Community response to the applicant's 6 October 2000 submission
Georgetown University campus plan, BZA application number 16566

This document consists of three parts:

1. Response to the applicant's cover letter
2. Critique of the "point by point" chart that was entitled "Response to BZA's Request for Additional Information"
3. A summary of the community proposals for the campus plan that are relevant to the applicant's response.

In addition, the submission includes several appendices.

1. Response to cover letter
   1. Regarding enrollment: We acknowledge that, as described in their recent filings, the University has implemented several measures intended to reduce the negative impact of off-campus students on surrounding neighborhoods. We disagree strongly that these measures "address the issue of impacts from its students off campus so as to enable the Board to approve the increase in enrollment."
      • First, the new measures have not been shown to significantly reduce off-campus student impact. To the contrary, the impact this year appears to be worse than ever, despite the unilateral implementation by the University of most of the elements of its plan. Documentation of continuing negative impact is attached in Appendix A. Certain elements of the plan have been in existence for years, others for a few months. The plan has no record of effectiveness, and any modest benefits it does produce could be far outweighed by the negative effects of increasing enrollment.
      • Second, the new measures affect only behavior of off-campus students. Other neighborhood impacts noted in testimony were not addressed. These include negative effects on parking, traffic and housing.
      • We note that the University still refuses to provide full-time equivalent enrollment figures, as specified in the approved 1990 campus plan. As noted in our testimony, "full-time equivalent" enrollment seems to be higher than "traditional full-time undergraduate" enrollment. The current reported enrollment, 5840 "traditional full-time undergraduates" is very high and may lead to a violation of the 5627 FTE enrollment cap for the year-even in terms of this different unit of measurement.
      • It appears that, in addition to unilaterally implementing its own behavior management plan, the University is also unilaterally increasing its own enrollment cap. The point by point response chart indicates that the University's target enrollment for the current year was 5677, in excess of the existing 5627 FTE cap.

   2. Regarding on-campus student life: The community supports the projects in the campus plan that seek to "re-center student life on campus." We believe that these projects should be given priority over other elements of the plan. However, we have asked that non-student use that could burden the neighborhood be restricted for all of the projects named in the letter-the Performing Arts Center, McDonough Arena and Harbin Field.

      We applaud the decision of Dr. Juan Gonzalez this year to oppose holding the Student Charity Block Party on public space as in the past. We have long opposed this event as contributing to a student culture of drinking, and the University itself once effectively prohibited it. (Until recently, students in University housing were required to sign an agreement that they would not petition the city for a block party). However, the student outcry resulting from the block party cancellation shows the great need for positive steps to build on-campus student life. This was the reason for our concern about the reports in September of a student affairs budget cut of $900,000. Our concerns have been only somewhat allayed by the letter in Exhibit F of the submission.

   3. Regarding the University's claimed financial need: The University seeks to gain Board approval of a substantial enrollment increase by pleading poverty, saying that without the enrollment increase, it "simply cannot go forward with its plans" to improve on-campus student life. (Interestingly, when talking about the neighborhood impact, the enrollment increase is presented as "modest" but when discussing finances, it becomes a critical issue.) Such a linkage between the enrollment increase and specific projects has never been made before, either in testimony or in discussions. However, all testimony in this case has agreed that increased enrollment will mean an increased burden on the community, and that burden is already unacceptable. The University may simply have to accept limits to its growth.

      Regarding the argument of poverty, it is quite clear that the University possesses ample resources for implementing the projects in this plan. The University's published endowment is in excess of $625 million, and the University is in the midst of a very successful fundraising campaign with a goal of $1 billion. (According to the Sept. 25 edition of the University newspaper Blue & Gray, $600 million had been raised as of Aug. 31.) Audited financial statements, filed in connection with the transfer of Medical Center operations to MedStar Health, fail to support any claim of financial difficulty, Audited consolidated financial statements show that Georgetown University's net assets rose from $668 million in the fiscal year ending June 30, 1994 to $1.05 billion in the fiscal year ending June 30, 1999. This is a picture not of need but of prosperity. Thus, a decision not to proceed with certain projects in the plan would more reflect University priorities than financial hardship. We hope that the University will not hold student life hostage to other priorities.

   4. Regarding a ten-year plan: The University argues that because it has made some provisions for reporting on the status of its off-campus housing program, that the Board would be able to approve the plan for a ten year term. We strongly disagree. This approach does not address the other community reasons for requesting a five-year term:

      • Impending change in University administration
      • Massive planned on-campus development prior to plan (Southwest Quadrangle, Canal Rd entrance)
      • Change in medical center type of use (MedStar purchase)
      • Nearby community development that affects traffic impact
      • Lack of quantitative information now about traffic and student impact

      The changes already underway will make the University in five years a very different institution. We plan to work together with the University and MedStar, as proposed here and in the University's submission, to obtain information on student conduct, traffic and other impacts. After five years, the plan should be revised and resubmitted for approval. A simple review based only on off-campus student housing would be completely inadequate.

   5. Regarding plans for reporting to the community: The University's proposed means of reporting to the community are inadequate. We agree that the existing quarterly meeting procedure has been beneficial and should be retained. We also agree that the University should routinely report on progress with each new submission (see below). The University's letter does not specify what it means by "monthly reports to the community" or "annual reports to the community, the Office of Planning, and the Office of Zoning."

      However, we do not support the University's group called "ALL" as a means of community involvement. ALL has no real structure, no procedures or bylaws, and its meetings are closed to the public and to the press. The present membership of ALL, which was selected exclusively by the University, consists largely of University-affiliated groups, and ALL proceedings will be managed by the University, so ALL cannot provide an independent assessment of University impact.

2. Response to applicant's point-by-point chart
   

   Defects in the off-campus housing program	The program contains nothing fundamentally new, but is rather an expansion or extension of existing programs-programs that have decisively failed to remedy the problems. The Board rejected essentially this same program in September. More important than being "comprehensive" is being effective. However, the new program is no more comprehensive than the old programs from which it is composed. Among the negative impacts omitted are those involving housing (zoning and maintenance), which directly affect off-campus students' health and safety, as well as neighborhood quality of life. The program's stated goals will not eliminate neighborhood impact. Reducing the number of repeat offenses will not reduce first offenses, which comprise a large portion of the problem. There are easily enough student houses to fill every weekend with noisy parties on first offenses alone. The SNAP program might contribute to identification of potential problems, but SNAP personnel will not be equipped to effectively intervene. Contrary to its representation in the applicant's submissions, the ALL program is not community-wide but rather University-run. More detailed criticism of ALL is given below. On-campus student conduct is not part of the program, notwithstanding the applicant's statement, because the response and enforcement mechanisms don't apply to on-campus students, even when they are off campus. This is illustrated by hotline statistics reported in the chart, which are divided by whether the students lived on-campus or off-campus; no follow-up was done for on-campus residents. Yet disruptions by on-campus students are a serious problem off campus. The program is reactive. Response to problems is limited in time (Thursday, Friday and Saturday nights only) and in content (behavior problems only). At other times, residents can only leave a message and hope for follow-up, while for other problems there is no well-defined response mechanism. The primary response to problems at any time or of any nature is punitive, not preventative or curative. When imposed, sanctions are designed to discourage second offenses but not first offenses. The program is primarily punitive. It has no provisions-other than leaflets-for educating students on off-campus affairs and on their responsibilities and rights in the community. It has no provisions for advocacy by the University administration and faculty of civic responsibility for students. Education and advocacy could be part of a dialogue in mandatory assemblies (like the former off-campus orientation), in the classroom, in student newspapers, or elsewhere. This has not been done. A purely punitive program cannot succeed at Georgetown. A weak Code of Conduct has not been the problem, so a stronger Code won't be the solution. The Code of Conduct has always had strict sanctions but weak application of sanctions has historically undermined the effectiveness of enforcement. It will be difficult to monitor this in the future because of the University's refusal to disclose sanctions decisions. The ALL program cannot be called a "partnership." This program has been grossly misrepresented in the University's submission. It was established without community input, and membership and attendance are "by invitation only." As far as we know, there have been no commitments to participate by any city agencies or neighborhood organizations. Those from the community who have attended meetings have done so as individuals, not community representatives. Participants have no defined authority to set procedure or call meetings. ALL has no authority within the University to make decisions or implement actions. To date, there have been only two ALL meetings, the first of which was primarily organizational, and no fixed goals or plan for future action has been established. Contrary to the applicant's October 20 submission, ALL has not been "well received by the vast majority of the community." In the interest of cooperation, several community members have attended ALL meetings, but ALL has not been accepted by the community. (See Appendix B.) The essential problem with ALL is its fallacious premise that student conduct problems are to be solved by changing the surrounding community rather than the University community. In fact, a community-wide program should not be the primary approach to long-term resolution of conflicts; instead, the University must take steps to change its own culture. Problems and suggested solutions have been identified by past University task forces, notably the May 1999 Report of the Campus Culture Task Force. The recommendations have, in the main, not been implemented. (The Executive Summary and Recommendations of the task force are attached as Appendix C). Resources devoted to programs that directly affect off-campus student impact are only slightly increased over previous years. Citing the number of hotline staff persons is misleading because the staff works part-time. Bulk trash collection is an ongoing program which has been allocated no new resources. The management and budget cited are basically unchanged. Additional staff assignments outside the Off-Campus Student Affairs Office reflect no significant long-term increase in activity. The monies spent in fall 2000 amount to about $5 per off-campus student, and are insignificant in the context of the annual student affairs budget.
   Reporting indices for tracking complaints	Defects in the University's information sharing: Information reported by the University has not been in writing. To date, almost all information we have received from the University has been oral, and so has been hard to retain and verify. Information has not been given proper context. Statistics should be presented in full, but not without related information to give it meaning. At a minimum, incident reports (like hotline calls) should include figures from the previous year. Such data was omitted from the applicant's present submission. Hotline call reports should also include details like the address of the disturbance and the ultimate resolution of the problem. The University's proposed indices are useful but incomplete. They understate the seriousness of the problem, to an unpredictable degree: The volume of hotline calls depends on community perceptions of the hotline's effectiveness. Community confidence in the hotline is now at a low level. If student disruptions increase, hotline calls could paradoxically drop as community confidence declines. Metropolitan Police Department reports depend on the availability of officers and the nature of the disruptions. As relatively low police priorities, noise, drinking or public nuisance complaints are likely to be bypassed if there are other demands, and arrests are rare. Short-time or mobile disruptions (walking through the community, or moving parties) are hard for police to catch and are often not reported for that reason. No record is made by police of calls for service that result in no action. The University Department of Public Safety is permitted to officially patrol only within the campus boundaries. Their reports will provide little information about off-campus problems. All of these indices relate only to student conduct problems. They will not measure housing law violations, complaints about property maintenance, landlord-tenant issues, parking violations, or many other issues that cause problems for students in the community. Even with their flaws, University statistics show a serious impact. In a one-month period alone, there were many incidents-57 hotline calls and 26 alcohol or behavior arrests. And as we have argued, these probably significantly underreport the problem. We urge that the Board consider the community's request for a full-time hotline that would receive, follow up on, and log community complaints about any University-related problem. The request is detailed in the following section, "Community Proposals", as item #2. If such a hotline were credible to the community, it would provide a very useful record. We feel that at this time there is no objective index that reliably measures University impact on the neighborhoods. The Board must continue to acknowledge the importance of citizen input like that obtained in the campus plan approval process. It is unfortunate that, while the University reportedly tasked three individuals to develop these indices, no community input was solicited. Other community recommendations for indices are listed in the section, "Community Proposals", as item #3.
   Code of Student Conduct	The changes in the Code appear to be improvements. The additional sanctions increase the possibility that some sanctions will be applied when needed. However, the problem is not with the Code but with the way in which it is enforced. There is plenty of room for leniency in the new Code; for example, co-curricular sanctions include suspension from athletic performances, but the term of the suspension is set by the Dean and the coaches-it may be just a few games. University refusal to disclose when sanctions are imposed greatly reduces the deterrent effect of the sanctions on others. Information to students on University expectations is inadequate. The letter from the President of the University (Exhibit H) partly illustrates the problem. This letter was distributed not on letterhead, as found in the submission, but as email. Reading such a long and wide-ranging letter on email is not easy, and finding the specific information about the Code of Conduct is difficult even on paper. The President of the University has never made a clear, specific communication to the students on any topic related to neighborhood relations. The letter of Exhibit H was sent on August 29; the following weekend (Labor Day) was one of the worst weekends for student noise in recent history. Informational fliers to students have been distributed as leaflets throughout the neighborhoods. Many of these are ignored and blow away. Evidently the University proposal to have all students sign a document committing them to responsible citizenship and the Code of Conduct has not been implemented. Even this is no guarantee of understanding or compliance.
   Mechanisms for coordination with Metropolitan Police	Evidently, no procedures were established for better prevention or improved response to inappropriate student behavior. (For example, coordination between SNAP and MPD). One new "mechanism" is reported: the procedure whereby a University officer retrieves weekly incident reports. Student orientation meetings as described have been held for many years. Assisting MPD in community outreach will hardly affect student behavior. Cmdr. Newsham, Lt. Bray and Lt. Contee did not attend the second meeting of ALL; instead, they sent a representative.
   Partnership with the Community	The 9 meetings detailed in Exhibit K of the submission include none (except the ALL meetings) specifically held to discuss student conduct and community issues. Most are community meetings that are usually attended by a University representative. There was one meeting (Oct. 11) to discuss underage drinking, which was organized by a University employee and co-sponsored by Mothers Against Drunk Driving. Amazingly, no advance notice of this meeting was provided to any community organization or to ANC 2E. The meeting was not advertised in or reported on in local media. Attendance from the community was very low (reportedly less than 20 individuals). Regarding the BZA Quarterly meeting on September 21: A single "feedback form" from that meeting is included in Exhibit M, signed by two individuals who were not present at the meeting (see the signup sheet in Exhibit L). None of us present at the meeting can remember any such "feedback form" being distributed there.
   Partnership with DPW and DCRA	The measures described in the chart amount to very little. There is no partnership with either DPW or DCRA. Partnership with DPW DPW has assisted with the University's bulk trash pickup for many years. Such one-time assistance can hardly be called a "partnership". The community has worked closely with Tom Day, the DPW chief solid waste inspector. To our knowledge, the University has never met with Mr. Day to learn what is expected of group houses, what trash procedures are, and so on. The University's October 20 submission includes a form letter meant to notify off-campus students of trash violations. Factual errors in this letter are a good indication that it was not compiled with DPW cooperation. We have seen no evidence of University patrols to issue trash citations. Such a program has not been described in the University's plan, and no record of its accomplishments has been submitted. However, such a program should be implemented, and might serves as a basis from which to seek a partnership with DPW. Partnership with DCRA Evidently no partnership with DCRA exists, beyond a meeting with-or a telephone call from-ALL. The University's stated refusal to list illegal properties on the rental list is almost meaningless because it is based on the property owner's statement and not on a partnership with DCRA. The University should obtain information on compliance from DCRA and likewise inform DCRA if it learns-from student or neighbor report or its own investigation-of unsafe or illegal conditions in listed properties. The University should have a procedure to receive housing complaints and act on them. Furthermore, the University should make a good-faith effort to use information at its disposal to detect housing problems.
   Registering student vehicles	The University evidently chose to disregard the Board's request for University registration of all off-campus cars. Neither SNAP nor any other University agent will cooperate in enforcing DC registration laws. Instead, the University has distributed fliers informing students of the law.
   A "full-time hotline"	The University's hotline is grossly inadequate. It responds to problems for only certain times. Its scope is limited to disturbances from off campus-it can't even respond to noise complaints about University functions or from on-campus students. Even when functioning, it has not been supported by effective enforcement or follow-up. Because of its shortcomings, the hotline has low credibility in the community and is underutilized. What is required instead is the community proposal (above) of a full-time, broad-scope hotline.
   Identify how the Board of Review operates	We're not sure if the response addresses the question the Board intended to ask. However, we can comment that probably the most crucial requirement of the plan is the support of the University President. The impending departure of the current President is an important reason to limit the term of any approved plan.
   Provide an up-to-date count of students	This information is inadequate: Despite frequent requests, no FTE counts of undergraduate enrollment have been submitted The information provided is nonetheless disturbing: The current enrollment is very close to the cap and may well exceed it, depending on events in the spring. More comments on enrollment are given above, in point #1 of the response to the cover letter.
   Student Council response	We received the GUSA response only with the applicant's October 20 submission. The Board had asked how the student council would reach out to students with disciplinary problems. The response indicates The Student Council does not support the University program The Student Council has identified no steps to reach out to students with disciplinary problems; instead, it proposes a public relations program with "non-student residents."

3. Community proposals for the University's off-campus student program
   1. Taking responsibility: The University must in principle and in fact take responsibility for actions of their students. Note that most GU undergraduates are young and from outside the DC area. The University, in enrolling them and inducing them to live in the community, has an obligation to ensure that they understand and comply with local laws and customs. Examples of areas where the University should bear ultimate responsibility are
      • Noise disturbances
      • Maintenance of housing and trash
      • Health and safety (housing codes and zoning violations)
      • Parking impact: ensuring that students park legally and register their vehicles as required by law.
      • Generally, compliance with all laws relevant to neighborhood impact.
      University responsibility in these areas should include establishing
      • Means to inform students of their obligations and of resources available to them;
      • Procedures to remedy problems arising from noncompliance (such as removing garbage and towing cars) and other problems (such as working to obtain housing inspections and to improve city services); and
      • Procedures to sanction students who cause problems. Sanctions could include means to reimburse the University for costs that it incurs in remedying student-caused problems.
   2. Community hotline: The University should institute a hotline that is manned at all hours of the day, every day of the week, to take complaints or comments by community members about all aspects of University operations. This hotline should not be limited to student disruptions, but should be able to address concerns about housing, zoning, traffic, malfunctioning equipment, and so on. All calls should be logged by tracking number, the operator should be empowered to take immediate action for urgent matters (including noise disturbances), and otherwise an initial response should be made within a reasonable time (by the next business day). The disposition of every complaint should be noted in the log. These logs should be part of the record for any BZA action.
   3. Information sharing: The University should be required to share all relevant information with the community in writing, including:
      • Weekly reports of hotline calls (or similar communications) and relevant police reports
      • Off-campus addresses
      • Yearly counts of off-campus students by community within Zip code 20007
      • Sanctions imposed for misconduct off-campus
      • University actions in connection with the plan
      • Communications from the University to any city agency (including the BZA) regarding the plan. This includes any reports or minutes from meetings of public or private bodies charged with community affairs. (Such documents, if submitted to the BZA, should likewise be timely served on the parties to this hearing.)
   4. Other proposals: Other community proposals which have not been implemented by the University include the following
      • The Office of Off-campus Student Affairs should be given funding one year in advance to ensure year-to-year consistency in its operations.
      • Off-campus residence should be considered a privilege requiring a record of good behavior. Students with past behavior problems should not be permitted to live off campus, and students living off campus who have proven not to be good citizens should be returned to campus for their senior year. This recommendation is supported by the ANC 2E position. (A similar procedure already applies for students in University-owned housing.)
      • Off-campus parties in non-university-owned housing should be registered in the same fashion as parties occurring in university-owned housing.
      • Varsity athletic teams should be required to live on campus, inasmuch as they represent a disproportionate share of the problem houses. The same rule should be applied to club teams. This provision could be a team-building benefit of participation in the sport, similar to the housing benefit we understand is now available to the basketball team.
      • The University should commit to working closely with city agencies like DCRA and DPW to ensure that the houses occupied by their students are safe and well maintained. (Programs described in University submissions are all short-term or poorly defined.)
   5. Simple remedies that would greatly reduce negative impact were omitted from the applicant's submission, but follow directly from the evidence in this proceeding:
      • Provision of additional on-campus undergraduate student housing. All parties, including the University's expert, have agreed on the beneficial effect of this measure. In fact, the University already has facilities on campus not presently used for undergraduate student housing that would be suitable for that purpose now or in the near future. Furthermore, housing a greater fraction of undergraduates on campus is not as unusual or as great a burden as the University has implied. Most of the University's peer institutions house a greater percentage of undergraduates on campus than they do (see Appendix D).
      • Reduction in University enrollment. This would appear to be the Board's only recourse if the University proves unable to control negative impact in any other way.