and potential residents;
-
Provide (a) information, now missing
from the report, about the widths of Wisconsin Avenue from curb to curb and
from property line to property line for each segment studied, and (b) meaningful
sun-shade studies of the alternative building heights and set backs for the
revised Framework Plan; and
BE IT FURTHER RESOLVED THAT, ANC 3F designates Commissioner Cathy Wiss, ANC 3F06, to represent
it at any hearing and on any committees concerning the Upper Wisconsin Avenue
Corridor Strategic Framework Plan.
Approved by a vote of 6-0-0 at a duly noticed public meeting of ANC 3F on January 12, 2004, with a quorum present (a quorum being four).
_______/s/ Cathy Wiss___________ ______/s/ David J. Bardin_________
Chair Secretary
[1] The highest building on
the corridor is the office tower of the Chevy Chase Pavilion at nine stories/100
feet. See Zoning Order No. 492 (April
14, 1986). In approving this PUD at C-2-B zoning,
the Zoning Commission rejected a plan for a ten-story office tower of 110
feet, reasoning that even with terracing and set backs it would be visually
intrusive. Id., 19.
C-2-B zoning normally carries a maximum height of 90 feet for a PUD
(70 feet as a matter of right). The Draft Plan erroneously
identifies the zoning of this PUD as C-3-C. Draft
Plan, 8.
[2] When the Best Buy project
was being planned, the developers told the community the building was designed
to mirror potential redevelopment of Square 1770 across the street.
[3] This is the most recent 24-hour count taken by the District Department of Transportation, according to Ruby Williams Staggs, Transportation Data Analyst with the Traffic Safety Division Traffic Services Administration, DDOT.
[4] The Framework Plan arbitrarily
includes some neighborhood institutions in the area for redevelopment while
excluding others. For instance, the Tenley Study Center
at 4300 Garrison Street, N.W., is excluded from the Framework Plan even though
it is adjacent to a commercial building on Wisconsin Avenue zoned C-2-A. Its sister institution, Bon Secours Convent, farther off
the avenue in a complex of institutional properties all zoned R-1B, is slated
for redevelopment at four to six stories. The institutions
around Tenley Circle are no less valuable to the community than the institutions
in the growth restriction area. (See
Draft Plan, 27) Most of them house schools that are
subject to zoning controls, just like the schools slated for protection elsewhere
in the neighborhood.
[5] For information on the Perna family and its contribution
to Tenleytown, see Judith Beck Helm, Tenleytown: Country Village into City Neighborhood, 2d Edition
(Washington, D.C.: Tenally Press, 2000) 72-73. The
unattractive fire escape was added in recent years when the building housed
a group home for the City.
[6] National Association of Home Builders, Smart Growth: Building Better Places to
Live, Work and Play, (Washington, D.C., 2000)
12.
Attached : excerpt from the Generalized Lanbd Use
Map