PLATKIN ON PLANNING-Just when you think a stake has been driven through the heart of another Los Angeles real estate scam, LA City Planning is resurrecting its Purple Line Extension “transit neighborhood plan” (TNP).
They are trying, once more, to craft a convoluted specific plan that would permit even larger, taller, un-planned luxury high-rise buildings in the Miracle Mile and Beverly-Fairfax neighborhoods.(Photo above: Wilshire Boulevard’s Miracle Mile corridor. Existing zoning is creating another Century City.)
Their heroic effort to keep the TNP out of the morgue must overcome a series of political and technical barriers:
- METRO long ago wiped its hands clean of this scheme, and the TNP does not appear on any METRO websites.
- The TNP project has been stalled for several years. Funding began in 2013, followed by public meetings in 2016, 2017 2018, and 2019, yet the project’s details remain a mystery.
- The TNP is either unsupported or openly opposed by all local Neighborhood Councils and resident associations.
- In July 2018 City Planning initiated an Environmental Impact Report (EIR) for its vague TNP concept. A year later City Planning has maintained an oath of silence about this premature EIR. If any work has begun, it is in secret.
- No City Council office has publicly supported this project, and one Councilmember, David Ryu, actively opposes it.
- In April 2019 David Ryu sent a devastating letter to the Director of Planning criticizing this project. To adequately respond to his multiple concerns, METRO’s Purple Line Extension subway stations and City Planning’s Transit Neighborhood Plan would need complete revamping.
- The Director of Planning has not yet publicly responded to David Ryu’s letter.
Despite these barriers, City Planning is valiantly, though clumsily, keeping this duplicitous project on life support. Since City Planning’s false claim that “METRO is demanding that City Planning quickly complete this project ahead of the impending Update of the Wilshire Community Plan” was easily exposed as a lie, City Hall’s fallback position was hiring a TNP consultant to organize several “outreach” meetings and prepare a community survey. Some City Hall naïf imagined that a few public presentations and a rigged questionnaire could salvage the TNP from heaven’s gate. But this latest rescue operation suffers from four fatal blunders:
The first blunder was the consultant’s survey. It consisted of leading questions that excluded basic information about the Purple Line Extension study area, such as its remaining zoning capacity; failing infrastructure; vacancy rates; and ridership, population, and construction trends.
The second blunder was that the survey ignored previous public input about the same TNP area. Because these prior public comments were open-ended, they were authentic, not an artifice of leading questions.
The third blunder was the survey’s microscopic response rate of 0.7 percent (.007). Of 45,500 people contacted, only 308 people responded, and 60 percent of these respondents lived outside the TNP area. Presumably, most of these respondents were linked to Abundant Housing, a real estate lobbying group committed to unplanned and unmonitored up-zoning near future transit lines.
The fourth blunder was the survey’s failure to answer Councilmember David Ryu’s five-page letter to the Director of Planning, dated April 22, 2019, which presented the Councilmember’s detailed critique of the TNP project:
Criticisms raised in David Ryu’s letter to the Director of Planning:
- The TNP should create substantial affordable housing for extremely low income to the working middle class. New housing must serve the neediest, including seniors, families that cannot afford market housing, and workforce housing.
- The TNP must add residential units without adding congestion since most new residents will continue to use cars instead of switching to transit.
- A specific plan that results in new luxury towers with large box store commercial ground floor, where high income tenants rely on a mixture of ride sharing and street parking, will do nothing to reduce per capita Vehicle Mile Traveled (VMT) in the area.
- Broad corridor improvements and the subway stations’ designs must offer alternative transit options, upgraded public and private infrastructure, bicycle and e-scooter docking and storage facilities at METRO stations, and station pick-up and drop-off areas for cars, ride-sharing vehicles, and busses. (I would add parking structures to David Ryu’s list.)
- TNP pedestrian areas (e.g., sidewalks on Wilshire, San Vicente, Fairfax, and LaBrea) require ADA accommodations, trees, shade, landscaped green spaces, ground floor public open spaces, street level agriculture, day care, and community centers. (I would add bus shelters, improved street and sidewalk lighting, and extensive sidewalk repaving.)
- The TNP must guarantee that all residents, including those who currently live in nearby residential areas, receive reliable electricity and emergency services.
- The Transit Neighborhood Plan’s zone changes should ensure that current residents in Rent Stabilized apartments are not displaced.
- These same zone changes should not replace Transit Oriented Communities (TOC) bonuses now required to enlarge new residential projects.
- Existing vacancy rates for residential and commercial buildings must be determined and analyzed.
- New buildings should be held to higher environmental standards to reduce their carbon footprint and load on the electric grid.
- The existing Wilshire Community Plan must guide changes in the TNP area, including its potential for further growth through new, by-right residential units, as well as additional density through Accessory Dwelling Units and Transit Oriented Community (TOC) density bonuses.
- The TNP must be closely coordinated with the forthcoming Update of the Wilshire Community Plan, to assure that there will not be two concurrent but separate community planning efforts.
Would the TNP produce “more housing” through its upzoning schemes?
The planning philosophy guiding the Transit Neighborhood Plan is trickle down economics. It is inspired by the market fundamentalism of Ayn Rand and the deregulation of government programs during the Reagan and Clinton administrations. Therefore, we need to ask: if the City Council eventually adopts the Transit Neighborhood Plan, would its program of extensive upzoning result in increased transit ridership, an enhanced built environment, and new housing on transit corridors? Or would this upzoning compound LA’s existing crises?
My answer is the latter. The TNP is a complete boondoggle, and it will compound LA’s multiple crisis unless it is completely reworked, beginning with David Ryu’s detailed critique. It the TNP were completely transformed, it might work as intended. But, if its elaborate zone changes were conditionally approved and then subjected to rigorous annual monitoring to verify their promised outcomes of increased transit ridership and additional affordable housing, the Specific Plan would be quickly repealed. This is why:
Housing production depends on many factors other than zoning, such as the business cycle, consumer demand, profitability, interest rates, tax laws, availability of cheap capital, vacancy rates, code enforcement, and the whims of global investors. They, after all, must decide among thousands of investment alternatives to building even more expensive housing in the already over-built Miracle Mile area.
As a result, there is no guarantee that adopting new zoning laws that allow taller, larger, denser buildings in the TNP area would make a difference. After all, this area’s neighborhoods already have extremely generous zoning laws, and the Wilshire Corridor is becoming another Century City without the TNP’s zone changes. Furthermore, the TNP area is filled with new, pricey apartment buildings, and they all post “For Lease” signs to fill their vacant rental units. This is a red flag that the TNP’s upscale housing market has run out of upscale tenants and that landlords are playing a waiting game. For now they are holding on, in the hopes that can attract more well off tenants, or, as a back up, discreetly fill their empty units through Airbnb and short-term leases.
If the TNP’s upzoning did somehow produce “more housing,” we can already predict three outcomes:
Outcome #1 – Failing infrastructure. The new housing would tax the area’s frayed public infrastructure and services to the breaking point. Existing levels of new construction, whether McMansions, apartments, and commercial buildings, have already changed the character and scale of the Greater Miracle Mile area, and undergrounded and aboveground utilities are failing. This area has frequent electric blackouts and water main breaks. The LADWP is playing an endless and game of catch-up, and even more unplanned real estate development would make this bad situation worse.
Outcome #2 - Disasters. This slow and steady failure of local infrastructure would become a torrent when the “big one,” a large San Andreas Fault earthquake, finally occurs. At that point, the area’s old infrastructure would collapse. All those overhead electrical and telecommunications cables will sway, arc, and then snap. The undergrounded electric, gas, water, sewer, and storm drain conduits will break, leaving Los Angeles paralyzed, while most fires will be left to burn out because of low water pressure and buckled streets blocking fire engines.
Outcome #3 – Expensive, car-oriented apartments. If the TNP’s upzoning does result in additional apartment buildings, these units will be expensive and car-oriented. The new residents will be no different than current residents living in similar, recently constructed, up-scale apartments. These tenants will be well off, and nearly all of them will own and drive cars, seldom taking nearby bus lines.
When the Purple Line Extension opens in 2023, these new tenants will resemble the affluent tenants currently living in DTLA, Koreatown, Hollywood, and North Hollywood, close to
Above: Granada Hills street after 1994 Northridge earthquake.
METRO’s Red Line subway. They will rarely take the adjacent subway, instead relying on their cars or ride-sharing services for transportation.
But, while the above is likely to happen, we know one certainty about the TNP. Its broad upzoning sharply increases property values. If the City Council adopts the TNP, it would hand over many millions in untaxed gifts to property owners. As soon as these property owners sold their suddenly more valuable property, their paper profits would become real profits, taxed at embarrassing low 2018 capital gain rates, not the higher income tax rates of their tenants.
This is the key to understanding the nine lives of the Purple Line TNP. The possibility of flipping up-zoned properties for barely taxed capital gains, or, in a few cases, building lucrative high-rise residential towers, keeps this boondoggle alive. The job of residents committed to good planning is to expose this real estate scam and ensure that our elected officials represent their constituents, not the capital gains crowd and their City Hall lobbyists.
(Dick Platkin is a former Los Angeles city planner, who reports on local planning controversies for CityWatch. He serves on the board of United Neighborhood for Los Angeles (UN4LA) and welcomes comments and corrections at firstname.lastname@example.org. Prepped for CityWatch by Linda Abrams.