Sunday, November 25, 2012


Good Density or Bad Density, That is the Question

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WILSHIRE CORRIDOR, HOLLYWOOD UPDATE - The Update of the Hollywood Community Plan has been challenged by three lawsuits.  As this litigation slowly works its way through the court system, the debate about increasing planned and zoned density has not quieted down.  Let us therefore revisit that debate as it applies to two Los Angeles neighborhoods with mass transit, Hollywood and the Wilshire Boulevard Corridor.

Density, in the form of larger buildings and more people, is welcome in Hollywood, Wilshire Boulevard, and elsewhere, but only when it is properly planned.  In fact, when it is done right -- instead of being added on the cheap as an after thought to spark real estate speculation – increased density can be extremely beneficial for health, social, and environmental reasons. 
Hollywood:  In the case of the Hollywood Community Plan Update, however, there is only one approach to increased density: up-planning and up-zoning.  Not a nickel is allocated to prepare Specific Plans for the neighborhoods surrounding existing subway stations where the density would be located.  Likewise, these areas do not have funded programs for tree planting, public landscaping, parks, parklets, playgrounds, schools, fire stations, police stations, bike paths, street lighting, ADA curb cuts, street furniture, and median strips.  
These and many other local amenities, public infrastructure, and public services are essential when a proposed plan increases density in the name of promoting transit use.  Without those missing pieces, a density plan, such as the Hollywood Update, is just a short-term gift to real estate developers and a long-term formula for planned failure and neighborhood blight.
Furthermore, the proposed Hollywood Plan does not have a rigorous annual monitoring program capable of tracking the gradual implementation of the Update.  Likewise, there is no mechanism to accurately detect changes in population, housing, and employment; local user demand for infrastructure and services; and changes in the quality of services and infrastructures resulting from either the Update or from unexpected factors.  
Finally, the updated Hollywood Plan does not calculate the population increases actually resulting from its own density program, nor how these increases in population and building density translate into increased demand for public services and infrastructure, as well as the amenities required to make Transit Oriented Districts near subway stations a success.
Wilshire Boulevard Corridor:  Furthermore, these obvious lessons appear to have been forgotten in other areas where mass transit is or will be used as a justification for increasing residential densities.  A perfect example is the neighborhoods on the Subway to the Sea, the initial extension of the Wilshire Red Line Subway from Western to LaCienega.  
In the previous subway alignment planning efforts for this section of the Wilshire corridor, in the 1980’s, the Department of City Planning prepared detailed Specific Plans and Draft Environmental Impact Reports (DEIR) for the Wilshire/LaBrea, Wilshire/Fairfax, and Wilshire/LaCienega station areas.   These Specific Plans and their DEIR’s extended out in a quarter of a mile radius from the actual station sites and addressed all features in adjoining private and public areas. 
Unlike Hollywood, this is the precedent for how Transit Oriented Districts should be developed in conjunction with mass transit, and it was figured out 25 years ago, when the RTD/MTA hired the Department of City Planning to conduct the workshops and hearings, as well as prepare and adopt the Specific Plans.  
These Specific Plans proceeded as far as the City Planning Commission, but were forgotten once the subway alignment changed to Vermont, and the Wilshire segment terminated at Western Avenue.   Nevertheless, all of this work is filed away and could be pulled out of file cabinets, scanned, and become working documents applicable for proper transit-oriented stationary planning on the Subway to the Sea. 
The lesson from Hollywood and the Wilshire Corridor is obvious.  We know how to properly plan for increased density on mass transit corridors.  If done correctly, as could have happened on Wilshire Corridor, it could succeed.  But, if the station area planning and related programs are ignored, as happened in Hollywood, and is likely to happen on the Subway to the Sea, increased density will be a curse, not a blessing.
(Dick Platkin is a city planning consultant who teaches sustainable city planning at USC’s Price School of Social Policy.  He is a CityWatch contributor and can be reached at Full disclosure: Mr. Platkin is associated with La Mirada, one of the parties participating in the lawsuit.)-cw
Vol 10 Issue 93
Pub: Nov 20, 2012

Tuesday, October 16, 2012

The Scam That Keeps on Giving - 2nd Column in a CityWatch Series

The Scam That Keeps On Giving

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In a previous CityWatch column debunking the myth of LA’s “green” McMansions I explained that the widespread mansionization of many Los Angeles neighborhoods is a deliberate rather than accidental failure of the planning process.

I further explained how this scam has been perpetrated by officials who portrayed McMansions as “sustainable” development, even though mansionization is one of the least ecological schemes ever spawned by the real estate industry.
It is even more disturbing to learn that this deception is not an anomaly.  It has been reinforced by previous and subsequent ruses intended to quietly promote mansionization throughout Los Angeles.  This is why these overstuffed houses are popping up at an accelerating rate throughout much of the city.

Yes, it is true that the city’s legally adopted city plans, such as the General Plan Framework Element and the Community Plans, clearly protect the character and scale of Los Angeles’s residential neighborhoods.  In terms of their blue-sky policy language, mansionization is clearly out-of-bounds.  This is even clearer in Do Real Planning, a planning policy document prepared by the previous Director of Planning, Gail Goldberg.

NEUTRALIZE MANSIONIZATION:  Neighborhoods zoned single family deserve protection.  The most pervasive threat they face is the replacement of existing homes with residences whose bulk and mass is significantly lager than the street’s current character – sacrificing greenery, breathing room, light, and air.  Let’s be the champions of a city-wide solution to prevent out-scale residences.

These are beautiful sentiments, but City Hall’s actions speak far louder than these and other noble words.

The first deception was directed at one of LA’s mansionization epicenters, Beverly Grove.  This Fairfax neighborhood area contains 700 mostly Spanish Revival homes constructed in the late 1920s.   Near medical services, parks, shopping centers, grocery stores, restaurants, and museums, Beverly Grove has an ideal location.

Furthermore, it is surrounded by a gated community (Park LaBrea), Historical Preservation Overlay Zones, as well as Beverly Hills and West Hollywood, two cities that have successfully limited McMansions.

Since the contractors and private investors responsible for mansionizing Los Angeles were blocked from those desirable areas, they descended on unprotected Beverly Grove to pick the carcass clean.  The mansionizers have built over 50 McMansions there is the past decade, over half in the past two years.

In response to the sudden appearance of McMansions, Beverly Grove residents beseeched their local Councilperson at the time, Jack Weiss, to take action.   After many delays, Weiss finally moved when his own neighborhood survey revealed that 60 percent of Beverly Grove residents wanted to stop McMansions.  Then, when he balked and protested that 60 percent was no longer solid enough evidence for him, a neighborhood petition campaign raised the threshold to about 75 percent.

Unable to retreat further, Weiss reluctantly granted the community an Interim Control Ordinance (ICO) to stop McMansions.  It had wonderful Whereas clauses, but Weiss’s trickery was buried in the details.  His ICO allowed new homes to be built as large as 6,600 square feet, or 2,000 feet larger than the McMansions he pretended to stop in response to community complaints. 

Furthermore, Weiss got the last laugh because his fraudulent ICO set the precedent for the equally fraudulent citywide Baseline Mansionization Ordinance that replaced it.

But Weiss did not stop there.  As a Councilmember, he also proposed that the Baseline Mansionization Ordinance grant a bonus to new houses that became LEED certified.  This, then, is the origin of the debunked urban myth that LA’s McMansions are sustainable development.

Weiss’s suggestion soon appeared in City Planning’s draft mansionization legislation.  It then sailed through the City Planning Commission and the City Council.   The Mayor, always a booster of “greening” Los Angeles, quickly signed off on it over the objection of the Director of Planning.

Because the public objected to this fraud at official hearings, the final mansionization legislation created a Residential Floor Area Overlay Zone (RFA).  In theory, this provision gives local communities relief from mansionization.  In other words, to actually end mansionization, a local community must devise an elaborate escape route from the Baseline Mansionization Ordinance.

The first step is a request to their local Councilperson to submit an RFA motion to the City Council.  If the motion is submitted and adopted, the Department of City Planning then has the authority to reject it.  This is exactly what has already happened to several communities.

For example, in Valley Village the community undertook a detailed survey that resulted in a Council RFA motion to stop mansionization.  But, because the Department of City Planning chose to ignore it, the Valley Village RFA died on the vine.   After two years the City Council declared its own RFA motion void because of City Planning’s inaction.

But, why would City Planning rebuff Council RFA motions?  One reason is that when the City Council created the RFA option, it did not fund any City Planning staff.  Since the Department of City Planning, however, has over 200 staff members paid for from the City’s General Fund, the real explanation runs deeper.  Once the RFA option was created, the City Planning Department then established 10 pages of intricate administrative steps to prepare an RFA ordinance.

In other words, the “we don’t have resources for such a large undertaking” is really a self-inflicted wound that blocks these overlay ordinances.  The intricate and arbitrary steps required to stop McMansions, ensure that few, if any, such RFA ordinances will ever be prepared or adopted.  The result is, as probably intended, quietly maintains the mansionization process while officials can publicly object to them.

This is why these mysterious investors and their contractors are still feverishly bulldozing large swaths through beautiful older LA neighborhoods.

Furthermore, as I previously wrote, there are many simple fixes to this web of deceit that could turn the tables on the mansionizers and their many stealth friends at City Hall.  For example, the Mount Washington neighborhood of Los Angeles has an ordinance that requires all new homes to go through environmental review.

This administrative procedure could be adopted throughout Los Angeles.  It would be based on the principle that McMansions have clear environmental impacts, and when communities, like Beverly Grove, are extensively mansionized, these impacts become cumulative.

Each new McMansion adds to the community’s energy needs, as well as producing emissions, noise, dust, asbestos, loss of parking, loss of trees and parkways, loss of solar access, and loss of rain water percolation.  In combination, these environmental impacts are significant, with the downsizing of these monster homes the only real environmental solution.

But, as was made clear in the previous article, the problem is not a lack of technical solutions.  It is City Hall’s continued, but unstated commitment to mansionization.

(Dick Platkin is a city planning consultant who teaches sustainable city planning at USC’s Price School of Social Policy.  He is a CityWatch contributor and can be reached or on his blog:
CityWatchVol 10 Issue 81Pub: Oct 9, 2012

Monday, October 1, 2012

Debunking LA’s Urban Legend: “Green” McMansions

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WHERE WE LIVE - New York might have alligators roaming its sewer system, but LA can now boast of its own urban legend: “green” McMansions.  Yes, that’s right; in Los Angeles, McMansions, those boxy, oversized, energy-demanding suburban houses plopped into the middle of older neighborhoods are officially considered to be sustainable development.
How could this be?  After all, McMansions require huge amounts of energy to assemble their building materials and move them to job site.  Furthermore, the houses themselves are massive, which means enormous heating and air conditioning bills, even if their windows are double-paned, their walls padded with extra insulation, and their restaurant-sized refrigerators and stoves Energy Star rated.

Then we need to consider their multiple bathrooms and heated outdoor pools and spas, the most energy intensive features of modern houses.

Other McMansion features also have their detrimental environmental effects.  During demolition they release dust and asbestos into the air.  After construction, their large patios, pools, spas, and double driveways reduce natural open space.  Combined with their elimination of parkway trees and landscaping for driveway cuts, the cumulative result is a heat island with less penetration of rainwater.

Last, but certainly not least, we need to factor in their transportation system.  All McMansions are built on single-family residential lots located away from bus stops and transit stations.  This is why McMansion residents rely on their cars to get around; the only difference being that most of their vehicles are large, thirsty SUVs.

Given this environmental profile, some advanced jurisdictions, like Marin County, require a full energy audit of all new houses larger than 3,500 square feet.  Many other cities, like West Hollywood, simply restrict the size of R-1 homes to prevent McMansions.

But, certainly not in Los Angeles where the treatment of McMansions has raced in the opposite direction.  Our city government offers a “green” incentive to contractors so they can super-size their McMansions.  Finally, all this is done through a misnamed ordinance, the Baseline Mansionization Ordinance.  It purports to stop mansionization, but, in fact, does exactly the opposite.

Just like the Patriot Act, that curbs civil liberties, the Commodity Futures Modernization Act, that stops the regulation of derivatives, and the Farm Dust Regulation Prevention Act of 2011 that bars the EPA from regulating soot, the Baseline Mansionization Ordinance -- despite it name -- is deliberately filled with enough exemptions and bonuses to permit McMansions to still be built by-right in most of Los Angeles.

Since 2008, after two years of detailed research and preparation by the Department of City Planning, public hearings and adoption by the City Council, and then signed by Mayor, mansionizers still have a free rein in most of Los Angeles.  This is why they are building McMansions at an accelerated rate as market conditions improve.

This fraud was deliberately and carefully crafted as follows:  Unlike large lots, the 77 percent of the LA’s single-family lots zoned R-1 grant homes a Floor Area Ratio (FAR) of .5.  This means that in Los Angeles houses built on a typical 6000 square foot R-1 lot begin at 3000 square feet, already a thousand square feet larger than the average R-1 home.  Then, if the contractor adds such green features as extra insulation, double-paned windows, and new appliances, they get an additional 600 square feet through a 20 percent “green” LEED bonus, for a total of 3,600 square feet.

After that, the McMansions' attached garages, which are often surreptitiously used as play rooms or storage, are exempted for an additional 400 square feet.  This increases the McMansion total to 4,000 square feet.  Next are the exemptions for high entryways and semi-enclosed decks and balconies.  They legally raise the total to 4,350 square feet.  In some cases slip-shod plan check and inspections appear to allow even more massive structures.

Voila.  These tricks result in the same McMansions that were built before the Baseline Mansionization Ordinance was prepared and adopted under the pretense that it would stop McMansions.

How easy would it be fix this fraud?  The answer is that it is simple.  A minor amendment to the Baseline Mansionization Ordinance would stop mansionization in its tracks.  If R-1 lots were treated like large lots, and their by-right FAR became .35, most of the work would be done.

To put some frosting on the cake, if the exemptions and bonuses, especially the “green” bonus or the garage exemption, which are spurious to begin with, were ratcheted down to 900 square feet, McMansions would then be limited to 3000 square feet.  This is the size of the largest existing homes in most R-1 neighborhoods.

But the real questions are not technical because municipalities all across the United States have devised many effective legislative and administrative procedures to stop mansionization, such as design and environmental review.

In Los Angeles, the real question is political.  Do we have any elected officials who are willing to show leadership and prevent vast swaths of Los Angeles’s residential neighborhoods from being quickly wrecked by speculators bulldozing charming older homes and then building and flipping McMansions?

*Dick Platkin is a city planning consultant who teaches sustainable city planning at USC’s Price School of Social Policy.  He is a CityWatch contributor and can be reached at .

Vol 10 Issue 79
Pub: Oct 2, 2012

Monday, July 2, 2012

Corrupted Planning Rules and the Downward Spiral of Los Angeles

A Strategy to Turn L.A. Around

Posted on June 30, 2012 by Ron

EDITOR’S NOTE: Retired LA City Planner Dick Platkin, now consulting to community groups and teaching about sustainable city planning, wrote a version of this article for the Summer 2012 issue of Progressive Planning magazine ( ). The article provides a valuable analysis of what has gone wrong in L.A. and what it takes to fix the city. Platkin can be reached at
“If you cannot predict, how can you plan?  The answer is clear; you cannot; you proceed blindly.” -- Gabriel Kolko, “Why America is Doomed to One Disaster After Another,” CounterPunch, May 14, 2012.

How the Planning Process Contributes to LA’s Malaise

By Dick Platkin
There is a widespread feeling inLos Angelesthat the bloom is off the rose, that a formerly dynamic city has been in the doldrums for several decades and that, at best, its future offers more of the same.  I have no argument with this view. Instead, I would like to explain how the city’s planning process has contributed to this malaise by accommodating a political process molded by economic forces.  Hopefully my account will also offer an alternative model to the governance and planning ofLos Angeles.
Part of the explanation is, of course, that LA has been whipsawed by global and national trends.  In this regard Gabriel Kolko’s article was about this country’s endless, futile, bankrupting foreign wars.  He argues there is no end in sight for these military interventions, and the U.S. government will continue to mindlessly wage them because they are no longer capable of either predicting or planning.
Sadly, the domestic consequences of these wars, combined with local government’s similar inability to predict and plan, have become a curse on American cities.
The bipartisan, neo-conservative foreign policy that Kolko dissected neatly dovetails with the neo-liberal (i.e., austerity, deregulation, heavy policing and surveillance) approach to local government is painfully visible in most large American cities, including Los Angeles.  In both cases the quirks of market forces, whether global or local, subvert the planning process because of our economic system’s regular booms, bubbles, and busts, as well as it periodic breakdowns into crises and conflicts.
CASE STUDY OF LOS ANGELES:  A close look at Los Angeles, the second largest metropolis in the United States, reveals how this downward spiral is unfolding, and how it is abetted by a corrupted planning process.
While the city’s increased emphasis on policing and surveillance parallels the globalized militarism of the United States, so too are City Hall’s selective business subsidies and tax breaks, encouragement of new real estate bubbles, and local austerity programs.   For example, in the past several weeks alone, the local press has reported a $67 million dollar tax break for a new, downtown hotel, unprecedented cutbacks in public education, and a large surge in police murders.
On the 20th anniversary of the 1992 civil disturbance that torched 1000 buildings, murdered 50 people, wounded over 10,000, and arrested another 10,000, Los Angeles is a sad sack of a city.  Despite City Hall and media boosterism, decay and decline are in the air.  While the city’s elected officials, nearly all centrist Democrats tethered to the real estate sector, still portray Los Angeles as a boomtown, the city is tired, aging, with many unattractive neighborhoods.  In reality, it perfectly reflects the broad plight of the United States described by Kolko.  Imperial over-reach is far from over and has already resulted in substantial domestic stagnation, with long-term prospects even worse.
Furthermore, the revival strategies of the Los Angeles’s business elites and their political sidekicks are comedic.  In response to long-term economic decline, accelerated by the bursting of the housing bubble, they have spared policing and spying, while otherwise cutting public payrolls, employee compensation and hours, and public services and infrastructure to the bone.  At the same time they are systematically deregulating private real estate investment and environmental review processes in the pollyannaishneo-liberal belief that, investors will then rush in for another building boom – a tide that will lift all ships.  The absence of sufficient consumer demand due to the City’s stagnant economic base and the resulting high levels of unemployment, does not, apparently enter into their municipal strategy/business model.
To their credit, a small part of their calculation might be correct.  There certainly are enough dormant piles of capital stashed around this planet to build many new shopping complexes and upscale apartment buildings in the ritzier parts of Los Angeles.  City Hall may even find a few bold investors willing to plunk someone else’s money into the distressed inner-city neighborhoods that revolted 20 years ago in the largest urban unrest since New York City draft “riots” of 1863.  Even today, a drive through these scarred neighborhoods reveals how little they have changed and how much vacant land is ripe for real estate speculation.  In fact, some of the empty lots on major streets, such as Vermont Boulevard, are the remains of fires set in 1992 by local residents when their anger at police violence and decrepit neighborhoods boiled over.
Unlike the previous Watts civil disturbance of 1965, which was a catalyst for public investment, much of it from the Federal government, in the two decades since 1992 public investment has dwindled.  Furthermore, the disbanding of the Los Angeles Community Redevelopment Agency (CRA) has reinforced these cutbacks since the CRA was one of the few remaining sources of public investment.
In response to these developments, local officials have never mentioned the obvious: military spending, coupled with tax breaks and bailouts for the well off, the national recession, and Prop. 13’s two-thirds requirement to raise taxes in California, have totally undermined state and local government.   Furthermore, deindustrialization due to the outsourcing of factory jobs to low wage foreign countries, has undermined the economic base of Los Angeles and many other American cities.
NEO-LIBERAL NOSTRUMS:  Instead, city officials have resorted to the same neo-liberal nostrums associated with Presidents Reagan and Clinton: deregulation of private investment to spur the economy.  Their municipal cure-all is the flush real estate sector that is supposed to ensue.  While there has been a minor boom in illegal garage conversions, McMansions, billboards and supergraphics, and marijuana dispensaries, there is little evidence that their arsenal of local give-aways has “unleashed” the private sector.
According to the Bureau of the Census, Los Angeles’s population has been nearly flat for the past 20 years, with many historic neighborhoods, such as Hollywood, losing population – despite the introduction of subway stations, zoning exceptions, and investment subsidies.  As for employment, there has been no gain at all, with visible weakening in the city’s core historic industries of construction, heavy manufacturing, garment, and entertainment.  In fact, Los Angeles no longer hosts the head office of any Fortune 500 company.  Because of the stagnation of the City’s economic base, there is less population growth and purchasing power to support new development.  Furthermore, the city is still one of the most unequal in the United States.  It Genie Co-efficient is .49, ranking it fifth in the entire country.  Another index of economic stagnation and decline, unemployment, has been stuck at an official rate of 12-14 percent since 2009.  Inequality and unemployment results in more poor people and poorly paid working people who cannot afford to rent new apartments or buy homes because they are priced higher than they can afford.
A more careful look at the planning process in Los Angeles reveals how this decline is unfolding.  It also reveals why further deregulation will compound the deteriorating conditions experienced by most Los Angeles neighborhoods.
In the boom years prior to the 1992 civil disturbance, the Los Angeles Department of City Planning had 350 employees serving a population of 3.2 million people.  In response to lawsuits from the politically powerful Canyon and Hillside Federation, local slow-growth movements in many Los Angeles neighborhoods, and a legal mandate from the Environmental Protection Agency, this Department undertook an ambitious planning program.
The first component was AB 283, an enormous zoning consistency program.  It comprehensively revamped the city’s parcel-level zoning and plan designations, to bring zoning into conformance with the City’s General Plan’s Land Use element, the Community Plans. This program reduced the build-out population capacity of the city’s zoning to prevent over-development in most of the city.
At approximately the same time, many local community organizations responded to overly dense and poor quality commercial projects with such sustained political pressure that the City Council adopted a dizzy array of overlay zoning districts.  In addition to Specific Plans, there were HPOZs (Historical Preservation Overlay Districts), CDOs (Community Design Overlay Districts), PODs (Pedestrian Overlay Districts), and SNAPs (Station Neighborhood Area Plans).  Recent additions include CPIOs (Community Plan Implementation Overlays) and RFA’s (Residential Floor Area Overlays) to stop mansionization.   However, the specific plans and overlay zones cover only a small portion of the City’s land area, leaving the rest of the Los Angeles unprotected from poor quality development. Only the squeaky wheels got oiled with strengthened regulations for small geographical areas, while the underlying citywide problems of weak land use and design controls were left to fester.
The final leg of this triangle was a legal directive from the Environmental Protection Agency that forced Los Angeles to update its General Plan.  This resulting plan, the General Plan Framework Element, was based on 1990 census data and adopted in 1996, with a 2010 horizon year.  Its intent was to politically balance the interests of neighborhoods and real estate developers through a policy of growth neutrality and a program of extensive monitoring of citywide and local trends, including demographics, traffic, construction, infrastructure, and public services.
An exemplary General Plan that could have addressed the citywide problems responsible for the multiple zoning overlay ordinances, the Framework’s policies were quickly ignored and its monitoring program was abandoned in 1999.  Ironically, several Framework goals, particularly those related to transit, have often been quoted out of context to justify zoning waivers for large commercial projects.
REVERSAL OF PLANNING INITIATIVES:  Likewise, the plethora of zoning overlay ordinances ground to a halt because a change in City Hall’s governing philosophy was reinforced by staff reductions – but not because the wheels stopped squeaking.  The original impetus of many of the planning initiatives from the 1980’s and 1990’s was to manage market forces through carefully prepared plans and zoning rules.  But by the late 1990’s until today, unpredictable market forces have prevailed over community concerns.  In this period the city’s planning and zoning processes have been systematically weakened to the point that the City’s elected officials and their appointed managers consider the planning process to be little more than an annoying barrier to real estate investment.
For example, the General Plan Framework Element seriously over-estimated the city’s population, projecting it to grow from 3.2 million in 1990 to 4.3 million by 2010.  Even though the Bureau of the Census only counted 3,750,000 Angelinos in 2012, the General Plan has not been updated to reflect the new census data or augmented with an Economic Development Element to address the city’s financial doldrums.
Instead, the Framework has been left to languish, demonstrating Gabriel Kolko’s insight that without the ability to predict, there is no ability (or intent) to plan.  Old census data, left over from the boom era, is still used by a City Planning Department whose staff was reduced from 350 to 240 staffers by budget cuts.  (Factoring in furloughs, the number of full-time positions is closer to 220.)  These old population numbers are now being used to justify (but not predict) expansive programs of up-zoning and up-planning disconnected from the city’s actual demographic and economic trends.
Instead of updating the General Plan Framework Element and its related planning elements (e.g., Air Quality), or preparing critical new elements addressing the economy or climate change, a planning program called Community Plan Updates has been rolled out.  It will revise Los Angeles’s 35 community plans.  Seven are under preparation, but all 35 will eventually be tackled.  These Updates have only the most superficial connection to the Framework Plan, without any link to observable demographic or infrastructure trends.  If the recently enacted Hollywood Plan Update is any indication, the role of the Updates is to green light speculative real estate development.  This is being done through companion ordinances that allow higher densities in selected locations, permitting much larger and higher projects to be quickly approved.  Missing in action is secured funding for Hollywood’s infrastructure and public services, as well as programs to monitor the Update itself and the impacts of new private projects.
Unfortunately, or luckily, in seven years of work on these Community Plan Updates, only the Hollywood Update has been presented to the public.  Approved by the City Council on June 11, 2012, lawsuits will tie it up in the courts for an extended period of time.  Although the Hollywood Update was intended to be a template for the remaining 34 Community Plan Updates, staff shortages, the lengthy, multi-step approval process, and a loss of expertise has stalled the release of the other plans.  While their exact status has been kept under careful wraps, their slowdown has become an unintended blessing for many Los Angeles communities.  They had braced themselves for an onslaught of new zoning ordinances permitting much larger buildings, oblivious to local character or infrastructure capacity.  Despite years of delay, the communities are still holding their breath in anticipation of what comes next, in particular when the law suits challenging the Hollywood Community Plan Update are adjudicated.
NEW FORMS OF LAND USE DEREGULATION:  At the same time, the shrunken Department of City Planning has undertaken three programs to further deregulate private land use:
  • It is preparing over 20 piecemeal amendments to the Los Angeles Municipal Code (LAMC) to insulate applicants for discretionary zoning actions from strict rules, environmental reviews, public hearings, and appeals.
  • It is undertaking a new five-year program, recently funded by the cash-strapped Los Angeles City Council, to totally revamp the city’s zoning code.  The details of this program are still murky, but critical observers assume this is one more effort to deregulate real estate investment.
  • It is showcasing Transit Oriented Development (TOD).  In theory, Los Angeles, one of the country’s most polluted, auto-centric cities, desperately needs sustainable development.  Unfortunately, the Department of City Planning’s is promoting TOD on the cheap.  While the successful model for transit-oriented development consists of a dense mass transit system, bike lanes, extensive local amenities at or near transit stations, and pedestrian improvements such as sidewalk widening and street trees, in Los Angeles TOD has been simplified.  Forget the public improvements.  Instead, private lots near minimalist transit stations will be up-zoned in the belief that developers will then rush in to build mostly market rate apartments in run-down neighborhoods lacking market demand.
This combination of a truly stagnant economy and drought in government investment, especially in public infrastructure and services, such as education, suggests that these planning schemes are doomed.  After all, when the city’s air is still highly polluted, the highways and roads are as congested as ever, the transit system is embryonic and underfunded, the sidewalks and streets are in deplorable shape, the overhead wires and billboards are an assault on the eyes, and the schools and colleges are in free fall from years of cutbacks, how could most new upscale projects succeed?
While a few projects, such as USC’s expansion or a new AEG football stadium in the downtown, might succeed because they are near major employment centers, most new projects will either languish or fail.  Local subsidies, usually in the form of tax breaks favored by the city’s elected officials, can temporarily help a few of the well-connected, but the fate of most new projects is sealed.  Private investment, no matter how large or touted by squadrons of expediters, publicists, and technicians, cannot succeed when the city’s economic base is stagnant, when public investment is so stunted, and when even worse reductions are likely.
Furthermore, there is no white knight to rescue Los Angeles.  Unlike 1965, there are few remaining Federal urban programs other than Department of Justice grants for police spying on Moslems and occupiers.  As for the State of California, it, too, is in desperate financial shape, so Sacramento cannot be relied on.  Prop 13’s two-thirds requirement to raise taxes, which gives conservative Republicans a veto power, has contributed to structural deficits decimating the state’s public infrastructure and public services for the foreseeable future.  Even hopes that the private sector could come to the rescue, truly an idea born of desperation, have not panned out.  Rebuild LA was the business community’s program for the Los Angeles neighborhoods decimated in 1992.  It eventually folded because the lack of purchasing power in low-income communities could never attract enough private capital to replace reduced public investment.  It only lasted a few years, and it sole legacy is five oversized boxes stored at the library of Loyola Marymount University.
PROSPECTS:   With no help on its way, and with local officials who consistently manage to weakly play the poor hands they have been dealt, what are the options?
In this case the ball is in the court of the public.  While the local campaigns of the 1980’s and 1990’s that resulted in a new General Plan, many specific plans, and the wholesale revamping of the city’s zones have fragmented, they have not been forgotten.  Los Angeles still has many active community groups and official neighborhood councils.  While some neighborhood councils have been hi-jacked by real estate interests, many still represent highly committed local residents.
Furthermore, many of the neo-liberal schemes originating at City Hall have met stiff resistance from local opponents and citywide alliances.
What is needed in Los Angeles, however, is a citywide political force that can tackle the city’s enormous problems, in particular its stagnant economy, by supporting increased public investment.  While the LA Weekly and on-line journalism have chiseled away at City Hall’s veneer and occasionally pried it back enough to peek inside, at this point Los Angeles is, at best, moving sideways.  Exposes of poor management and backroom deals are helpful, but, like Rebuild LA, in themselves they cannot replace major improvements to municipal services and infrastructure.
For a short time many local activists had great hopes in enormous immigration marches and most recently in Occupy Los Angeles(OLA).   While Occupy Los Angeles did captivate the public and had hundreds of people living on the grounds of City Hall, few of the occupiers managed to successfully analyze what took place within the building right next door.
Even though OLA fractured after the Mayor directed the LAPD to evict it from the grounds of City Hall, it has survived.   Many people expect its spirit to combine with LA’s ongoing deterioration to spark a serious, long-term, fully engaged, inclusive, and deeply analytical movement before another civil disturbance rips the city apart a third time.
This entry was posted in City HallCommunity ActivistsDevelopment/CRAHot TopicsLos Angeles. Bookmark thepermalink.

Wednesday, June 20, 2012

Hollywood Community Plan - Alternative Vision


June 19, 2012
Case Number:  CPC-2005-6082-CPU

Submitted by:
East Hollywood Neighborhood Council Planning Entitlement Review Committee
Doug Haines, Chair
David Bell
Edward Hunt
Armen Makasjian
Richard Platkin

TABLE OF CONTENTS                                                                                            Page

Glossary Note - 2                                                                                                         
Introduction the Alternerative Vision  - 2                                                                           
Principles of the Alternative Vision - 4                                                                    
Implementation of the Alternative Vision - 9                                                                      
Credentials - 10                                                                                                                                

                     IN HOLLYWOOD
                     AND PLAN DESIGNATIONS
Appendix 4:  PEDESTRIAN ORIENTED DISTRICT ON SANTA                      14
                     MONICA BOULEVARD
                     TO THE UPDATE

Glossary Note: 

Alternative Vision refers to the outline of an alternative, resident-focused Hollywood Community Plan Update proposed by the East Hollywood Certified Neighborhood Council (EHCNC).  In the view of local residents, the Alternative Vision is based on an approach to city planning that emphasizes high levels of review and a high level of public amenities.

Proposed Update refers to the version on the Hollywood Community Plan Update approved by the Los Angeles City Planning Commission in December 2011 and that, with minor revisions, will be considered by the Los Angeles City Council in early 2012 and will be submitted to the City Council on June 19, 2012.  In the view of the East Hollywood Neighborhood Council (EHNC), the Proposed Update is based on an approach to city planning that relies of reduced levels of regulation and review and on low public amenities.


This Alternative Vision for the Update to the Hollywood Community Plan is presented by the East Hollywood Neighborhood Council, based on its review of the Proposed Update prepared by the Los Angeles Department of City Planning, approved by the Los Angeles City Planning Commission, and to be voted for adoption by the Los Angeles City Council.  Instead, the EHNC has developed the following vision of an alternative plan.  It is presented here for a detailed review prior to its elaboration and prior to the City Council’s adoption of the Update of the Hollywood Community Plan. 

The vision underlying the alternative Community Plan Update is driven by quality of life issues for those who live, work, travel through, visit, or conduct business in Hollywood.  The Alternative Vision’s approach emphasizes local amenities and careful review of local trends and all private projects, in particular their compliance with LAMC zoning regulations and the requirements of the California Enviornmental Quality Act (CEQA).  The Alternative Vision can also become a model for the other 34 Los Angeles Community Plans, all of which are scheduled for similar updates. 

In terms of its research methodology, the Alternative Vision rejects the approach of the Department of City Planning used to prepare to the Proposed Upate.  As is carefully outlined in Appendix 6, this proposal inflates anticipated population growth in Hollywood by ignoring the 2010 census data, and then uses the resulting inflated population figures to justify major increases in locally permitted densities through zone changes, heigh district changes and General Plan amendments.  These new zones would allow the construction of large, tall buildings, avoiding the careful zoning and environmental reviews that are now required of such buildings.

The Alternative Vision stands in sharp contrast to the Hollywood promoted by the commercial interests who will financially benefit from the city’s Proposed Update.  For them the Hollywood Community Plan Area is a potentially lucrative location for speculative private investment in quickly approved commercial real estate projects.  It is this business model that drives the methodology, goals and policies, and programs of the Proposed Update to the Hollywood Community Plan.  Furthermore, unless prevented, commercial investment agendas will guide the Community Plan Updates scheduled for LA’s other 34 community plan areas in 2012 and in subsequent years.   Based on the precedent set by the Proposed Update, the entire city could eventually be transformed into a permanent low amenity, low regulation “business-friendly” distopia.

In contrast, the East Hollywood Neighborhood Council’s Alternative Vision for the Hollywood Community Plan is based on the purposes, intent, and methodology of the General Plan Framework Element (as required by the Los Angeles City Charter, Sections 556 and 558).  This is why the Alternative Vision carefully builds on the five following features:

1)     Current Census Data:  The Proposed Plan will utilize 2010 census data and related population projections, in contrast to the Proposed Update, which relies on old census data and inflated population projections.

2)     User Demand Data: The Proposed Update relies on the most recent municipal-level data on future user demand for public services and infrastructure in the Plan area, in contrast to the City’s approach through the Proposed Update’s Final Environmental Impact Report (FEIR).  As befits a low amenity approach, the FEIR concludes that the commerical projects ushered in by the Update will overwhelm local public services and infrastructure, as well as air quality.  These adverse outcomes are then dismissed through a Statement of Overriding Considerations to be adopted by the Los Angeles City Council.  This statement argues that substantial transit use and employment will result from the Proposed Update and that these benefits offset the Plan’s unmitigated environmental impacts.

3)     Infrastructure:  The Proposed Update is based on the most current data on Hollywood’s public services and infrastructure, including maintentance levels and construction linked to secured funding between 2010 ro 2030.  This approach contrasts to the Proposed Update’s FEIR, which fails to analyze the sources and security of infrastructure funding and maintenance.

4)     Buildout: The Proposed Plan will incorporate accurate calculations of the buildout capacity of Hollywood based on General Plan designations and adopted zoning ordinances in the Hollywood Community Plan area.  This is in contrast to the Proposed Update, which offers no buildout calculations for private or publicly owned land, including existing categories, as well as proposed General Plan and zoning amendments.

5)     Emergency Preparedness:  The Proposed Plan will give careful consideration to emergency preparedness for the natural and man-made disasters likely to befall the Hollywood Community Plan area over the life-time of the Update, again in contrast to the Proposed Update, which fails to consider these critical issues.


In general, the Alternative Vision must remedy five critical methodological flaws in the Proposed Update approved by the City Planning Commission.  By correcting these flaws, presented in Appendix 5  (METHODOLOGICAL FLAWS OF PROPOSED PLAN PREPARED BY THE DEPARTMENT OF CITY PLANNING AND APPROVED BY THE CITY PLANNING COMMISSION), the proposed Update intends to transform the Hollywood Community Plan Area into a high amenity, high regulatory area of Los Angeles.

The alternative vision is a not a detailed technical alternative to the Hollywood Community Plan Update, and this alternative was not evaluated in the Draft Environmental Impact Report that City Planning prepared for the Proposed Upate.  The production of such an alternative document is beyond the scope of an unfunded community organization.  Rather this document is a vision of what such as alternative plan should address and incorporate.  It is based on many suggestions offered in public testimony to the Department of City Planning on the flaws and limitations of the Proposed Update, as well as from a focus group internally organized by People for Livable Communities Los Angeles.  In addition, specific examples for implementing the Alternative Vision were provided in “Greening East Hollywood  -- An Open Space Network,” a graduate student project dated December 8, 2011 and prepared for the East Hollywood Neighborhood Council by UCLA graduate students Daisy Allen, Runlin Cai, Lars Carlson, Bradley Cleveland, Lu Lu, Jinghua Suo, and Xinfeng Wang.

1)             Scale and Character:  The Alternative Vision is centered on the maintenance of the current scale and character of commerical and residential buildings in Hollywood, including their use, height, and building mass.  Instead of sky-scrapers, the focus of new development and redevelopment should be pedestrian-oriented low rise buildings, utilizing both sidewalks and alleys for movement and outdoor dining. 
A potential low and mid-rise model for Hollywood’s future development is Old Pasadena, not the high-rise, automobile-centric, pedestrian-unfriendly model of Century City.  Implementation would include:
-       Adoption of a Pedestrian Oriented District on Santa Monica Boulevard.
-       Adoption of a Pedestrian Oriented District on Western Avenue.
-       Redesigning alleys with porous pavers, landscaping, street furniture, and traffic calming features to reduce automobile use.  A prototype of such an alley conversion would be Lyman, between Santa Monica Boulevard and Lexington.  This alley make-over would include a stone or brick surface complementing the adjacent public library, as well as bollards to slow traffic, additional trees, signage limited automobile access, public art, additional lighting, and street furniture.

2)             Preservation:  Hollywood’s future should be extensively based on historical preservation, with special attention to iconic buildings related to the entertainment industry, such as the Capitol Records and Cinerama Dome buildings.

3)             Zoning:  Without credible census data analyses that predict subsantial population gains between 2010-2030 and without any evidence that the buildout of Hollywood’s existing arrangement of legally adopted General Plan designations and zones, including Height Districts, are inadequate for any population scenario, the up-planning and up-zoning ordinances appended to the Proposed Update have been rejected. 
-  Amendments to the LAMC to allow or encourage green (landscaped) and white  roofs on commerical and residential structures.

An Alternative Matrix of Changes to Zones, Height Districts, and Plan Designations is presented in Appendix 3.

Local sub-areas with stable population would not have their General Plan designations and zones changed.  In contrast, however, those Hollywood neighborhoods that have had appreciable population decline from 1990 to 2010 would be down-planned and down-zoned through the Alternative Vision’s eventual implementation program.  Similarly, sub-areas within 500 feet of freeways would also be down-zoned and down-planned whenever existing or proposed densities exceed public health standards.

Because the Alternative Vision would include a thorough annual monitoring program, any unintended consequences resulting from this down-planning and/or down-zoning, such as over-crowding, would be quickly flagged.  Changes in policies, including their implementation through ordinances, administrative procedures for municipal programs operated by City departments, and the City of Los Angeles’s annual budgeting process, would then quickly ensue.

4)             Public Infrastructure and Services:  The Alternative Vision requires careful attention to the capability of local public services and infrastructure to meet the needs of Hollywood’s residents, employees, and visitors.  For the life of the  Alternative Vision capability would be determined by a detailed annual inventory of existing conditions, including funding, related to public infrastructure and services.  The findings resulting from this annual monitoring program would then be used to modify the Update’s policies and implementaton programs.  These modifications would be incorporated into the City of Los Angeles’s Capital Improvement Program (CIP) in order to catalog, budget, and plan future municipal capital projects. 

The Alternative Vision’s long-term intention would be to maintain and upgrade all categories of public infrastructure and public services to ensure an improved quality of life for the residents, employees, customers, and visitors to Hollywood.  The categories of public services and inrastructure that the monitoring progam would assess, but not be limited to, include:  

·      Parks, including pocket parks and small neighborhood parks, with basic services, such as landscaping and bathrooms, as well as local resident-serving recreation programs included whenever possible.  Some of these goals can be achieved as follows:
-       Converting school play grounds into joint-use parks.
-       Temporarily using vacant lots as pocket park and community gardens, including community gardens, dog parks, and community artistic and cultural events.
-       Reconfiguring parking lots to become mixed-use lots.
-       Reengineering of wide residential streets to incorporate small pocket parks and bike lanes.  A prototype of such a pocket park could be located on Mariposa Avenue, near the 101 Freeway.  In this area the road is wide enough to be diverted around two pocket parks where gated playgrounds could be located.

·      Community gardens in public areas, as well as private areas offered to the City for temporary community gardens.  Whenever possible, the City would offer local residents training in gardening, as well as assistance in planting, maintaining, and composting drought tolerant landscaping and gardens in front, side, and and back yards. 

·      Sidewalks, including regular maintenance and repair of cracked, raised, and crumbled sections, as well ADA required curb cuts for those with limited mobility or other special needs, such as shoppers with grocery carts, families with baby carriages, or residents who depend of walkers and wheelchairs for mobility.

·      Urban forest and complimentary landscaping of public areas, including the planting of drought tolerant trees for parkways (i.e, planting strip between sidewalks and curbs), median strips, and other public and quasi-public areas.  All landscaping should be planted with a long-term program of watering and related maintenance, either by City employees or through contracts with local community groups.

-   In-fill tree planting on parkways, median strips, playgrounds, and other portions of  the public right-or-way.

·      Safe bike lanes on appropriate streets, particularly secondary highways, based on the City of Los Angeles recently adopted citywide Bike Plan.  All bike lanes should be painted, with appropriate signage.  Based on monitoring and safety records, high volume or dangerous bike routes on public streets would be upgraded through signage, lighting, grade separations, and other safety mechanisms.

·      All public utilities and related infrastructure, including street lighting, elecricity and power lines, water, storm water and drains, waste water including sewers, solid waste, emergency services, street conditions, and libraries, would be monitored through an annual monitoring program.  All findings would be used to modify scheduled maintenance programs, as well as construction projects included in the City’s annually updated Capital Improvement Program in order to maintain service levels and to ensure public safety during emergencies.  Whereever possible, improvements of existing systems, in particular the undergrounding or power and telecommunications lines, would be a high priority for reasons of both esthetics and public safety during emergencies.

·      All regulated private utilities, in particular telecommunications and natural gas, would be addressed in the annual monitoring report.  All shortcomings, especially those with health and safety implications related to natural and man-made emergencies, would be forward to the appropriate regulatory agencies and departments for implementation and follow-up.

·      Temporary use of vacant lots for community gardens and temporary art displays.

·      All public infrastructure and services operated by non-municipal public agencies, including K-12 education (LAUSD - Los Angeles Unified School District), colleges and universities (LACCD - Los Angeles Community College District, CSU - California State University system, UC - University of California sysem), transit (MTA/Metro - Los Angeles Metropolitan Transit Authority), and highways (Caltrans – California State Department of Transportation) would also be addressed in the annual monitoring report.  All findings addressing quality of life and health and safety issues for these categories would be forwarded to the responsbile agencies, with follow-up in future monitoring reports.  Particular examples of local improvements include the following:

-       Defortifying public school playgrounds to allow their use after normal school hours and transforming school playgrounds into joint-use parks.
-       Community access to school athletic fields.
-       Conversion of parking lots at Los Angeles City College to mixed use plazas relying on porous pavers, vendors, shaded seating, active play areas, drought resistant landscaping, and bio-swales for rain water catchment.
-       Replacing asphalt at school recreation areas with athletic fields, restrooms, and bike facilities.

5)             Future housing needs, as identified by the annual monitoring report of neighborhoods and income groups, should be met through the preservation of existing rent controlled housing, including consistent code enforcement of houses and apartments, in combination with the construction of future affordable housing.  Market rate housing intended to attract new upper income residents to Hollywood is acceptable, can be built by-right with discretionary actions.  It should not, however, be facilitated through grants, subsidized loans or infrastructure, fee waivers, zone changes, variances, or General Plan Amendments.

6.         The mobility needs of Hollywood’s residents, employees, shoppers, visitors, and those driving through, must be met by multi-modal transportation options.  These options must be carefully linked to land use capacity.  In addition to expanding such alternative transportation modes as transit, carpooling, vanpooling, telecommuting, and biking, no increases in planned or zoned density should be adopted without a demonstration of available transportation capacity as documented in environmental data.  Examples of such capacity would be major intersections with A, B, or C levels of service, and busses and shuttles with available seats during rush hours.
-       Pedestrianization can be encouraged through such sidewalk improvements as curb cuts, tree plantings, landscaped bulbouts and media strips at corners, and landscaped traffic circles as a traffic calming device.
-       Madison Avenue could be pedestrianization demonstration project by reducing the width of traffic lanes, introducing bike lanes, and systematic tree planting.

7.        Design Review of major projects will not only focus on continuity in scale and character with Hollywood’s existing built environment, but signage will be minimized.  This approach will not only apply to new projects, but thorough enforcement of LAMC sign regulations would also apply to existing projects.  High profile signage, particularly supergraphics and billboards, would be highly restricted.  A program to phase out these forms of signage and improve the appearance of Hollywood’s commercial corridors would be included in the Alternative Vision.


1.    As identified in the previous discussion, a carefully prepared annual monitoring report examining all public infrastructure and service categories is the corner stone of the Alternative Vision.  This report would carefully examine all findings in the Update’s Draft and Final Environmental Impact Report.  This approach will be able to confirm which infrastructure categories are overwhelmed by population growth, which are subject to ambient growth, such as drive through traffic, and which categories are able to meet increased user demand from existing residents, employees, or visitors.  These reports will also carefully track the maintenance of existing infrastructure and the construction of new infrastructure, with special attention to those categories for which the FEIR indicated future funding is not secure.

2.    Part of the implementation of the Alternative Vision will be the City of Los Angeles Capital Improvement Program (CIP).  It will be revised and updated according to the policies, programs, and monitoring report.  All categories of public infrastructure and services will be included in the CIP.

3.    The City of Los Angeles, through the City Administrative Office (CAO) and the Office of the Mayor, proposes an annual budget to the City Council, which then reviews and adopts it, with periodic mid-course corrections.  For Hollywood, and incrementally for the entire city, this budgeting process would be linked to the Alternative Vision and its Annual Monitoring Report.  Budget priorities and allocations related to the implementation of the Alternative Plan would be accordingly modified.

4.    An alternative matrix of changes to zones, height districts, and plan designations, is presented Appendix 1

5.    In selected cases, the implementation program will include special zoning areaa, in particular on Pedestrian Oriented District on Santa Monica Boulevard.

6.    Footnotes to the Community Plan Map requiring the approval of demolition permits to be contingent on an approved building permit for ther same site.

Richard Platkin is a city planning consultant and Adjunct Instructor at USC’s Sol Price School of Public Policy.  He was previously a city planner for the City of Los Angeles, during which time he worked on the General Plan Framework Element.  As a result, he is familiar with the legal requirements, development, and content of Los Angeles’s primary General Plan documents.

The Hollywood Community Plan is part of the Land Use Element of the General Plan.  This means it is fully subject to State of California planning codes and administrative guidelines.  The update must not only be consistent with the General Plan, but also be timely and comprehensive.  Based on my knowledge and experience, the proposed update and its attached ordinances do not meet any of these legal and administrative criteria.  The purpose of the East Hollywood Neighborhood Council’s Alternative Vision is to initiate a Community Plan Update built on a community outlook and consistent with these State of California planning codes and guidelines.


Note: The land use map of the existing plan designations in Hollywood would be amended to reflect the zoning changes in Appendix 3.



Existing Zoning
Proposed Zoning
Rationale for Change
500 feet on either side of the 101 Freeway
R4, R5
RD1.5-1XL or lower
Public health concerns over air quality and disease.
Hollywood Redevelopment Project Area, between Vine Street and Serrano Avenue
R3, R4, R5
- Dissolution of Community Redevelopment Agency.
- Lack of supportive infrastructure and services.
Area between Melrose Avenue, Gower Street, and Santa Monica Boulevard
R3-1XL, R4
Commercial uses permitted by current zoning are not compatible with existing community.
Virgil between Fountain Avenue and Santa Monica Boulevard
Reverse land use changes implemented through SNAP to up-zone these areas.
Santa Monica Boulevard Corridor
All zones restricted to Height District 1XL, with conditions
Creation of Pedestrian Oriented District with 30 feet height restrictions, as proposed in Appendix 4.  Transitional height differences with adjacent properties restricted to a maximum of 15 feet.
Western Avenue Corridor

All zones restricted to Height District 1XL, with conditions
Creation of Pedestrian Oriented District with 30 feet height restrictions.  Transitional height differences with adjacent properties restricted to a maximum of 15 feet.
Hillside areas in and near Beachwood Canyon
RD1.5, RD2, RD4, R2, R3
R1, [Q]R2
Restrict development to two single-family homes or one duplex per lot.


December 21, 2011

Dear Councilmember Garcetti and Councilmember Reyes;

Over the past several months, the Route 66 Task Force has been in correspondence with staff overseeing the Hollywood Community Plan, Kevin Keller and Mary Richardson. Correspondence includes e-mail and meetings. On several occasions, the Route 66 Task Force proposed the establishment of a Pedestrian Overlay District (P.O.D.) along Santa Monica Blvd. between the Hollywood (101) Freeway and Hoover Avenue, to preserve the flow of pedestrian traffic and require fa├žade improvements to help protect the historical significance of Route 66 in East Hollywood. West Hollywood has capitalized on this very same issue.

Therefore it is imperative to implement an overlay zone within the proposed Hollywood Community Plan to preserve the character of the street and buildings.

Santa Monica Blvd. in East Hollywood is served by a Metro Rail Station located on the southwest corner of Santa Monica Blvd. and Vermont Ave. as well as twenty (20) Metro bus stops which contribute to the large pedestrian flow within the corridor. Therefore, a P.O.D. designation would protect and enhance the existing pedestrian experience. Although the Hollywood Planners expressed strong support and proposed wording in the Hollywood Plan to implement building design and “walkability”, such “loosely-written” wording will have no effect. As in the past, wording has been placed in the plan to promote and preserve neighborhood character but has always failed to achieve those objectives. The proposed wording in the proposed Hollywood Plan is very general and will not have any impact to preserve “walkability” and neighborhood character.

According to the current Planning Code [Sec. 13.07 (B) (1)(2)], a P.O.D. requires that contiguous parcels be separated by streets and alleyways. This is typical for Santa Monica Blvd. In addition, at least two of the following criteria must be met:

a. The street must have a variety of commercial uses,
b. A majority of the buildings along the street must have a similar size and architectural design with windows and building interiors that enhance “pedestrian atmosphere”,
c. The street must have street furniture, outdoor restaurants, and open-air sales, which are integrated with public sidewalks.

Santa Monica Blvd. satisfies criteria “a” and “b” as follows:

1) Santa Monica Blvd. has a commercial corridor (Type II Hwy) with a variety of commercial uses. This is apparent with the numerous commercial structures.
2) The buildings have good fenestration with windows faced adjacent to the public’s right of way. Most commercial businesses do create a “pedestrian atmosphere” due to easy accessibility of foot traffic to the interior of the buildings.

The current Planning Code specifies that a P.O.D. can only be applied to lots having the following zoning designation: CR, C1, C1.5, C2, C4, and C5. Properties location along Santa Monica Blvd. are zoned “C2” and therefore satisfy this P.O.D. requirement.

According to the P.O.D. requirements (copy attached to this letter), the following criteria must also be met:

a. At least 75% of a building’s frontage on ground level must have entrances for pedestrians and windows that permit viewing of interior retail, office, and lobby areas,
b. Any parking area adjoining a Pedestrian Oriented Street must have a 3.5 ft. block wall separating the right of way from the parking area.
c. Building height not to exceed 40 feet.

Santa Monica Blvd. contains few strip shopping centers, built in the 1980’s with 3.5 ft. block walls separating the parking area from adjoining pedestrian right of ways. In addition, most buildings are single-story, have large, pane windows that allow pedestrians to view retail and/or office areas. Although there are buildings exceeding the 40-foot height limit, such buildings would be legal and nonconforming which is typical for most neighborhoods within the city of Los Angeles. The preceding requirements are therefore also satisfied with the existing configuration of the buildings within the corridor.

As required by the planning ordinance, a P.O.D. should include neighborhood retail and services. Santa Monica Blvd. currently has a wide variety of retail and neighborhood services as follows:

a. Major supermarket (Jon’s market)
b. Major bank (Kaiser Federal)
c. Major drug store (Rite Aid)
d. Barber shops
e. Numerous restaurants
f. Bakeries
g. Insurance and real estate services
h. Medical supplies
i. Dental and medical offices
j. The Cahuenga Library
k. Immaculate Heart of St. Mary Church
l. Two L.A.U.S. D. schools (Kingsley and Ramona elementary schools)
m. Photographic studio and supplies
n. Optician
o. Locksmith
p. Dry cleaner and laundromats
q. Copying services
r. “Mom and Pop” grocery stores and businesses

The Route 66 Task Force is working diligently in restoring Santa Monica Blvd. (Historic Route 66) in East Hollywood. It was recently awarded a $3,000 maintenance grant by the Los Angeles Neighborhood Initiative (LANI). Matching funds were allocated by the East Hollywood Neighborhood Council for “Route
66” signage and additional cleanups. LANI has agreed to write a Transportation Planning grant for March 2012. Metro has partnered with the Task Force for maintaining the bus stops within the corridor. U.C.L.A. urban design students have presented design interventions for Route 66. This revitalization project is
scheduled to proceed irrespective of any zoning change proposed by the Hollywood Community Plan. Therefore is it important to establish a Pedestrian Overlay District to assist in preserving the history of the corridor.


David Bell
East Hollywood Neighborhood Council, President.

Armen Makasjian
Route 66 Task Force, Chairman


General Plan Framework Element, Chapter 9:  2.  How will the City identify where, when, and how many improvements are needed for infrastructure and public service systems?
“Los Angeles needs consistent information concerning its infrastructure and
public service systems, for effective capital investing. The City therefore
needs to maintain up-to-date inventories of all its systems; computer models
capable of evaluating the impacts of proposed projects on City-owned
infrastructure; regular forecasts of each infrastructure system's needs, which
can be used to guide capital improvement decisions; trigger mechanisms that
can warn decision makers when and where future needs will occur; and
reporting systems that enable the City to update its models. All of this
information should be compiled in a Annual Report on Growth and
Infrastructure, which will provide City staff, the City Council, and service
providers with information that can facilitate the programming and funding of
improvements or making decisions when to take other actions.”

PARKS:  General Plan Framework Goal 9L Regarding Parks and Recreation: Sufficient and accessible parkland and recreation opportunities in every neighborhood of the City, which gives all residents the opportunity to enjoy green spaces, athletic activities, social activities, and passive recreation.

URBAN FOREST:  General Plan Framework Element Goal 9 regarding the Urban Forest:  A sustainable urban forest that contributes to overall quality of life.
Objective 9.41:  Ensure that the elements of urban forestry are included in planning and programming of infrastructure projects which involve modification.

General Plan Framework Element Goal 9P regarding Street Lighting:  Appropriate lighting required to (1) provide for nighttime vision, visibility, and safety needs on streets, sidewalks, parking lots, transportation, recreation, security, ornamental, and other outdoor locations; (2) provide appropriate and desirable regulation of architectural and informational lighting such as building facade lighting or advertising lighting; and (3) protect and preserve the nighttime environment, views, driver visibility, and otherwise minimize or prevent light pollution, light trespass, and glare.

General Plan Framework Element Goal 9M regarding Power:  A supply of electricity that is adequate to meet the needs of Los Angeles Department of Water and Power electric customers located within Los Angeles.
Objective 9.26:  Monitor and forecast the electricity power needs of Los Angeles'
residents, industries, and businesses.

General Plan Framework Goal 9D Regarding Solid Waste:  An integrated solid waste management system that maximizes source reduction and materials recovery and minimizes the amount of waste requiring disposal.

General Plan Framework Element Goal 9C regarding Water Supply:
Adequate water supply, storage facilities, and delivery system to serve the
needs of existing and future residents and businesses.
Objective 9.8: Monitor and forecast water demand based upon actual and predicted growth.

General Plan Framework Element Goal 9B regarding Stormwater:  A stormwater management program that minimizes flood hazards and protects water quality by employing watershed-based approaches that balance environmental, economic and engineering considerations.

General Plan Framework Element Goal 9A regarding Wastewater:  Adequate wastewater collection and treatment capacity for the City and in basins tributary to City-owned wastewater treatment facilities.

General Plan Framework Objective 9.15 regarding Emergency Services:
Provide for adequate public safety in emergency situations.

General Plan Framework Element Goal 9J regarding Fire Services:  Every neighborhood has the necessary level of fire protection service, emergency
medical service (EMS) and infrastructure.

General Plan Framework Element Object Objective 9.20 regarding Libraries:  Adopt a citywide library service standard by the year 2000.

PRIVATE TELECOMMUNICATIONS: General Plan Framework Element Objective 9.34 regarding Private Telecommunications:  Maintain the City's authority to regulate telecommunications in such a way as to ensure and safeguard the public interest.

PUBLIC EDUCATION:  General Plan Framework Element Goal 9N regarding Public Education:  Public schools that provide a quality education for all of the City's children, including those with special needs, and adequate school facilities to serve every neighborhood in the City so that students have an opportunity to attend school in their neighborhoods.


FLAW 1)  IMPROPER SEQUENCING:  To meet the State of California requirements of General Plan timeliness and comprehensiveness, an accurate update of a locally focused Community Plan must be based on a city’s General Plan, or in the case of Los Angeles, the citywide General Plan Framework Element, adopted in 1996.  This document, the backbone of the Los Angeles General Plan, should be totally revised and updated based on current demographic and infrastructure data.  Only when this essential and overdue planning process is completed, should the General Plan’s Land Use element, Los Angeles’s 35 local Community Plans, including Hollywood, be updated, based on the same demographic and infrastructure data bases utilized to update the General Plan Framework Element.  But, at this point, to implement an outdated General Plan – which essentially expired in 2010 -- at the local level, much less with different base and horizon years, defies both State of California planning guidelines, professional standards, and common sense. 

After all, changes in local conditions are part of a mosaic, which when completed, must replicate the most current and accurate version of the citywide General Plan.  If either is out-of-date, this is impossible, and there is no way to locate, on a citywide basis, the locations mostly like to have the best combination of likely population growth with sufficient zoning and secured funding for adequate infrastructure capacity and public services. 

This is the reason why California cities are required to have General Plans prior to local plans and local implementation ordinances.

If at all possible, the Alternate Vision would only be finalized when the Update of the General Plan Framework Element was prepared and adopted.

FLAW 2)  FAILURE TO BE CONSISTENT WITH THE GENERAL PLAN FRAMEWORK ELEMENT:  To comply with State of California planning codes and Los Angeles City Charter requirements, the Update of the Hollywood Community Plan must be consistent with the General Plan Framework Element.  Consistency between these plans is, therefore, required and unavoidable.  This is clearly spelled out in Los Angeles City Charter Sections 556 and 558.

Description: ookmarkLos Angeles City Charter Section 556.  General Plan Compliance.

     When approving any matter listed in Section 558, the City Planning Commission and the Council shall make findings showing that the action is in substantial conformance with the purposes, intent and provisions of the General Plan.  If the Council does not adopt the City Planning Commission’s findings and recommendations, the Council shall make its own findings.

Description: ookmarkLos Angeles City Charter Section 558.  Procedure for Adoption, Amendment or Repeal of Certain Ordinances, Orders and Resolutions.

     (a)     The requirements of this section shall apply to the adoption, amendment or repeal of ordinances, orders or resolutions by the Council concerning:
     (1)    the creation or change of any zones or districts for the purpose of regulating the use of land;
      (2)       zoning or other land use regulations concerning permissible uses, height, density, bulk, location or use of buildings or structures, size of yards, open space, setbacks, building line requirements, and other similar requirements, including specific plan ordinances;
     (3)        private street regulations;
     (4)        public projects.   

Nevertheless, despite this City Charter requirement, the Proposed Update turns the General Plan Framework Element on its head.   Even though the Framework is explicitly growth neutral, the Proposed Update’s implementation program of extensive up-zoning and up-planning is growth inducing and unabashedly presented as so.  Its purpose is to promote large real estate projects that are claimed to meet secondary Framework goals, in particular transit use and housing.  This is an approach that mocks LA's growth neutral General Plan Framework Element and in no way is consistent with its purposes, intent, and provisions.  According to the General Plan, the purpose of transit is to meet the mobility needs of the public, at present and during the life of the plan, for the Framework from 1990 to 2010, and for the Proposed Update, between 2005 and 2030.  Instead the Proposed Update offers a zoning and planning program to dramatically increase density in Hollywood with the express purpose of locating more people near transit lines, to, presumably, increase transit ridership.  This approach clearly conflicts with the intent and purposes of the General Plan.  Based on its growth neutral approach, transit should serve real and likely mobility needs.  It should not be used as a pretext for real estate speculators to build large new building in profitable locations that happen to be near subway stations and bus stops. 

In the case of housing, the arguments for increasing density through zone changes and General Plan amendments in order to meet General Plan Framework Element goals is even flimsier and more contradictory.  The rationale is that Hollywood will have a population boom during the 20-year life of the plan, and new housing is necessary to meet the demands of that future population.  This is in stark contrast to reality, in which existing market rate housing in Hollywood continues to have high vacancy rates. The construction of even more market rate housing – with a few units set aside for low-income tenants -- is intended lure people to the community.  This housing is not being constructed to meet the unmet housing needs of existing residents, which only applies to low-income individuals and families priced out of market housing.  Instead, the purpose is to attract new, better off tenants into the new, by-right apartment and condo buildings encouraged by the Proposed Update and permitted by its extensive zoning ordinances and General Plan amendments.

The Los Angeles City Charter, Section 556 and 558, excerpted above, requires that all plan amendments and zone changes must be consistent with the City’s General Plan, even if its horizon year has already been reached.  This translates into consistency with the methodology and policies of the General Plan Framework Element, despite the weakness of its data. 

The General Plan Framework Element was adopted in 1995-6 and is clearly growth neutral, based on the finding that existing General Plan designations and existing zones could support a citywide population in Los Angeles of 8 million people. 

This theme is repeated throughout the Framework, such as in:  ___________              

This objective of growth neutrality means that the city’s population could be doubled without any increase in underlying densities.  What is required, instead, is the steady, upgrading of public infrastructure and public services to meet the changing needs of this growing population.  In this approach, zoning, which is already sufficient for all growth scenarios, is not the critical variable.  Instead, infrastructure and services are critical because of increases in user demand resulting from both local population growth, as well as growing number of employees, visitors, and pass through traffic in Hollywood.

In rare cases, however, where population growth has exceeded locally permitted zoned capacities, the Framework would allow local increases in density through Zone Changes and, when necessary, also General Plan Amendments.  For these legislative actions to occur, the applicant, whether the City or a private party, would need to demonstrate a minimum of three thresholds:

1.    The build out capacity of a local area based on the full utilization of adopted zones and General Plan land use designations has been reached.

2.    The local area’s population is overcrowded, and there is no more remaining private land that could be developed to meet their needs for housing and employment.

3.    The local area has and will continue to have sufficient, carefully monitored public infrastructure and public services to meet the housing and employment needs of the current and anticipated population.
Despite this clear requirement, the Proposed Update’s Final Environmental Impact Report (FEIR) does not present a planning rationale for the Proposed Update’s 105 pages of up-planning, up-zoning, and changes in Height Districts, consistent with the "growth neutrality" theme of the General Plan Framework Element.  Los Angeles, according to the General Plan Framework, has enormous untapped capacity for population and housing growth based on the legally adopted plan designations and zones that existed when the Framework was prepared and adopted in the mid-1990s.  Since then, Hollywood has modest increases in zoned capacity through discretionary actions. To exceed these expanded local densities in the Hollywood Community Plan are, the Department of City Planning would, therefore, need to present a clear demonstration of documented increases in population growth and housing demand that have exceeded Hollywood’s expanded build-out capacity. 
This is a substantial requirement; yet the Proposed Update does not present a calculation or an analysis of the remaining build out capacity of the privately zoned parcels in the Hollywood Community Plan area.  It also fails to demonstrate that these private parcels do not have enough undeveloped capacity to meet the future housing and employment needs of the population they project by 2030 in Hollywood. 
This is the exact approach of the General Plan Framework Element, and for the Proposed Plan to be consistent with the Framework, which is required by the Los Angeles City Charter, it must follow the Framework’s methodology.  This is not an optional requirement.  Until the Charter is amended, it is mandatory.

FLAW 4)   VIOLATION OF TIMELY REQUIREMENT OF STATE OF CALIFORNIA GENERAL PLAN GUIDELINES:  The Proposed Update of the Hollywood Community Plan ignores 2010 census date, and, instead, is based on outdated census data from previous decades.  As a result, it does not meet the State of California’s legal requirement that all planning documents be timely.  California State planning laws and guidelines require General Plans, including their land use elements (e.g., the Hollywood Community Plan) to be current and internally consistent among their required and optional elements.  In this case the General Plan Framework Element was based on 1990 census data.  This data, was in turn, was extrapolated to the Framework’s 2010 horizon year.  When these forecasts were compared to real 2010 data, they were substantially higher, by about 12 percent or 400,000 people. The Update of the Hollywood Community Plan is supposed to apply the Framework to local communities, but it is based on year 2000 census data, augmented by a 2005 “guestimate,” and then extended to the year 2030 based on long-term trend data rooted in LA’s boom decades of the 1970s and 1980s.   

The two plans – the General Plan Framework Element and the Hollywood Community Plan Update -- are not only inconsistent with each other, but neither is based on current census data.   The new 2010 census data has been available for over one year and should have been used for all plan reviews and updates, including the General Plan Framework Element, the General Plan Land Use Element (i.e., Los Angeles’s 35 Community Plans, including Hollywood), and for related implementation ordinances.  It also should have been used for long neglected General Plan monitoring of the demographic and infrastructure trends that shape the General Plan.

If 2010 census data had been used for the Hollywood Community Plan, including its DEIR and FEIR, they would have demonstrated that Hollywood had a serious population decline from 2000 to 2010 of about 15,000 people, on top of a slightly declining population between 1990-2000.  This means that the Framework’s original projects, as well as 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 preparing a Community Plan Update with a horizon year of 2030.

Had more realistic trend data, based on the past two stagnant decades, been used to update both the Framework and the Hollywood Community Plan, there would have been no extravagant claims of burgeoning population growth in Hollywood.  At best, there would be extremely modest growth, and at worse, the significant population decline from 1990 to 2010 would be extended for twenty more years, resulting in major population loss, not gain, in Hollywood.

Nevertheless, even if these outdated and inflated population numbers were accepted for a planning exercise, such as a DEIR scenario, there is absolutely no evidence in the Proposed Update or its support documents that Hollywood’s existing General Plan designations and zones are not capable of meeting the inflated population’s needs for housing and employment at any point in the plan’s 2005 – 2030 time period.

FLAW 5)   FAILURE TO MONITOR INFRASTRUCTURE:  According to the Proposed Update’s Final Environmental Impact Report, most categories of public infrastructure and services are not capable of meeting the needs of the residents, employees, and customers that the Proposed Plan hopes to attract to Hollywood through its program of up-zoning and up-planning.  These astounding revelations of a future low-amenity Hollywood are not surprising considering that citywide concerns over public services and infrastructure are barely detectable at City Hall.  For example, the City of Los Angeles, in particular the Department of City Planning, despite state and local mandates, has not monitored local public services or infrastructure construction and maintenance since 1999.  Changes in the intervening 12 years, which could be dramatic in an era of budget cutbacks, are unknown, but nevertheless set the context for the Proposed Update of the Hollywood Community Plan.

Furthermore, in some categories, there has been no formal planning for public infrastructure in Los Angeles through the General Plan process in over 45 years.  The adopted General Plan Elements addressing infrastructure were prepared and adopted in the late 1960s.  In the intervening decades they have not been updated, replaced, or rescinded.  They have, however, been ignored, even though EIRs, such as that for the Proposed Update, concede that the city’s infrastructure cannot handle existing user demand, much less the anticipated demands of the larger population resulting from extensive up-planning and up-zoning in Hollywood ushering in extensive by-right construction. 

According to the General Plan Framework Element, there should be no increases in permitted density without adequate public services and infrastructure.  Furthermore, there does not appear to be any proposal in the FEIR or the Proposed Update to monitor local public services or infrastructure conditions, including changes in demographics and related user demand, as well as the effectiveness of the updated Plan's policies and programs.  Considering that the Proposed Update’s FEIR’s Statement of Overriding Considerations adopted by the City Planning Commissions is clear that Proposed Update will overwhelm the following environmental categories: public services, utilities, water resources, transportation, air quality (including construction and emission of greenhouse gases), noise, and cultural resources, these are astounding predictions of a low amenity future.  Few Hollywood residents will accept the reduced quality of life in Hollywood resulting from the Update, even in the unlikely case that the promised jobs and transit ridership appear.  To not even monitor these categories, as well as the other categories that the FEIR asserts will be mitigated, such as emergency services, is an extraordinary lapse in responsible local municipal governance. 

This is why the Proposed Plan is based on a combination of low amenities and low regulation.