How Philly’s Next Comprehensive Plan Can Make Housing Fairer

(Source: Philadelphia City Planning Commission)

Eric Adams, New York City’s presumptive next mayor, spoke with the journalist/podcaster Ezra Klein about his city’s housing shortage, and how he would try to resolve the dysfunctional housing and planning politics that have blocked progress in addressing it. It’s worth a listen because Adams’s responses contain some important insights for Philadelphia as the Kenney administration and his planning bureaucracy begin to think about undertaking the city’s next Comprehensive Plan.

For those not yet familiar, the city’s Comprehensive Plan is the City’s roadmap that guides a lot of the long-term housing and transportation and infrastructure work, and it’s required to be updated once a decade under state law. This is the main opportunity that the Mayor’s office has to impact city housing policy and set long-term policy priorities for the built environment.

During this process, the Planning Commission analyzes conditions in each of the 18 Planning Districts across the city; creates local stakeholder committees with residents, local organizations, and city staff to set priorities; conducts resident surveys and several public planning meetings; and then produces 18 District plans with all kinds of recommendations for zoning, infrastructure, key focus areas, and so on. Those districts generally line up with intuitive regions like Central District, South District, Riverwards, University/Southwest and so on.

This process is the main activity that could be considered actual planning in Philadelphia, as opposed to the more reactive rezonings and project-level debates that people are used to hearing about, and it involves the most proactive public outreach about planning-related topics that the City ever does. As such, the plans arguably are imbued with a lot more democratic authority than the typical neighborhood zoning meeting is, and they cover a larger and more rational geographic area than a single neighborhood for the purpose of making planning decisions.

This is important because in the day-to-day of zoning politics, the debates that really matter often are largely out of reach. Residents of Point Breeze don’t get to vote for more of the new housing to go in Graduate Hospital or Fitler Square, and for less of the housing to go in their neighborhood. Brewerytown and Sharswood residents don’t get a vote on sending more of the new housing to Fairmount and Spring Garden. The Comp Plan is the only venue where anybody gets a say on things like that, and the Planning Commission can do more to structure and operationalize those choices.

This is really the one big chance that any mayor gets to articulate their planning vision and try to shape the terms of the debate over these things in a forward-looking way. Mayor Michael Nutter’s Planning Commission won an American Planning Association award for the city’s Philadelphia 2035 plan last time around, in part for the unprecedented public outreach and cross-agency collaboration that went into it, and now it’s almost time to do it all over again. It’s unclear when the plan is actually due, but the last one took several years, starting toward the end of Mayor John Street’s administration and ending when the final District Plan was adopted just a few years ago. At this point in time, the Kenney administration doesn’t seem to be in a hurry to get any substantial portion of this done in the remainder of Mayor Kenney’s second term, and it’s likely going to fall mostly to the next Mayor to carry out—creating a good focal point for housing politics in the 2023 elections. 

There is not much yet that is publicly known about the Kenney administration’s thinking concerning the next Comprehensive Plan, but there are a few things. The Planning Commission for some reason decided that the “Re-Imagine Philadelphia Steering Committee” they formed to help guide their policy on participatory budgeting would also be the same steering committee for the next Comprehensive Plan—a bizarre choice given that people who were really interested in working on participatory budgeting might not care so much about the Comp Plan, despite its outsized importance. 

The first phase of that committee’s work shaping the parameters for the participatory budgeting pilot is now over, the administration recently announced, and the committee recently held its first meeting about the Comp Plan. The City has hired HR&A Advisors as the Comp Plan consultants, according to Committee sources, and the Committee will be tasked with making a plan for the Comp Plan process. That phase will go on through June. 

That plan for the Plan is really a crucial step to allow the  Mayor to articulate some big-picture goals right at the outset. And this brings us back to the Eric Adams interview and his political framing for what the Mayor should do to change housing politics. 

Adams says that every neighborhood in the city must be a part of the solution to NYC’s housing supply woes, and his suggestion is to give every neighborhood a target number for housing production, and then task locals with figuring out where it should go. 

It’s worth focusing on the larger political point he’s making with this because it points to a new way of thinking about housing fairness, and a new strategy for how Philadelphia’s Mayor and Planning Commission can flex their power in this process—something they should absolutely not shy away from in the face of a City Council that’s been moving very aggressively to take planning power away from them.

In recent times, a perverse conception of fairness has taken hold in Philadelphia housing politics, where City Council has expanded the power to exclude new housing in more and more neighborhoods. This has been going on for a while, but it really took off after Councilmember Mark Squilla passed a special zoning overlay covering part of Society Hill, which increased some parking requirements and nullified some positive mixed-income housing and historic property reuse rules that could have led to some less expensive housing getting built there. The Planning Commission criticized Squilla’s overlay as exclusionary, and Mayor Kenney vetoed the bill at the end of the last term. But Squilla reintroduced it and passed it right away in 2020. That was the only bill in recent history to see four Councilmembers—Helen Gym, Jamie Gauthier, Kendra Brooks, and Isaiah Thomas—break with the tradition of Councilmanic Prerogative, although the bill still passed easily with everyone else’s votes. 

Ever since then, more and more neighborhoods have been asking for their own exclusionary zoning overlays, often citing the Society Hill situation explicitly as a rationale. “If Society Hill can have this, why can’t we?” the reasoning goes.

It should be obvious why this conception of fairness—equal access to increasingly stronger exclusionary powers for everybody—is a total dead-end for housing access and affordability in our city. But to date, nobody’s really been out there articulating a compelling alternative to this. 

The Eric Adams proposal to give each neighborhood a housing target that they must meet is a glimpse of what that alternative fairness paradigm looks like: more proportional responsibility on the part of all neighborhoods to accommodate new housing, with a particular focus on high-resource neighborhoods. 

The way the geography of housing development plays out today does feel very unfair when it comes to which areas are expected to accept a lot of new housing construction, and which aren’t.

New housing activity seems to gravitate toward places on the gentrifying edge where there is the most empty land, and the least political power to stop new housing, while most wealthier neighborhoods are off-limits mainly due to government regulation. It’s true that neighborhoods near the gentrifying edge are often places with the greatest amount of vacant land for easy redevelopment, but you also don’t have to look too hard to find vacant land in the form of parking lots or one-story buildings or other “soft sites” in more central neighborhoods either.

Meanwhile, the areas with the highest rents and land prices where developers would most like to build more housing if they were allowed—neighborhoods like Society Hill, Chestnut Hill, Logan Square, Washington Square West, and similar—are so loaded down with special zoning restrictions, guarded by hyper-active, high-power civic organizations, that it’s a rarity anybody even tries to propose building anything of significance in those places. They’re considered so off-limits that it’s unthinkable.

A new fairness paradigm could play out something like this: 

The new Comprehensive Plan would include a citywide housing production target announced by the Mayor right at the outset. From there, the 18 Planning Districts in Philadelphia would be assigned portions of that citywide housing production goal. And then one of the objectives of the public engagement processes for each of the 18 District Plans would be to solicit feedback from the residents in those Planning Districts about where that new housing should go. 

Ideally, Mayor Kenney would announce his citywide housing target right now when the Comp Plan steering committee is still thinking about how to structure the whole endeavor, and what questions the public will be asked to weigh in on.

It would be good for this number to be based on some kind of ambitious but attainable projection, but fundamentally what the situation calls for is just a Big Dumb Number that everybody can anchor their expectations around, and just about any Big Dumb Number will do.

For a real-life example of this from Washington, DC, then-newly-elected Mayor Muriel Bowser declared back in 2019 that the city should produce 36,000 housing units by 2025, and this number then became a central pole of the city’s comprehensive planning process that had real implications for proposed neighborhood rezonings. Where did this 36,000 homes number come from? Doesn’t matter! What matters is to start with a big number, and then assign portions of the big number to all of the 18 District plans, which they then need to incorporate. The targets shouldn’t be divided up equally per district, but should be set in concert with the administration’s Housing Action Plan goals, prioritizing strong-market areas with good transit and jobs access that have historically under-built housing.

Those District housing targets would then show up in all zoning recommendations that the Planning Commission makes to City Council. This new goalpost would also be the reference when individual neighborhood zoning is remapped as part of the Comp Plan process.

Where things could fall apart—and where there’s a need for more state intervention to strengthen the governing power of the Comp Plan—is the fact that Councilmembers can and often do ignore Planning’s zoning recommendations from the Comp Plan, and will often just do whatever they want. Still,  in many cases, the initial recommendations that Planning presents to neighborhood groups and City Council help set the tone for what does happen down the line. 

Critically, under this new fairness framework, the question of how much housing should get built in Philadelphia should be made at the city level, or ideally the state level, with legally-binding housing targets for county governments across Pennsylvania. Individual neighborhoods shouldn’t be the ones to decide the “how much” question because this really impacts too many people’s lives to be left up to unelected private organizations. Responsible elected officials need to make that decision. Rather, the  “where” question is the better place to solicit more local input, although the administration shouldn't be completely neutral there either. Most new housing should have abundant access to jobs, transit, and other opportunities in line with city goals for greenhouse gas reductions, the economy, and so much more.

NYC Mayoral hopeful Eric Adams has the right general idea about how to effectively exercise Mayoral power in a system where City Council owns the day-to-day zoning choices, and Philadelphia’s Mayor—whether Mayor Kenney or his successor—should similarly insist on putting District housing targets in the next Comprehensive Plan to structure a more productive debate about fairness in housing. Housing targets for Planning Districts are one of the best ways for the Mayor to set the agenda, while preserving space for residents to work out the specifics. 

While Mayor Kenney won’t preside over the bulk of this process, and may not want to stand up a major new initiative at this point in his second and final term, he should recognize that he has a very important role to play right at the beginning in setting the new Comp Plan’s goals, and he shouldn’t waste the time he has left in office to really impact where and how his constituents will live in Philadelphia for many years to come. 


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  • Jon Geeting
    published this page in Blog 2021-10-14 19:23:15 -0400