AHCA Comments on Pentagon City Plan draft#2

The following comments on the 2nd Draft of the Pentagon City Plan were provided on behalf of AHCA to the County staff and Pentagon Study Planning Study coordinators October 31. Residents are encouraged to continue to participate, send in their own comments, and share their thoughts with AHCA at info@aurorahighlands.org.

Please assume that previous positions in AHCA’s comments have not changed and those comments still stand if there have not been relevant alterations to the draft. We encourage you to review and adopt the proposals in that document. We request that for this second draft you specifically respond to these comments with sufficient time for analysis before additional responses are due to ensure they are as responsive as possible.

Vision Statement

In regards to, “diversify housing options,” it’s not clear how strongly the plan actually achieves this vision. The plan primarily focuses on high-rise multifamily buildings and has only a very small selection of townhouses proposed in the RiverHouse site. Either the plan should adjust to actually provide a diversity of housing options or this should be removed or edited. It would be also good to mention transportation and public spaces in the vision. We also concur with the National Landing BID that Pentagon City in itself should not be viewed as “a downtown”, but rather part of a well-interconnected downtown area of National Landing.

Flexibility vs Certainty

From the community point of view, this plan still errs too much towards flexibility for developers. It should be acknowledged that this plan, compared to potentially similar area plans in Clarendon, Rosslyn and Crystal City, offers significantly less detail. This is a great benefit to developers but it is less clear that there is an equivalent benefit to community members. It also leads to a very extensive document that is primarily narrative, leading to potential difficulty for future generations in interpreting it.

There is logic in being flexible in areas where better and more protective outcomes around sustainability and climate mitigation, as well as transit promotion, are stronger. However, flexibility will not, as the plan states, have a clear connection to cause SPRCs to be more responsive to community input. Instead, because the guidelines are high level, developers will be given a lot of latitude when there may be conflicts in perceived interpretation of whether a proposal meets the spirit and intent of the plan.

It is also not clear when further clarity will be added. For example, the draft lists a number of followup studies that may occur but it does not provide clarity about when or under what circumstances they will happen. For example, would a potential reconfiguration of South Hayes be associated with Brookfield development? Or with Simon or Pentagon Centre? Or is it a separate county project, tied potentially to the CIP? It is not clear which, if any of these might be connected. Similarly, does a study on curbside management pre-date significant projects expected to be filed shortly after the adoption of this plan? Flexibility provides little value if there is not at least some level of predictability on next steps. County communication indicates the next draft will include an implementation matrix, something that should have been included from the start, and we look forward to reviewing it if so.

Again, there is also some logic in being flexible in areas that are more likely to develop in the longer term. But that flexibility should mean that there be high level and neighborhood-sized planning for those sites comparable to the ones expected to deliver soon. For example, when Simon plans to redevelop its parking garage, the plan should receive the same level of scrutiny and guidance that the River House and Brookfield sites are now. Whether that’s a separate block PDSP or an amendment to this one to provide equal levels of detail, it is clear that these sites will need additional planning prior to SPRC.

It is particularly frustrating that this plan provides no details or pathways to community facilities. It identifies the need for schools, community space, etc, but provides no detail on the pathway for them to be achieved, how it will be funded and other critical components. The community has been told again and again that additional steps are needed before anything like this can happen. Each time, it’s a new plan or a new waiting period. Yet again, this plan has vague proposals but no pathway or timeline for how any of these will be achieved. It easily could be decades, or never, while in the meantime developers move forward with projects that provide only minimal new community benefits in terms of facilities. The county must not only rely on developer contributions to improvements to our neighborhood, which represents a significant tax base, but also ensure public funds are equally used for investments here.

Housing

It is excellent that the plan requires committed affordable units to be on-site. This is something that 22202 civic associations have asked for.

Biophilia

There is a concern that aspects of biophilia may include not live plants but instead stamped concrete and other non-natural structures. Developers claiming to use biophilic elements should not be able to use such elements without substantial living elements and be able to testify to being aligned with the vision for Pentagon City. The references to biophilic design throughout, especially for the green ribbon and design guidelines, should specifically refer to use of natural materials in addition to analogues.

Diversity and Equity

The framework focuses on the need to make spaces welcoming for people of all types, a laudable goal. But it is silent on how the voices of marginalized populations will be included in the decision making process. This has been a historical problem with Pentagon City residents that are underrepresented by virtue of the difficulty of reaching those who are new residents, renters and living in high rises, a substantial portion of our neighborhood. The framework should include a specific metric around the rate of feedback and participation in site reviews and county driven projects at the least in a way that reflects the makeup of Pentagon City and the surrounding area.

Zoning and Density

The GLUP re-envisions the potential for development for both the Regency care site and “others bordering the Fern Street corridor.” If there is other development potential along this corridor, between 15^th and 18^th St, the plan should explicitly say so. If not, then that phrase should be eliminated.

The general principle that RiverHouse density should be lowest at the south end and increase further north is generally aligned with the neighborhood’s philosophy. But the proposed heights are less aligned. In general, south of 15^th St, the plan should encourage much more in the realm of townhouses and missing middle style housing rather than the mid-rises proposed now. While the proposed buffer of townhouses at the immediate south end provides some transition in the current plan, it quickly shifts to multifamily. Specifically, the zone of height limits should be 150 feet, not 75 feet, from the R2-7 zone. This would facilitate a two sided street of rowhouse style housing between 16^th St and the new more dense infill, and also increase the number of units likely to be for ownership, rather than rent.

Green Ribbon

As previously stated, the green ribbon is a positive connection, driving a nature focused pedestrian pathway through 22202. It was among the most popular efforts of the plan as initially surveyed among 22202 residents. However, we also feel this is being heavily sold as a new benefit when substantial portions of Pentagon City such as streetscapes along the Southampton parcel and within the Brookfield parcel already provide this foundation from the 1976 PDSP. Below is an image showing the sidewalk along 15th St, approaching Hayes from the east that could be described as part of the green ribbon concept in many respects. 

While certainly a positive part of the neighborhood, we are concerned that aspects of the green ribbon, such as linear plantings along roadways and sidewalks that already exist, could be counted as open space contributions or otherwise seen as a community benefit that significantly offsets new density, thereby reducing other important funding recipients like housing, a community facility and open space. Implementing a sidewalk like shown above on 15th could be counted as a community benefit, and this should not be the case. Arlington cannot drift to a trend where features that were not previously considered community benefits in site plans become so. The PDSP should explicitly state in what scenarios aspects of the green ribbon are or are not countable towards community benefits. For example, the images shown on the bottom of page 97 of the draft plan could be found in any sidewalk area with plantings and under normal circumstances would not be considered a community benefit. The park-like top right picture on that page would be more aligned with a community benefit.

The current PenPlace proposal does not appear to adhere to the Green Ribbon design guidelines, with much less greenery edging the proposed primary east-west pathway, particularly at the Fern Street Plaza.

The Green Ribbon clear zone should be at least 10 feet to achieve a real pedestrian refuge.

The Green Ribbon should explicitly include elements to protect pedestrians from the environment, like shade shelters that provide cover during the rain.

Community Benefits

The listed community benefits, while appreciated as an addition to the draft with new clarity, are minimal. As expressed above, it appears the green ribbon absorbs a large portion of these benefits. There is no mention that community benefits could go to community facilities, such as a school, additional acquisition of open space or community center. These are mentioned throughout the PDSP but not connected to funding mechanisms.  

The plan needs to be much more explicit in the specific community facilities that are required to maintain at least the current levels of service to residents: new open green space, a school facility, and an expanded community center & library. We describe the need for new green open space in further detail below.

There should be explicit mention for the RiverHouse and Brookfield sites of “additional community facilities as mentioned in this plan” to ensure the proposed list is not seen as a ceiling by developers.

More specifically, given the increase of residents expected, the existing, already too small, Aurora Hills community center and library cannot meet the needs of the area. Instead, the plan should explicitly call for and site, potentially at RiverHouse, a new full-service community center, akin to others in the county like Lubber Run. This community center could be located on the River House property and be partially funded by community benefits. Such a feature would be an exciting draw for neighborhood residents if included in this plan. 

Limiting potential for Community Facilities

We take issue with the comment on page 41 that notes “subsequent processes to identify a potential school site should focus on County-owned properties within 22202 such as the Aurora Highlands Library/ Community Center site (as one example).”

Limiting the focus for community facilities on county-owned properties Is both short sighted and sets up residents for increased convention over already limited resources, particularly as the only “county-owned properties” in the study boundaries would limit any facility to Virginia Highlands Park.The processes to identify school sites and other community facilities must focus on all suitable locations, not just county-owned properties.

Bicycle facilities

We continue to believe that a bike lane is needed along 12^th street, given its immediacy to the Metro and connection to Crystal City and the Eads bike lanes going south. The county should make every effort to accommodate both the transitway and dedicated, protected bike lanes, even if this means encouraging parking and pick up/drop off at other locations. The county has stated it is prioritizing the transitway, but it is prioritizing car uses as well. In order to achieve the desired mode split, we cannot force bike users to go blocks out of their way, along Army Navy. More likely, when confronted with a lack of facilities in their most desired path, many simply will choose not to bike.

Parks and Plazas

Access to parks and open space has been a consistent top priority of residents as shown in county processes such as the PSMP update and our own community survey on the PDSP conducted in May. The plan works hard to reflect this, with a focus on green space and biophilia, but those general concepts are not adequate to ensure the required access to basic open green space  — consisting of predominantly natural, unprogrammed park spaces — is provided. One analysis found that 8.5 acres of net new space is required to maintain current levels of open space access, and the plan must set this goal as the minimum. If there is an expected need for additional fields and facilities, those need to be quantified and included in addition to this goal.

The call for a mix of paved plazas is inconsistent with the draft’s primary emphasis on biophilia and nature. This creates flexibility for developers to propose unpleasant, windswept plazas. Instead there should be a clear emphasis that open and public spaces should focus on greened, canopied areas with biophilic features, like incorporations of water.

We continue to emphasize that re-routing Joyce Street and moving Grace Murray Hopper Park (GMHP) is not a goal for the community. This appears to be a highly costly approach, requiring the developer to pay for an entirely new dedicated street, when the funds could be better directed to simply acquiring new land. Virginia Highlands is already large sized and combining the two centralizes park space instead of distributing it throughout the community. While the potential addition of park space along Army Navy at RiverHouse is positive and should be confirmed, the RiverHouse project would benefit from a centralized park space as well.

However, if the plan to move GMHP is included in a final plan, it is not acceptable to allow dining or other primarily for-profit uses at the southern end of the site identified for community uses. That space should be clearly dedicated to community use, such as a community center.

In addition, there should be a clear SPRC item about maintaining the parks and who will be responsible. It would make sense for the BID to take primary responsibility in maintaining the new Green Ribbon areas.

Pedestrian Circulation

An eight foot clear zone does not match the urban nature of 11^th St and the other public ways that could come out of this plan, such as those that may eventually break up the Simon block. In order to achieve walkability and mode split goals, we need to make walking as appealing as possible. Clear zones should be no less than 10 feet throughout the PDSP sector – as required by the original 1976 PDSP (“All major sidewalks shall be a minimum 12 feet in width with an adjacent 8-foot planting area. All minor sidewalks shall be a minimum of 10 feet in width with an adjacent 8-foot planting area.”). Despite inclusion in the PDSP, this hasn’t lived up to reality, with cafe zones enriching on those desired widths. Therefore, the plan should make it clear that other zones in the sidewalk, like plantings and café, should not encroach and have their own clean standards and dimensions that allow for the goals of those areas. In particular, when retail is present, an adequate café zone should be planned for.

When protected bike lanes are not present, sidewalk clear zones must be even wider, given anticipated conflict between bikes, micro mobility and pedestrians.

Sustainable Design

The addition of language encouraging property owners to work together is appreciated. In addition, language should be added that plans for united sustainable design elements planning for future design. For example, sustainable features proposed in the first phase of a site expected to phase in over time should account for connecting to features in the next phases.

Upper Floor Façade Variation

Under this proposal, it appears balconies cannot be more than 3 feet deep into the public right of way. This minimizes the functionality of this pro-community feature. Many balconies on new buildings are so small to be practically impossible to use. For balconies specifically, developers should be able to push to 4 or 5 feet into the public right of way to allow for greater personal outdoor space for residents.

Community Integration

This plan would lead to thousands of new residents in Pentagon City, primarily through new multi-family buildings, likely to be residential. Without intentional planning, these new residents are likely to fail to participate and integrate into the broader neighborhood. The civic association has faced many barriers to engaging with current residents who live in these buildings, particularly reluctance for property managers to regularly share information and news with them. The plan should explicitly endorse access for community organizations to sharing information with residents of buildings in Pentagon City and structure the built environment to facilitate community communication channels such as providing community bulletin boards in public spaces, and access by community organizations to electronic signage, information kiosks, etc.. 

Evaluation of the PDSP Over Time

This plan sets out a series of goals and metrics. The county should explicitly commit to reviews of these goals and metrics and whether they are being achieved, at least every ten years.

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