Government of the District of Columbia

Board of Zoning Adjustment

Application No. 15302 of the President and Directors of Georgetown College, pursuant to 11 DCMR 3108.1, for a special exception under Section 211 for review and approval of its campus plan for the period 1989 through the year 2010 located in an R-3 District at premises 37th and 0 Streets, N.W., (Square 1321, Lots 815-817; Square 1222, Lots 62, 801 and 802; Square 1223, Lots 85, 86, 804, 805, 807-810, 812, 815, 821, 824, 826, 827, 831, 843, 846, 847, 852, 853, 855 and 857; Square 1226, Lots 91, 94-101, 104, 105, 803, 804, 806 and 811-815, and; Square 1248, Lots 122-125, 150-J.57, 800-802, 804-806, 829-831, 834 and 835)

FINDINGS OF FACT:

1. In Order No. 14021, dated December 30, 1983, Georgetown University ("Georgetown" or "University") was required to submit a revised campus plan by December 30, 1988. At Georgetown's request, and after receiving comments from the Office of Planning and Advisory Neighborhood Commission 2E, the Board extended the deadline for submission of a revised campus plan to December 30, 1990. On February 12, 1990, Georgetown filed the subject application for review and approval of the "Bicentennial Master Facilities Plan, 1789-1989 through the year 2010 and beyond" (hereinafter, the "Campus Plan").

2. The public hearing on the proposed Campus Plan was initially scheduled for May 16, 1989. On April 9, 1990, at the request of the community, Georgetown filed a letter with the Board requesting postponement of the public hearing until June 20th in order to allow additional time for community review of the Campus Plan and, specifically, completion of the Working Group process initiated by the University. Advisory Neighborhood Commission 2E, the Business and Professional Association of Georgetown, the Citizens Association of Georgetown and the Burleith Citizens Association all supported the requested postponement. Advisory Neighborhood Commission 3B requested a later hearing date than June 20th. On May 16th, Georgetown revised its request to suggest a date in July for the continued hearing and the Board granted the request and postponed the hearing until July 11th.

3. The Georgetown Campus is located in an R-3 and C-1 District and is known as premises 3800 Reservoir Road, N.W. The University campus contains 104 acres of land. There are dramatic topographic changes in the site which affect the organization and use of the campus. The land rises twenty feet from Reservoir Road on the north to a large, relatively level area, then falls sixty feet to the large parking lot at the southern end of the campus, then falls another sixty feet to Canal Road below. Moving from east to west, the original portion of the University sits on a bluff which falls off at a thirty-five foot high cliff to the aforementioned parking lot and then drops another fifty-five feet down a steep slope into Glover-Archibald Park. The medical campus occupies the high ground to the northwest and the main academic portion of the University campus sits on the bluff located to the southwest.

4. Georgetown University is located in an urban setting composed of residential, institutional and commercial uses. The main campus, which includes both the university and medical campuses, is bordered on two sides by public parkland and Canal Road. The southern boundary extends east along Prospect Street to 35th Street, excluding the structure along the north side of Prospect Street between 37th and 36th Streets. On the west the campus is bounded by Glover-Archibald Park, where the parkland slopes rapidly down to the west. The northern boundary is Reservoir Road across which are the French Chancery, the Hillandale, a residential development, the Duke Ellington High School Athletic Field and a block of rowhouses. The eastern boundary starts on the north at Reservoir Road and 37th Street and zig zags south and east past the Cloister's residential rowhouse development and the grounds of the Sisters of Visitation High School and Convent to a point just west of 36th and P Streets. The boundary then continues south, excluding a row of residences on the west side of 36th Street to 0 Street, south on 36th Street to N Street, east to 35th Street and finally south to Prospect Street. The uses along the eastern boundary of the campus are largely residential and institutional with some scattered commercial uses.

5. Georgetown University is located within the Georgetown Historic District. In addition, Old North, the Observatory and Healy Hall are, all landmark buildings. Because the campus is within the boundaries of the Old Georgetown Act, the Commission of Fine Arts has architectural review authority for specific building projects.

6. The applicant, Georgetown University has filed for a special exception under 11 DCMR 211 for review and approval of a revised campus plan.

7. Section 211 of the Zoning Regulations provides that a college or university which is an academic institution of higher learning, including a college or university hospital, dormitory, fraternity or sorority house proposed to be located on the campus of a college or university, is permitted as a special exception in a residential district, provided that:

1. Such use is so located that it is not likely to become objectionable to neighboring property because of noise, traffic, number of students or other objectionable conditions (11 DCMR 211.1);
2. In R-1, R-2, R-3, R-4, R-5-A and R-5-B Districts, the maximum bulk requirements normally applicable in such districts may be increased for specific buildings or structures provided the total bulk of all buildings and structures on the campus shall not exceed the gross floor area prescribed for the R-5-B District (11 DCMR 211.2);
3. The applicant shall submit to the Board a plan for developing the campus as a whole, showing the location, height and bulks, where appropriate, of all present and proposed improvements, including, but not limited to buildings, parking and loading facilities, screening, signs, streets, and public utility facilities, and a description of all activities conducted or to be conducted therein, and of the capacity 'of all present and proposed campus development (11 DCMR 211.3);
4. Within a reasonable distance of the college or university campus, the Board may also permit the interim use of land or improved property with any use which the Board may determine as a proper college or university function (11 DCMR 211.4); and
5. Before taking final action on an application for such use, the Board shall have submitted the application to the District of Columbia Office of Planning and the District of Columbia Department of Public Works for review and report (11 DCMR 211.5).

8. Since the adoption of the 1958 Zoning Regulations, the University has submitted eight campus plans to this Board for review and approval. All of the property proposed for inclusion in the present plan was included in the previous plans. The plan's campus boundaries include, with certain exceptions, land owned by the University and actively devoted to University use for nearly 200 years. The University recently completed its bicentennial celebration.

9. The 1983 Campus Plan established a framework of physical development policies to support academic programs, foster long-term flexibility, and maximize efficient use of existing facilities. The 1983 Plan defined seven functional categories of land use to frame and shape new growth according to fluctuating conditions and needs. Among the specific policies of the 1983 Plan were the University's commitment to the tiered architectural podia concept to contain a mix of uses, the construction of a south entrance to improve transportation patterns both at the University and in the surrounding neighborhood, and leadership in the exploration and use of new technologies at the Medical Center and through projects like photovoltics and cogeneration.

10. Since the approval of the 1983 Campus Plan, the University has had eleven projects approved as special exceptions by this Board. Of the approvals, ten were granted by bench decision. Among the projects approved and constructed were Village C, a dormitory complex housing approximately 674 undergraduate students; the Leavey Center, a major facility housing student services, guest room facilities for university visitors, student affairs offices, and an approximately 1,000 car parking garage; the physicians health care center and outpatient facilities; the research/resource facility; and a one-story structure in the hospital complex housing a magnetic resonance imaging (MRI) facility.

11. Georgetown University was founded in 1789 and is fully accredited. It has been located on its present campus since its founding. It offers degree and non-degree programs in its college of Arts and Sciences, School of Medicine, Nursing School, Graduate School, School of Foreign Service, School of Languages and Linguistics, School of Business Administration and School for Summer and Continuing Education, all of which are located on the campus under consideration. Its Law Center is located at 600 New Jersey Avenue, N.W. and is not part of the subject application.

12. University officials testified that in charting the course for the University's third century in Washington, they relied heavily on past traditions and experiences that have worked well for the University. The Bicentennial Campus Plan builds upon the concepts contained in the eight previous plans approved by the Board. In particular, it has its foundations in the 1983 Plan; rather, the document refines and updates University programs and policies as set forth in 1983.

13. University officials also testified that the Campus Plan had been improved as a result of community involvement in the planning process. Over the course of the last two years, that involvement took two forms. First, at the time the University first applied to the Board for a two year extension of time, representatives of the University began meeting with the Community to talk about the programs and policies in the Campus Plan and to receive feedback on issues of concern. Those Town Gown meetings began in January 1989. The second phase of community involvement began in the fall of 1989. At that point, representatives of the University began meeting with citizen members of the Community Working Group representing nine community organizations. The University filed in the record a document providing a complete chronology of community meetings with copies of all correspondence, notices of meetings, and minutes.

14. The proposed 1989 Bicentennial Campus Plan (Draft #3 Revision Date 1 June, 1990) is marked as Exhibit No. 100-D of the record. In preparing the proposed Bicentennial Campus Plan, the University was guided by the following planning factors:

1. Education goals and objectives of the University
   1. Commitment to a vital liberal arts tradition - its national and international character reflects its location in the capital of the United States.
   2. Commitment to excellence in undergraduate and graduate education, with a fertile interplay between teaching and research.
   3. Commitment to building a strong sense of community with a dedication to serving.
   4. Commitment to providing first rate facilities in order to support its educational mission of teaching and research, service and administration.
   5. To continue to develop a medical center as a leading catalyst to the progress of biomedical knowledge.
   6. To attain new orders of excellence in the education of future physicians, nurses and biomedical scientists.
   7. To bring to patient care the most sophisticated technologies, the latest findings of biomedical research, and the skill and compassion of leading health care professionals.
   8. To improve the quantity and quality of classroom spaces and faculty offices.
   9. To provide additional space and upgraded facilities for the University's expanding science book collection.
   10. To provide national and international leadership in meeting the energy and power needs of the campus and surrounding community through the use of emerging technologies that are clean, efficient and economical.
2. Land Use Goals
   1. Implement the concept of intensive mixed use development through the tiered architectural podia concept which integrates all functions under one roof to engender a strong spirit of community among students and faculty.
   2. To preserve, protect and enhance existing open green spaces on the campus and to earmark future open green spaces while unifying and improving the landscaping of all campus areas.
   3. Seek to make the campus setting more beautiful and a distinguished architectural setting suited to the traditions of the unique Georgetown neighborhood and to the University's stature as an urban academic institution.
   4. Seek to assure that the campus is a place for use mainly by pedestrians and cyclists, a pleasant and safe environment that minimizes intrusions by motor vehicles.
   5. Provide an orderly flexible framework within which its long term needs for future facilities, growth and development can be accommodated with a positive impact on important surrounding features.
   6. Provide new facilities to support and enhance the excellence of its academic, research, service, religious, cultural and recreational programs.
   7. Meet the needs of faculty, staff, undergraduate and graduate student housing through the construction of new dormitory space and the utilization of existing townhouses east of 37th Street.
3. The Comprehensive Plan for the National Capital.
   The proposed plan recognizes the need for consistency with the Comprehensive Plan Act of 1984, as amended. The proposed plan notes the Generalized Land Use Map depicts the general land use in the campus area as institutional. The University described how it believes the proposed Bi~'entennia1 Campus Plan is consistent with Comprehensive Plan policies with particular regard to architectural character, building height limitations, physical and symbolic imagery, historic preservation and stabilization of neighborhood, development of facilities for learning, teaching and research, containment of health care costs, improved air quality and energy conservation, and many others.
4. Need for flexibility
   The proposed Bicentennial Campus Plan notes that detailed building design is not feasible until programmatic details and funding arrangements have been worked out for a specific development proposal. The plan requests the same flexibility granted by the Board in previous campus plan cases.
5. The Zoning Envelope
   The Zoning Regulations permit development to an FAR of 1.8 for the University campus. With the projected building program for the University, the Bicentennial Campus Plan projects a building envelope of approximately 1.6 FAR as compared with the 1.4 FAR requested under the 1983 Plan.
6. Off Campus Uses
   A complete listing of properties owned by the University outside of the campus boundaries is included as an appendix to the Campus Plan consistent with what was provided at the time of the 1983 Plan.
7. Student Enrollment
   The proposed plan anticipates modest enrollment increases of approximately 340 undergraduate FTE students over the next four years.

15. University officials testified that the goals of the proposed Bicentennial Campus Plan are consistent with those contained in the 1983 Plan. These will guide campus growth and physical development as follows:

1. To provide flexibility in the development of projects through designation of mixed and multiple use facilities;
2. To concentrate new development internal to the campus and away from the perimeter boundary;
3. To continue to orient student activities on-campus rather than off-campus;
4. To maximize open and green spaces;
5. To provide centralized, underground parking, and improved internal circulation;
6. To minimize traffic impacts on the surrounding community;
7. To pursue transportation management policies reducing dependence on the private automobile; and
8. To foster a working relationship with the surrounding communities.

16. The Bicentennial Campus Plan was initially proposed to cover the time period 1989 through 2010. University officials selected this time frame to allow time to plan and construct development projects, given the approvals that are required, particularly with Commission of Fine Arts review. At the request of the community, the University officials agreed at the public hearing to the time period through the year 2000, making the plan a ten-year plan. The Board concurs.

17. The Bicentennial Campus Plan continues the land use categories of the 1983 Plan. These categories are:

1. Educational - classrooms, administrative and faculty office.
2. Educational mixed use - residential, education, decentralized recreation.
3. Educational support - parking, utility plant and miscellaneous auxiliary uses.
4. Medical - hospital, clinic, staff, doctors offices, administrative and faculty offices, medical libraries, classrooms, lecture halls, conference facilities and research laboratories.
5. Medical support - parking and miscellaneous uses.
6. Recreational - recreational.
7. Residential - residential.
8. Commercial - commercial.

18. The proposed Bicentennial Campus Plan calls for continuation of the campus boundaries approved by the Board in 1983.

19. In terms of undergraduate full-time equivalent (FTE) students, the University has projected in Appendix H the planned increases over the next four years. The undergraduate FTE numbers in Appendix H do not include non-traditional students such as women returning to school, English as a second language students, commuters, and other non-traditional students not requiring housing. This increase in undergraduate FTE enrollment translates to approximately l percent annual growth. As University officials testified, because of changes in the enrollment patterns at universities nationwide, the University has not even achieved its enrollment projections made in 1983.

20. The proposed Bicentennial Campus Plan projections for faculty and staff total 7,500. For visitors, the number is 2,100 which includes the visitors to the Medical Center. A comparison of the 1983 and 1989 Plans is as follows:

21. The proposed Bicentennial Campus Plan anticipates the addition of approximately 2,600,000 square feet of floor space within the campus boundary over the life of the proposed plan, as set forth in Appendix C to the Plan. The bulk of the projected growth in building space results from the need to replace obsolete facilities, to relieve overcrowding of existing facilities, and to provide needed space for the hospital and patient needs. A significant portion of the new development will be new dormitory space to meet the request of the community that the University provide 925 new beds on campus. Finally, needed support space including additional library space and athletic facilities, as well as the needed cogeneration facility are also included in the new space projections.

The projected space increase under the proposed plan is not significantly higher than the space increase that was projected under the 1983 plan. In addition, the existing space figures demonstrate that many projects which were projected have yet to be built.

Existing Space	>4,280,324 sq. ft.
Proposed Space (1983 Plan)	>6,179,270 sq. ft.
Proposed space (1989 Plan)	>6,817,064 sq. ft.
Difference Between 1983 & 1989 Plans	>637,794 sq. ft.

22. The Bicentennial Campus Plan places a high priority on the development of on-campus housing and other facilities. The following list indicates the phasing of new development on-campus:

1. On-Campus housing: to meet its commitment to provide 925 new beds on campus by 1997, the University has identified the following three priority projects for new beds:
   1. Rehabilitation of Loyola, Xavier and Ryder to create 225 new beds.
   2. Construction of a new dormitory to create 500 new beds.
   3. Reconstruction of St. Mary's to provide 200 new beds.
   Other options may be considered by the University so long as the 925 beds are provided. The alternative locations for the new dorms are shown in Appendix H to the Campus Plan. The financial ability of the University to provide these new beds is based upon tax exempt bond financing, alternate financing and the construction of the cogeneration facility.
2. Educational and Educational Mixed Use: facilities for support of library, science, student activity and general academic programs are also priority needs. The following projects have been identified as needed for student educational programs and activities:
   1. Podium B to provide additional classroom space and to relieve overcrowding
   2. Leavey Center addition to consolidate and expand the facilities for student health services and to provide additional space for student affairs.
3. Educational support and recreational: a cogeneration facility is priority and is needed to provide utility service for new campus development and to offset the costs associated with dormitory development and renovation.
4. Medical and medical educational support: priority projects are needed to provide improved medical research and support space and to continue to provide quality health care for residents. They are:
   1. The Perinatal Infill building on the west side of the hospital.
   2. Buildings R and S for medical research and support, including the relocation of FGIN from its temporary space elsewhere on campus.
   3. The Lombardi Cancer Center addition.
   4. Parking garage P to provide below grade parking and to replace surface spaces.

23. University officials stated that the University's development priorities for all its projects are subject to the availability of financing (whether through tax exempt bonds, grants by individual donors, or more conventional financing) in addition to the wishes of an individual donor. Many of the projects listed as priorities, for example, were expected to be built under the 1983 Plan and, instead, have been carried over because the University was unable to finance the construction. (Some of these projects include Podium B, the medical research facilities, the cogeneration facility and the Lombardi Cancer Center addition). Other projects, like the South Entrance, require coordination with other local and federal agencies. Further, unlike other universities that are not located in historic districts, Georgetown University's phasing of new development is often impacted by the timing of public reviews required for individual projects.

24. The University presently has housing for approximately 83 percent of its undergraduate students. As described in Appendix H to the Bicentennial Campus Plan, at the community' s request, the University has agreed to significantly increase the supply of on-campus beds for undergraduate students and to create a residential college environment. Specifically, the Bicentennial Campus Plan proposes the following:

1. To adopt as a long term goal of the University, the ability to provide housing for 100 percent of its undergraduate students on campus.
2. To make a policy change to require all freshman students to live on campus beginning academic year
3. To extend this requirement to sophomore students upon completion of dormitory rehabilitation and new construction.
4. To move graduate students off-campus in order to accommodate incoming undergraduate students, until the new dorm beds are in place. (This would provide approximately 200 beds for immediate use by undergraduate students).
5. To maintain the use of University-owned townhouses for undergraduate students.
6. To commit to providing a total of 925 beds by the fall of 1997, contingent on the ability to finance, approval of bond money, approval of the Campus Plan, and approval of the cogeneration facility. This 925 beds is in addition to the 2,170 beds the University has constructed since 1976.
7. To implement a new program for off-campus student affairs to improve the University's ability to respond to the concerns expressed by the community.

25. University officials testified as to the history of the University in the Georgetown community and also provided information as to the economic impact of the University on the city from 1988-1989 including the following:

1. The University employs 6,800 District of Columbia residents paying a total compensation of $83 million.
2. The University purchased $61 million in goods and services within the District and paid $6.4 million in district taxes.
3. The University awarded $8.5 million in financial aid to District students.
4. The University paid over $11 million in debt service to District institutions and paid over $20 million to D.C. construction firms creating more jobs for District residents.
5. Over 6,400 Georgetown alumni reside in the District of Columbia, working and paying taxes in the city.
6. The University provides over sixty-five community programs and services, one of which is the National Capital Poison Center, which it runs.
7. The University provides cultural, educational, legal and health services to the needy.
   

   These examples were cited by the University as just a few of the numerous ways that Georgetown directly or indirectly contributes to the health and welfare of the city and its residents.

26. The University provided financial information on the University in relation to the number of students, tuition and financial aid, and constraints on the ability to provide more on-campus housing. University officials testified that the University was highly tuition-dependent and that tuition and fees accounted for 74 percent of the main campus budget. Less than 1 percent of the University's income is contributed from its endowment fund. Approximately 42 percent of the University's students receive some form of financial aid which represents 15 percent of the campus budget. Further, the most recent survey by the Higher Education Research Institute indicates that Georgetown ranks second only to Stanford University in the percentage of minority degree recipients among thirty-one highly selective and competitive institutions.

27. University officials described the major accomplishments in the area of transportation that have taken place at the University since the time of the 1983 Plan. These include:

1. The closing of the main gate at 37th and 0 Streets, N.W.
2. The new underground garage located in the central area of the campus.
3. Increased bicycle parking spaces near every major building on the campus.
4. Continued development of the Transportation Management Program with the result that traffic levels of the University are relatively stable with those at the time of the 1983 Plan.
5. Continued improvement of traffic routing to reduce pedestrian confrontation with vehicles.
6. The testing of the new program for carpooling.
7. Coordination and cooperation with the Federal Highway Administration on the design of the improved South Entrance which has been in the plans for the University since 1971.

28. The proposed Bicentennial Campus Plan continues the improved South Entrance project that was included in the 1983 Plan. Rather than the circular drive shown on the 1983 Plan to route traffic into and put of the southern end of the campus, however, the Bicentennial Campus Plan proposes a north/south spine road linking the improved South Entrance with the center of the campus, and a medical road loop linking entrances 1 and 4 on Reservoir Road with the north/south spine road. The two road systems would channel vehicle traffic into the center of the University where the current underground parking garage is located and where two new underground garages are proposed. The road entrance points allow the University to direct Virginia, Southeast Maryland and Southeast/Southwest D.C. Commuters into the south entrance, and northern Maryland and northern D.C. commuters into the two entrances on Reservoir Road.

29. With regard to the Transportation Management Plan, the University proposes to continue many of the components already in place including the following:

1. Continued increases in the annual parking rates to discourage single occupant vehicles in favor of ride sharing programs.
2. Improvements to the GUTS bus system and in particular the advanced vehicle design fuel cell buses scheduled for initial delivery in FY 95; and,
3. Implementation of University-leased vehicles as an instrument to the carpool rideshare program for faculty and staff of the University.

All of these programs enable the University to stay within the parking cap of 4,080 spaces imposed by the Board at the time of the 1983 Plan. This parking cap also operates as a control on the number of employees and visitors to the University. An increase of 342 parking spaces is projected over the life of the Plan. The existing and proposed parking allocation is shown in the following table:

	PRESENT		PROPOSED
	Parking Allocation		Parking Allocation
Doctors	360	9%	380	9%
Faculty	920	25%	1,000	25%
Staff	1,808	48%	2,050	50%
Students	250	7%	250	6%
Visitors	400	11%	400	10%
TOTALS	3,738	100%	4,080	100%

30. In preparation for the Bicentennial Campus Plan, the University's Director of Transportation testified that the traffic consultant provided an updated traffic analysis study including projections of planned growth for the University both in terms of building size as well as student, faculty and staff projections. In terms of levels of service on major arterials surrounding the University, these have remained relatively stable since 1982.

31. With regard to pedestrian safety, the Bicentennial Campus Plan furthers this goal by the proposed road network system. Pedestrians are separated from the vehicle roads and, conversely, vehicles will no longer be using paths used by pedestrians. The realignment of the entrance at 38th Street and Reservoir Road will also help improve pedestrian safety at that crossing.

32. The Bicentennial Campus Plan proposes to increase and intensify landscaping on the campus including distinctive sidewalk paving, trees and other plantings, special lighting, and other features. The landscaped elements of the Campus Plan improve pedestrian connections between the Georgetown campus and adjacent outdoor recreational areas, such as the Potomac River, as well as to the Georgetown neighborhood. Pedestrian pathways will be established to the Chesapeake and Ohio Canal footpath, a popular hiking, cycling and jogging trail. Footpaths will also connect the campus with the Glover-Archbold Parkway trail system.

33. The proposed Bicentennial Campus Plan describes past historic preservation efforts by the University and notes the University's continuing commitment to develop its campus with buildings of the highest architectural quality. Because of the University's location in the Georgetown Historic District, each new building requires review by the Commission of Fine Arts.

34. The proposed Bicentennial Campus Plan acknowledges the University's goal to create new facilities that make the campus a more beautiful and distinguished physical setting by providing a framework for historic preservation and restoration programs, as well as for sensitive new construction and improvements to the campus landscape. The plan helps to ensure a stronger architectural identity for the campus.

35. For all of its campus facilities - many of which will become important historical architectural resources in the future - Georgetown is implementing a Comprehensive Deferred Maintenance Program. Architectural and engineering consultants have completed a full scale survey of all campus buildings, noting steps that must be taken to care for and preserve the usefulness of the University's existing investments. Restoration and maintenance efforts will be assisted by a computer-based facilities information management system. Building on the commitments expressed in the 1983 Plan, the Bicentennial Master Plan recognizes and reinforces the historic character of the campus and its surroundings.

36. The Bicentennial Campus Plan updates and improves the University's energy programs. The plan describes the University's long history of involvement in the area of energy innovation and conservation. The central energy plant to heat and cool University buildings was first approved in 1968, well over 20 years ago. In 1977, the Board gave approval to construct a fluidized bed combuster addition to the heating and cooling plant. In 1983, a second addition was approved by the Board allowing the University to achieve cogeneration from the fluidized bed system. The 1983 Campus Plan included the concept of cogeneration and other innovative energy systems. University officials explained that with the proposed cogeneration facility which is continued in the Bicentennial Campus Plan, the University will be able to serve its growing heating and cooling needs reliably and efficiently for the next thirty-five years while simultaneously serving the public need for electricity, produced economically through cogeneration. The proposed cogeneration facility will be located within an expansion of the existing energy plant, which the Board in previous cases has found to be sufficiently removed from the surrounding community. University officials also pointed out that the facility will meet all applicable local and federal environmental requirements.

37. The University anticipates the proposed Bicentennial Campus Plan will not create objectionable noise conditions. All construction proposed by the plan will occur within the campus boundaries. Within its boundaries, the Plan locates activities so as to satisfy the university's need for quiet and secure places of study. In addition, the University intends to design future facilities so as to further reduce noise to the neighborhood. Further, the proposed plan locates new development and, in particular, athletic and recreational activities, in the southwestern quadrant and interior of the campus, thus as far removed from surrounding neighborhoods as possible. Finally, with regard to the proposed cogeneration facility, the facility will feature noise suppression measures, will use underground transmission lines and will operate in compliance with all local and federal regulations, including any noise requirements.

38. The University anticipates the proposed Bicentennial Campus Plan will not create objectionable traffic impacts. The University continues to implement a Traffic Management Program designed to reduce campus traffic and parking demand through such measures as charging higher rates for parking and coordinating a carpool system. In light of this program, the University's Director of Transportation testified that the percentage of University traffic on adjacent streets has remained constant at 1982 levels and in some areas has actually decreased, despite increases in staff and visitors. The Transportation Director noted that in addition to the GUTS shuttle bus service, the University had recently completed a study of a new program for carpooling which would provide for University-leased vehicles used by faculty and staff, thereby reducing the number of vehicles driven to the campus on a daily basis. This new program is scheduled for implementation in the fall of 1990. As to traffic circulation and levels of service, the study prepared by the University comparing present day levels of service with those at the time of the 1983 Plan indicated that levels of service on major arterials surrounding the University have remained relatively stable since 1982 and, further, the percentage of University traffic has actually decreased. The intersections studied by the consultant were the same intersections selected by the Department of Public Works and the same ones requested for study by the community.

39. As to the traffic impacts from the improved South Entrance, the University's Director of Transportation testified that the south entrance will have positive impacts on transportation patterns for the larger community and pointed out that this is the same conclusion reached by the Department of Public Works. This is consistent with the earlier findings of both the University and the Department of Public Works at the time of the 1983 Plan. The University pointed out that the improved South Entrance will result in decreases in traffic levels on Reservoir, Foxhall, and Georgetown residential streets. Further, to the extent that there is any slowdown in Canal Road/M Street traffic as a result of the South Entrance, it will add less than one second of increased travel time. Finally, with regard to the realignment of the entrance at Reservoir Road and 38th Street, the Transportation Director emphasized that this was being done in the interest of improved pedestrian safety and was an issue which the University was prepared to further discuss with the community and the Department of Public Works. Finally, as to parking impacts, the Transportation Director pointed out that the University was agreeing to continue to be limited by the. 4,080 cap set at the time of the 1983 plan. The University further pointed out that this cap operates as a transportation management strategy to control traffic to and from the University and operates as a limit on the University's ability to add faculty and staff, unless those faculty and staff are able to carpool or use public transportation so as to stay within the cap.

40. The University anticipates the proposed Bicentennial Campus Plan will not create objectionable conditions because of the number of students or other objectionable conditions. In Appendix H, the proposed Bicentennial Campus Plan provides a limitation on undergraduate FTE enrollment which results in relatively modest increases of approximately 1~ percent over the next four years. The proposed increases in faculty and staff and visitors to the University will also have no objectionable impact because of the University's limitation on the number of parking spaces which operates as a control on traffic to and from the University. The building program envisioned by the 1989 Plan results primarily from the commitment to provide on-campus housing for undergrate students, the need to increase program quality, the need to replace functionally obsolete structures and the need to alleviate classroom constraints and faculty overcrowding. Further, University officials pointed out that the plan concentrates academic and student facilities within the campus core and places new building development in the southwestern quadrant of the campus. This results in the placement of facilities generating high volume activity away from residential areas. On the other hand, the plan locates facilities generating less student activity on the periphery of the campus. Finally, where the campus abuts private residential development the proposed plan minimizes adverse impacts associated with increased physical development by containing University growth within the campus boundary through inclusion of a policy to preserve historically and architecturally significant buildings, landscaping and other screening devices, and incorporation of a policy to build new structures manifesting excellent design.. Through the program described in Appendix H to the Campus Plan, the University also proposes to immediately address the issues of undergraduate students living off campus by immediate policy changes to move undergraduates on campus, strengthened procedures to regulate the conduct of students living off campus, and an aggressive building program to eventually provide enough beds on campus for all of its undergraduates.

41. The University maintains compliance with the provisions of the Zoning Regulations mandating submission of a unified Campus Development Plan. The following pages of the Plan, Exhibit No. 100-D of the record, reference the specific information required for compliance:

42. The University seeks no specific relief for the interim use of land at this time, but anticipates a possible need to seek such relief from the Board in the future. The Board acknowledges the possible interim space needs of the University and addresses this issue in its conditions.

43. By this application, the University does not seek special exception approval for the construction of a specific University building or use. However, the University has acknowledged the requirement for special exception review in the future as it processes specific development proposals in accordance with the proposed plan. In particular, the University has stated that it anticipates coming back to the Board as soon as possible with the proposed cogeneration facility. The Board acknowledges the University's future need to process special exception applications and addresses this issue in its conditions.

44. The Office of Planning (OP), by report dated July 10, 1990 and through testimony at the public hearing, recommended conditional approval of the proposed Campus Plan. OP stated that the proposed plan was essentially a reiteration of the approved 1983 plan with several changes and refinements. Their analysis of any proposed changes from the 1983 plan found that the differences were relatively minor with insignificant potential impacts. In formulating its specific recommendations, OP sought to respond to community concerns and to show that the plan was building on earlier concepts and approvals. Guided by this, OP reported on the following issues and offered the following recommendations:

1. The proposed Campus Plan elaborates on and refines the framework establishing the University's Campus Plan of 1983, which looked forward 25 years. The proposed plan constitutes a progress report and update on the foundation provided by the 1983 plan and draws upon the University's experience in implementing key portions of the plan.
2. The projected space increase under the proposed plan is not significantly higher than the space increase that was projected under the 1983 plan. OP pointed out that under the 1983 plan the University proposed 6.2 million square feet of space and under the proposed plan the projection was for 6.8 million square feet of development. OP also pointed out that many projects which were projected to be built under the 1983 plan have not yet been built and are, thus, included again under the 1989 plan. OP had no objection to the proposed development density and heights of structures and pointed out that such construction projects as the new science library, library addition, central utility plant expansion, and the expansion of on campus residential facilities contribute to the projected FAR increase. OP also pointed out that the Campus Plan gives consideration to the architectural merits of the proposed structures in relation to existing structures, especially those of historic significance. OP pointed out that a student population of 10,000 was projected under the 1983 Plan and no increase in this number was proposed under the current Campus Plan. OP also had no objection to the proposed increase in faculty, staff and visitors which represented a slight increase over what had been proposed under the 1983 plan.
3. OP pointed out that the Campus Plan extends and refines established landscape development and screening/buffering strategies through the development and implementation of a master landscaping plan. This again was building on concepts provided in the 1971 and 1983 plan and continues the University's efforts to replace surface parking areas with underground facilities and to use the concept of "architectural podia" to provide landscaped green space areas for academic, athletic and support functions. OP also referenced the scenic easement agreements that the University was establishing with the National Park Service and the District Government.
4. With regard to proposed facilities, OP pointed out that the construction of new facilities would take place within the seven functional land use categories previously established in the 1983 plan. Although the University would be adding approximately 2.6 million square feet to existing space by the year 2010, the projected FAR was comparable to what had been forecast under the 1983 plan. The building parameters described in the Campus Plan show the heights and guidelines for building massing and configuration and identifies locations and uses. OP had no objection to the University's need for space.
5. With regard to transportation in its report, OP pointed out that parking allocation and location remains an important element to the proposed plan and stated that overall an increase of 342 spaces was proposed. The plan keeps within the 4,080 spaces established as a cap by the Board under the 1983 plan. OP also pointed out that the Plan carries out several important transportation objectives that were introduced in the 1983 plan and are continued to improve pedestrian and vehicular circulation on campus and to minimize external impacts. These include the Transportation Management Program, the construction of an improved South Entrance and the redirection of traffic within the confines of the campus.
6. With regard to the energy, utilities and waste management system proposed under the plan, OP had no objection to any aspect of the plan. OP pointed out that the provision of the new on-campus power plant was still in the conceptual phase and that the Department of Consumer and Regulatory Affairs (DCRA) would be required to review and evaluate any forthcoming cogeneration facility in terms of environmental impacts. This issue and the specifics of the proposal can be addressed by the Board and OP during further processing of the Campus Plan.
7. OP pointed out that the University plans to add an additional 925 on-campus beds for undergraduate students and to require all freshman undergraduates to live on-campus by 1991. Later this requirement would be extended to sophomore students. In addition, OP described the University's commitment to work with the community to resolve problems associated with students living off campus.
8. In response to community concerns about campus commercialization and, in particular, the planned power plant, OP stated that these kinds of uses were not inappropriate so long as they were in the furtherance of the University's essential mission and did not have any substantial adverse impacts on the surrounding community.
9. Having reviewed the plan in detail with both the University and the community, OP was of the opinion that the proposed plan did not propose any significant changes from the 1983 plan and would have insignificant potential impacts. As such, it recommended approval of the application subject to the condition that approval be for a period of ten years, that each individual request to construct a building come back to the Board, that the University continue the remedial traffic and parking proposals, and that the University and the community continue to seek solutions to the problems associated with on-campus housing facilities.

45. The Department of Public (DPW), by report dated July 9, 1990, reported on the following issues and offered the following recommendations:

1. The plan is an update and a revision of the approved 1983 plan and adds approximately 640,000 square feet of gross floor area and new construction to the totals proposed under the 1983 plan. This new construction includes Podia B, C, D and F as well as the addition of 925 beds by 1997. The number of students would remain essentially the same as that proposed under the 1983 plan and faculty and staff would increase. The number of parking spaces would be maintained at the 1983 level of 4,080 spaces.
2. Most of the proposed new construction was included in the 1983 Campus Plan and was designed to improve existing services. DPW pointed out that the University was taking several steps to reduce traffic and parking impacts on the area surrounding the campus, including:
   1. Providing on-campus housing for students presently living off campus.
   2. Implementing the south entrance.
   3. Installing a University shuttle service to help further reduce University traffic on the street system in the area.
   4. Adding to the University parking supply.
3. DPW recommended approval of the improved South Entrance, pointing out that the implementation of the south entrance would produce a far reaching effect to reduce University traffic impacts on the Georgetown neighborhood streets. DPW stated that the successful completion of the south entrance on Canal Road coupled with the closing of the Prospect Street access would have positive impacts on the surrounding neighborhood. In addition, DPW recommended that the University commit to the implementation of the Comprehensive Traffic Transportation Management Plan as stated in Appendix G.
4. In terms of proposed traffic operational improvements, DPW supported the improvement of the south entrance and the major access to the campus and the University's development of an intermodel transportation center under Podium E. With regard to internal campus road improvements, DPW agreed with the proposed street improvements with certain recommendations. As to the recommendation that University Drive be built as a two-way roadway without parking, the University Plan shows it as a two-way street with no parking rather than a one-way street with parking on one side. This was designed by the University to provide at least two main access points on Reservoir Road for traffic which is a reduction from the four that presently exist. Finally, with regard to the realignment of the 38th Street entrance, DPW agreed in concept subject to design to minimize University traffic entering 38th Street.
5. The Department of Public Works concluded that the 1989 Plan can work from a transportation standpoint and recommended that the University coordinate all design and construction elements in the public space with the Department of Public Works and assume their costs.

46. The Fire Department by report dated June 8, 1990 stated that it had no objection to the 1989 Plan.

47. The Department of Finance and Revenue by report dated May 7, 1990 stated that it had no objection to the 1989 Plan.

48. The Metropolitan Police Department by report dated May 9, 1990 stated that it was not opposed to the request for approval of the Campus Plan.

49. A representative of the National Capitol Planning Commission (NCPC) testified at the public hearing and raised concerns about the potential impacts of the proposed Ancillary I Facility (Building F) on the Potomac River views recognizing that specific building plans had not been prepared. Building F is shown in the Plan as a single structure having 700 to 800 feet of frontage along the Potomac Palisades at the southern boundary of the campus. The building mass is indicated as rising to a height of 96.5 feet and containing some 313,000 square feet of floor area. The NCPC believes a building of this scale and configuration in the proposed location would have significant visual impacts on the entire Potomac River setting as defined under the Federal Element of the Comprehensive Plan for the National Capital. The Federal Interest is described in the Parks, Open Space and Natural features element as it relates to the Palisades and the C&O Canal National Historical Park.

50. Advisory Neighborhood Commission (ANC) 2E, by report dated July 3, 1990 and by testimony presented at the public hearing, recommended approval of the proposed 1989 Campus Plan by unanimous vote of the Commissioners. The ARC testified as to the extensive process of communication and negotiation between the University and ARC 2E that led to the development of the Campus Plan and made the following specific recommendations:

1. In January 1989, ARC 2E established a University/Community Relations Committee and delegated the difficult tasks of developing a working relationship between the University and the community. The community learned an important lesson during the year long ARC, University/Community Relations Committee process: the negative impacts of the University on the community could be mitigated if the community and the University work together to analyze and develop solutions.
2. In every negotiation there are compromises and concessions on both sides and the Campus Plan negotiations were no exception. During the course of the Working Group meeting process, the interests of certain groups diverged with the result that not all members of the Working Group have decided to support the University's plan. Despite the lack of consensus, however, the Working Group process served to reinforce the channel of communication and the University made major modifications to its initial proposals.
3. After several sessions, compromise was reached as follows:
   1. The University would commit to the enrollment projections in Appendix H which show an addition of 340 undergraduate FTE students;
   2. The University would make on-campus housing currently used by graduate students available to approximately 200 undergraduates;
   3. The University would construct an additional 925 beds on-campus by 1997;
   4. The University would create a Department of Off-Campus Student Affairs to address the needs of students and the community during the interim period.
4. With regard to transportation, the ANC 2E believes that the Transportation Element to the Campus Plan will help to eliminate some of the University's current impact on traffic in Georgetown. The ANC supports the construction of the improved South Entrance which will channel traffic from Key Bridge and the Whitehurst Freeway into the campus in the morning and back to these arteries in the evening. In conjunction with the construction of the south entrance, the ANC also supports the closing of Prospect Street.
5. The ANC also recommended a process for improving communications between the community and the University so that existing and future problems can be addressed jointly and successfully. Finally, it was recommended that a process be put in place for a five year update by the University as to its progress on its Housing Program.

51. Advisory Neighborhood Commission (ANC) 3D by letter dated June 27, 1990, expressed its support for the Transportation Elements of the Campus Plan and took no position on the other elements of the Plan.

52. Advisory Neighborhood Commission (ANC) 3B by letters dated July 3, June 27 and June 26, 1990, and by testimony presented at the public hearing, expressed its opposition to the Campus Plan because of the possible adverse housing, traffic and environmental effects. ARC 3B raised the following issues:

1. With respect to housing, ANC 3B requested that the University be required to house all undergraduate students on campus, that Appendix H be made a firm commitment of the University, that the University accept responsibility for student misbehavior in surrounding communities, that the University rescind its policy of requiring misbehaving dormitory students to live off campus and that the University freeze its enrollment at the 1989 level.
2. With regard to the proposed cogeneration plant, ARC 3B requested information in order to be able to assess its impact on the community.
3. With respect to traffic and circulation, ANC 3B filed in the record the report of its traffic consultant concerning the impact of the proposed south entrance. The ANC asked the Board to disapprove the south entrance, the realignment at 38th Street, and the placement of an entrance adjacent to Archbold-Glover Park. The ANC also asked the Board to retain the Prospect entrance.
4. The ANC also raised questions concerning the green space and the lack of detail in the plan. It requested that if the University's Campus Plan were finally approved, that it be approved for no more than ten years.

53. The Business and Professional Association of Georgetown by letter dated July 10, 1990 and by testimony presented at the public hearing appeared in support of the 1989 Campus Plan by unanimous vote of its Board of Directors. The Association stated that the Campus Plan was responsive to physical planning concerns within the campus and that the long-range planning solutions proposed by the University were resourceful and appropriate. The Association commended the University for its policy to require freshman to live on-campus beginning with the 1991 academic year and also complimented the University for establishing the Office of Off-Campus Student Affairs. The Association stated that it fully supported the improved South Entrance and believed that it would facilitate the smooth access and egress of traffic at Whitehurst Freeway, Key Bridge and Canal Road. The Association stated that the University had responded to all of the neighborhood issues in an admirable, professional and thoughtful manner and that it gave its full support to the adoption of the Campus Plan.

54. The Citizens Association of Georgetown (CAG) by letter dated July 11, 1990 and by testimony at the public hearing, testified in support of the Transportation Element of the Plan and in opposition to the Housing Element of the Plan. With reference to the Traffic Plan, CAG stated that it was a brilliant scheme to minimize traffic problems throughout the perimeter of the University and that it would help alleviate the evening rush hour gridlocks on 34th Street at both Prospect and M Streets. The Association viewed the closing of the Prospect entrance as essential, together with the construction of the improved South Entrance. With regard to student housing, the Association applauded the University's commitment to provide 925 new campus beds by 1997. The Association felt that the University should go further, however, and require at least 90 percent of the student body (including graduate students) to live on-campus, should provide adequate and affordable housing for 90 percent of the student body, should preserve all housing including the townhouses currently occupied by students, and should limit all new facilities to the area within the Campus Plan boundaries.

55. The Burleith Citizens Association by letters dated June 29, and May 23, 1990, and by testimony presented at the public hearing, appeared as a party in opposition to the Campus Plan. The Association cited as its reasons the inadequacy of the housing element of the Campus Plan as well as its concern with the realignment of the 38th Street entrance. On the housing issue, the Association requested a cap on enrollment, that the University be required to house 90 percent of its undergraduates by 1994 and 100 percent by 1997, that the promises and goals in Appendix H be made enforceable by this Board, and that the University be required to charge competitive rates for housing. On the realignment issue, the Association objected to the straightening out of the exit leading into 38th Street believing that it would increase traffic in residential Burleith. The Association also requested that the Plan be approved for a period not in excess of ten years.

56. A representative of the Glover Park Citizens Association (GPCA) submitted a statement and testified in opposition. The GPCA opposition is based on the off campus housing policies of the University and the lack of a population cap; traffic issues related to the south entrance, Prospect Street entrance and realignment of the 38th Street entrance; and the cogeneration facility.

57. A representative of the Foxhall Community Citizens Association testified at the public hearing in opposition to the Plan with regard to undergraduate housing, cogeneration and the impact on neighborhood traffic and recommended the creation of an ongoing process for continued communication.

58. A representative of the Committee of 100 on the Federal City testified in opposition to the Plan regarding traffic and cogeneration. The representative testified, however, that in concept the cogeneration plant was unobjectionable. With respect to traffic, it was requested that the Plan include a Transportation Management Plan.

59. Councilmember James Nathanson submitted a statement and testified in opposition to the Campus Plan. The Councilmember testified that he was supporting his constituency in Glover Park, Burleith and Foxhall in opposing the Plan because of the off campus housing policies of the University. He also questioned the proposed closing of Prospect Street and expressed a need for more information on the cogeneration facility.

60. A representative of the Georgetown Visitation Preparatory School, which abuts the Georgetown University Campus on its eastern border, by letter dated June 29, 1990 and by testimony presented at the public hearing, testified in support of the application. The representative stated that at no time had any activity of the University adversely affected or interfered with the educational mission at the school or the convent and that it supported the University's growth and development as set forth in its plan.

61. The President and Vice President of the Student Government Association at Georgetown University testified in support of the Campus Plan. The representatives indicated that the commitments made by the University in Appendix H represent significant concessions by the University and that the student body fully supported the University and was willing to work with the University and the community toward resolution of community concerns.

62. Present and former students living in the community surrounding the University testified in support of the Campus Plan. They complemented the University on its efforts to address community issues and committed to work with the University and the community on any long term solutions to the issues of student housing and students living off-campus.

63. Individual property owners living in the neighborhood surrounding the campus testified in support of the Campus Plan and complimented the University for its willingness to negotiate with the community on issues of concern. These individuals testified that the University was an asset to the neighborhood, that it maintained the architectural character of the area, that it provided the opportunity for educational and technological advances, and that it offered significant employment opportunities for District residents.

64. Many residents of the neighborhood appeared in opposition to the Campus Plan and testified as to severe conduct problems associated with students living in their neighborhoods as well as to concerns about the proposed cogeneration facility and traffic.

65. Several letters in support and opposition to the Campus Plan were submitted into the record expressing concern about student housing, cogeneration and transportation issues.

66. The Board is required by statute to give "great weight" to the issues and concerns raised by ANC 2E, 3B and 3D as those are reduced to writing and in resolution form. Recognizing that ARC 2E is the ANC within which the Georgetown University campus is located, and recognizing that there is a divergence of opinion between ANC 2E and ARC 3B, the Board is unable to accept all recommendations made by the ANCs in their entirety. In addressing the ANC's concerns as well as those raised by other opponents of the plan, the Board finds as follows:

1. The Board concurs with ANC 2E that the University has made attempts to identify and address existing objectionable impacts of the University on the community and to assess ways in which those impacts can be reduced and alleviated. While the process established by the University and the community may not have been perfect, it nonetheless provided an opportunity for input by the community into the final development of the plan. The Board notes that the process included notice to nine community associations, including representatives of ANC 3B and ARC 3D. In its conditions, the Board provides a continuing process for communication and input.
2. The Board concurs with ANC 2E and ANC 3B, as well as the others who testified at the public hearing, that the question of providing additional on-campus housing is an issue which the University should address. The Board finds that the proposal in the 1989 Campus Plan as described in Appendix H, to provide an additional 925 beds on campus is an important commitment by the University and the Board intends to condition its approval on the provision of those beds. To further ensure that there will be no adverse impacts, the Board incorporates as a condition to its Order a limitation on enrollment so that by the year of 1997, the University will be providing beds on campus for essentially 100 percent of those undergraduate students requiring housing. The Board further incorporates a condition requiring a showing of compliance with the housing program described in Appendix H with each subsequent University special exception application process under the 1989 Plan.
3. As to requiring all undergraduates to live on campus, the Board believes that a significant portion of the undergraduate students should be required to live on-campus. The Board finds the commitment by the University to require freshmen to live on campus in 1991 and sophomores as soon as the beds are in place, to be a significant commitment. Rather than require all undergraduates to live on campus, the Board believes a better course of action to be the proposed Director of Off-Campus Affairs Program proposed by the University in Appendix H. Assuming the University and the community are successful in the implementation of this program, the program ensures a process to alleviate potential adverse impacts and directly addresses the issues of students living off campus.
4. With regard to the issue of students living off campus, the Board agrees with the testimony presented by the University as well as several of those both in support and opposition to the application, that the issue is community-wide and not simply a university issue. The Board finds that the initial responsibility for student conduct lies with the University and in this Order, the Board is imposing conditions on the University to address the issue. At the same time, the Board understands the responsibility of the community to address the issue in terms of building and zoning violations, absentee landlords, and recognition of the conduct and rights of students, as well as the need for enforcement by public officials. The Board finds that the process agreed to by both the community and the university to work together on these issues is a positive one and encourages the parties to move quickly along those lines.
5. The Board finds reasonable the Campus Plan's proposed increase in undergraduate FTE enrollment of approximately 340 students, as described in Appendix H. The Board believes a freeze on enrollment at past or current levels unduly restricts the University in carrying out its educational mission. With the projections included in Appendix H, the percentage increase in undergraduate enrollment is 6~ percent over the life of the Plan, which is less than the 8 percent and 15 percent recently approved by this Board in two other campus plan cases. Further, the Board believes a more appropriate approach with regard to enrollment is to regulate the potential external affects, i.e., noise, traffic, parking and location of development, resulting from enrollment increase. Accordingly, the Board incorporates a number of conditions into its Order designed to ameliorate the external affects associated with additional students.
6. As to concerns about the commercialization of the University, the Board concurs with OP's finding that these kinds of uses are not inappropriate so long as they are in the furtherance of the University's essential mission and that they do not have substantial adverse impacts on the surrounding community. The Board notes that the Leavey Center, which includes guest room facilities for University guests, was specifically approved by the Board, in addition to the medical buildings located on the medical center campus. As each new building is presented to the Board, the question of impact is evaluated. The educational, research and medical functions conducted by Georgetown University on its campus are not unlike those conducted by other universities in the District of Columbia. Further, while cogeneration may be a new concept to the community, a power plant has been on the University's campus since 1968 and there are power plants located on several university campuses within the District of Columbia.
7. The Board agrees with DPW's recommendation, which is shared by ARC 2E, ANC 3D, BPAG, the Citizens Association of Georgetown and many others, that the transportation elements of the plan will have positive impacts on the surrounding neighborhood. While ARC 3B and others have raised questions about the improved. South Entrance, the Board notes that the report prepared by their traffic consultant supports the recommendations of the University and DPW. The Board agrees that the improved South Entrance will have positive impacts on traffic on Reservoir Road, Foxhall Road, and the residential streets of Georgetown. The Board further finds that the impacts on Canal Road and M Street will primarily be positive and that any minimal negative impact on traffic flow during peak period is outweighed by the substantial benefits the South Entrance will achieve. As in its approval of the 1983 Plan, the Board will condition in this Order the completion of the improved South Entrance project before the Prospect Street entrance may be closed.
8. With regard to the internal road improvements proposed by the University, the Board agrees that the north south spine with the medical center loop is an improvement over what was proposed in the 1983 Plan. The Board finds that this configuration minimizes pedestrian and vehicular conflicts. The Board agrees with DPW that the north south spine should be a two-way operation with no parking. The Board finds that the University proposal for the medical center drive to be a two-way operation with no parking is also appropriate. With regards to the realignment of the 38th Street University access point, the Board agrees with the University and with DPW. In its Order, however, the Board is conditioning its approval on remedial measures taken by DPW, in consultation with the community and the University, to minimize the use of residential streets by University traffic.
9. With regard to the concerns expressed by ANC 3B and many others in opposition that the promises made by the University be firm commitments, the Board agrees and in its Order is conditioning its approval on the University's implementation of the program outlined in Appendix H.
10. As to concerns regarding the Campus Plan's lack of specific information on the University's campus, the Board finds these arguments unpersuasive. Appendix C to the 1989 Plan, as well as the information on building priorities submitted by the University, fully provides the information required by the Zoning Regulations. Under the District's Zoning Regulations, the regulatory scheme is a two tiered decision-making process. This requires that, at a later date, the University come forward with each specific building for implementation pursuant to an approved Campus Plan. At that time, the Board will look at the specific design of the building, building materials, the allocation of space within the building, the number of employees for that structure, and many other detailed issues. For purposes of campus plan review, the Bicentennial Plan shows the location, height and bulk, where appropriate, of all proposed improvements and is sufficient for the Board to evaluate whether the proposed use, as a whole, is likely to become objectionable.
11. As to concerns expressed about the proposed cogeneration facility, the Board approves the facility in concept. The Board emphasizes that, as with its approval in the past of the power plant and additions to that structure, the University will be required to come back to the Board with a specific case and to demonstrate compliance with the approved Campus Plan and all local and federal environmental regulations. For purposes of the Campus Plan hearing, the University has presented testimony that this facility will meet all requirements, that the use is so located so as not to be objectionable, and that the facility will be environmentally benign. The Board notes that even the opposition testimony presented by the Committee of 100 acknowledged that cogeneration plants are unobjectionable in concept. The Board notes that, in addition to federal requirements, the District of Columbia has now passed its own Environmental Policy Act. In its conditions, the Board is ensuring that the proposed facility will demonstrate compliance with the requirements. On the basis of the record before it, the Board finds persuasive the testimony by the University's engineer that a proposed cogeneration addition will be energy efficient, and will comply fully with limitations on noise and air emission, and improve ambient air quality compared to existing plant operations. The Board further notes that the record includes the Order of the Public Service Commission endorsing the concept and citing the public interest in cogeneration.
12. As to NCPC's concerns regarding the proposed Ancillary One Facility (Building F), the Board in its Order is requiring the University to address the Comprehensive Plan issues and that the proposed design be compatible with the historic character of its location at the time it comes before the Board for specific building design approval. The specific building design is not required to completely fill the building envelope as described in the Campus Plan. The Board further notes that the project will require review by the Commission of Fine Arts and that many of the design issues will be addressed in that forum, as required with all University buildings.
13. The Board finds persuasive the request of ARC 2E, 3B, and others for ten year approval of the Plan, as compared with the initial twenty year approval requested by the University.
14. The Board further finds it necessary to impose upon the University the burden of demonstrating its compliance with the housing program outlined in Appendix H with each future special exception application under the 1989 Plan for specific development proposal. The Board prefers this approach rather than those suggested by ARC 2E and others, because it will provide an opportunity for a more frequent up-dating of the University's efforts to carryout the housing program.
15. As to specific instances of student conduct off-campus, the Board agrees with ARC 2E and others who testified, that the University has proposed an innovative program to address the issue of students living off campus. The Board finds that this program addressees the impact issues stemming from student life, including noise, trash, and other conduct issues, and commends the University for its efforts to directly address the external affects associated with student life. The process that has been put in place by the University is one which the Board believes can work. The Board further finds that the commitment of ANC 2E and others, including the commitment of the student body at Georgetown University, to work together on the program is commendable. This process provides a model for other universities and will directly address student life issues in a positive and constructive manner.

67. The Board finds that the University, the community parties, and other individuals who testified at the public hearing have reached an understanding or agreement on a long term process for ongoing communications and input. At the instruction of the Board at the conclusion of the public hearing, good faith efforts were made by all who testified to meet and to reach agreement on the long term process. By letter dated August 17, 1990.and marked as Exhibit No. 129 in the record, the Board believes that agreement has been reached on the long term process. The Board commends all of those who were able to work towards this agreement and believes that it will significantly improve University and community relations in the future. As to areas of possible agreement on issues, the Board finds encouraging the progress that has taken place and urges the parties to continue working together for solutions. To the extent that agreement can be reached on any issue that changes in any way the Campus Plan approved by the Board in this Order, the Board would instruct the University to bring those changes back to the Board at the time it comes forward with specific buildings for implementation pursuant to the Plan.

CONCLUSIONS OF LAW AND OPINION:

Based on the foregoing, findings of fact and the evidence of record, the Board concludes the applicant is seeking a special exception, the granting of which requires compliance with the requirements of Section 211 and 3108.1, and that the relief requested can be granted as in harmony with the general purpose and intent of the Zoning Regulations and that it will not tend to affect adversely the use of neighboring property. The Board concludes that the University has met its burden of proof. However, the Board concludes that it is necessary to condition its order to minimize any impacts from existing conditions and any potential impacts from planned future development.

The Board concludes that the Campus Plan is an updating and refinement of previous plans and continues the same boundaries, the same traffic limitations, and many of the same buildings and uses projected under the 1983 Plan. Accordingly, it is ORDERED that the application is GRANTED SUBJECT to the following CONDITIONS:

1. Approval of the Campus Plan shall be through the year 2000.

2. The University shall prepare a revised campus plan that is consistent with this order, and shall submit it to the Board for review. The revised Plan shall be as shown in the revised Bicentennial Master Plan (Draft #3, Revision Date 1 June, 1990) that is marked as Exhibit No. 100-D in the record, and as modified to reflect this order. The University shall submit the revised Plan no later than November 2, 1990, and shall serve all parties with copies by hand delivery. The revised Plan shall be accompanied by a table of changes that lists each page on which a page appears, parenthetically identifies the corresponding page in Draft #3, and describes the changes that appear on each page. Parties may submit comments on the revisions not later than November 21, 1990. Comments on the revisions shall be strictly limited to whether the revisions correctly or clearly reflect this Order. Any party that submits comments on the revisions shall serve a copy of the comments on the University and every other party.

3. The boundaries of the University's Campus shall be as described on pages 11 and 17 of the Plan, and marked as Exhibit No. 100-D of the record.

4. The University shall submit a special exception application to the Board for each structure or addition to an existing structure that the University proposes to construct over the life of the Plan. In addition to demonstration of compliance with applicable provisions of the Zoning Regulations and the contents of the approved Bicentennial Campus Plan, each application shall include the following:

1. A detailed statement about the effect of the proposed building on traffic and parking, and the relationship to and impact of the request on, and the status of, development of the proposed changes to entrances to the campus.
2. An update on the University's progress in carrying out its Housing Program as outlined in Appendix H to the Campus Plan.

5. The Housing Program described in Appendix H to the Campus Plan is incorporated in this Order and these conditions as though fully set forth herein, and shall be enforceable in the same manner as any other condition contained in this Order. That housing program includes the cap on the increase in undergraduate enrollment of 340 FTE undergraduate students as set forth herein, the University's commitment to provide new beds on campus, and the new Director of Off-Campus Student Affairs program. Further, any actual increase in undergraduate enrollment shall be conditioned upon and subject to the provision by the University of additional beds on campus to accommodate that increase. The University may provide beds by: (1) moving graduate students and faculty off campus; (2) rehabilitation of existing buildings; or (3) construction of new dormitories. The number of new students admitted to the University pursuant to the authorized increase in enrollment shall not exceed the number of additional beds that the University shall have provided for occupancy before the start of any academic semester. Further, until all Freshmen and Sophomores live on campus, no students shall be admitted to the University pursuant to the authorized increase in enrollment.

6. The University shall provide 4,080 off-street parking spaces within the campus boundary.

7. The terms and conditions of the agreement on traffic and transportation issues as set forth in a letter dated August 29, 1990 and submitted to the record as Exhibit No. 145-B are incorporated in this Order as though fully set forth herein, and shall be enforceable in the same manner as any other condition contained in an Order of the Board.

8. The University shall undertake over the life of the plan the remedial traffic and parking proposals, and shall develop new proposals to limit the effect of the University on traffic and parking.

9. When the University is ready to seek approval of the proposed Ancillary I facility (Building F), the Board will address the specific design issues for that building. In the final design of the building, the University shall alleviate the potential impact on the Palisades and the Canal, and address the compliance of the building with the Comprehensive Plan for the National Capital.

10. The University and the community must continue to work together to seek solutions to the problems associated with the Campus Plan pursuant to the long-term communication process outlined in Exhibit No. 129 dated August 17, 1990 of the record and agreed to by the parties. The goal is to provide an inclusive process for communication and information and a consistent timetable for community discussion and review.

11. The cogeneration facility is approved in concept as a part of the Campus Plan. Consideration of the specific impact and design details, including capacity, shall be the subject of an application for further processing.

VOTE: 5-0 (William Ensign, Charles H. Norris, Paula L. Jewell, William F. McIntosh and Carrie L. Thornhill to approve).

BY ORDER OF THE D.C. BOARD OF ZONING ADJUSTMENT

ATTESTED BY: <s>
EDWARD L. CURRY
Executive Director

FINAL DATE OF ORDER: OCTOBER 12 1990

PURSUANT TO D.C. CODE SEC. 1-2531 (1987), SECTION 267 OF D.C. LAW 2-38, THE HUMAN RIGHTS ACT OF 1977, THE APPLICANT IS REQUIRED TO COMPLY FULLY WITH THE PROVISIONS OF D.C. LAW 2-38, AS AMENDED, CODIFIED AS D.C. CODE, TITLE 1, CHAPTER 25 (1987), AND THIS ORDER IS CONDITIONED UPON FULL COMPLIANCE WITH THOSE PROVISIONS. THE FAILURE OR REFUSAL OF APPLICANT TO COMPLY WITH ANY PROVISIONS OF D.C. LAW 2-38, AS AMENDED, SHALL BE A PROPER BASIS FOR THE REVOCATION OF THIS ORDER.

UNDER 11 DCMR 3103.1, "NO DECISION OR ORDER OF THE BOARD SHALL TAKE EFFECT UNTIL TEN DAYS AFTER HAVING BECOME FINAL PURSUANT TO THE SUPPLEMENTAL RULES OF PRACTICE AND PROCEDURE BEFORE THE BOARD OF ZONING ADJUSTMENT.

THIS ORDER OF THE BOARD IS VALID FOR A PERIOD OF SIX MONTHS AFTER THE EFFECTIVE DATE OF THIS ORDER, UNLESS WITHIN SUCH PERIOD AR APPLICATION FOR A BUILDING PERMIT OR CERTIFICATE OF OCCUPANCY IS FILED WITH THE DEPARTMENT OF CONSUMER AND REGULATORY AFFAIRS.

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