A Simpler Comprehensive Plan. But Will It Make Development More Predictable?

KEY TAKEAWAY

DC’s Attorney General has recommended a shorter, clearer Comprehensive Plan with fewer land use categories and more specific density guidance. That could help property owners, project teams, and residents understand the planning framework, but real predictability will depend on how the new plan balances clear direction with room for judgment.

“The goal isn’t to eliminate judgment from planning. It’s to make that judgment more transparent, consistent, and grounded in clearly articulated policies.”

Washington, DC's Comprehensive Plan is more than 1,300 pages long. It contains hundreds of policies, dozens of land use designations, and enough cross references to keep even experienced planners busy. And unlike comprehensive plans in many other jurisdictions, DC's plan carries the weight of law. So when the District's Attorney General suggests that it might be time to simplify things, it's worth paying attention.

On October 20, 2026, Attorney General Brian Schwalb released a white paper recommending changes to the structure and presentation of DC's next Comprehensive Plan, known as DC 2050. The recommendations include shortening the document, simplifying the Future Land Use Map, establishing clearer density guidance, and making the plan easier for residents to navigate.

Those are worthwhile subjects for discussion. But they also raise a larger question: Can we make the Comprehensive Plan easier to understand without losing the flexibility needed to make thoughtful land use decisions?

Why clarity matters in DC

In most jurisdictions, a comprehensive plan establishes a long-term vision for growth and development. It guides decisions about housing, transportation, public facilities, economic development, and neighborhood character.

DC's Comprehensive Plan does all of that, but it also plays a particularly important role in the zoning process. The District's Zoning Commission must determine that its decisions are not inconsistent with the Comprehensive Plan when considered as a whole. That last phrase matters.

The plan contains policies that can point in different directions. One policy might encourage additional housing near transit. Another might emphasize preserving neighborhood character. A third might address historic resources, environmental sustainability, or affordable housing. A proposed development may advance several of those objectives while creating tension with others.

The Zoning Commission's responsibility is not simply to find a policy that supports or opposes a project. It must consider the plan as a whole and explain how competing policies have been evaluated. That's not always easy. And when the relationship between policies is unclear, disagreements can become lengthy, expensive, and difficult for the public to follow.

The Attorney General's white paper identifies this problem and argues that a clearer, more focused plan could help reduce uncertainty and legal challenges. There's merit in that idea. But clarity alone won't eliminate disagreement. Even a perfectly organized Comprehensive Plan will contain competing objectives. Planning, after all, is largely about figuring out how to balance them.

Fewer land use categories. Clearer expectations?

One of the white paper's most consequential recommendations concerns the Future Land Use Map, or FLUM.

The existing map contains 59 land use categories, including numerous combinations of residential, commercial, institutional, and other uses.

The Attorney General recommends reducing that number to nine categories, with defined density ranges to provide clearer guidance for zoning decisions.

The Office of Planning is already moving in a similar direction. Its preliminary DC 2050 framework proposes ten place types intended to describe not only land use but also building form, street connections, and the public spaces that help define different parts of the city.

The two approaches share an interest in making the map easier to understand. The distinction is the degree of specificity they would provide, which deserves a closer look.

The current Plan already provides typical FAR ranges and examples of appropriate zones, while allowing flexibility through tools such as Inclusionary Zoning and PUDs. The opportunity for the rewrite is to make that guidance easier to understand and apply. Owners, architects, and neighbors should be able to see what development is generally anticipated, and how a proposal outside those expectations would be evaluated.

A shorter plan isn't necessarily a better plan

The Attorney General also recommends substantially reducing the length of the Comprehensive Plan and reorganizing its policies into a clearer hierarchy. The proposed structure would connect a small number of overarching goals to broader planning topics, specific policy objectives, and implementation actions. That makes sense.

The current plan contains policies that overlap, repeat similar concepts, or address related issues in different elements. Understanding how those provisions work together can require considerable time and familiarity with the document. A more coherent structure could make the plan more useful to everyone involved in development decisions.

But I would be careful about treating the number of pages or policies as the primary measure of success. Some complexity reflects the fact that DC is a complicated city.

Its neighborhoods have different development patterns, housing needs, historic resources, transportation conditions, and environmental challenges. Policies addressing those differences cannot always be reduced to a few broad statements without losing something important. The objective should not simply be to have fewer policies. It should be to have clearer policies that serve a purpose, work together, and provide meaningful guidance when decisions need to be made.

That includes explaining how policies should be considered when they conflict. For example, a plan could establish a clear citywide priority for increasing housing near transit while also identifying the circumstances in which historic preservation, environmental constraints, or neighborhood-specific conditions warrant a different approach.

That would be more useful than either a long collection of loosely connected policies or a short document that leaves too many questions unanswered.

Should planning areas follow ward boundaries?

Another recommendation would replace the District's ten Comprehensive Plan planning areas with eight areas corresponding to its political wards. The argument is straightforward: residents generally know which ward they live in, and ward-based planning areas could make the document easier to navigate. There are practical benefits to that approach, but planning geography and political geography aren't always the same thing.

Neighborhoods, commercial corridors, watersheds, and transportation networks frequently cross ward boundaries. And ward boundaries can change following the decennial census. A corridor that functions as a single commercial district may be divided between two wards. A neighborhood may share infrastructure, development pressures, and community concerns with an adjoining area represented by a different Councilmember. Organizing the plan by ward could make it more familiar to residents, but it would be important to preserve the ability to address those shared conditions.

The white paper proposes more geographically focused planning areas within each ward. That could help, provided the resulting structure allows for coordination across ward boundaries rather than treating them as planning boundaries.

The most useful planning geography is not always the one that's easiest to identify on a political map.

Making the plan accessible is about more than putting it online

One recommendation I find particularly valuable is the emphasis on making the Comprehensive Plan easier for the public to use. An interactive, web-based plan with searchable policies, maps, graphics, and supporting data could be a substantial improvement, but accessibility involves more than presentation.

A resident should be able to understand what the FLUM means for their neighborhood without needing a planning consultant to interpret it. A property owner should be able to distinguish between what the Comprehensive Plan recommends and what the zoning regulations currently allow. And someone participating in a zoning hearing should be able to identify the policies relevant to a proposal and understand how the decision-making body is expected to consider them. That requires plain language, clear explanations, and transparency about how policies are applied.

It also requires being candid about what the Comprehensive Plan does not do. A future land use designation is not a building permit. It does not automatically change a property's zoning. And it does not guarantee that a particular development proposal will be approved. Making those distinctions easier to understand would go a long way toward improving public participation.

Predictability shouldn't mean predetermined outcomes

The Attorney General's white paper raises important questions at an especially useful moment. The Office of Planning is developing DC 2050, the District's first complete Comprehensive Plan rewrite since 2006. There is an opportunity to reconsider not only what the plan says, but how it works.

A clearer plan could help property owners make informed decisions earlier, give architects and development teams a more reliable basis for evaluating proposals, and allow community members to participate with a better understanding of the policies involved. It could also help the Zoning Commission explain its decisions more consistently.

But I would distinguish between predictability and certainty. Predictability means understanding the rules, the relevant policies, and the considerations that will influence a decision. Certainty suggests knowing the outcome before the proposal has been evaluated. Those are different things.

A comprehensive plan should provide enough direction to make the development process understandable and reasonably predictable. It should also leave room for professional judgment, changing conditions, and legitimate differences among properties and neighborhoods. The goal isn't to eliminate judgment from planning. It's to make that judgment more transparent, consistent, and grounded in clearly articulated policies. As DC 2050 moves forward, that seems like a worthwhile standard against which to evaluate the next Comprehensive Plan.

THE PRACTICAL NEXT STEP

What DC’s Comprehensive Plan Means for Your Project

If you’re evaluating a property or potential zoning change, start with the current zoning, the Future Land Use Map designation, and the Comprehensive Plan policies relevant to the site. Track DC 2050 as its framework develops, but don’t assume a proposed place type or density range changes what is permitted today. UrbanKind can help you interpret the existing guidance, identify where policy questions may affect a proposal, and plan a practical path forward.

RELATED READING

• What Does “By-Right” Actually Mean?
• RFK’s Next Chapter: From Stadium Site to City Neighborhood
• Land Use Strategy & Early Project Planning

SOURCES AND FURTHER READING

• DC Office of the Attorney General — Recommendations for DC 2050: Simplify, Clarify, and Modernize to Serve the District (October 2026)
• DC Office of the Attorney General — October 20 announcement
• DC Office of Planning — DC 2050
• DC Office of Planning — Place Types: A New Approach

UrbanKind Consulting provides land-use strategy, zoning guidance, and planning advisory services in Washington, DC, and the surrounding region.