Members of citizens' organizations and representatives of the hotel industry have clashed over proposals to restrict hotel construction in the city at three hearings held in recent months.

Hotels now may be built in areas zoned for apartment houses, but the D.C. Zoning Commission is considering changes in the regulations governing hotels and motels.

Civic groups have asked the commission to bar construction of hotels in all types of residential zones. Industry representatives say that such restrictions could drive builders of new hotels to the suburbs.

"A dark cloud would from over the investment climate for hotels," said Earl McDonough, general manager of the 1,168-room Washington Hilton.

"Hotels are fundamentally commercial," said Ann Loikow of the Foggy Bottom Advisory Neighborhood Commission.

"Hotels operate 24 hours a day. That's a benefit in a commercial zone but a detriment in a residential zone. It means traffic and noise," she said.

The city Office of Planning and Development (OPD), stated in a recent report that hotels are "essential facilities," but agreed with the civic groups that no more hotels should be built in residential zones except the R-5-D zone, where 90-foot apartment houses are allowed. In that zone, OPD recommended that hotels be permitted only with the permission of the Board of Zoning Adjustment (BZA), which would hold public hearings on construction requests.

According to the OPD report, 26 of the city's 66 hotels are in residential zones - including the three largest hotels, the Shoreham, the Washington Hilton and the Sheraton Park. Many citizens who testified at the hearings directed their complaints at those three hotels.

"We have to make a distinction between hotels and this other animal we call convention hotels," said Lindsley Williams of the Cleveland Park ANC. Williams supported a suggestion by the Foggy Bottom ANC that the Zoning Commission set up a separate category of hotel called a convention hotel. ANC leaders defined a convention hotels as one having at least 200 rooms and extra facilities such as meeting rooms and exhibit space. The extra facilities would have a capacity that exceeds the number of persons that could be accommodated in the hotel's guest rooms, they said. Under the proposal, these hotels would be allowed only in high-density commercial zones.

Whayne Quin, an attorney for the Hotel Association of Washington, said some of the citizens' complaints about hotels might be valid. But he suggested that the congestion to which residents object, such as that created by parking, traffic loading berths and the need for a staging area for trucks and buses, could be eased without regulations that restrict hotel development.

James Clark, assistant director of the D.C. Department of Transportation, said the city would consider establishing a staging area for tractor trailers that deliver exhibits to the convention hotels. After they are unloaded, the trailers are parked on the Ellington Bridge until the exhibit is over, said Clark.

No new hotels are planned in residential zones, but hotel representatives said the proposed restrictions would make it difficult for hotels in residential zones to expand. Under the proposed regulations backed by civic groups and by OPD, additions would to be approved by the Board of Zoning Adjustment. This status would make it difficult for hotels to obtain financing for expansion or improvements, according to Byron Black of the Metropolitan Washington Board of Trade.

Another issue raised at the Zoning Commission hearings was the conversion of apartment buildings to apartment hotels, which are exempt from rent control.

"Our landlord has applied to convert the Boston House to an apartment hotel," said Herman Hochman of the tenants association of Boston House at 1711 Massachusetts Ave. NW.

OPD recommended that conversions from apartments to apartment hotels be prohibited in all residential zones except the highest density apartment house zones, where they would be permitted with BZA approval.

The Zoning Commission is expected to decide on whether to make changes in the zoning regulations governing hotels at its July 12 meeting.