Editor’s Note: Dick Platkin, a former LA city planner, writes regularly about planning issues with an insider’s insight and a resident’s concern. He is now a planning consultant and board member of the Beverly Wilshire Homes Association, and can be reached at firstname.lastname@example.org.
By Dick Platkin
18 years of work, LA’s Department of City Planning has finally unveiled a draft
update for the 1988 Hollywood Community Plan, including 105 pages of detailed
amendments to increase permitted building densities in Hollywood, as well as a Draft
Environmental Impact Report (DEIR). If
or when this update is eventually adopted, it will then become a template for similar
updates of LA’s 34 other community plans.
In theory, it also could become a model for Specific Plan amendments to
permitting greater densities.
of the Hollywood plan’s importance to potentially alter private land use
patterns all throughout Los Angeles, many analysts have carefully scrutinized
the draft, especially its DEIR, and submitted their analyses to the Department
of City Planning. Among these many submissions,
one theme stands out; the Draft Environmental Impact Report does not present a credible
planning rationale for the proposed Community Plan update.
following six points summarize much of this DEIR testimony:
1. Infrastructure and Services: First, LA’s public infrastructure, which has
not been monitored in over 11 years, and in some categories, not planned in
over 40 years, cannot handle the needs of the city’s existing and projected population
and commuters. In the case of the DEIR,
there is no analysis to demonstrate that local services and infrastructure in
Hollywood are capable of meeting the demands of the larger population which
could result from the update’s extensive up-planning and up-zoning. Without demonstrated unused infrastructure
capacity in the DEIR, there should be no increases in permitted densities in
Hollywood according to the General Plan’s Framework Element.
there is no proposal in the DEIR or the draft Community Plan itself to monitor
local infrastructure conditions, including changing demographics and user
demand, as well as the effectiveness of the updated Plan’s infrastructure-related
policies and programs. The proposed plan
also fails to identify any threatened infrastructure systems in Hollywood and
offers no mitigation process to address these likely infrastructure breakdowns.
put it bluntly, this is a plan that will dramatically reduce the quality of
life in Hollywood. For that matter, the
hope that increases in allowed densities will spur increased investment in real
estate is unfounded. Who will want to
live, work, visit, or invest in a Hollywood which has inadequate, deteriorating,
unplanned, and unmonitored infrastructure and public services?
2. Conflicts with the General Plan: The city’s outdated but still official and
legally required General Plan is “growth neutral.” According to the 1996 General Plan Framework
Element, Los Angeles has enormous untapped potential for population and housing
expansion based on adopted plan designations and zones. In fact, the Framework notes that Los Angeles
could double its population without any need to change its underlying zoning or
exceed local densities in Hollywood, City Hall must therefore present a clear
rationale based on documented increases in population growth and housing demand
which have outstripped locally permitted densities but still retain sufficient
public services and infrastructure capacity.
Yet, in the case of the proposed update of the Hollywood Community Plan
there is no analysis of the remaining buildout potential for the privately
zoned parcels in Hollywood or the area’s remaining infrastructure capacity
based on projected deterioration and increases in user demand. Likewise, there is no evidence that if these
parcels were fully built out, they still could not meet the housing and
employment needs of Hollywood’s current or future residents.
3. Census Data: The update of the Hollywood Community Plan is
based on outdated census data.
California State planning laws and guidelines require each city’s General
Plan, including its Land Use element, such as the Hollywood Community Plan, to
be current and internally consistent among its required and optional elements. In this case the General Plan Framework Element
is based on 1990 census data which was extended to the Plan’s 2010 horizon
year. The update of the Hollywood
Community Plan, which is supposed to apply the General Plan Framework Element
to a local community, is, however, based on year 2000 census data, augmented by
2005 estimates, and then extrapolated to the year 2030.
two plans are not only inconsistent with each other, but neither is current
because the new 2010 census data is now available and should be used for monitoring,
reviewing, and updating all components of a city’s General Plan.