20 Tell-Tale Signs: The Purple Line Neighborhood Transit Plan is a Real Estate Scam

If adopted, the TNP would minimally up-zone and up-plan large sections of the Beverly-Fairfax, Beverly-Grove, Miracle Mile-Museum Row, Restaurant Row, Pico-San Vicente, and LaBrea corridor neighborhoods.  In other words, it will increase the height, size, and density of many commercial, apartment, and duplex-zoned lots in these historic and highly congested neighborhoods. 

Furthermore, the Purple Line TNP study area covers the western half of the Wilshire Community Plan, from Beverly on the north to Pico on the South, from Beverly Hills on the west to Rimpau on the West. The TNP’s long-term impacts (e.g., increased traffic congestion) on this large area, shown below, will be extensive. 

Billed as an essential part of METRO’s Purple Line Extension, because that project includes new subway stations at Wilshire-LaBrea, Wilshire-Fairfax, and Wilshire-LaCienega, the TNP is nothing more than a brazen real estate scam. Furthermore, City Planning is fast-tracking it, with virtually no public outreach. Even though the TNP will fundamentally alter these celebrated neighborhoods, local residents and community groups were totally blindsided by City Planning’s TNP proposal. 

In fact, this project is being pushed through so quickly that no one in charge even bothered to cover up their fingerprints. The telltale signs of a scam are hidden in plain sight, including these top 20 reveals: 

1. Climate change and power outages:Like the entire metropolitan area, the classic neighborhoods that the TNP targets for large new commercial and apartment buildings, are already suffering frequent power outages and broken water mains. Why? We are living through a perfect storm of climate change-induced heat waves, over-development, and deferred maintenance. Nevertheless, this Purple Line real estate scam totally ignores these trends. They are nowhere to seen in any plan materials.  

2. Missing public outreach:The Department of City Planning has prepared this sketchy “plan,” with virtually no public outreach or input. Even though the TNP increases the mass, height, and density of commercial, apartment, and duplex-zoned lots in many local neighborhoods, resident associations, homeowner groups, HPOZ boards, and Neighborhood Councils were totally out of the loop. None of them knew what was heading straight for them – at the speed of a hedge fund’s keystroke.  

3. The TNP ignores its Impacts on single-family neighborhoods: The project’s study area is Beverly Hills on the west, Rimpau on the east, Beverly on the north, and Pico on the south. Within this large area, City Planning has not analyzed how their plan will impact enclosed single-family areas. They have not considered how their plan will increase cut-through traffic, housing costs, displacement, mansionization, gentrification, air pollution, shade and shadow, and deterioration of shared public services and infrastructure, especially electricity. 

4. Missing plan details:Even though the proposal’s environmental review noticewas backdated to July 12, 2018, the public still does not yet know exactly what is proposed, including reductions in parking requirements. This notice also references General Plan Amendments, zone changes, zoning overlay ordinances, new re:codeLA zones, amendments to the Los Angeles Municipal Code, and design requirement, none of which have been made public. 

5. Fake Community Plan update:The TNP is framed as an update of the Wilshire Community Plan, including amendments to the Community Plan’s official map, goals, policies, programs, and land use designations. Nevertheless, the Department of City Planning does not include the Wilshire Community Plan on its list of Community Plans in Progress. In fact, the actual Wilshire Community Plan update is scheduled to begin in 2021, long after the potential completion of the TNP. 

6. Missing Community Plan update data:The planners in charge of the Purple Line TNP have not assembled, analyzed, or shared any data on current or forecast population or transportation trends.  In fact, they do not even know how many additional people the TNP will add to local neighborhoods, how many of these newcomers will become transit riders, nor how many existing residents, including transit users, will be displaced by the new, upscale buildings the TNP boosts. 

7. Missing community plan outreach:City Planning’s established and published processes for updating a community plan have been totally ignored by this faux update of the Wilshire Community Plan. Despite recent City Hall decisions to accelerate the update of community plans, there is no evidence that the existing Wilshire Community Plan was ever reviewed, that any Neighborhood Councils reviewed issues and opportunities in the plan area, that City Planning staff analyzed or reviewed information from Neighborhood Councils, that City Planning met with any focus groups (e.g., five local HPOZ boards, HOAs, and resident associations), or Planning staff consulted with the three City Council offices (CDs 4, 5, and 10) in the large TNP study area. 

8. Backdating comment dates:The Transit Neighborhood Plan posted its new plan materials on July 30, but quietly opened its comment period on July 12, 2018, more than two weeks prior. It deadline for comments is August 13, which is only two weeks after they posted their sketchy plan materials on-line. 

9. Failure to consider critical public infrastructure and services: The Planning Department has not prepared any analysis of the area’s failing public infrastructure, especially frequent power outages and 90-year-old exploding water mains and sewage lines. They also offer no upgrades for any local public services and infrastructure prior to or even after the TNP’s intended building boom of private real estate projects. 

10. Conflicts with the General Plan:The General Plan Framework Element is clear that Los Angeles’ adopted plans are growth neutral. City policies should not deter growth, and they are explicitly opposed to inducing growth, which is, nevertheless, the express purpose of the Purple Line TNP. According to the Framework’s Chapter 2, “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.” 

11. Missing Population Data: The Purple Line TNP is built on the belief that the local area’s population must grow to fill subway cars, yet the TNP offers no analysis of population trends in the Wilshire Community Plan area. This information is easy to assemble, and I present and analyze it below:

The available Wilshire Community Plan population data does not reveal any population boom, historically or forecast, for this area. 

1. According to the Bureau of the Census, the Wilshire Community Plan area lost 14,000 people between 2000 and 2010. 

2. The Southern California Association of Government’s (SCAG’s) 2010 forecast – the Wilshire Community Plan’s horizon year -- was 59,000 people higher that the 2010 U.S. Census. 

3. By 2015, the Wilshire Community Plan was 48,000 people below the Plan’s 2010 horizon year population forecast. 

4. The population gain between 2000 and 2015 was about 1,300 people, or about 100 people per year in the entire Wilshire Community Plan area. 

5. The population gain from 1990 to the 2015 estimate is 21,841 people, or about 880 people per year. At this rate, the Wilshire Community Plan area will add 22,000 people by City Planning’s TNP 2040 horizon year. This extrapolation is 311,000 people, or 22,000 people below SCAG’s original forecast for 2010, 30 years earlier. 

6. It will take about 20 more years, until the year 2055, to reach SCAG’s 2010 forecast of 337,000 people for the Wilshire Community Plan area. 

12.The TNP conflicts with the General Plan because it presents no evidence that local infrastructure can support the additional buildings and population the plan induces through up-zoning: The City Council-adoptedGeneral Plan Framework is clear that major upzoning proposals – such as the TNP’s broad increases in heights, building mass, and density limits -- require prior evidence of sufficient local public services, infrastructure, and transportation demand reduction programs (e.g., carpooling, home occupations). 

Adopted General Plan Framework Policy 3.3.2.c.“Initiate a study to consider whether additional growth should be accommodated, when 75 percent of the forecast of any one or more category listed in Table 2-2 is attained within a community plan area. If a study is necessary, determine the level of growth that should be accommodated and correlate that level with the capital, facility, or service improvements and/or transportation demand reduction programs that are necessary to accommodate that level.” 

13. The TNP fails to present any data that existing zoning cannot support its intended building and population boom: All of the commercial corridors at or near the Purple Line Extension are zoned for commercial uses and apartments. Developers can already build apartment houses on these corridors without any zoning waivers. As a result, the TNP’s corridors, specifically Beverly, Third, Wilshire, Pico, San Vicente, Fairfax, LaCienega, and LaBrea, could be minimally built to three stories. Then, through voluntary and effectively unappealable affordable housing bonuses programs(SB 1818 and TOC Guidelines), all lots could be built to five stories, or higher – without the TNP. The claim that this neighborhood lacks sufficient zoning to accommodate future population growth is totally specious. The only growth barrier is the area’s crumbling infrastructure and strained public services. 

14. The TNP violates the City Charter: The Los Angeles City Charter states that when the City Council considers zone changes, the applicant (i.e., the TNP) must presentevidence of good zoning practices. Since zoning implements the General Plan’s mandatory and optional chapters, the TNP’s up-zoning should, therefore, follow, not precede, General Plan updates. This includes the General Plan’s Land Use Element, which contains LA’s 35 community plans. Since the Wilshire Community Plan begins its three-year update in 2021, all local land use changes, including the TNP, should be tabled until these good zoning practices are demonstrated. 

15. The TNP does not include any amenities that facilitate transit use: The $7.5 million grant that METRO gave the Department of City Planning to prepare five Transit Neighborhood Plans calls for “attractive streetscapes and new community amenities.” These public improvements are certainly welcome and are critical to the success of any transit plan, yet the Purple Line TNP offers no public improvements for the proposed up-zoning corridors or for its larger study area.  

16. METRO’s Purple Line Extension website makes no mention of the TNP.How odd that a land use program that is supposedly essential to the Purple Line Extension is invisible to METRO. A careful review of the METRO website, including the section devoted to the Purple Line Extension, does not include a word about the Purple Line Transit Neighborhood Plan. The obvious explanation is that the TNP uses mass transit as a plausible cover story to fast track the up-zoning of popular neighborhoods that happen to be near new subway stations. 

17. The Purple Line TNP totally ignores existing residents: Many local residents already live in affordable apartments and use transit, and many more could become bus and subway riders if offered the right incentives and public improvements. But, the TNP does not offer them any incentives or improvements, such as subsidized TAP cards in new buildings, free or reduced subway fares improved sidewalks, boulevard trees, safe crosswalks, bicycle parking and grade separated bicycle lanes, and bus and car interface facilities at the Purple Line stations. It is all missing; more evidence that this plan’s actual goal is real estate speculation, not increasing transit ridership, walking, bicycling, or home occupations. 

18. The Purple Line TNP ignores City Planning’s extensive efforts to promote Transit Oriented Districtsin lieu of Transit Oriented Development (i.e., Transit Adjacent Market Housing). For example, the extensive list of first-mile, last-mile programs in City Planning’s impressive Transit Hubs document are omitted in the TNP. Even though the Department of City Planning has prepared an excellent document describing many available planning tools to promote non-car mobility, the TNP staff apparently never “got the memo.” Maybe this is why the TNP never proposes such no-brainers as improved sidewalks with ADA curb cuts, tree canopies, and shorter cross walks?  

19. The TNP does not include any inspection or monitoring programsto ensure that the plan’s intended outcomes appear. Will new residents use transit more than displaced current residents?Unknown. Will new affordable housing displace existing affordable housing? Unknown. Will pledged affordable rental units remain affordable or will they quickly and illegally revert to market rate housing? The TNP has no mechanisms to measure these outcomes and no way to prevent any SB 1818 or Transit Oriented Community affordable units from being quickly rented out at market rates, already a common practice in Los Angeles. 

20. Re-code LA zones for the TNP area do not appear on the re:code LA site.The Environmental Scoping Document, which was the focus of the July 26 open house, states that TNP would include new re:code LA zones, potentially reducing parking requirements. Not only are these changes missing from any public documents, but the re:code LAweb site also makes no mention that these new zones will soon be folded into the Purple Line Transit Neighborhood Plan. 

Next Steps 

These top 20 giveaways make it clear that the Purple Line Transit Neighborhood Plan is a total fraud.  It has nothing to with reducing car use or increasing transit ridership. Its purpose is to facilitate real estate speculation in new apartment and commercial buildings, regardless of their impacts on transit ridership or local housing markets. 

This is why the Purple Line Transit Neighborhood Plan should be tabled and then prepared correctly.  It needs to be part of the Wilshire Community Plan update. It needs to be developed through extensive outreach to all community groups in the Wilshire Community Plan area, and the eventual plan must represent a community consensus. The current approach of secretly and quickly developing a land use plan whose real purpose is to fuel real estate speculation must end.    

More to the point, even though elected officials claim they, too, were out of the TNP loop, they are now in the driver’s seat. It is their job to make sure the Wilshire Community Plan is correctly updated. They must make sure it is not carved up years ahead of its formal update, allowing some local property owners to either enjoy a financial windfall through zoning upgrades or build large upscale buildings without zoning waivers and environmental assessments.

(Dick Platkin is a former LA city planner who reports on local planning controversies for CityWatchLA. Please send any questions, comments, or corrections to [email protected].) Prepped for CityWatch by Linda Abrams.