I don't even know where to begin (DC's lack of an integrated land use and transportation policy)
I testified a few times last year against approving the Comprehensive Plan revision, not because it was terrible--for the most part it is not--but because transportation and land use policies were not substantively integrated. (Reading the Comp Plan recently, there are more than 100 policies and actions related to transportation and land use, yet there are only three suggested changes to zoning regulations. And they aren't that substantive.)
I argued that urban design should have been defined as the primary element--meaning that land use policies should have favored compact, walkable places, and that transportation demand management, both as a general policy, as well as a package of services, designed to maximize the use of the transportation infrastructure and to minimize the number of single occupancy vehicle trips, should have been the primary organizing principle for the Transportation Element.
I got heat from some people in the Smart Growth arena -- "don't let the perfect be the enemy of the good."
And at one hearing, I went up to a person who testified in favor of the Comp Plan because it _mentioned_ TDM (at that point the Comp Plan draft didn't even require TDM for planned unit developments, something that changed as a result of my testimony -- I joke that I changed one word in the comp plan, from "suggested" to "required" but only for PUDs, which affect only a small portion of new development). She has 10x more experience in transportation than myself btw. I said how can you testify in favor of the comp plan because it mentions TDM when it is only a mention with no substantive requirements? She didn't have a good response...
One of the points I made in this blog entry "Transit without borders or five omissions "in" the Transportation Element of the DC "Comprehensive" Plan" was about TDM:
Why doesn't the Transportation Element require transportation demand management as a matter of course, for all uses other than that of single-family housing, instead of only suggesting it be required for planned unit developments? (* Note that I would change this now. Parking and curbside management requirements would also impact single family housing.)
This makes no sense. Institutions including schools and churches should be required to develop plans that reduce car trips in a substantive way.
Support for bicyclists and pedestrians should be required. (* Support for bicycling is one of the three zoning changes called for in the Implementation section.)
Parking subsidies should be, for the most part, forbidden, or at the very least matched by comparable subsidies to transit riders. (* Now I would also argue more closely about the need to reduce or eliminate parking requirements for new construction Downtown and in transit corridors and within one half mile of subway stations.)
Multiunit developments should be discouraged from promoting car usage, especially when located to convenient transit.
Incentives should be provided for car sharing. (* And should be required for multiunit housing buildings of a certain size. Plus Downtown, office buildings should have to open up parking at night to the public. Plus they need to participate in TDM planning. I didn't write then either about the creation of "Transportation Management Districts.")
Instead of just focusing on creating "truck routes" through the city, figure out how to time-shift as many commercial deliveries as possible to evening hours because for the most part, roads downtown, and in the northeast and southeast quadrants are underutilized. This would have to be balanced with the desire to not negatively impact neighborhoods. (* Delivery services should also be encouraged as part of BID services and by multi-store shopping facilities and by grocery stores.)
Certain businesses, such as the Au Bon Pain restaurant chain and the Yes! Grocery Stores get the bulk of their deliveries at night, significantly reducing the impact deliveries would otherwise impose on a somewhat stressed road network.
This practice needs to be more widespread and should be spearheaded through TDM requirements (not guidelines, not suggestions) in the Transportation Element.
More recently I have written that District Government agencies should be required to conduct TDM. Partly this was a response to proposals for special street parking privileges for firefighters. See "Council ponders reserved parking for firefighters" and "Signs at the Hine School polling site."
Another example of why there should be TDM planning requirements for building uses as well as "accessibility planning" as part of DC land use regulations (zoning) comes from yesterday's Post, with the announcement that the DC Government is going to move the Police Department headquarters to 225 New Jersey Avenue, a building about 6 blocks from the Capitol South subway station, if you walk under the freeway (and somewhat further away from the Navy Yard Green Line and the Federal Center subway stations), and miles away from any other District Government building. See "Police HQ And 1,100 Workers Going to SE."
Accessibility planning does three things:
1. Sites are rated by their access to transportation infrastructure (roads and transit).
2. Uses are rated by their demand for transportation infrastructure (how many trips are generated).
3. Uses can be placed only where transportation demand and transportation supply are at equilibrium, with a bias towards mode shift from single occupancy vehicle trips.
But the accessibility planning paradigm isn't part of the Comprehensive Plan.
From a Transportation Demand Management perspective, it is a disaster to move the Police Department from a central location served by transit and in close proximity to other government buildings housing functions that are "consumed" by Police Department employees during the course of their work day.
1. The current building is within 200 feet of one red line subway station and pretty close to a green-yellow line subway station.
2. Police Department employees frequently must spend time in Court, located immediately next door
3. And meeting with attorneys from either the Federal or City offices, those offices are located close to the current location of the Police Department as well.
4. Plus the building is located across the street from one of the main DC government buildings, as well as being just a few blocks from City Hall.
5. Not to mention the location of some retail services, places for lunch and coffee.
The advantage of agglomeration--the competitive advantage of a "Central Business District" including both commerce and government functions--is that a variety of services and functions are available in a reasonably compact and central fashion.
From the perspective of transportation, this means that most work day business-to-business trips can be conducted on foot or on transit, not via car.
In the new location, Police Department employees will now drive most everywhere, because most of the business and personal trips they will need to make are not satisfiable on site or in close proximity.
Accessibility planning--linking use to its ability to be satisfied by extant transportation infrastructure--should be one of the primary elements of the Zoning Regulations and Land Use Planning. It should trump matter of right.
Currently, matter of right provisions such as allowing schools or churches or police functions to locate anywhere within allowed zones fail to take into account that some locations are much better positioned than others to accommodate the transportation demand produced by the use.
Most new charter schools generate tremendous numbers of car trips every day. Most churches do not provide alternative transportation options other than driving--and they prefer to tear down houses in favor of parking lots, rather than work with communities to figure out ways to accommodate their large but very short term requirements. E.g., tearing down houses to make parking lots that are used only 3 hours of 168 hours in a week is practically the definition of insanity. And locating the Police Department far away from other government offices, far away from transit, and far away from services means that most workers will not have alternative transportation options other than driving.
Government is supposed to drive best practices forward by implementing and practicing best practices. Government is supposed to be a proponent of what is called "rational planning."
Plans to move the Police Department headquarters, and similar proposals and actions to move other DC Government (and related, such as WMATA) functions out of the Central Business District, are a major step backward in local land use and transportation planning, and in the efficient provision and consumption of government services.