PLATKIN ON PLANNING-It’s rare that I use my CityWatch column to praise a City Hall official for doing the right thing. But, Councilmember David Ryu and his staff deserve compliments for their clear and critical letter to the Director of Planning, Vince Bertoni, posing their many criticisms of the Purple Line “Transit Neighborhood Plan (TNP)” as tough questions.
Reposted in the April 25, 2019, issue of City Watch, David Ryu’s letter lists the proposal’s multiple failures, many of which CityWatch previously published.
Coyly formulating the TNP’s major shortcomings and outright deceptions as simple questions, David Ryu’s letter presents the Planning Department with four detailed pages of TNP flaws. This includes relying on erroneous assumptions, rigging public comments, bypassing the forthcoming update of the Wilshire Community Plan, and ignoring transit improvements. Putting it bluntly, the letter implies that the TNP will exacerbate the very conditions it purports to remedy: declining transit ridership, traffic congestion, gentrification, high housing costs, and climate change.
CityWatch readers may recognize the following points – among many -- from the letter.
- The housing that the TNP would add to the greater Miracle Mile area is expensive, not low income. Because new TNP tenants will necessarily be well off, most of them will own and drive cars. They will not be transit-dependent residents who could never afford to live in these new buildings, even if they had been recently displaced from the same sites to make way for Transit Oriented Development. The TNP will, therefore, increase traffic congestion and overall Vehicle Miles Traveled.
- The TNP does not improve any alternative mobility options, including car and bicycle sharing, bike and scooter lanes and storage areas, METRO transit passes, and shuttle services.
- The TNP has no plans or funds to improve the pedestrian environment on Wilshire Boulevard, San Vicente, Fairfax Avenue, and La Brea Avenues. It leaves bus stops and sidewalks in the same deplorable shape they are in today, without any repairs and reconstruction, ADA upgrades, kiss ‘n ride, landscaped parkways, street furniture, green space, public plazas, street lighting, street tree replacement and planting, street level urban agriculture, and community centers.
- The TNP gives developers added density, height, and building size (FAR) from the get-go, reducing their need to apply for low income housing density bonuses, such as less open space. If they do, however, apply for such waivers, areas suitable for landscaping, trees, mini-parks, and air and light would shrink.
So far missing from the letter are the following concerns, although they could be added to future correspondence.
- The letter did not mention the TNP’s Environmental Impact Report (DEIR). In July 2018 the Department of City Planning held a sudden DEIR Scoping meeting for the TNP, even though few details of the project had been made public. Nine months later, there is no public information on what the DEIR project alternative includes, other than rampant upzoning of private parcels. This means we still do not know what the stalled DEIR will evaluate. It is also pure guesswork if the DEIR will continue as is, or if it will be merged into the parallel environmental review of the Wilshire Community Plan Update.
For that matter, no one knows how the DEIR may eventually assess the far-reaching TNP components identified in its July 2018 DEIR scoping letter:
- Land use and zoning changes, including General Plan Amendments.
- Amendments to the Los Angeles Municipal Code to implement the yet-to-be-completed re:code LA re-zoning program.
- Amendments to the Wilshire Community Plan, including those that would align it with (unspecified) statewide policies.
- Updates to the Wilshire Community Plan’s zoning classifications, maps, goals, policies, and programs through the year 2040.
- Amendments to the General Plan Framework Element.
- Amendments to the General Plan Mobility Element and other (unspecified) General Plan Elements.
- Amendments to citywide ordinances.
- New City ordinances to create zoning overlay zones.
- New zoning classifications incorporating the Miracle Mile’s existing Community Design Overlay Ordinance.
- Rezoning private properties.
- David Ryu’s letter also neglected to mention the similarities between Senator Scott Wiener’s contentious Senate Bill 50 and the proposed Purple Line Transit Neighborhood Plan. Though SB 50 is more dangerous, they would both upzone, without conditions, commercial and multi-family residential zones on Wilshire Boulevard, San Vicente, LaCienega, Fairfax, and LaBrea Avenues. Furthermore, both laws circumvent all local planning processes, even when State laws or the Los Angeles City Charter require them.
Furthermore, neither legislation contains any inspection or monitoring requirements. Finally, they are both based on the same faulty planning theory: Transit Oriented Development (TOD). This theory claims that if cities cut zoning and environmental laws, developers will rush in to build housing for low-income tenants and transit users.
In fact, TOD does exactly the opposite. It builds expensive housing, in which few tenants ever take buses or subways. This is why TOD housing leads to more, not less, gentrification, traffic, and further declines in transit ridership.
This increased driving also worsens climate change, as does its undermining of the California Environmental Quality Act (CEQA). Unlike the status quo, most future TNP projects will be ministerial, which automatically exempts them from CEQA-required environmental reviews.
Although David Ryu’s letter used a question format, his office, his constituents, and CityWatchLA readers already know the answers. There is no way that City Planning can reinvent their Purple Line TNP proposal to meet the multiple concerns raised by Councilmember Ryu. City Planning’s METRO grant was never anything but a real estate scheme to upzone private property, through which property owners would immensely benefit from suddenly inflated property values.
When these points are added to the discussion, and when Councilmember Ryu can supplement his letter with similar concerns from fellow Councilmembers Paul Koretz and Herb Wesson, along with a clear statement that City Planning must fold the TNP into the forthcoming update of the Wilshire Community Plan, David Ryu will have hit a home run.
(Dick Platkin is a former Los Angeles city planner who reports on local planning controversies for CityWatch. He serves on the Board of United Neighborhoods for Los Angeles (UN4LA) and welcomes comments and corrections at email@example.com.) Prepped for CityWatch by Linda Abrams.