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MURIEL BOWSER
MAYOR
November 20, 2025
The Honorable Phil Mendelson
Chairman
Council of the District of Columbia
John A. Wilson Building
1350 Pennsylvania Avenue, NW, Suite 504
Washington, DC 20004
Dear Chairman Mendelson:
Enclosed for consideration and adoption by the Council of the District of Columbia is the
"Special Police Officer and Special Privates Rulemaking Approval Resolution of 2025."
This resolution would approve a proposed final rulemaking to amend Chapter 11 (Special Police)
of Title 6-A (Police Personnel) of the District of Columbia Municipal Regulations.
The rulemaking amends regulatory provisions that implement An Act making appropriations to
provide for the expenses of the government of the District for the fiscal year ending June
thirtieth, nineteen hundred, and for other purposes, approved March 3, 1899 (30 Stat. 1057; D.C.
Official Code§ 5-129.02). The rulemaking establishes that no person shall be appointed as a
special private officer unless he or she has reached the age of 21, is a citizen of the United Stat es
or lawful permanent resident, is of good moral character, and has been approved by the Chief of
Police. The rulemaking also clarifies references to the respective regulatory provisions under
which special police officers and special privates are appointed and restructures the training
requirements for special police officers in separate subsections.
I urge the Council to take prompt and favorable action on the enclosed resolution.
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3 at the request of the Mayor
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7 A PROPOSED RESOLUTION
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11 IN THE COUNCIL OF THE DISTRICT OF COLUMBIA
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16 To approve proposed final rules of the Director of the Department of Licensing and Consumer
17 Protection and the Chief of the Metropolitan Police Department amending Chapter 11 of
18 Title 6-A of the District of Columbia Municipal Regulations, regarding special police
19 officers and special privates.
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21 RESOLVED, BY THE COUNCIL OF THE DISTRICT OF COLUMBIA, That this
22 resolution may be cited as the "Special Police Officers and Special Privates Rulemaking
23 Approval Resolution of 2025".
24 Sec. 2. Pursuant to An Act Making appropriations to provide for the expenses of the
25 government of the District of Columbia for the fiscal year ending June thirtieth, nineteen
26 hundred, and for the other purposes, effective March 3, 1899 (30 Stat. 1057; D.C. Official Code
27 § 5-129.02(c)), the Council approves the proposed final rules of the Director of the Department of
28 Licensing and Consumer Protection and the Chief of the Metropolitan Police Department to amend
29 Chapter 11 (Special Police) of Title 6-A (Police Personnel) of the District of Columbia Municipal
30 Regulations, regarding special police officers and special privates, which was transmitted to the
31 Council by the Mayor on __ , and for which a notice of second emergency and proposed
32 rulemaking was published in the District of Columbia Register on May 9, 2025, at 72 DCR 005755.
33 Sec. 3. Transmittal.
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The Council shall transmit a copy of this resolution, upon its adoption, to the Mayor, the 34
Director of the Department of Licensing and Consumer Protection, the Chief of the Metropolitan 35
Police Department, and the Administrator of the Office of Documents and Administrative 36
Issuances. 37
Sec. 4. Fiscal impact statement. 38
The Council adopts the fiscal impact statement of the Chief Financial Officer as the fiscal 39
impact statement required by section 4a of the General Legislative Procedures Act of 1975, 40
approved October 16, 2006 (120 Stat. 2038; D.C. Official Code § 1-301.47a). 41
Sec. 5. Effective date. 42
This resolution shall take effect immediately. 43
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DEPARTMENT OF LICENSING AND CONSUMER PROTECTON
METROPOLITAN POLICE DEPARTMENT
NOTICE OF FINAL RULEMAKING
as transmitted to the Council for its review and approval pursuant to An Act Making
appropriations to provide for the expenses of the government of the District for the fiscal year
ending June thirtieth, nineteen hundred, and for other purposes, approved March 3, 1899 (30
Stat. 1057; D.C. Official Code § 5-129.02)
The Director of the Department of Licensing and Consume r Protection (“DLCP”), pursuant to
authority set forth in An Act Making appropriations to provide for the expenses of the government
of the District for the fiscal year ending June thirtieth, nineteen hundred, and for other purposes,
approved March 3, 1899 (30 Stat. 1057; D.C. Official Code § 5-129.02), Mayor’s Order 2022-024,
dated February 9, 2022, and Mayor’s Order 2022-149, dated September 29, 2022, and the Chief
of the Metropolitan Police Department (“Chief of Police”), pursuant to the authority set forth in
Section 1 of An Act Relating to the Metropolitan police of the District of Columbia , approved
February 28, 1901 (31 Stat. 819; D.C. Official Code § 5- 105.05), Sections 378 and 379 of the
Revised Statutes of the District of Columbia (D.C. Official Code § 5 -129.03), Mayor’s Order
2009-4, dated January 16, 2009, Mayor’s Order 2012- 28, dated February 21, 2012, and Mayor’s
Order 2015- 167, dated June 16, 2015, hereby give notice of their adoption of the following
amendments to Chapter 11 (Special Police) of Title 6 (D.C. Personnel Regulations), Subtitle A
(Police Personnel), of the District of Columbia Municipal Regulations (“DCMR”).
The rulemaking clarifies the requirements applicable to the appointment of special privates without
pay for duty in connection with any emergency of riot, pestilence, invasion, insurrection, or during
any day of public election, ceremony, or celebration, and to make technical and conforming
revisions to existing provisions concerning special police officers.
An initial Notice of Emergency Rulemaking was published in the District of Columbia Register
on November 15, 2024, at 71 DCR 013997, and expired on March 1, 2025. A Notice of Second
Emergency and Proposed Rulemaking was published in the District of Columbia Register on May
9, 2025, at 72 DCR 005755. No public comments were received in response to the Notice of
Second Emergency and Proposed Rulemaking during the thirty (30)-day comment period.
The Director of DLCP and Chief of Police thereafter approved a proposed Notice of Final
Rulemaking for submission to the Council for its review and approval pursuant to the Act (D.C.
Official Code § 5-129.02). No changes were made in the proposed final rules to the text of the
rules set forth in the Notice of Second Emergency and Proposed Rulemaking. A proposed
resolution to approve the proposed final rules was transmitted by the Mayor to the Council of the
District of Columbia on _______, for a forty -five (45) day period of review pursuant to the Act
(D.C. Official Code § 5- 129.02). See Police Personnel Regulations Rulemaking Approval
Resolution of 2025, as introduced on ______, 2025 (P.R. 25- ____). The 45-day period of review
having expired on ________ with no Council action to approve or disapprove the proposed
resolution, the proposed final rulemaking was deemed approved.
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The rules were adopted as final by the Director on ______ and the Chief on _______ and shall
become effective upon publication of this notice in the District of Columbia Register.
The final rules include a technical correction to the amended 6A DCMR § 1100.8 to clarify that
pre-assignment training is among the required training programs for special police officers, as
required by the Act (D.C. Code § 5-129.02(b)). Otherwise, no substantive changes have been made
to the text of the rules as proposed final rules submitted to the Council.
Section 1100, APPOINTMENT: GENERAL PROVISIONS , of Chapter 11, SPECIAL
POLICE, of Title 6-A, POLICE PERSONNEL, of the DCMR is amended as follows:
Subsection 1100.3 is amended to read as follows:
1100.3 Commissions issued to special police officers appointed pursuant to § 1100.1 shall
specify the following information:
(a) The particular place or property they are commissioned to protect;
(b) Any waiver of the uniform requirement; and
(c) Any requirement for storage or special provisions for transportation of
firearms or other dangerous weapons.
Subsection 1100.5 is amended to read as follows:
1100.5 Each appointment of a special police officer appointed pursuant to § 1100.1 shall
be made for a specified time, and no person appointed shall legally exercise any
authority conferred by that appointment after the date of expiration of that
appointment.
Subsection 1100.6 is amended to read as follows:
1100.6 Special police officers appointed pursuant to § 1100.1 and special privates
appointed pursuant to § 1100.4 shall be subject to the rules laid down for the
government of the Metropolitan Police Department insofar as those rules are
applicable.
Subsection 1100.7 is amended to read as follows:
1100.7 No person shall be appointed as a special police officer pursuant to § 1100.1 unless
the person:
(a) Is twenty-one (21) years of age or older;
(b) Is a citizen or lawful permanent resident of the United States;
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(c) Is of good moral character;
(d) Is approved for appointment by the Chief of Police;
(e) Possesses a high school diploma or a general equivalency diploma, or one
year of experience as a special police officer in the District of Columbia;
(f) Can read, write, and speak the English language;
(g) Has been certified by a licensed physician as physically and psychologically
fit to perform the duties of a special police officer; and
(h) Has not been dishonorably discharged from the military.
New Subsections 1100.8, 1100.9, 1100.10, 1100.11, 1100.12, 1100.13, 1100.14, and 1100.15 are
added to read as follows:
1100.8 Each special police officer appointed pursuant to § 1100.1 shall complete pre-
assignment, on-the-job, and in- service training programs which have been
prescribed or approved by the Chief of Police.
1100.9 (a) The p re-assignment training required by § 1100.8 shall include at least
sixteen (16) hours of training on arrest powers, search and seizure laws, the
District of Columbia Official Code, and the use of force.
(b) The p re-assignment training required by § 1100.8 shall also include an
additional twenty-four (24) hours of training generally relating to the special
police officer’s duties and specifically including:
(1) Terrorism awareness, including building evacuation, unattended
packages, and unknown substances;
(2) Emergency procedures, including evacuation and first aid; and
(3) Customer service and interaction with the public.
(c) The pre -assignment training required by §1100.8 shall be satisfactorily
completed by each special police officer appointed pursuant to § 1100.1
before the special police officer’s employment.
1100.10 The on-the-job training required by § 1100.8 shall include at least sixteen (16) hours
and shall be satisfactorily completed by each special police officer appointed
pursuant to § 1100.1 within ninety (90) working days after their first day of
employment.
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1100.11 The in -service training required by § 1100.8 shall include an eight ( 8)-hour in-
service training course and shall be satisfactorily completed by each special police
officer appointed pursuant to § 1100.1 during each year of the special police
officer’s employment.
1100.12 Each special police officer appointed pursuant to § 1100.1 shall satisfy all
additional initial and re -qualification training standards for firearms and other
equipment, as applicable.
1101.13 Upon satisfactory completion of a required training course, a special police officer
shall obtain from his or her employer a certificate evidencing satisfactory
completion thereof.
1100.14 Nothing in this section shall be construed to prohibit a security agency from
voluntarily providing training programs and courses that exceed the minimum
requirements of this chapter.
1100.15 No person shall be appointed as a special private under § 1100.4 unless the
applicant:
(a) Has reached the age of twenty-one (21) years;
(b) Is a citizen or lawful permanent resident of the United States;
(c) Is of good moral character; and
(d) Is approved for appointment by the Chief of Police.
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GOVERNMENT OF THE DISTRICT OF COLUMBIA
OFFICE OF THE ATTORNEY GENERAL
BRIAN L. SCHWALB PRIVILEGED AND CONFIDENTIAL
ATTORNEY GENERAL ATTORNEY-CLIENT COMMUNICATION
LEGAL COUNSEL DIVISION
MEMORANDUM
TO: Tomás Talamante
Director
Office of Policy and Legislative Affairs
FROM: Adele El-Khouri
Deputy Attorney General
Legal Counsel Division
DATE: July 16, 2025
SUBJECT: Legal Sufficiency Review of Draft Le gislation, the Police Personnel Regulations
Rulemaking Approval Resolution of 2025
(AE-25-326)
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This is to Certify that the Office of the Attorney General has reviewed the
above-referenced legislation and found it to be legally sufficient. If you have any questions in this
regard, please do not hesitate to call me at (202) 262-6402.
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Adele El-Khouri
______________________
Adele El
-
Khouri