After 18 years of work, LA’s Department of City Planning has finally unveiled a draft update for the 1988 Hollywood Community Plan, including 105 pages of detailed amendments to increase permitted building densities in Hollywood, as well as a Draft Environmental Impact Report (DEIR). If or when this update is eventually adopted, it will then become a template for similar updates of LA’s 34 other community plans. In theory, it also could become a model for Specific Plan amendments to permitting greater densities.
Because of the Hollywood plan’s importance to potentially alter private land use patters all throughout Los Angeles, many analysts have carefully scrutinized the draft, especially its DEIR, and submitted their analyses to the Department of City Planning. Among these many submissions, one theme stands out; the Draft Environmental Impact Report does not present a credible planning rationale for the proposed Community Plan update.
The following six points summarize much of this DEIR testimony:
1. Infrastructure and Services: First, LA’s public infrastructure, which has not been monitored in over 11 years, and in some categories, not planned in over 40 years, cannot handle the needs of the city’s existing and projected population and commuters. In the case of the DEIR, there is no analysis to demonstrate that local services and infrastructure in Hollywood are capable of meeting the demands of the larger population which could result from the update’s extensive up-planning and up-zoning. Without demonstrated unused infrastructure capacity in the DEIR, there should be no increases in permitted densities in Hollywood according to the General Plan’s Framework Element.
Furthermore, there is no proposal in the DEIR or the draft Community Plan itself to monitor local infrastructure conditions, including changing demographics and user demand, as well as the effectiveness of the updated Plan's infrastructure-related policies and programs. The proposed plan also fails to identify any threatened infrastructure systems in Hollywood and offers no mitigation process to address these likely infrastructure breakdowns.
To put it bluntly, this is a plan that will dramatically reduce the quality of life in Hollywood. For that matter, the hope that increases in allowed densities will spur increased investment in real estate is unfounded. Who will want to live, work, visit, or invest in a Hollywood which has inadequate, deteriorating, unplanned, and unmonitored infrastructure and public services?
2. Conflicts with the General Plan: The city’s outdated but still official and legally required General Plan is "growth neutral." According to the 1996 General Plan Framework Element, Los Angeles has enormous untapped potential for population and housing expansion based on adopted plan designations and zones. In fact, the Framework notes that Los Angeles could double its population without any need to change its underlying zoning or plan designations.
To exceed local densities in Hollywood, City Hall must therefore present a clear rationale based on documented increases in population growth and housing demand which have outstripped locally permitted densities but still retain sufficient public services and infrastructure capacity. Yet, in the case of the proposed update of the Hollywood Community Plan there is no analysis of the remaining buildout potential for the privately zoned parcels in Hollywood or the area’s remaining infrastructure capacity based on projected deterioration and increases in user demand. Likewise, there is no evidence that if these parcels were fully built out, they still could not meet the housing and employment needs of Hollywood’s current or future residents.
3. Census Data: The update of the Hollywood Community Plan is based on outdated census data. California State planning laws and guidelines require each city’s General Plan, including its Land Use element, such as the Hollywood Community Plan, to be current and internally consistent among its required and optional elements. In this case the General Plan Framework Element is based on 1990 census data which was extended to the Plan’s 2010 horizon year. The update of the Hollywood Community Plan, which is supposed to apply the General Plan Framework Element to a local community, is, however, based on year 2000 census data, augmented by 2005 estimates, and then extrapolated to the year 2030.
The two plans are not only inconsistent with each other, but neither is current because the new 2010 census data is now available and should be used for monitoring, reviewing, and updating all components of a city’s General Plan.
4. Population Decline: Fourth, if the new 2010 census data had been used for the Hollywood Community Plan’s DEIR, it would demonstrate that Hollywood had a serious population decline from 2000 to 2010 of about 15,000 people, on top of a totally static population for the 1990-2000 decade. This means that the DEIR’s population projections, obtained from the Department of City Planning and from the Southern California Association of Governments, are highly inflated, inaccurate, and therefore not acceptable for the DEIR. Therefore, the update’s planning rationale for substantially ramping up zoning densities in Hollywood is bogus.
5. Framework Turned on its Head: The Hollywood Community Plan's implementation program of up-zoning and up-planning is being proposing to encourage growth to promote secondary Framework planning goals, such as transit use. This is an approach which turn LA's growth neutral General Plan Framework Element on its head. It also conflicts with Los Angeles City Charter Sections 556 and 558, which require consistency with the intent and purposes of the General Plan. The role of transit is to serve the public's growing need for mobility, while the update’s call to increase density in Hollywood as a planning tool to boost transit use absolutely conflicts with the intent and purposes of the General Plan.
6. The General Plan should be up dated prior to Community Plans: Sixth, to properly plan Los Angeles, the General Plan Framework Element should be totally revised based on new demographic and infrastructure data. Once this process is completed, only then should the 35 local community plans, including Hollywood, be updated. But, at this point, to implement an outdated General Plan at the local level, much less with different base and horizon years, defies both common sense and State of California planning codes and guidelines.
* Dick Platkin is a planning consultant and board member of the Beverly Wilshire Homes Association. He can be reached at rhplatkin@yahoo.com.
Comments
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