The Planning Process and What’s Wrong in Our City

By Michael Callahan

All cities in California are required to develop a General Plan. The Plan is a policy document that addresses future land use and resource requirements in light of impartial and unbiased growth estimates. As quoted from the City of Los Angeles Planning Department website,

“The General Plan serves as a blueprint for the future, prescribing policy goals and objectives to shape and guide the physical development of the City.”

Planning starts with a projection of population growth over time. The Southern California Association of Governments, or SCAG, makes these projections. Using official projections is important. It ensures all local, regional, and state agencies base their future needs and requirements on the same level of growth.

The General Plan contains eleven elements that focus on, and reflect, many issues of importance to the citizens of Los Angeles. Such issues include land use (i.e., the 35 Community Plans), air quality, health, and safety. Each element implements policies to ensure the meeting of goals in the General Plan. The eleven general plan elements are shown in the graphic below. The graphic is from the Planning Department website with additional data added and discussed in the paragraphs that follow.

Click graphic to go to LA City Planning Page

The Plan, and each plan element, must be analyzed in detail in accordance with the California Environmental Quality Act (CEQA). This ensures that the implemented programs and policies do not result in a significant impact. If they do, the impacts require mitigation. CEQA analysis is a mandated feature so that the public and their representatives can make informed decisions regarding the adoption of the Plan.

Following Plan adoption, there is a required annual assessment of the Plan and its elements. This assessment ensures the meeting of goals. The results of this assessment are used to modify or adjust the Plan elements. Elements may be amended to account for new rules and regulations. A major update to the General Plan occurs on a ten-year cycle.

That is a brief overview of the planning process each city within the state of California should follow. Los Angeles fails to follow this process. The General Plan is many years out of date. The adoption of individual Community Plans is ongoing. This out-of-sequence action causes a major disconnect. Each Community Plan does not assess the overall regional impact of implementing all the other plans. This action is like chopping up a major development into smaller projects. Each project piece may pass CEQA analysis without triggering significant impact, but the project, overall, would fail.

In the Planning Department graphic, the dates shown are from the reference works provided to support each element. Green checks denote works that are less than 10 years old. Red checks denote works that are more than 20 years old. According to the data, six of the eleven Plan elements are more than 20 years out of date. The same applies to the framework element. Air quality, conservation, infrastructure, open space, public facilities & services, and noise are out of date. The level of up-zoning proposed in the recently adopted Community Plans impacts all of these Plan elements.

By law, the General Plan Elements must be inter-coordinated. They must be consistent. CEQA requires an assessment of all impacts, both individually and collectively. Significant impacts must be mitigated to the full extent feasible. The outcome is to produce a Plan that provides for the projected level of future growth while minimizing the impact on the community and city overall.

The purpose of CEQA is to promote smart growth. It forces the proponent to consider alternatives, to identify ways to mitigate impacts. Unfortunately, the City has taken the position that CEQA impedes their actions. As a result, there is no proper analysis performed. There is a rejection of mitigation measures with no discussion. Ignoring and failing to address public comment is standard.

Hollywood Heritage Preservation Committee

As an example, look at the Hollywood Community Plan (HCP) update that was just adopted. All growth targets the historic core. Zoning changes allow the replacement of historic buildings with high-density buildings. This destroys the character of this Federally recognized historic district. The plan repeals thirty-five years of protective regulations. It replaces them with unwritten plans and policies. Yet, none of this growth and up-zoning targets East Hollywood - an area served by three Metro stations, a community college, and several major medical employers.

The HCP update fails in that it makes no effort to “optimize” growth. All projected growth occurs in a very limited area.

No effort is made to minimize the impact on the existing Hollywood community. No effort is made to locate the growth where it’s most needed and makes the most sense. Rather than help the community grow, it saturates and destroys the historic core.

In essence, the HCP update isn’t a “plan” at all. The adopted update is a simplistic “all or none” approach to the problem. All the growth focuses on the historic Hollywood district while nothing is done to promote growth in East Hollywood. One can only hope that a recent last-minute effort by Councilmember Hugo Soto-Martinez is successful. He wants to reassess zoning throughout his district and provide tenant protections. He wants developers to provide much more low-income housing in exchange for higher density, as opposed to upzoning and getting nothing in return. His actions will help bring some actual planning back into the process.

Hollywood Heritage commits to working on this issue, to bring the importance of historic preservation and smart growth forward in the coming months. We welcome your support. If you or anyone you know wants to help, please contact the Hollywood Heritage Preservation Committee via this site.

ABOUT THE AUTHOR

Michael Callahan is a registered engineer with almost 40 years of experience in the fields of environmental compliance, air emission control design, industrial pollution prevention, and chemical process design. Major clients include the cities of Santa Barbara and Los Angeles, CA, DHS, USEPA, Navy CLEAN, SCE, JPL, LLNL, SRRP, and most local refineries. In addition to the technical work, projects often included the issuance of impact reports, studies, manuals, and guidebooks directed toward the public.

Mike retired in 2019 and thought he would spend his time as a freelance historian digging into local history. A friend requested that he review and comment on a study about illegal work at the Pig ‘n Whistle Café. Mike thought it would be a 1-page response. It ran 15 pages. A 42-page addendum about site history followed. More and more, Mike saw similar studies of questionable quality being used to justify inaction against responsible parties, or demolition of historic sites. It was at this point that the Hollywood Heritage Preservation Committee reached out to Mike, and he was more than willing to help in the fight.