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A Guide to Understanding the Baffling Changes to LA’s Planning Rules

Editor’s Note: Radical changes are being made to LA’s planning rules by First Deputy Mayor Austin Beutner — changes intended to simplify and expedite approval of new developments as he explained this week in an LA Business Journal article. Already, community leaders have filed one lawsuit  and others are expected as elements of Beutner’s scheme are rolled out. What is going on is widely seen as a threat to quality of life in neighborhoods, nothing but an attempt to densify the city for the benefit of developers by bulldozing zoning protections and the environmental review process. If you want to know where the City Council stands read what Greig Smith and his chief-of-staff Mitch Englander, his wannabe successor, has to so say (smith-pleanning.rtf).

By Dick Platkin, former city planner

The Los Angeles Department of City Planning is currently preparing three related sets of detailed urban design guidelines. They separately address future residential, commercial, and industrial projects subject to a discretionary action.

Once approved by the City Planning Commission, these guidelines will become an appendix to the General Plan Framework Element, the backbone of the Los Angeles General Plan. These guidelines are not binding, but would be advisory for discretionary actions (e.g., plan amendments, zone changes) for which there are no approved or adopted design guidelines otherwise available to decision makers.

Full copies of these guidelines, including background information, can be found at City Planning’s web-site.

The preparation and on-going public information campaign to promote these Design Guidelines is baffling for at least three reasons, and I have little doubt that readers will find additional wrinkles regarding the preparation or use of these guidelines.

WHY THE PROPOSED DESIGN GUIDELINES ARE SO BAFFLING

Baffling Reason #1: 
The main problems of the General Plan Framework Element have absolutely nothing to do with the presence or absence of advisory urban design guidelines for residential, commercial, and industrial land uses. Therefore, why allocate so much time and energy to their development, promotion, and adoption?

The most serious problem of the General Plan Framework is that it has reached the end of its intended life span. This plan was based on 1990 census data, was prepared by the Department of City Planning in the early 1990′s, and was adopted by the Los Angeles City Council in 1995.  Its horizon year is 2010, which means that 2010 is the final date for which the plan’s demographic estimates, infrastructure data, goals and policies, and implementation programs.

According to my calendar, it will soon be 2011, and by the General Plan Framework’s own internal logic it ought to be sent to the City’s archives at Piper Tech. It also should be immediately replaced by a new General Plan element, one which is based on 2010 census data and which has 2030 or a later date for its horizon year.

Furthermore, because California State law (Government Code 65040.2), the City of Los Angeles Charter (Sections 554-558), and Los Angeles Municipal Code (Section 11.5.6) all require the City to have a current and accurate General Plan, and because the General Plan Framework Element is the heart of the Los Angeles General Plan, it is now crunch time. This is not a discretional project; it is a legal requirement!

The process of replacing the General Plan Framework with an updated General Plan document should have begun several years to assure that the new General Plan Framework Element would be adopted as soon as the old plan expires at the end of December 2010. This update would have, however, only assured formal compliance with state and local legal requirements because professional city planning practice calls for municipal general plans to be updated on a 10 year cycle, not the 20 year plus cycle which is the default practice of Los Angeles, and then usually in response to law suits.

In the meantime, however, despite the imminent end of the General Plan Framework’s period of intended use (1996-2010), and the City’s failure to update the plan, the Department of City Planning has undertaken a series of Community Plan updates apparently based on the rapidly expiring 1995 Framework document.  At this point, both Hollywood and Granada Hills are in the pipe-line and could soon be considered for adoption.

So, instead of waiting until an updated General Plan Framework document, which will be based on 2010 census data and its 20 year extrapolation to a 2030 horizon year, the outdated 1995 General Plan Framework is driving the update of local Community Plans.

In effect, this means that the original data base for the General Plan Framework, 1990 census data, will be extrapolated 40 years into the future to determine the growth trends, infrastructure needs, and implementation programs required for such dynamic Los Angeles communities as Hollywood.
The chance that a 40 year extrapolation of 1990 data could be accurate and a reliable basis for an extensive General Plan implementation program, including proposals to increase the density of zones and plan designations in Hollywood, is nil.  In fact, the Planning Department’s own data already indicates that the General Plan Framework was wildly inaccurate for Hollywood.  It predicted Hollywood would grow by 43,000 people between 1990 and 2010, but by 2008 City Planning’s own data revealed that Hollywood’s population had only increased by 12,700 people.  30,000 predicted people never materialized.

Similarly, the General Plan Framework had predicted that there would be 17,610 new housing units constructed in Hollywood between 1990 and 2010, but by 2008 the number had only reached 2,686, despite the active intervention of the Community Redevelopment Agency and numerous discretionary planning and zoning actions approved by the City of Los Angeles.

Furthermore, if the amount of affordable housing removed to make way for new construction in Hollywood had been factored into the analysis, the net housing gain in Hollywood would have been even smaller, and the Framework’s 2010 projections would have been even more inaccurate.

Conclusion: 
The resources used to develop these optional design guidelines should have been spent on remedying the Framework’s main problem:  it is an out-of-date General Plan document in urgent need of replacement.

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Baffling Reason # 2:  To assure that the General Plan Framework Element
remained accurate during its intended life 1995-2010 lifetime, its
underlying statistics regarding growth and infrastructure, as well as
its track record of successfully implementing required policies and
programs, were to be monitored through an annual report prepared by the
Department of City Planning.

The need for this annual report, the legal obligation to prepare it, and
the report’s contents, are all spelled out in detail in the General
Plan Framework, as well as the Framework’s extensive Final Environmental
Impact Report (FEIR).  To assure the Plan’s relevance and accuracy, the
annual reports were to include both raw data and analysis of the
following:

*  Los Angeles’s growth trends, including those for the city’s
35 Community Plan areas, such as Hollywood and Grenada Hills, where
local Community Plans are now being updated.

* Infrastructure construction, changes in user demand for
infrastructure and municipal services, and the availability of
sufficient infrastructure capacity to absorb actual and anticipated
construction and user demand through the plan’s 2010 horizon year.

* Extent to which the General Plan Framework’s implementation
program has been funded, rolled out, and met the goals of the General
Plan Framework.

* Overall analysis of the General Plan Framework’s accuracy and
effectiveness.  Since the General Plan Framework is a growth neutral
document, this means that all discretionary actions by the Department of
City Planning or City Council to increase density (e.g., zone changes
and variances) must be based on hard data demonstrating that the
Framework’s projections – both local and citywide – had been exceeded
and that it policies and implementation programs were no longer capable
of meeting the needs of the city’s residents.

So far so good, except for one minor glitch.  The Department of City
Planning never monitored the implementation of the General Plan
Framework, and it stopped any monitoring of the Framework’s underlying
growth and infrastructure data over 10 years ago.

In other words, the City of Los Angeles has been flying blind since the
year 2000 because its General Plan has not been monitored.  There is no
way to know if the city’s underlying growth and infrastructure data are
accurate or if the city’s policies and programs are effective.  For that
matter, we don’t even know which implementation programs were rolled
out, and if any of them functioned as intended.  To say the least, this
is a serious planning problem, and it is wholly oblique to the
preparation and approval of supplementary design guidelines which will
become nonbinding appendices to an outdated General Plan.

This failure to either update or monitor the General Plan Framework may
have slipped under the radar at City Hall, but some local planning
activists noticed this lapse.  As a result two law suits have been filed
against the City of Los Angeles.  When the suits are resolved, it is
likely that the City will be forced to resume and expand General Plan
monitoring, which means collecting, analyzing, and applying current
growth and infrastructure data.  Furthermore, the City could also be
required to prepare 10 years of missing reports, from 2000 to 2010. 
Finally, if the trial or appeal judge develops an understanding of
California State planning laws, he or she should also require the City
of Los Angeles to quickly and fully update its General Plan.  This means
that the judge would conclude that rigorous monitoring of an expired
plan was not sufficient, and that the new 2010 census data must be used
to develop a new General Plan, including all legally required elements,
such as transportation.

If the City were to immediately address these serious problems, or if it
finally acts in response to a court order, it will quickly discover
that the proposed supplemental design guidelines are of little help.  
At that point the public might wonder why so much time and energy had
been devoted to such secondary activities, especially when it could have
been devoted to the formidable tasks or monitoring and/or updating the
General Plan Framework and other General Plan elements…

They might even wonder why such obvious tasks were neglected to the
point that community groups had to sue the city to force it to comply
with own laws, as well as to pursue what every city planning student is
taught: maintain your city’s general plan.

Baffling Reason #3:  The three sets of supplemental design guidelines
intended to become an appendix to the General Plan Framework do not
appear to have any connection to the Framework’s actual chapters,
including their policies and programs.  For example, the Framework’s
Chapter 5, Urban Form and Neighborhood Design, offers 17 pages of
detailed design goals, objectives, and policies, all of which are then
linked to the Framework’s Chapter 10, Implementation Programs.

These design guidelines were part of the original Framework document
adopted 14 years ago by the City Council.  Since then they have quietly
rested on a shelf at City Hall.  In fact, their profile was so low that
apparently the proposed design appendices do not even reference the
Framework’s own legally adopted design guidelines.  While this is a
baffling, the situation is actually more curious because in June 2009
the Department of City Planning presented detailed amendments to the
Framework’s adopted design guidelines to the City Planning
Commission.    The curious can listen to the full discussion on the City
Planning Commission’s web-site.  When they do, they will learn that the
City Planning Commission endorsed the proposed General Plan amendments,
including the accompanying staff report.

At this point, however, the trail inexplicably goes cold.  Despite the
positive action of the City Planning Commission, the proposed General
Plan amendments and staff report have not been considered by the City
Council, including a hearing before the Council’s Planning and Land Use
Committee.

So, for over a year and a half these amendments and the staff report
have languished at City Hall, while advisory design guidelines were
prepared which do not appear to make any references to the Framework’s
Chapter 5 on neighborhood design or the Planning Department’s proposed
2009 amendments to the same Framework chapter.
 
Baffling Reason #4:

  The Framework’s existing design guidelines in its
Chapter 5 could have been used, as these appendices are intended to be
used, to impose design conditions on any of the thousands of
discretionary actions which moved through the City’s bureaucracy between
1996 to date.  Yet, they never were.  (If any readers of this column
have information to the contrary, they should share it.)

That’s right.  From the date the Framework was adopted in 1996 to the
present any decision maker could have invoked 17 pages of existing urban
design guidelines to condition design changes for any building in any
discretionary action considered by the Department of City Planning, the
City Planning Commission, or the City Council.

So, the obvious question is: if the adopted urban design guidelines were
never invoked by decision makers, even though they were fully part of
the adopted General Plan, why should appendices only approved as
advisory design guidelines by the City Planning Commission be utilized? 
If quasi-judicial zoning administrators, City Planning staff acting on
behalf of the Director of Planning, the City Planning Commission, the
Council’s Planning and Land Use Committee, or the full City Council
never found the time or necessity to utilize the Framework’s Chapter 5
for the thousands of land use decisions they made over the past 14
years, why will they now turn to these appendices?

ARE THE ADVISORY DESIGN GUIDELINES BAD?

Considering that the General Plan’s existing design principles and
guidelines have been shelved since they were formally adopted by the
City Council 14 years ago, it is certainly likely than non-binding
design guidelines only approved by the City Planning Commission, not the
City Council, and which will become appendices, instead of adopted
policies, will have little impact.  Does this, therefore, mean that such
potentially innocuous documents lay below the threshold of being either
good or bad?
 

Not necessarily.  On the good side there always is the possibility that
the current public outreach campaign regarding the proposed appendices
will be a catalyst for City Planning and/or City Hall decision makers to
utilize the new design guidelines for future discretionary actions.  If
this happens and the design guidelines are actually used, they could
improve the appearance of some projects.   This would be a positive
outcome.

But, the guidelines might also add a design patina to real estate
projects which could not otherwise be built according to the Los Angeles
Municipal Code (LAMC).  This means that projects requiring zone
changes, plan amendments, variances, or other special approvals to
side-step the LAMC’s zoning restrictions, could be made more palatable
through design enhancements.  Based on current practices, it is also
likely that contentious projects will make amends toward critics by
changing their external appearance and citing the guidelines – while
holding fast to the zone changes or related discretionary actions they
are requesting.

This means that, in effect, the design guidelines would function quite
differently than those now attached to Specific Plans or Historical
Preservation Overlay Districts.  In those cases the overlay ordinances
ensure that projects are not only built below existing zoning
limitations, but that the same projects are also given an additional
review regarding their design.  In effect, under Specific Plans a good
(i.e., undersized) project becomes better, while, in contrast, a bad
(over-sized) project approved through a discretionary action becomes
more acceptable through a design “make-over” intended win over some of
the project’s critics,

If this happens, then the extensive efforts by the City of Los Angeles
to reduce barriers to real estate speculation now underway will have
been augmented through the use of non-binding urban design guidelines
for a wide range of discretionary actions.

Former city planner Dick Platkin is a Los Angeles based city planning consultant. He invites comments or questions on this article at rhplatkin@yahoo.com. He also blogs at http://plan-itlosangeles.blogspot.com.

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22 Responses to A Guide to Understanding the Baffling Changes to LA’s Planning Rules

  1. Brad Smith says:

    Not only should we wait for the 2010 census data, the state of California’s growth rate was ~1 percent last year – which, along with declining birth rates, suggests that the state’s population is approaching a static number. See:
    http://californiawatch.org/dailyreport/population-growth-california-slows-7354
    And having watched the Granada Hills GP “process” (basically, the city upzoned everything they possibly could), I’d suggest a moratorium on all planning changes and approvals for major developments until the census data is in hand and can be evaluated by experts outside of the BIA…
    Exactly who, for example, is expected to live in the projects moving forward in Cahuenga Pass, Tejon Ranch, etc, etc.?
    As Mr. Platkin suggests, “Just in Time” planning is ridiculous; only in LA City Hall.
    Best,
    Brad Smith
    smithforcouncil.org

  2. Anonymous says:

    Why can’t Dick Platkin be the LA Planning Director?

  3. N.Y. Times Crossworder says:

    13 A – Aptly named city planner
    Sorry, Dick Platkin cannot head up the planning department; he’s too logical, thoughtful, reasonable and sane.

  4. Anonymous says:

    Dick, thank you for your detailed analysis, however, the General Plan Framework was never meant to replace Community Plans and its update is a waste of time and money. Its usefulness was for only two purposes. It, for the first time, provided a broad and overall picture of the entire city outlining the Regional Centers where growth was to be intensified; the Community Centers where medium-range growth with a certain mix of uses was to be encouraged and finally the Neighborhood Centers where the type and mix of growth/uses would be catered to the neighborhood. The Framework also outlined the mixed-use and pedestrian-oriented streets in the city as a guide for the kind of uses and densities to be encouraged for this purpose.
    Its second useful or one may say revolutionary concept was to require an annual Infrastructure & Growth Report, which clearly shows the relationship between development and the infrastructure capacity in the entire city.
    A large city like LA cannot be covered by a broad and general document such as the Framework and its limitations are obvious. The Community Plans, on the other hand are comprehensive documents that analyze or should, each and every parcel in that community and adjust their zoning to accomodate that population capacity based on the reality on the street and other future trends.
    The problem in LA is that absolutely nothing is monitored or analyzed. Discretionary actions willy nilly change and approve land uses without any guidance from the Framework or the Community Plans. In fact, Plan Amendments are doled out to anyone who applies for one. The Planning Department is a whore that will serve anyone who paid the highest price to the Councilman or Mayor. We have just such a Director who is in that position due to favors to developers.
    So unless, a Community Plan is revised to up-zone properties to the maximum allowed, how do you put an end to discretionary actions? There is no law to prohibit developers from requesting the maximum. When the politicians and the Planning Department ignore all good planning concepts already outlined in the Framework and the Community Plans, their updates is an excercise in futility.
    The only solution is to have a comprehensive Infrastructure and Growth Report that includes all development that has occured, the future infrastructure capacity in the city, and if growth is still permissible then where it should be allowed.

  5. Anonymous says:

    Let me add to my comment above. A lot of time, money and effort was wasted in the new design guidelines, which are anything but new. All the updated Community Plans along with the Framework have a chapter devoted to design guidelines that are routinely ignored. The problem is not about having good planning priciples, policies and guidelines in place but rather of implementation.
    As long as developers and their politician puppets set the rules, let’s not waste the city’s limited resources in updating “meaningless” plans that are dead on arrival.

  6. Anonymous says:

    From Curbed LA, regarding the City Planning Commission meeting on Dec. 16th.
    “Despite a warning from the City Attorney’s office that creating a new sign district could open up the city to more legal challenges from billboard companies, today the Planning Commission voted to approve the Wilshire Grand hotel/office project, as well as a new sign district for the AC Martin-designed building”.
    This is the reality in LA. Even City Attorney warnings have no relevance when a development must be approved per the Mayor and Council orders. Corrupt Mayor, City Council. City Planning Commission and the Planning Department.
    Even Moses’ 10 new Commandments on planning issues would be ignored. Why waste taxpayer monies for writing a new General Plan Framework, Community Plans and Signage regulations that are not worth the paper they are written on.

  7. A. Shepherd says:

    Dick – on target. Two things about the General Plan Framework worth noting.
    First, it was launched because the City lost a lawsuit over the Hyperion Sewage Treatment Plant. Hyperion was fouling the Bay due to inadequate capacity. In order for the City to secure big money to improve Hyperion, the City committed to prepare — within two years — a long range comprehensive land use policy plan. The lawsuit settlement directed the City to complete a Growth Management Plan to enable rational planning for the future capacities of big infrastructure, e.g. sewage treatment. Framework was born out of a lawsuit. Second, the General Plan Framework was paid for by proprietary and infrastructure departments including the Airport, Port, CRA, DWP and Public Works.
    Smart.
    I agree, the Growth and Infrastructure Report was useful and revolutionary, especially for a city the size of LA. One can only hope the court sees it the same way when it reaches conclusions over the current lawsuits. Another settlement, ironically, may be good for planning.
    18 months ago the Framework was amended by the Planning Commission to put urban design principles into it — these were updated to the realities of today (2009) — and conversations about the ud principles were held all over the city with a wide range of stakeholders. They got a very good reception and were approved by Commission (not sure why they did not get to Council). They were specifically intended to “ground” the community planners to prepare appropriately tailored and detailed standards and guidelines for each New Community Plan. The Plans, which had been limping for awhile, continued to lag. Very little to show.
    The planning execs got the idea that they could kill two birds with one stone by preparing citywide design guidelines that would help the community planners further. A lot of time was spent by a bunch of people re-inventing this stuff. And more time was spent subsequently to make them more practical not vague and useless. While well intended, guidelines only effect discretionary projects; once all the up zonings are finished, things will be by right and no discretion, no guidelines.
    If the community can make hay of these guidelines, then they serve a constructive purpose. If they are window dressing to otherwise neighborhood-destructive projects then they will enable — as you write — “a bad (over-sized) project approved through a discretionary action [to become] more acceptable through a design “make-over” intended win over some of the project’s critics.”
    I hope more than wonks follow this.

  8. Anonymous says:

    The Framework took more than 6 years to complete, and will take longer if attempted again. The Community Plans do not need the Framework to update the Plans as the data utilized for that purpose is available elsewhere. The requirement to produce annual Growth & Infrastructure reports is also included in all the updated Community Plans. Updating the Framework serves no purpose. Infact, its housing and population projections for Hollywood show the innaccurate numbers.

  9. anonymous says:

    Framework took two years to prepare and two years to adopt (92-96); during the adoption process lots of refining, clarification took place in response to folks who wanted iron clad language that the Framework would not supercede the good and detailed policies of the individual community plans. Inevitably a lawsuit on the transportation infrastructure section extended its final re-adoption to sometime in 2000. Give or take a few years, it got done alot faster than any community plan — especially Hollywood2.
    UR correct insofar as the data is concerned; current plans use SCAG data then re-distribute the data according to the community plan policy direction (Framework analyzed both a market-driven and a policy-driven population/jobs distribution. Policy-driven approach assessed development growth focussed mostly in regional centers and fixed rail transit).
    There are no Growth and Management reports produced. Not since the last one done on a citywide basis. There are collections of data scattered around, but the whole point was to bring the data under one roof to enable a better understanding of implications.

  10. Anonymous says:

    “While well intended, guidelines only effect discretionary projects; once all the up zonings are finished, things will be by right and no discretion, no guidelines.
    Could you come back and explain what you mean by your statement that once upzonings are finished—. Do you support those upzonings?

  11. anonymous says:

    @5:03. Yes and no: some up zonings make sense, others don”t. The promise of the New Community Plans was that once the community (whole range of stakeholders) agreed on where growth was appropriate, then there could up zonings (more capacity) AND down zonings (neighborhood protection) and those would be processed as the Community Plan went through its adoption to City Council. That kind of clarity would stabilize the community, provide developers and neighborhoods clear direction. On density, intensity and use.
    Once a property is re-zoned (up or down) the people developing need only secure a building permit. Their project does not go through more review, hearings, environmental, etc. if it complies with all the zoning regs., including the zone itself. No discretionary, no guidelines apply.
    The description above does not include specific plans, HPOZ’s and other specialized zoning regs that carry their own unique brands of review.

  12. Anonymous says:

    11:25 a.m., thank you for responding. At the risk of calling you Gail Goldberg or her tape recorder speaking, I won’t blame you for writing or believing in the “new Community Plans” and the BS fed to communities about them. While the issues are far more complex than simple up-zoning and down-zoning, let’s just deal with one issue.
    Up-zones (more density/more money) are simple, and the property owner would give everyone a big hug and a bottle of Dom Perignon for saving him the trouble of applying for one. He even gets to save on the bribes, er, political contributions to the Mayor and Councilmember of the District. This assumes that everyone in the community is happy and agrees with the upzone.
    The down-zones, however, are not that easy. Which property owner is going to allow the city to down-zone (less density/less money) his/her property without a lawsuit, especially, when the city gave a free gift of up-zone to someone a block away and took away his property rights. I would wager that the city will lose this one. For the moment, let’s just be lawsuit neutral. The property owner files an application for an up-zone, since there is no law that prohibits him from applying for one, and the “new” Community Plans cannot prevent this either. What will be the results? I’ll let you ponder on that, based on LA’s history.
    Now back to the up-zones. The property owner has already been granted the maximum allowed, but wants more. A 20% increase is warranted under the “new” Community Plans and their implementing ordinance (for this purpose) aka CPIO Ordinance. The owner also decides to utilize the increases allowed by the SB1818 ordinance, which by law must be granted to him. So we now have a project that may be 20-30% or more denser/higher than what the community envisioned. Too late. Can’t do anything about it, cause the CPIO ordinance allows this process to be administrative ie. staff/bureacrats decide on the project without a public hearing.
    Also, let’s say, someone new moves into that community that was gung-ho about the up-zones and finds activity taking place around their property, and further they have no idea what that building is and have no voice in it, cause a handful of people made that decision for them a few years back. They’d be pissed.
    Having said that, I respect you for responding and wish more people like you would be engaged in separating the wheat from the chaff.

  13. Anonymous says:

    @11:25. Down-zonings are absolutely called for in the following ways. First, those nicely maintained residential neighborhoods with single family or low multiple family density (duplex, 3, 4-plex) where the current zoning is R3. The promise to down zone these kinds of intact areas is made in the Housing Element. The second example is large areas of single family homes, ag-zoned, but planned for smaller single family lots. Developers always filed up-zoning applications for the most dense sf zone and the staff aquiesced. This changed the complete character of an sf neighborhood: lots went from one – 17,500 to 3 – 5,000+- sf lots. Staff rarely asks if tripling density in the context of the larger neighborhood is right.
    Downzoning in the first example would be a service to neighborhood stability. in the second example, other possibilities exist: Down-planning the community plan into consistency with the ag-zoning; or limited up-zoning to only the next level of SF zoning (11,000 sf/home).
    Certainly, follow the money. However, planning actions for preservation (down zoning, down planning) help property values. Just look at the outcome of HPOZ areas.
    But UR correct: developers can blast thru all of this with density bonus, CPIO 20% auto-granted density increase.

  14. Dick Platkin says:

    The quality of the comments on the my article which Ron Kaye published is top notch. The only remarks with which I disagree are the claims that Los Angeles does not need to update its General Plan because local community plans could suffice.
    First, State law, the City Charter, the Los Municipal Code, and the standards of the planning profession all indicate cities, including Los Angeles, require a general plan.
    Second, even if there were no legal requirements or professional standards, without a current and accurate General Plan, the City of Los Angeles flies totally blind in its budgeting process, especially the preparation of its CIP (Capital Improvement Program).
    Third, there is no way in which Los Angeles can be properly governed by separately planning 35 communities. How do you possibly deal with any issue larger than a local community if planning is restricted to such small geographies? How would you address air quality, economic development, and traffic congestion? How would you plan mass transit, public infrastructure, and public services?
    After all, despite the efforts of City Hall’s decision makers to reduce planning to building permits for projects on privately owned lots, legally adopted plans still cover 100 percent of the city’s land, not the 20 percent which are private parcels.
    To ignore this heavy lifting intrinsic to good governance or to believe it can be addressed by 35 separate local plans is to accelerate LA’s already rapid decline.

  15. Anonymous says:

    Dick, your comment that “First, State law, the City Charter, the Los Municipal Code, and the standards of the planning profession all indicate cities, including Los Angeles, require a general plan” is correct. Your confusion starts when you believe that the Framework Element is the General Plan. It is NOT. A General Plan in smaller cities is a single document. In a large city like LA, 35 community plans comprise the General Plan. The Framework, born of a lawsuit for a specific purpose is a useful document for presenting the general picture of the entire city, however, it is not the General Plan, and was never planned to replace the Community Plans.
    Its usefulness as stated earlier, was providing that general picture and the requirement for an annual Infrastructure and Growth Plan. Once those statements have been replicated in the updated Community Plans and the ones that need to be revised, the Framework serves no useful purpose. What you should be focusing on is the lack of those Reports that were specified in the Framework and the Community Plans that include that language.

  16. Anonymous says:

    7:08 a.m., you are correct that downzonings are absolutely called for in the circumstances you have described. The sad thing is that it is the Planning Department that helped destroy those communities with their upzones. A prime example is North Valley, specifically Sylmar, where large horsekeeping lots were downzoned to multiple-family, which developers took advantage of and totally disintegrated neighborhoods that should have remained as the last bastion for a semi-rural equine district.
    This destruction will continue because experience in LA has shown that except for a handful of people, most people don’t understand head or tails about long range/Community Plan Update process. By not attending these meetings and their lack of interest gives planners a carte blance to do whatever they want to. The community always wake up when it is too late, when a single-family lot next to them is being subdivided into 20 lots or when that single story building is now a 20 story monstrosity.
    If anyone thinks it is in the past history of LA or where communities were not well-informed, take a pause. The same stunt was pulled this year with the CPIO Ordinance.

  17. Dick Platkin says:

    The General Plan Framework is an element of the Los Angeles General Plan. It is also the most important element because it is the only one which deals with all planning issues, such as design and infrastructure, does so on a citywide basis, was intended to be monitored and updated on an annual basis, and provides critical buffering against the ups and downs of market conditions.
    The 35 Community Plans are also elements and cumulatively comprise the Land Use Element of the General Plan. This means they cannot in themselves be the General Plan, even if all 35 of them were finally updated. What they should do is integrate citywide elements, particularly the Framework, and apply them at a finer grain to smaller geographies, to implement citywide policies, goals, and programs based on the same planning analysis. Since the Framework Element’s horizon year is 2010, based on extrapolations of 1990 census data, in a city committed to real city planning, the same planning horizon year should apply to all General Plan elements, including the 35 Community Plans, to assure the legal requirement of internal consistency.
    Because 2011 is just days a way, and the new census data is becoming available, the importance of a comprehensive update of the General Plan Framework Element immediately followed by updates of the Community Plans/Land Use Element is both possible and essential to assure accuracy and internal consistency.
    To barge ahead with several updates of Community Plans at this point, without considering the new census data and current infrastructure data
    – at a citywide and community level — is both baffling and bad planning.
    Furthermore, the Framework’s annual monitoring reports that many people have mentioned are referenced in recent Community Plans. This means that these monitoring reports were not only intended to guide mid-course corrections for the Framework’s underlying citywide growth trends, infrastructure capacity factors, and implementation programs, but also for the Community Plans.
    Lots of coulda’s, shoulda’s, and woulda’s!

  18. anonymous says:

    The Great Value of the Framework was to gather socio-economic and land use data on a citywide basis; the community plans don’t do that. Even the New Community Plans are not as comprehensive as the Framework. For big infrastructure planning, Framework is it: water demand, power demand, sewage treatment, per capita demands like police, fire, library, park acreage. And a basic (framework) structure for design, kinds of focussed growth areas, LA River as the open space spine etc. Not to mention transit (fixed rail/bus not the stupid density bonus “bus routes”)
    I am with Dick, but for different reasons. The Framework is not mandatory, but it was the best comprehensive plan the City had for a long time.
    The really bad thing about Sylmar is that: 1) it was planning symptomatic of the misperception of reality in attempting to create reality — something AICP planners are skilled at. The Sylmar neighborhoods looked “dumpy” so obviously higher density would bring in new quality. Of course what the planners failed to see was that new populations were moving into Sylmar and they LIKED and did horse keeping, just weren’t moneyed; and 2) this up-zoning was sprawl at its deadliest (take the rural areas of the city, and develop with low medium density — yikes! pave the land, drive forever to services). I cannot in honesty blame the planners because the demise of Sylmar’s rural neighborhoods was accelerated by Hal Bernson. Some planner fought it, most through in the towel.

  19. Anonymous says:

    Actually, it was Alex Padilla and his sleaze developer friends who raped Sylmar and other North Valley areas under his jurisdiction.

  20. Anonymous says:

    OK. Before we confuse everyone else, here is a quickie on Planning 101. There are seven mandatory State Required Elements comprising Land Use, Circulation, Housing, Conservation, Open Space, Noise and Safety that together comprise the General Plan. There can also be optional Elements such as Economic Development, Infrastructure that addresses water, wastewater/septic, storm drainage and solid and waste infrastructure, and Community Services that identifies standards and facilities for the provision of fire protection, law enforcement, schools, libraries, health care, cultural amenities, and parks and recreation in the community.
    The Framework Element was a hybrid that does not neatly fit into anyone of the General Plan Elements. In fact, it encompasses several features of other elements. As mentioned earlier, it provided an overall picture of the entire city, which community plan areas bifurcated into 35 areas cannot. However, it took 8 years and millions of dollars funded by proprietary departments to be adopted. That kind of time and money makes it an almost meaningless document, cause by the time it is adopted new census data and other growth numbers will be around.
    Why not focus on the best thing that came out of the Framework Element; the requirement for an annual Infrastructure and Growth Report that incorporates and condenses useful and on-time data that can be produced quickly and at a lesser cost than the large-scale production of the Element.

  21. Dick Platkin says:

    The Annual Monitoring Report is a must, but it then needs to be applied to the underlying assumptions and implementation programs for all of the City of LA’s adopted plans.
    Furthermore, the elements, both required and discretionary but important, like the Framework, should also be updated on a regular schedule. Professional planning practice recommends local (community) plans be updated on a five year cycle and general plan elements on a ten year cycle.
    I fail to understand why cost should be an issue for such essential work. Over half of the Los Angeles General Fund goes to the LAPD while crime is in long-term decline, so lets move a few million toward long-term citywide planning.
    Or if that is such a high priority (despite it just being one more public service in the Framework!), lets go for other low hanging fruit, such as the $200 billion per year in direct expenses being wasted on two losing wars based on flat-out lies: Iraq and Afghanistan.
    Or how about some more bail-out money? Surely the second largest city in the United States is too big to fail!

  22. Anonymous says:

    Dick, I agree with some of your thinking and feel the same frustrations. However, the reality is that despite millions being spent in the Planning Department for Community Plans during the last six years, not a single one has been produced. The Hollywood Plan is about 16 years in the making and is a disgrace. There is no accountability and no one in City Hall cares if they are ever produced. Gail Goldberg was kicked out not because of failure to produce a community plan, but due to 12-2.
    Even though, I’ve written that the Framework will take too long, the way the CPUs are progressing, it hardly matters. It’s my conclusion that throwing more staff the Department’s way, is a waste of taxpayer dollars. The time has come to reduce it drastically and parcel the work out to private companies who can do it in a fraction of the time and cost. Bottom line is that we want out communities protected with proper development controls, and we know it is beyond the Planning Department’s capability to do it.

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