As the D.C. Council prepares to debate and propose amendments to the city’s Comprehensive Plan, a new analysis from the Council’s Office of Racial Equity has issued a withering assessment of the plan’s impact on racial equity.

“As introduced, [the bill] will exacerbate racial inequities in the District of Columbia,” says a report from Brian McClure, the director of the council’s newly established office.

The analysis is expected to be the subject of intense discussion Tuesday, as lawmakers convene to work on proposed changes to the roughly 1,500-page land-use document, which guides development and growth in the city over a 20-year period. The markup is the latest phase in a five-year-long amendment process watched closely by low-income housing advocates, real estate developers and supporters of “smart growth” policies.

D.C. Mayor Muriel Bowser has sought to amend the plan to make it easier to build housing in neighborhoods across the city. Council Chairman Phil Mendelson last week released his own amendments to the plan, which is the version councilmembers will be considering today. His revisions added numerous references to racial segregation, racial equity and prioritizing housing affordability, but some critics say the additions won’t prevent displacement of Black and brown residents.

D.C.’s Zoning Commission is required to size up proposed zoning changes based on their alignment with the Comprehensive Plan. The commission’s decisions must be “not inconsistent” with the plan, or they can be subject to legal challenges that block or stall development. Frustrated by a series of appeals that have held up new housing construction, the Bowser administration — which has an ambitious goal to add 36,000 new homes to the city by 2025 — has sought to change language in the plan to discourage lawsuits.

In his analysis of the revised Comprehensive Plan legislation, McClure writes that the chairman’s changes to the mayor’s proposed language “elevate racial equity as a policy priority,” but the sheer size of the plan “reduces the impact” of those changes.

“The Comprehensive Plan, as introduced, fails to address racism, an ongoing public health crisis in the District,” the report says. “It appears that racial equity was neither a guiding principle in the preparation of the Comprehensive Plan, nor was it an explicit goal for the Plan’s policies, actions, implementation guidance, or evaluation. These process failures laid the groundwork for deficiencies in policy: proposals are ahistorical, solutions are not proportionate to racial inequities, and directives are concerningly weak or vague.”

Activists with the D.C. Grassroots Planning Coalition, which have demanded more community input into land use decisions, said in a briefing Monday that the plan needs to be strengthened to reinforce rent control, improve public housing conditions and require low-income housing construction, among other provisions that would support racial equity.

“Rent-controlled and subsidized housing are central to the lives of thousands of D.C. residents and are at risk because of the city’s development patterns. They absolutely must be addressed in the Comp Plan — as should the other priorities and concerns of low-income residents most frequently harmed by development decisions,” said Parisa Norouzi, executive director of Empower D.C., a member of the D.C. Grassroots Planning Coalition.

Greater Greater Washington, a nonprofit advocacy organization that supports more transit-adjacent housing development, including affordable housing, says many of the coalition’s asks would be better addressed by legislation or the budgeting process, rather than the city’s primary land use document.

“I think we’ve probably missed a lot of opportunities for good legislation to prevent displacement, protect tenants, get more vouchers to people more quickly, etc., because the Comp Plan has taken up so much time,” says Alex Baca, policy manager at GGWash.

McClure’s analysis includes an overview of racial inequity in the city, describing it as among the worst in the U.S. It notes that at least 20,000 Black residents have been displaced from D.C. since the last Comprehensive Plan passed in 2006, driven out by rising home prices as young, educated white people flocked to jobs in the city.

“It is against this backdrop that CORE reviewed the guidance, policies and actions proposed in the Plan,” the report says.

After the racial equity analysis was released, Mendelson said in a statement Monday that “everyone should realize that while lengthy, this bill is nothing more than a plan. It guides. It directs. But it does not actually implement. So of course, much more must be done to disrupt the status quo of racial inequity.”

Councilmember Elissa Silverman (D-At Large) complimented CORE’s report, saying it raises crucial points that lawmakers must consider as they begin the markup process.

“How we use our land impacts where someone can live, what access to schools, services, jobs and amenities they can have. We know in this city, there has been a deep racial divide, and a lot of it has to do with the historic biases we’ve had in land use planning and policy,” Silverman said.

Councilmember Janeese Lewis George (D-Ward 4) said in a text message that the city “cannot afford to preserve a status quo that has been displacing thousands of Black and Brown D.C. families.”

In her own text message, Councilmember Brianne Nadeau (D-Ward 1) said she agrees with the conclusion of CORE’s analysis, but that it confirms “what we knew from the outset: that updating the Comp Plan alone was not going to undo generations of racist land use and other policies in the District.”

“While it is important we pass an amended plan, I hope we can ultimately end up with a new land use planning document that is radically different — in all senses of the word ‘radical’ — and reflects the ambition of CORE’s work,” Nadeau added.

The Comprehensive Plan is up for a full rewrite in 2026. The current round of changes is part of separate, medium-term amendment process.

The D.C. Council’s Committee of the Whole is scheduled to begin working on the Comprehensive Plan committee draft at noon today. It’s scheduled for an initial vote May 4, followed by a final vote May 18.