It wasn't planned as an indictment, but a recently published position paper on economic development in the District has an accusatory ring to it.

Regardless of how one views the paper, it would be difficult to dispute several points it makes in citing longstanding deficiencies in the District's economic development program.

Essentially, the District lacks a comprehensive economic development program to attract new businesses and to encourage the upgrading of commercial and retail areas in existing neighborhoods, says the Institute for Neighborhood Reinvestment & Minority Business Research.

At best, the institute charges, the District has identified a number of elements that, when combined, might produce a comprehensive program. But the city lacks the required coordination and institutional and legal framework to make economic development a reality, the institute contends in a paper entitled "An Economic Development Program for the District of Columbia."

Sent to D.C. Mayor Marion Barry and other city officials last week, the paper's purpose is to "draw attention to things that can and need to be done," says the institute's president, Philip L. Johnson.

The institute certainly hasn't broken any new ground in that regard. But its view of the problem and its suggestions for improving economic development add a new dimension to the issue.

During the past seven or eight years at least, commissions, blue-ribbon committees, task forces and consultants have documented the need for a comprehensive economic development program in the District. Ostensibly, many of the findings of those groups will be incorporated in a comprehensive plan to be implemented under the aegis of the city's reorganized department of economic development.

But the institute and several community leaders want assurances that an economic development program will include a neighborhood revitalization plan. It's clear by the tone of its position paper that the institute doubts there will be little shift in the city's emphasis on economic development.

"What we're trying to do is not to be too critical but to continue making recommendations and hope the city will listen," Johnson says. "Our main concern is that the District does more to encourage economic development in the communities."

Although the institute has not had an official response from anyone in city government, it has every right to expect some feedback. After all, the mayor strongly encouraged recommendations on the subject in December during an appearance at an economic development conferencethat the institute cosponsored.

Many of the recommendations and conclusions from that conference have been incorporated in the institute's position paper. Nonetheless, it is clear from a disclaimer in the paper that its biting tone may not reflect the views of all participants in the conference.

To be sure, some may well disagree with the institute's position that "the District government as a whole has yet to demonstrate that it is cognizant of the competitive environment that exists between itself and other jurisdictions in the metropolitan area."

In a memorandum accompanying the institute's recommendations, Johnson pointedly observes: "A few ribbon cuttings and groundbreakings make great press, but that in and of itself is not an economic development program."

Despite substantial investment by the private sector in downtown Washington, Johnson noted in an interview Monday that "the way to make economic development work is to get rid of the disincentives and then get out of the private sector's way."

In the meantime, the institute notes, an economic development program "must concentrate upon job creation, both jobs in the short term and jobs in the long term. Loans, land write-downs and other business incentives should be tied directly to job creation."

Among other things, the institute calls for greater involvement of the private sector in a partnership designed to improve economic development, establishment of an industrial development corporation and an upgrading of the D.C. Office of Business Development, which "has suffered from the vagueness of its coordination mandate."

The institute's criticism of city officials may have bruised some egos at the District Building, but its recommendations deserve a better fate than some that have gathered dust over the years.