LA’s New Housing Element Meets A Bump In The Road

The first criticism was that the new Housing Element will not meet its goals because it is based on a regression model that cannot compensate for interest and tax rate changes, recessions and depressions, Pandemics, construction breakthroughs, updated housing policies and programs, and new consumer housing preferences.  By extending previous statistical relationships into the future and then using these extrapolations to determine the City’s housing policies, the new Housing Element is headed for failure.

The second criticism was that the new Housing Element is a Fiasco Foretold because it makes the housing crisis worse.  It will cause transit ridership to further decline, traffic congestion to increase, and climate change to accelerate.  The cure is no better that the diseases it claims to treat. 

When the City Council soon adopts the new Housing Element, it still needs to act on implementing ordinances appended to future Community Plan Updates.  Los Angeles is divided into 35 Community Plan areas, and their updating process is at least 17 years old, when former Planning Director Gail Goldberg first called them new community plans.  

Nearly two decades later the Los Angeles City Council has only adopted five Community Plans: Sylmar, South Los Angeles, Southeast Los Angeles, West Adams-Baldwin Hills, and Granada Hills.  The rest are either slowly underway or do not even have a start date. 

But in order to defeat the Neighborhood Integrity Initiative in 2017, the Los Angeles City Council directed the Department of City Planning to update LA’s 35 Community Plans on a six year cycle.  As a result, the five updated Community Plans are already due for their Council-mandated six-year update.  They would join the 16 Community Plans undergoing their own drawn-out updates.  As for the remaining 14 Community Plans, such as the critically important 21 year old Wilshire Community Plan, City Hall has not posted any start dates. 

How, then, will the 2021-2029 Housing Element be implemented, with only half of the Community Plans available for appended up-zoning ordinances under the most optimistic schedules?  Will the five plans due for their six-year update join the 14 old Community Plans waiting for a start date?  Or will they be lumped together with the 16 Community Plans already quagmired in the update process?  If anyone at City Hall knows, they are good at keeping this secret. 

New Hollywood Community Plan will be the test case.  When the City Council adopts it, the “new” Hollywood Community Plan will repeat many of the same mistakes that led to the court-ordered demise of its 2012 predecessor. 

It is based on old census data.  Even though the 2020 US census data is available at the City of Los Angeles Redistricting Data Hub, like 2012, the new Hollywood Community Plan relies on old census data.  For example, the August 2021 Draft Hollywood Community Plan indicates that Hollywood’s population is 206,000 people, relying on a Bureau of the Census update of its 2010 data.  Had the draft Hollywood Plan used readily available 2020 census data, the correct Hollywood population figure would be 197,598 people.  This is 700 people less than Hollywood’s 2010 population of 198,288, which is 13,000 people less than Hollywood’s 1990 population of 211,000 people and its year 2000 population of 212,000 people.   

These population figures compare to a 1980 Hollywood Community Plan population of 181,000 residents, which amounts to a paltry increase of 16,000 people over 40 years. The 1988 plan also forecast a 2010 population of 219,000.  This forecast was 21,000 people too high, a precursor of equally dubious forecasts in the draft 2021 update since it claims that Hollywood’s population will likely soar by 77,000 people over the next 18 years.  

Despite this grandiose boosterism, the long-term trends indicate population decline in Hollywood, despite intentionally induced growth. 

• Growth inducing. Like the rejected 2012 Plan, the current Hollywood Update intends to induce population growth that defies historical trends.   This approach clearly contradicts the General Plan Framework Element, adopted by the City Council in 1996, but still in force.  Its Chapter Two states: 

“The General Plan Framework Element is population growth neutral: it is not the intent of the Framework Element to cause any specific level of population growth to occur. It is a plan to accommodate whatever growth does occur in the future, which could include loss of population.” 

The proposed increase in population, housing, and employment in Hollywood not only runs counter to long-term trends, but, like before, it is not based on the capacity of the area’s infrastructure and public services. 

2-A) Inadequate infrastructure and public services.  Another shortcoming of the 2012 Hollywood Community Plan was its failure to adequately address the capacity of existing infrastructure and public services to meet expanded user demand.  The same failure has not been corrected in the 2021 version of the Hollywood Plan.  For example, the current EIR’s Statement of Overriding Considerations concedes the inadequacy of public services in Hollywood. 

“Given the existing deficits in existing pocket, neighborhood, and community parks; the increased demand for such parks; and the severe challenges in the provision of new parks, it is anticipated that the increased use of existing parks and recreational facilities could result in significant deterioration of these facilities. Therefore, the Proposed Plan would result in a significant and unavoidable impact related to existing parks and recreational facilities. This significant and unavoidable impact would also contribute to significant cumulative impacts.”  

 2-B) The Housing Element’s Policy 121- Re-Zoning indicates that its up-zoning program will largely take place through Community Plan Updates, like Hollywood’s, by appending up-zoning ordinances.  But this implementation program is not matched by corresponding upgrades to local infrastructure and public services sufficient to meet the need of more residents, employees, and cars. 

“Policy 121 - The Rezoning Program is anticipated to be implemented through a number of work efforts, including updates to up to 16 Community Plans (four West LA plans and six SE/SW Valley plans, two Downtown plans, Boyle Heights, Hollywood, Harbor-Gateway and Wilmington), two Specific Plans (CASP and Slauson TNP,) as well as at least one citywide ordinance that will create additional zoning capacity through an expansion of affordable housing incentive programs.” 

While we wonder how the 2021 Hollywood Community Update has managed to masterfully channel the 2013 legal decision of Superior Court Judge Alan Goodman, we also need to acknowledge its strictly new flaws.  According to Frances Offenhauser, a former LA City Planner who worked on the 1988 plan that Judge Goodman restored, the 2021 version has its own unique shortcomings. 

• If the 2021-2029 Housing Element’s citywide goal of building 456,643 new housing units by 2029 were disaggregated across LA’s 35 Community Plan, Hollywood’s share would be 31,965 units. They could all be accommodated by existing zoning.  Yet, the proposed Hollywood plan calls for 75,274 new units, all of which would be located on up-zoned parcels. 

• Relying on new construction as the panacea for affordability causes more displacement because one-quarter of the proposed up-zoning sites require the eviction of existing tenants living in rent-controlled apartments. 

• The Hollywood Plan undermines the effectiveness of TOC density bonuses to build low income housing because the Housing Element’s policies gives developers extra height, size, and density upfront. As a result, they would no longer need to apply for the density bonuses their business plans require.  In Hollywood they could build larger buildings without any TOC affordable units. 

• Up-zoning in Hollywood cannot reach the Housing Element’s affordable housing goals because it does not include any public subsidies for low-priced housing. 

• Areas of Hollywood having superb access to MetroRail, colleges, schools, parks, and jobs are untouched by the Plan’s proposed up-zoning.  

As Hollywood goes, so goes the rest of Los Angeles, when it comes to implementing the highly flawed Housing Element.  Whether the Housing Element flounders because of its own inherent defects or because of the stalled adoption of updated Community Plans, Angelinos should brace themselves for a low-income housing crisis that will get worse. 

(Dick Platkin is a former Los Angeles city planner who reports on local planning issues for CityWatchLA.  He serves on the board of United Neighborhoods for Los Angeles (UN4LA) and co-chairs the new Greater Fairfax Residents Association.  Previous Planning Watch columns are available at the CityWatchLA archives.  Please send questions and corrections to [email protected].)