January 6, 2021

D.C. Council Chairman Introduces Comprehensive Plan Amendment Act of 2020

Holland & Knight Alert
Christine M. Shiker | Kyrus Lamont Freeman | Dennis Russell Hughes | Leila Marie Jackson Batties | Jessica R. Bloomfield | Christopher S. Cohen

The District of Columbia's urban planning and land use goals will be an early order of business for the Council of the District of Columbia (D.C. Council) in the new year. On Jan. 4, 2021, Chairman Phil Mendelson introduced the Comprehensive Plan Amendment Act of 2020 (B24-01) – the first bill of Council Period 24. The introduction of this bill serves to revive its predecessor, B23-0736, which had not been agendized for a Council legislative meeting following public hearings last November.

This bill is a companion to Bill 23-01, the Comprehensive Plan Amendment Act of 2019, which became law in August 2020 and amended the Framework Element (Chapter 2) of the Comprehensive Plan. The proposed changes would update the remaining 24 District Elements of the Comprehensive Plan (Chapters 1 and 3-25). In addition to the proposed textual updates, the D.C. Council will consider proposed changes to the Future Land Use Map (FLUM) and the Generalized Policy Map (GPM). The FLUM, which depicts intended land uses throughout the city for roughly 20 years into the future, is generally focused on growth at metro stations and along corridors and anticipates the transfer of federal land.

The GPM helps to guide land use decision-making in conjunction with the FLUM and the Comprehensive Plan text and maps. The updated GPM includes several new designations, including Future Planning Analysis Areas, Resilience Focus Areas and the boundary for the Proposed State of Washington, Douglas Commonwealth, which encompasses all of the District of Columbia, except an area around the Monumental Core that will remain a federal government enclave.

This Comprehensive Plan amendment is the product of significant public engagement and integrates more than 40 plans prepared by District agencies, including Small Area Plans. In her memorandum to Chairman Mendelson regarding the proposed bill, District of Columbia Mayor Muriel Bowser stated that the proposed amendments "will serve as an important touchstone to guide us in the aftermath of the COVID-19 event and beyond."

B24-01 has already been referred to the Committee of the Whole. The D.C. Council Chairman will set the time frame for consideration of the bill with the possibility that the D.C. Council will conclude its work prior to transmission of the District Budget on or before March 31, 2021. If the D.C. Council approves the legislation, the bill would take effect after a 30-day congressional layover and publication in the District of Columbia Register. However, no District Element of this Comprehensive Plan amendment will apply until after it has been reviewed by the National Capital Planning Commission.


Bill 24-01 represents a significant update to the Comprehensive Plan, and will influence development opportunities for several decades. The proposed amendments to the GPM and FLUM are particularly critical, as the new maps will reflect the shared vision for neighborhoods throughout the city and dictate preferred land uses. If you have any questions regarding the proposed amendments to the Comprehensive Plan, please contact the authors or a member of Holland & Knight's Mid-Atlantic Land Use Team.

Information contained in this alert is for the general education and knowledge of our readers. It is not designed to be, and should not be used as, the sole source of information when analyzing and resolving a legal problem, and it should not be substituted for legal advice, which relies on a specific factual analysis. Moreover, the laws of each jurisdiction are different and are constantly changing. This information is not intended to create, and receipt of it does not constitute, an attorney-client relationship. If you have specific questions regarding a particular fact situation, we urge you to consult the authors of this publication, your Holland & Knight representative or other competent legal counsel.

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