Lack of Historic Preservation in the revised VMP plan
In 1991, the DC Historic Preservation Review Board designated McMillan Park as a Historic Landmark. Recently, the Site has also been nominated for the National Register of Historic Places. These designations are critical in order to ensure that a substantial contiguous portion of the McMillan Sand Filtration Site would forever be reserved for recreation and open space and requiring adaptive reuse of the site’s historical elements — both above and below ground. From the perspective of historic preservation, the Vision McMillan Partners plan has three primary flaws.
- The VMP plan would destroy the historical integrity of the site, and it does little to adaptively reuse the underground cells or the above ground structures. The road that is planned directly next to the above ground structures would make adaptive and commercial/creative reuse of the structures impossible. These structures are small and would need integrated open space around them to create possibilities for effective reuse. The VMP plan retains only at most three cells and generally retains the structures as monuments without establishing criteria or designs or an implementation plan that would enable reuse.
- Beyond doing so much harm and so little good to the built infrastructure at McMillan, the VMP plan has an insufficient inventory of vistas and important view corridors that should be preserved. It also affords insufficient protection of the vistas from, into, and through the site that should be preserved. The plan’s proposed park is inadequate in size for a site of this significance and for a part of the District with so little park space. An appropriate park would link the above-ground structures, maintain the historic “sense of place,” allow for reuse of the structures, and allow for active, public multifunctional use of the green space.
- The design fails to include design elements that would document and preserve the historic significance of the site. Instead, what is planned is a generic mixed-use suburban development without sufficiently taking into account the specific materials, features, and history of the site. The design guidelines are vague and insufficiently developed to protect the historic characteristics of the site.
Although the revised VMP plan integrates some of the recommendations provided by the Historic Preservation Review Board during the hearing on July 12, 2012, it insufficiently deals with the conclusion of the evaluation, namely that the VMP plan would result in a loss of integrity of the site and loss of important engineering, architectural, and open space features for which the property is recognized and designated.
Proposed over-development and lack of adequate Transportation, Sewage, and Stormwater Infrastructure
The plan proposes 1 million square feet of medical office space, 756 residential units, and more than 33,000 square feet of retail space and restaurants. Transportation access to the site is insufficient to sustain the estimated 3,300 new employees in addition to the planned new residents. The traffic pressure north/south on North Capitol, First, and Second Streets NW, and east/west on Channing Street NW and Michigan Avenue NE/NW due to the proposed development would increase significantly with the estimated thousands of new daily vehicle trips to and from the site. Nothing that the VMP staff has shown to the public addresses the traffic backups in the surrounding neighborhoods that their plans would create. Likewise, neither the development consultants nor the District Government has offered any real improvements to the transportation infrastructure serving the McMillan Park area. They have yet to propose a Metro station, a street car, or any additions to the street grid, and they likely never will. Their best suggestions to date include a couple of extra buses and a few traffic signals.
The sewage and stormwater infrastructure systems in the neighborhood already operate at over-capacity and lack the ability to handle the current volume of sewage and stormwater. The proposed new development would significantly increase the risk of sewage overflows into the homes and businesses located in the downstream Bloomingdale community, as the current VMP plan lacks adequate onsite stormwater retention and detention planning.
Insufficient economic justification
The VMP fiscal impact analysis overestimates the expected tax revenues that the District would receive through development of this site. The District Government has yet to conduct an independent market study to justify the market demand, especially for 1 million square feet of new medical offices, in a location that lacks Metro access, has insufficient public transport in general, and is even difficult to reach by car. The VMP economic analysis also fails to account for the offices already developed in the District and current office vacancy levels. Likewise, the development consultants have received no assurances from the Washington Hospital Center regarding the need for or the ability to fill the proposed office space.
The lack of justification also extends to the fact that the area within a mile of McMillan Park has had, is having, and will continue to have an explosion of development. Since the late 1990s and through the last decade, at least 50 million square of development have occurred in this small area of the District. But no one has justified in the face of all this building, the proposed destruction of McMillan Park. In a city that is booming, when is enough building for the sake of building enough? McMillan Park has the ingredients for something extraordinary and unique in the District of Columbia.