Hollywood Community Plan - Alternative Vision
HOLLYWOOD COMMUNITY PLAN UPDATE – ALTERNATIVE VISION
June 19, 2012
Case Number: CPC-2005-6082-CPU
CPC-19967-43-CPU
ENV-2005-2158-EIR
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
Appendix 1: EXISTING PLAN DESIGNATIONS IN HOLLYWOOD 11
Appendix 2: GENERAL PLAN
FRAMEWORK PROPOSED CENTERS 12
IN HOLLYWOOD
Appendix 3: MATRIX OF
CHANGES TO ZONES, HEIGHT DISTRICTS, 13
AND PLAN DESIGNATIONS
Appendix 4: PEDESTRIAN ORIENTED DISTRICT ON SANTA 14
MONICA BOULEVARD
Appendix 5: GENERAL PLAN FRAMEWORK POLICIES
RELEVANT 17
TO THE UPDATE
Appendix 6: METHODOLOGICAL FLAWS OF PROPOSED PLAN 19
PREPARED BY THE DEPARTMENT
OF CITY PLANNING
AND APPROVED BY THE CITY
PLANNING COMMISSION
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.
INTRODUCTION TO THE
ALTERNATIVE VISION
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.
PRINCIPLES OF THE ALTERNATIVE VISION
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:
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.
IMPLEMENTATION OF 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.
CREDENTIALS:
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.
Appendix 1: MAP OF EXISTING PLAN DESIGNATIONS IN
HOLLYWOOD
Note:
The land use map of the existing plan designations in Hollywood would be
amended to reflect the zoning changes in Appendix 3.
Appendix 2: GENERAL PLAN FRAMEWORK PROPOSED CENTERS IN
HOLLYWOOD
Appendix 3: MATRIX
OF CHANGES TO ZONES, HEIGHT DISTRICTS, AND PLAN DESIGNATIONS
Location
|
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
|
RD1.5XL
|
-
Dissolution of Community Redevelopment Agency.
-
Lack of supportive infrastructure and services.
|
Area between
Melrose Avenue, Gower Street, and Santa Monica Boulevard
|
R3-1XL, R4
|
RD1.5-1XL
|
Commercial uses
permitted by current zoning are not compatible with existing community.
|
Virgil between
Fountain Avenue and Santa Monica Boulevard
|
R4
|
R2
|
Reverse land use
changes implemented through SNAP to up-zone these areas.
|
Santa Monica
Boulevard Corridor
|
C2
|
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.
|
Appendix 4: PEDESTRIAN ORIENTED DISTRICT ON SANTA MONICA
BOULEVARD
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
façade 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.
Cordially,
David
Bell
East
Hollywood Neighborhood Council, President.
Armen
Makasjian
Route 66
Task Force, Chairman
Appendix 5: GENERAL PLAN FRAMEWORK POLICIES RELEVANT TO
THE UPDATE
PUBLIC
INFRASTRUCTURE AND PUBLIC SERVICES:
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.
PUBLIC
UTILITIES AND RELATED INFRASTRUCTURE:
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.
APPENDIX 6: METHODOLOGICAL FLAWS OF PROPOSED PLAN
PREPARED BY THE DEPARTMENT OF CITY PLANNING AND APPROVED BY THE CITY PLANNING
COMMISSION
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.
Los 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.
Los 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.
FLAW 3) THE PROPOSED UPDATED FAILED TO CALCULATE
BUILD-OUT:
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.
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