Attorney General Schwalb Releases Recommendations to Streamline and Modernize DC’s Comprehensive Plan for Land Use

Attorney General Brian L. Schwalb today released a white paper detailing the Office of the Attorney General’s (OAG) initial recommendations for DC 2050, the District’s next Comprehensive Plan, which governs land use across the city and is currently being drafted by the Office of Planning (OP).

OAG’s white paper focuses on steps the District should take to simplify, clarify, and modernize the Comprehensive Plan, make it easier to understand and more accessible to District residents, and avoid confusion and ambiguity that can sometimes lead to protracted legal challenges. These recommendations, which have been shared with OP, are informed by the office’s participation in the District’s land use process, including intervention in Zoning Commission cases, research on how other jurisdictions approach land use planning, and best practices identified by the American Planning Association (APA).

“A rewrite of our Comprehensive Plan is a once-in-a-generation opportunity to shape the future of the District and create pathways to a more prosperous, sustainable, inclusive, and equitable city,” said Attorney General Schwalb. “OAG’s recommendations to simplify the Comprehensive Plan will help more DC residents—not just lawyers and land use experts—participate meaningfully in the zoning and development decision-making that shapes their everyday lives. We will continue to support the Office of Planning’s efforts to clarify land use guidance by proposing ways to prevent lengthy and expensive legal challenges to zoning decisions moving forward.”

Highlights of OAG’s recommendations for DC 2050 include:

• Shortening the Comprehensive Plan and simplifying its structure. The District’s current Comprehensive Plan is over 1,300 pages long and includes 956 policies and 600 associated actions in its citywide elements alone. OAG recommends adopting best practices from the APA and other jurisdictions to dramatically reduce the length and complexity of the next Comprehensive Plan. The District should adopt a simple structure used by cities across the country that identifies three overarching goals and links them to thematic topics, policy objectives, and implementation actions. OAG recommends other changes to the organization of the Plan, including moving supplemental information to appendices or supporting documents.
   
• Providing clear land use guidance to help prevent legal challenges in the zoning process. Under DC law, zoning decisions must not be inconsistent with the Comprehensive Plan. Because of this legal requirement, the Comprehensive Plan should refine its land use guidance and work to eliminate ambiguities that can foster distrust in the community and spur lengthy and expensive legal challenges to zoning decisions.
   
• Simplifying and clarifying the Future Land Use Map (FLUM). The current Comprehensive Plan contains 59 land use categories, which OAG recommends reducing to nine categories based on clear density bands. In spring 2026, OP published a draft version of a new FLUM featuring 10 “Place Types.” OAG agrees with OP’s effort to reduce the number of FLUM categories and move toward accommodating more mixed uses throughout the District. At the same time, OAG’s recommendations emphasize the importance of adding specific density ranges for each FLUM land use category to bring more clarity to the process and help prevent legal challenges down the road.
   
• Making the Comprehensive Plan more accessible to DC residents by using a web-based format and incorporating more visuals to display data. OAG recommends incorporating best practices from recent Comprehensive Plans in other jurisdictions by developing an easily navigable online format that allows DC residents to more easily access information and supporting data, including by using more sophisticated maps, charts, and graphics.
   
• Restructuring “Area Elements” to focus planning areas on Wards. OAG recommends changing the current Comprehensive Plan’s 10 geographic planning areas to match the eight District Wards. This change would make it easier for District residents to understand the Comprehensive Plan and help them more easily engage with the zoning and land use process. It would also help align the Comprehensive Plan with the District’s other Ward-based plans and policies.

A summary of OAG’s white paper is available here.

The full white paper is available here.

The appendices are available here.

Assistant Attorneys General Noelle Wurst and Jack Lyman work in OAG’s Equitable Land Use team, overseen by Michael Maurer, Assistant Chief of the Housing and Environmental Justice Section, and Joanna Wasik, Chief of the Housing and Environmental Justice Section.

What is a Comprehensive Plan?

Comprehensive Plans are land use plans. They lay out goals, recommendations, and policies, and guide local officials in making decisions about how land in a city should be used. In the District, the Comprehensive Plan has the weight of law, and all zoning decisions must not be inconsistent with the plan overall. In other words, the Zoning Commission must determine that any part of a zoning decision that conflicts with one or more of the plan’s policies must be outweighed by other policies. Comprehensive Plans are implemented through zoning laws, which regulate how real estate can be developed and used in specific areas.

OP is the agency responsible for developing the District’s Comprehensive Plan and is in the process of developing DC 2050, which will guide land use in the District over the next two decades. In March 2025, OP began its first phase of community engagement, focusing on assessing the District’s land use needs and opportunities. The next phase of engagement, starting in September 2025, introduced OP’s Place Types model and gathered feedback on accommodating growth in the city. OP is currently drafting DC 2050 and is expecting to make its first version available to the public in 2027. The DC Council and then Congress will consider approval of the plan, and if approved, it will enter into law in 2028. The District’s last Comprehensive Plan was written in 2006 and revised in 2021.
 

OAG’s Equitable Land Use Team

The Equitable Land Use team within OAG’s Housing and Environmental Justice Section advocates for the public interest in the District’s zoning, land use, planning, preservation, housing, and real estate processes. The Equitable Land Use team focuses on advancing affordable housing, racial equity, environmental sustainability and justice, and procedural equity – ensuring that all District residents have the tools to participate in the planning and zoning processes. The team intervenes in individual cases filed with the Zoning Commission (as well as, on occasion, the Board of Zoning Adjustment), and comments on and submits proposed text amendments to the Zoning Regulations and legislation impacting zoning and land use. Additionally, Equitable Land Use staff provide education and training for Advisory Neighborhood Commissioners, community groups, and District residents on zoning and land use planning.

Legal Disclaimer:

EIN Presswire provides this news content "as is" without warranty of any kind. We do not accept any responsibility or liability for the accuracy, content, images, videos, licenses, completeness, legality, or reliability of the information contained in this article. If you have any complaints or copyright issues related to this article, kindly contact the author above.