Thursday, December 10, 2009

Presentation to City Planning Commission on Hollywood Mega-Project

December 10, 2009


I am Richard Platkin, a city planning consultant, presenting today on behalf of the La Mirada Avenue Neighborhood Association of Hollywood. I am offering testimony in support of their opposition to seven entitlements for the proposed Columbia Square project, including a plan amendment, zone change, and height district change

Prior to becoming a planning consultant, I earned graduate degrees in city planning and sociology, worked for the City of Seattle, worked for non-profits and private firms in Los Angeles, and was a Los Angeles City planner from 1987 to 2007. During my 20 years in LA’s Department of City Planning most of my professional assignments dealt with long range planning, and I was, in fact, part of the team which prepared the General Plan Framework.

I therefore think I can speak with some expertise on whether the proposed plan amendment, zone change, and height district change before you today are justified. On, in other words, can you make the findings? In a word, you cannot, and it would be a travesty to sound planning and zoning practices for you to uncritically accept the legal findings offered to you in the staff report. As you know, the report claims that the proposed plan amendment conforms to Charter Section 555 and that it is consistent with the purposes, intent, and provisions of the General Plan. Nothing could be further from the truth. Similarly, the staff report also claims that the proposed zone change and height district change conform to Charter Section 558 and LAMC 12.32 because they support public necessity, convenience, general welfare, and good zoning. This, too, is equally incorrect.

Let me explain. The project before you today is a massive, extraordinarily expensive, up-scale, car-oriented regional center which can only be built in one of the most dense and congested areas of Los Angeles through seven discretionary actions and a statement of overriding considerations to its EIR’s many unmitigatable environmental impacts. Missing, however, from the long list of municipal laws which the project wants bent or broken is a zone variance to reduce required parking. This is because even though the staff report asserts that this project is transit and pedestrian-oriented, the project’s lenders, private investors, and architects know otherwise. They realize that this project would quickly fail if it depended on pedestrians and transit riders. It will only be viable if its tenants, employees, and customers can drive their cars to and from the site. This is why the project has an enormous, nine story parking structure with about 1800 spaces.

But wait, there is more, by placing this behemoth in the middle of Hollywood, the project flatly violates the purposes, intent, and provisions of the General Plan Framework. As you can see from Chapter 3, specifically Policy 3.18.1, which I am submitting, the General Plan is clear that areas, such as Hollywood, which already have high densities, heavily taxed infrastructure, inadequate services, and a wide range of existing uses similar to those proposed, should be down-zoned, not up-planned and up-zoned. If the Commission takes its job seriously to be the guardian of the General Plan, it will reject these proposed amendments and zone, and propose that the project either be withdrawn completely or resubmitted in compliance with the General Plan and existing zoning.

Furthermore, the staff report’s claims that the proposed zone change and height district change are based on public necessity, convenience, general welfare, and good zoning practices are equally unconvincing. Good zoning practice is to have timely community data, not to base major land use decisions which will leave their mark for decades to come, on a Community Plan which is 22 years old and a General Plan Framework Element which is now 15 years old. Furthermore, the Framework is based on census data which is 20 years old, and its 2010 horizon year is only three weeks away.

Finally, the argument in the staff report that the project’s zone and height districts changes should be granted because they are consistent with the draft Hollywood Community Plan update is equally weak. At this point no one knows what the final Hollywood document will look like, particularly because its draft EIR and Infrastructure Chapter have not yet been released. Once released and carefully scrutinized by the public, the rationale for extensive up-planning and up-zoning referenced in the Staff Report is likely to evaporate. After all, the Framework forecast 400,000 more people by 2010 than actually now live in Los Angeles. There are vacancy signs on residential and commercial properties all over Los Angeles, including Hollywood, and enrollment in the LAUSD has dropped by nearly 100,000 students in recent years. Some major industries, such as auto, have completely disappeared, while others, such as garment and film production are in long-term structural decline independent of the recession.

Given this information, good zoning practice would be to wait until you have timely data, the draft Hollywood Community Plan has been fully, not partially released to the public, and the long series of highly contentious workshops, hearings, and critical votes take place to carefully review and change the City’s planning, zoning, and height district proposals.