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Are LA’s Community Plan Updates Ready for “Unexpected” Bumps in the Road?


PLATKIN ON PLANNING--In their forced march to promote large, speculative real estate projects, LA’s elected and appointed officials have committed themselves to update LA’s 35 community plans over the next decade. Their public argument is quite simple; the Community Plans are old, and therefore need to be brought up-do-date, by which they mean increasing by-right density through elaborate zone changes and General Plan Amendments. 

But, as they are about to discover, this public argument does not hold much water because the only serious flaw of these older plans is their exaggerated population numbers. Like the General Plan Framework, these plans vastly overestimate LA’s population. LA’s population has hardly grown since the City Council adopted the Community Plans 15 to 20 years ago. And, some communities, like Hollywood and Wilshire, have actually lost population during the past two decades. This, then, creates a conundrum for City Hall’s density hawks. How can they justify vast programs to increase density in local communities when their rationale, population growth, has not panned out? 

One option, used for the Hollywood Plan, was to resort to old census data and SCAG population forecasts that foster the illusion of extensive future population growth. But this statistical illusion did not last long. It was quickly spotted by Superior Court Judge Alan Goodman, who summarily rejected the entire Hollywood Community Plan Update, including its text, maps, EIR, and land use ordinances. 

The other option, hardly any different from the one already overruled by Judge Goodman, is to cite newer SCAG data that points to the same dubious conclusion: hordes of newcomers to Los Angeles will soon need housing, so the City Council must now loosen up local zoning and plan designations. Once they do so, private investors will then rush into Los Angeles to build market housing for these newcomers. Voila. Problem solved by market forces (with support from well-treated friends in high places). 

Based on my review of a typical older plan, the Wilshire Community Plan, which regulates my Beverly Grove neighborhood, updates are a serious undertaking, not a hasty effort to create a windfall for commercial property owners. While each community plan is only 1/35 of Los Angeles, in size and complexity these plan areas are the equivalent of a medium-sized city. 

Furthermore, when City Planning takes out the time to carefully read the existing Community Plans, such as the Wilshire plan, they should gird themselves for some major bumps in the road. It will not be that easy to touch up the existing plan maps and texts in order to quickly leap frog to the real goal: appending extensive up-zoning and up-planning ordinances to each slap-dash Community Plan Update. 

So what are these bumps in the road? 

Bump #1 is Sequencing and Consistency. Depending on which side of their mouth you are listening to, City Hall officials say they only want to update the Community Plans, or they will simultaneously update the Community Plans and the other mandatory and optional elements of the General Plan. Once underway, they might stumble on this section of the existing Wilshire Plan, “Since state law requires that the General Plan have internal consistency, the Wilshire Community Plan must be consistent with the other elements and components of the General Plan.” 

If followed, this means that all elements of the General Plan must be based on the same population data; same demographic forecasts; and the same goals, policies, and programs. If some elements remain subject to inflated population numbers, while other elements have realistic demographic forecasts, Los Angeles’ General Plan would be inconsistent. The City would continue to be in violation of State of California planning laws.

So far, City Hall has not offered the third and most professional alternative; first update the General Plan’s citywide elements to obtain the big picture of Los Angeles over the next several decades before turning to local plans. If this option does not appear on its own, then the Neighborhood Integrity Initiative may mandate this serious bump in the road.  

Bump #2 is Accurate Forecasting: While SCAG can always be relied upon to conger up inflated population numbers, this is confounded by other factors. One such factor is actual population trends. For example, City Planning’s own data for the Wilshire Plan in 2015 indicate that it dropped about 2000 people since the Plan’s adoption in the year 2000. City Planning’s data also indicate that in 2015 Wilshire’s population was 45,000 people less than the Plan originally forecast for its 2010 horizon year. 

Bump #3 is Monitoring: Like the General Plan Framework, the Community Plans require clear monitoring programs that are intended to carefully guide the implementation of the plan. This section of the Wilshire Community Plan is typical: “In the fifth year following plan adoption and in every five years thereafter, the Director of Planning shall report to the Commission on the relationship between population, employment, housing growth, and plan capacities. If growth has occurred faster than projected, a revised environmental impact analysis will be prepared and appropriate changes recommended to the community plan. The plan and zoning changes shall be submitted to the Planning Commission, Mayor, and City Council as specified in the Los Angeles Municipal Code.” 

Although the Wilshire Community Plan is now over 15 years old, City Planning has never monitored it. If or when this were to happen, it is clear from this provision that the City Planning Commission should recommend up-zoning or even down-zoning to respond to changes, whether up or down, in population, employment, housing, and plan capacities. 

Bump #3 is Infrastructure: Community Plans include far more than the private parcels that City Hall aims to densify. They also include parks, schools and other public buildings, streets, driveways, parkways, sidewalks, power line easements, and open space. This is where public infrastructure is located, which is why Community Plans include data and policies for public infrastructure and services. At the same time the plans also should consider user demand for these same public services and infrastructure. Finally, according to the General Plan Framework, the Community Plans need to demonstrate that there is sufficient infrastructure and services, based on funded maintenance programs, to serve both the existing population and to accommodate future growth if or when it occurs. 

Bump #4 is Calculating Buildout: In order to make a convincing case that Los Angeles as a whole, or specific communities, like the Wilshire Plan area, have insufficient zoning to accommodate population growth, City Planning must calculate the potential build out of all local existing residential zones. This is not exactly a profound insight; it is just common sense, as well as standard city planning practice. 

Luckily, City Planning has already calculated residential build out several times. At the end of the AB 283 Zoning Consistency Program, in the early 1990s, City Planning staff determined that Los Angeles contained enough available zoning to absorb five million more people. 

Several years later, the consultants for the General Plan Framework Element and the Framework EIR reached the same conclusion in their background reports. They concluded that LA’s existing zoning – as of the mid-1990s -- could support a city of 8,000,000 people. The Framework’s text also noted that Los Angeles had enough commercially zoned parcels to accommodate all growth scenarios throughout the entire 21st century. 

Since the Framework’s population forecasts were 500,000 people higher than actual population in 2010, this indicates that Los Angeles has an extensive amount of existing but underutilized zoning. There is no evidence to indicate that this situation has changed over the past two decades. 

In the years since City Planning prepared these studies, I am also unaware of any subsequent zoning build out calculations, although current City Planning staff maintain that existing zoning could only accommodate 1,000,000 more residents. 

Clearly, there is a profound difference between zoning build out producing a city of 4,900,000 people or a city of 8,000,000 people. While both hypothetical cities are much larger than the LA of 2016, it is imperative that any updates of the General Plan, including the Community Plans, include a rigorous and transparent calculation of the likely population resulting from zoning build out, broken down by Community Plan area or even smaller neighborhoods. 

These data, combined with realistic population trends, as well as data on the capacity of local infrastructure and services, would result in plans that direct future growth to those neighborhoods that can best accommodate it. This approach should guide the update process, not the hunger pangs of investors intent on overloading neighborhoods like Hollywood and Koreatown with luxury high-rise developments that clash with existing character, scale, and capacity. 

Unknown Knowns: Following the insights of the famous Zen poet, Donald Rumsfeld, these four predictable Bumps-in-the-Road are known knowns. But this poet has also reminds us that there are unknown knowns, and sometimes even unknown unknowns. 

Clearly, once the Update process is in high gear, we should expect many more bumps in the road than this beginners list.


(Dick Platkin writes on Los Angeles city planning issues for CityWatch. He lives in Beverly Grove, and is a Board Member of the Beverly Wilshire Homes Association. Please send any comments or corrections to [email protected]


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