PLATKIN ON PLANNING-LA’s Council District 5 requested that a large group of its constituents – representing the neighborhood councils, resident associations, HPOZ boards, homeowner associations, and neighborhood associations impacted by and opposed to the proposed Purple Line Extension “transit neighborhood plan” -- write up their concerns and offer an alternative proposal. The following is this collective work in draft form. Comments are appreciated.
Why your constituents want the current Purple Line Extension Transit Neighborhood Plan (TNP) and its Draft Environmental Impact Report (DEIR) incorporated into the impending update of the Wilshire Community Plan.
- This Update will begin in 2021 and conclude in 2023, the same year that the subway opens.
- City Planning is using the Purple Line Extension as a pretext to increase the height, size, and density of privately-owned properties zoned for apartments and commercial uses in the neighborhoods surrounding the Purple Line Extension subway stations.
- We believe the proposed Crenshaw Line North Extension will be used in the same way, as an excuse to up-zone commercial and multi-residential parcels.
- Any community planning process that addresses transit and land use must link existing and proposed transit services to commercial, residential, public buildings, open space land use categories, as well as to all supporting infrastructure categories. This is why City Planning’s Transit Neighborhood Planning process for the Purple Line Extension is fundamentally flawed. Among its many shortcomings, it neglected to initially consider the adverse impacts (e.g., dislocation and toxic air pollution) of densified mass transit corridors on surrounding communities. This is why we are calling for the current, flawed process to be folded into the update of the Wilshire Community Plan.
- Transit Neighborhood Plans must be based on California’s mandatory Complete Streets law, City Planning’s Mobility Hubs and Complete Streets Manual, and METRO’s First-Last Mile Strategic Plan. Unlike the proposed Purple Line Extension TNP, which does not include any public improvements, such as streetscape, local neighborhoods urgently need their sidewalks repaired and upgrading, missing shade trees planted and maintained, and coordinated street furniture, bicycle infrastructure, bus shelters, kiss ‘n ride, park ‘n ride, and better street lighting installed.
- Neighborhood input is an essential part of the planning process, and in the case of the Purple Line Extension Transit Neighborhood Plan, it was ignored, even though the TNP proposal would substantially up-zone the western section of Wilshire Community Plan. Had it been obtained the Department of City Planning would have learned that the TNP’s upzoning proposals would displace existing residents and small businesses.
- Despite City Planning’s claims of broad outreach, no local planning-related groups played any role in the plan's preparation, which was first presented in City Planning’s 2013 grant application to METRO. This is why City Planning’s two alternative up-zoning proposals, publicly presented for the first time at a July 26, 2018, open house, completely blindsided local groups. No one knew about these proposals or City Planning’s previous November 2017 open house, from which they used misleading public comments submitted to them by developers and their lobbying groups to justify an even more intensive up-zoning scheme.
- In our neighborhoods, new developments based on existing zoning have already displaced rent stabilized apartment units and older single-family homes. These recent projects have replaced them with expensive houses and apartments that current residents cannot afford, while also reducing the quality of life in adjacent and surrounding neighborhoods.
- The San Vicente/Pico, Fairfax, Wilshire, and LaBrea corridors that comprise the greater Miracle Mile TNP study area do not have sufficient infrastructure, public services, or community support to become high density, luxury neighborhoods, such as Downtown Los Angeles.
City Planning’s claims that upzoning will produce transit-oriented, affordable apartments are not remotely credible.
- New residential developments in the TNP area and the surrounding DEIR study area, even when based on existing zoning, are already expensive, in the range of $2,500 to $4,000 per month for a one-bedroom unit. New apartments, priced similarly or even higher, will be rented to high-income tenants who drive cars and seldom use transit.
- Because the TNP grants developers unconditional increases in parcel-level building height, size, and density – along with unspecified reductions in parking requirements -- developers will no longer need SB 1818 and TOC density bonuses to obtain these entitlements. They will be an up-front, TNP-based tax-free gift to real estate investors from the City Council.
- If City Planning were truly interested in increasing the supply of affordable, transit-oriented rental units near mid-city bus and subway lines, it would down-zone, not up-zone parcels near transit. This would force developers to voluntarily include affordable rental units in their buildings in order to obtain additional height, building mass, density, and/or reduced parking.
No data exists forecasting a population boom or shortage of developable land in the Wilshire Community Plan or its Transit Neighborhood Plan sub-area.
- The TNP area’s existing zoning has permitted many new, by-right commercial and residential high-rise buildings over the past two decades.
- This is an intended consequence of the 389-page upzoning ordinance that the Department of City Planning appended to the Wilshire Community Plan and the City Council adopted in 2002.
- If the Wilshire Community Plan’s existing zoning were fully developed (i.e., build-out) through additional by-right real state projects, the plan area’s population would reach 573,000 people. If these projects then incorporated SB 1818 or TOC density bonuses, plus Accessory Dwelling Units, the buildout population would be 770,000 people – twice the number of people that SCAG predicted for this plan area.
- According to City Planning’s most recent population estimate, the Wilshire Community Plan area had 287,000 people in 2014. In contrast, the area’s most optimistic population forecast, SCAG’s forecast for the year 2010, the Wilshire Community Plan area would eventually reach 337,000 people.
- These data reveal that all real estate development and population scenarios can be met by existing zoning. In fact, this zoning is already producing the new commercial and residential buildings that the TNP planners claim would only appear through up-zoning.
- The real barrier to future growth in the TNP area is not existing zoning, but inadequate public services and infrastructure. Because of deferred maintenance, it is already failing at existing population levels.
City Planning’s efforts to jam through this ambitious up-zoning scheme, using two new Purple Line subway stations as an excuse, have galvanized all local communities and thousands of their residents.
- One local civic organization, the PICO Neighborhood Council, was, like other local groups, excluded from public participation, but nevertheless organized a large public meeting with City Planning in late September 2018. There was a standing room only crowd at this meeting, all local residents who opposed the Purple Line Transit Neighborhood Plan.
- These are some of the reasons they opposed the TNP:
- Lack of public outreach.
- Frequent power outages and bursting water mains.
- Insufficient police and emergency personnel and services.
- Harmful impacts of large new buildings on fragile surrounding neighborhoods and existing businesses.
- Displacement of teachers, nurses, office workers, and other middle class, working class , and fixed-income residents.
- Congested streets are already at gridlock, particularly Fairfax Avenue.
- Lack of municipal accountability, based on tracking and monitoring, to determine the impacts of proposed plans, like the TNP.
Conclusion: City Council Districts 4, 5, and 10 must make it clear to the Department of City Planning that this planning debacle should be deferred until all transit projects in this area can be properly planned through the forthcoming update of the Wilshire Community Plan. Until this happens:
- The proposed Purple Line Extension Transit Neighborhood Plan (TNP) will have no relationship to transit because it does not contain any transit-related public improvements.
- The TNP will have no connection to local neighborhoods because they were excluded from its rigged public participation process.
- Finally, the TNP will have no relationship to planning because the ordinances that would adopt and implement it precede and remain separate from the forthcoming update of the Wilshire Community Plan.
(Dick Platkin is a former Los Angeles city planner who reports on local planning controversies for City Watch. Please send any questions or corrections to email@example.com.) Prepped for CityWatch by Linda Abrams.