Where should the City of Dallas encourage new business centers and mixed-use developments to be built? What kinds of industries should the city try to attract and where should they be located? Which neighborhoods in our city should be protected and preserved and which need to be redeveloped? These and other important issues are critical to the future of our city. Today, the City of Dallas is unable to answer these questions because we do not have a long-term blueprint for growth. The City is working to change this by developing a comprehensive land use plan.

About a year and a half ago, the City of Dallas began working on a comprehensive plan that would guide zoning and land use development in our city for decades to come. A consulting firm -- Fregonese Calthorpe Associates -- was hired, and eight public workshops were held across the city to get input from residents. An advisory committee of neighborhood leaders, commercial and residential developers, business owners, and others met regularly to discuss the plan. (I served on the advisory committee for the comprehensive plan, and attended all public workshops until I was elected to the City Council last June.)

In late January of this year, the first draft of the comprehensive plan was publicly released. Two public meetings requesting input have been held since then, and no additional meetings are scheduled. Under the current timetable, the Dallas City Council is scheduled to consider this plan for adoption in June.

I am wholeheartedly supportive of Dallas’ adopting a comprehensive plan. A comprehensive plan will allow us to be proactive, rather than reactive, as our city grows. However, it is even more important that we get this plan right. Having read all 454 pages of the proposed plan, I have several concerns about the plan as it is currently drafted. I encourage you to review this plan for yourself at Forward Dallas!, particularly the sections on Land Use and Housing, as well as proposed Development Code revisions.

Below are my concerns with the draft comprehensive plan.

Dallas is already oversaturated with multi-family housing.

One of the purported goals of the plan is to significantly increase the population of Dallas over the next twenty years. While the North Central Texas Council of Governments (“NCTCOG”) predicts that Dallas will grow by 90,000 households over the next twenty years, the comprehensive plan recommends that we make policy decisions and zoning changes that will increase our population by 220,000 households.

My initial reaction to this dramatic increase in residents was “Where will these people live?” On our current path, 55,000 of the 90,000 new NCTCOG households would live in single-family homes, and the remaining 35,000 would live in multi-family housing (apartments, townhouses, and condominiums). The comprehensive plan, on the other hand, proposes that Dallas grow by the same 55,000 single-family homes, but increase our multi-family households by 165,000. To be clear, instead of 35,000 new multi-family households, the plan calls for the city to grow by 165,000 new multi-family households over the next twenty years. That’s more than 4½ times the number of multi-family units currently projected.

While the plan advocates that we dramatically increase multi-family households, proponents of the plan also claim they want to increase home ownership in Dallas. They argue that the vast majority of the proposed new 165,000 multi-family units will be owner-occupied townhomes and condos for low-income families. However, historic trends and current rental/owner occupancy rates simply do not support this claim.

Right now, only 51% of townhomes and only 5% of condos/apartments are owner-occupied. The comprehensive plan home ownership projections are entirely dependent on these percentages increasing to 85% and 75% respectively. As of yet, however, there are no plans on how to achieve such remarkably high rates of owner occupancy. Currently, the only type of housing that produces high owner occupancy rates (85%) in Dallas is the single-family home. If our goal is to increase home ownership, the only realistic way to achieve this is to encourage the new development of single-family homes.

Accepting for a moment that the higher multi-family owner occupancy rates are possible, there is no means by which to ensure that the new townhomes and condos would remain owner-occupied and would not become rental properties as they age. Such “flipping” happens all the time, particularly in depressed economic cycles. This would no doubt further undermine home ownership.

Another troubling fact is that the comprehensive plan predicts that the majority of the proposed additional households will fall below Dallas’ median income of $37,628 in yearly income. (Housing p. 5-13.) I am a strong proponent of affordable housing, and I realize that we already lack affordable housing in Dallas. If we lack affordable housing now, how is the city going to subsidize a huge increase in affordable housing for the future? What will these massive housing subsidies cost the city? How will dramatically increasing the number and density of poor within the city of Dallas affect our quality of life? These are fundamental questions that our plan – as currently drafted – cannot answer.

Do we really want to base our entire future housing model on the hope that we can (1) somehow more than quintuple the ownership rate of townhomes and condos, (2) prevent townhomes and condos from becoming rental units, and (3) dramatically increase affordable housing in Dallas at no cost to Dallas taxpayers? We need to fundamentally rethink this most basic aspect of the plan.

The plan’s proposed population increase has not been coordinated with DISD.

One of the City’s goals is to better coordinate with DISD. However, until two weeks ago, there was no clear plan for coordinating with decision-makers at DISD to address the significant student enrollment increase that would result from implementation of this plan. The leadership of DISD is unaware of our comprehensive plan and has not discussed its possible implications on the school system. The plan, which calls for dramatic population growth, will have a significant effect on attendance zones and school population. It appears that after my comments regarding this very issue at the last council briefing, advocates of the plan have engaged with DISD demographers. This is a good first step, but in addition to the demographers at DISD, we also need to talk with the school board and the new DISD superintendent about this proposed dramatic population increase.

The plan fails to identify “successful” or “stable” neighborhoods.

The plan places a lot of emphasis on “successful” and “stable” neighborhoods, and often states that such neighborhoods will be protected from zoning changes. Unfortunately, the plan does not identify these neighborhoods. If we haven’t defined or identified these neighborhoods, how can we possibly protect them? Similarly, if we haven’t identified areas ripe for change, how can we focus our energies on improving those areas? We need to identify areas of change and areas of stability, even though doing so may be controversial and challenging. Our consultants identified such areas when they worked on Denver’s comprehensive plan, and the same can be done for Dallas. Our neighborhoods deserve no less.

Proposed reduction in parking requirements will overburden our neighborhoods.

The plan advocates that we reduce parking requirements for businesses and multi-family housing. However, without a reliable, usable mass transit system already in place, under-parking commercial and high-density residential developments will result in severe parking deficits and problems for our neighborhoods and businesses. When businesses and apartments are under-parked, parking often overflows into surrounding neighborhoods, changing the character of our residential areas and resulting in additional litter and decreased safety.

Dallas residents love their cars. Simply reducing parking availability is not going to force residents to use mass transit, particularly when our mass transit system is, at best, in its adolescence. Useful mass transit must come first, then we can discuss reducing parking requirements.

It is important to point out that this is not simply a neighborhood problem. Unrealistically low parking requirements also scare away businesses. At our last comprehensive plan advisory committee meeting on March 6, Dallas resident and The Container Store co-founder John Mullen pointed out that he would refuse to locate his retail stores in a city with low parking requirements. He explained that in a “strip center” situation in which one or more restaurants share a parking lot with retailers, under-parked restaurants are a disaster for the retailers. Restaurants have significant parking needs during peak hours, reducing the spaces that are available for the retailers’ customers. When retail patrons can’t find parking spaces, they go elsewhere and the retailers lose business. Reducing parking requirements would only exacerbate the problem.

In addition, I must say I was disappointed at the last comprehensive plan advisory committee meeting when the comprehensive plan’s author, John Fregonese of Fregonese Calthorpe Associates, stated that the best way to address parking issues is to reduce parking space requirements, allow severe parking problems to develop, then let the affected businesses sort out the best solution. To me, that is reactionary and represents the antithesis of planning. Isn’t the whole point of developing a plan to address problems before they occur, not wait until after the problem happens and hope for a solution? Even assuming such an approach represented good planning, the facts do not support this theory. Otherwise, we already would have found solutions to the parking shortage problems on Lower Greenville and in Oak Lawn. Instead, we see significant overflow into our neighborhoods, resulting in litter, vandalism, trash, and traffic for our residents.

There may be some businesses in Dallas (such as big-box stores) that have parking requirements that are too high. I am open to reducing parking requirements when the situation merits. But to reduce parking requirements across the board disregards the current parking deficit problems in our city and the burden it places on our neighborhoods and retailers.

There are no requirements to increase greenspace in more densely populated areas.

Despite statements of generic support for parks and greenspace, the plan does not require greenspace as part of dense new developments. If we are going to more densely populate our city, we need to incorporate policy statements into the plan that require (not just “encourage”) set-asides for greenspace.

The “Vision Illustration” must be re-thought.

The proposed comprehensive plan includes a “Vision Illustration” for our city. The vision illustration is a map of Dallas with areas colored to represent residential neighborhoods, urban neighborhoods, the downtown area, mixed-use districts, campus districts, etc. So why is this map called a “vision illustration” instead of a “map”? Because under Texas law, a city’s zoning must follow its comprehensive plan map, and plan proponents don’t want to have to change the map every time the city makes a zoning change that doesn’t follow their map.

Fair enough. But there are problems with this map. Although proponents try to play down the importance of the map, the comprehensive plan itself states that the map will guide future development, and proponents have admitted in public meetings that it will be used in making future zoning decisions. So we must get it right.

Unfortunately, some areas of the map are colored wrong. For example, some areas are marked “urban neighborhood” (such as Northern Hills and Perry Heights) when they should be “residential neighborhood.” Uptown is colored “downtown.” We don’t need to start upzoning our wonderful Dallas neighborhoods to make way for more apartments and townhomes, and we don’t need Downtown to gobble up Uptown, which has lower building heights. The bottom line is that the map (or whatever it’s called) is important and we need time to discuss it and go over it in detail.

We need to analyze underutilized zoning rights.

One of the stated goals of the plan is to “increase zoning capacity” in Dallas. That basically means upzoning lower-intensity uses to higher-intensity uses. The comprehensive plan proposal is based on the assumption that we are running out of vacant land and will need to start upzoning our currently developed land. However, we have only catalogued vacant land in our city. We have not yet examined underutilized zoning rights.

Underutilized zoning rights are those rights that a property owner currently possesses that allow him or her to build more intensive uses today, without changing the zoning on the property.

Properties are typically zoned for a number of uses, giving property owners flexibility to develop their property as they see fit. A property would have underutilized zoning rights if, for example, the property were zoned for both apartments (higher intensity) and a parking lot (lower intensity), and the property owner was currently using the property as a parking lot. In this example, more intense development rights are already available on the property; they are simply unused. If we can build apartments on that site and increase our density by using those underutilized zoning rights, we won’t have to use up our vacant land or change the zoning in our single-family neighborhoods to apartments in order to increase our density.

It’s too soon for us to start bemoaning our lack of vacant land or clamoring to upzone low-intensity uses such as single-family neighborhoods when we haven’t even cataloged our existing underutilized zoning rights.

We need to grow in the Southern Sector.

The plan needs a greater focus on developing the Southern Sector. The Southern Sector is our future. It is underdeveloped, and this plan (not just the plan’s marketing language) needs to be devoted to achieving commercial and residential development in the Southern Sector. I was extremely disappointed to see that one of the many missing sections of the plan was the proposal for South Dallas/Fair Park.

Does this plan truly represent the vision of Dallas residents?

Most troubling to me personally, this plan does not represent the “vision” of Dallas residents, no matter what its marketing language says. The city hosted eight public workshops on discrete planning projects at key intersections/transit locations around the city. That small snapshot does not translate into a vision for the other 340 square miles of the city. What is our residents’ vision for the rest of the city? Where do they want to see growth and increased density?

I served on the Comprehensive Plan Advisory Committee, attended all of the comprehensive plan workshops, and attended the two recent public meetings. I have not once heard residents clamoring for dramatic increases in multi-family housing or reduced parking requirements. I have, however, heard great interest in pedestrian environments, trails, parks, attractive neighborhoods, and beautiful streetscapes. Let’s pursue that vision, not one of apartments as far as the eye can see.

Lack of public involvement and input.

Since the draft plan was made public in late January, there have been only two public meetings to collect input on this complex plan. There need to be additional public meetings after the consultants have incorporated the most recent public comments into the plan. The public needs an opportunity to review an updated plan to see that their input has been incorporated. I would also like to see a greater attempt to publicize this proposed plan.

The approval process is moving too fast.

Overall, the plan seems to be moving too swiftly through the approval process, even though parts of the plan are incomplete or missing, and much additional public input is needed. This is a complex document that will have substantial implications for the future of our city, and we need to get it right.