DC Office of Health Equity Succumbs to Gentrification Forces, Report Lacks Analysis

The DC Council voted to approve the Congress Heights Small Area Plan in mid-November. The legislation received unanimous approval from all 12 members of Council present for voting. Situated in the District's most socially and economically vulnerable Ward, the effects of intense redevelopment will be felt throughout Ward 8 for generations and well beyond the technical boundaries of the study area. The Plan focuses on the area bounded by St. Elizabeths and Suitland Parkway, Stanton Road SE, Oxon Run Parkway SE, and I - 295. Intended to be "implemented through private redevelopment and public investment," the Plan makes an alarming admission — the District seeks to push the gentrification wave eastward through land use decisions and public subsidy.

The Council Office of Racial Equity (CORE) determined that the Plan, as introduced, "maintains the status quo." Given the increasing politicization and "short-leashing" of CORE, an impartial assessment would have likely considered the Plan as "highly probable to exacerbate racial inequity." District planning has catered to the gentrification economy for the last 20 years, failing to implement effective mitigation against Black displacement and to grow the middle class. In fact, there is ample reason to anticipate that massive redevelopment in Congress Heights will have a much worse impact than it has in Southwest, Navy Yard, NOMA, and other gentrified hotspots given the acute social vulnerability in Ward 8. The median household income within the Plan's study area is $36,477, which is $40,000 less than the median household income citywide. The majority of occupied units are renter-occupied (79%), meaning that there is less protection against private action as opposed to public housing policies that are accountable to the public. Although Southwest is actively meeting threats due to proposed public housing redevelopment, Buzzard Point renters in private housing have been displaced and confronted with owners' attempts, sometimes illegal, to force families to vacate their unit.

The DC Office of Planning (OP) is the agency directing the development and implementation of the Congress Heights Small Area Plan. With glaring racial inequity in the spotlight, OP is learning to adapt to an environment that is demanding changes in public policy. OP is modifying its playbook aimed to spurring further gentrification by co-opting city agencies to sign off on its agenda and abusing equity language to create the appearance of being responsive. It repeatedly employs terms such as "equity," "shared community vision," "community," and "people-centered planning" in the Small Area Plan, as if saying them over and over again make them true. OP is not the only city agency engaged in performative equity. Our last issue discussed the Office of Racial Equity's manipulation of public perceptions with the Racial Equity Action Plan.

The Office of Health Equity - Health Equity Impact Review

In developing the Congress Heights Small Area Plan, OP engaged the DC Office of Health Equity (OHE), an office within the DC Department of Health. OHE conducted its Health Equity Impact Review. As opposed to the CORE report, OHE concluded that the Plan would "decrease health inequities in the Congress Heights SAP planning area and lead to improved health outcomes." The 72-page report did not reflect upon development elsewhere in the District to inform its findings, among other major flaws. It cites little data on contemporary Washington, DC and heavily draws on studies in other cities to make associations between a statement in the Small Area Plan with some benefit that purports to support health equity. The report's four-person staff of a preparer, support staff, and external reviewers all appear to be Caucasian women. Others listed on the Review were not close to the work, meaning that they did not substantively inform its direction and findings.

The Review relied on the Congress Heights Small Area Plan being implemented as intended in the future but did not consider that the Plan would require new laws, new funding, and a continuous implementation and oversight apparatus involving the Council and the Executive. The Council has failed to perform basic oversight of city agencies, especially pertaining to housing policy and spending. Many agencies are in crisis, with the media not yet airing other agencies' poor performance. The crisis of the DC Housing Authority is a direct result of lax Council oversight and accountability. The District went 20 years (1992-2008 and 2010-2022) without publishing election results in the DC Register, a legal requirement. It only did so at the prompting of a Southwest resident. It is unreasonable to expect that weak governance in the District can be expected to ensure the equitable implementation of the Congress Heights Small Area Plan. Currently, there is no neighborhood in DC where the District has fulfilled the health and racial equity provisions in initial large neighborhood planning documents. Southwest is proof of that. As housing financing and property-specific decisions unfold and the pretense of equity evaporates, DC neighborhoods become highly gentrified.

OHE's Health Equity Impact Review reached 324 findings overwhelmingly in support that the Congress Heights Small Area Plan will decrease health inequity, which sharply contrasts with the conclusion of the Council Office on Racial Equity. The Review concedes, "primary sources of background knowledge come from OP analyses," suggesting OHE did not actually conduct any independent data-gathering or analysis. OHE had neither expertise nor technical resources to support its 324 findings. The methodology section might have shed light on its reasoning, except that the Review provided no meaningful discussion of its methods. There is no structured or a priori set of determining factors. Indications of "yes" to decreased health disparities or improved health outcomes in each key driver (9) and focus area (6) do not tell readers why and how this was determined. The report conveniently points to some language in the Plan, then conveniently finds a study. This approach prevents it from actually synthesizing the Congress Heights Small Area Plan to understand the interplay and interaction of all of the moving parts. Instead, the Review inefficiently and separately analyzes each of the six focus areas (Housing Diversity and Affordability, Civic Facilities, Economic Development and Opportunity, Historic and Cultural Preservation, Parks and Public Realm, Transportation and Access) in each of the six drivers (education, employment, income, housing, transportation, food environment, medical care, outdoor environment, and community safety).

The Review cites, "The American Heart Association states that health is affected by four dimensions of housing: “stability, quality and safety, affordability and accessibility, and neighborhood environment”. This is of course true - axiomatically so. However, the report does not acknowledge a basic economic reality that the scale and scope of redevelopment in the Ward 8 study area will destabilize housing. New large-scale luxury housing will place upward pressure on rents across the area and catalyze land and property speculation. Matter-of-right redevelopment will have no obligation to produce affordable housing. Residents will be displaced and experience increased rent- and housing-related stress. The District will have little control once a tide turns for homeowners who seek higher rents from racially discordant, incoming populations. Existing households with housing vouchers will struggle to find affordable rents elsewhere in the District. We can conclude this because this is precisely what has happened elsewhere the city.

The Review claims that community feedback informed its findings but does not specifically cite community influence anywhere in the report. The CORE report noted that community data (e.g., surveys, in-person, etc.) were not public. In other words, it is unlikely that OHE had sufficient access to community opinions to support its analysis and findings. Further, the Review does not consider noise, air pollution, traffic, mental and psychosocial impact, including cultural gentrification, due to intense neighborhood redevelopment. As Southwest has experienced, rodent infestations for adjacent properties are a common result of land development. The redevelopment of contaminated land and resulting airborne contaminants are not addressed.

The Office of Health Equity's Health Equity Impact Review cannot be taken as a serious attempt to understand the health implications of the Congress Heights Small Area Plan. Unfortunately, the Office of Planning and developers will use its 324 findings to catalyze a tidal wave of gentrification to Ward 8.