Please share with your distribution lists:
The Department of City Planning invites you to attend one of four upcoming
informational meetings about the proposed Core Findings and Community Care
Facilities Code Amendments. For more information about both of these
efforts including the staff report and draft ordinances, please see the
"What's New" section of the Planning Department's homepage: *
www.planning.lacity.org*
Meetings will be held on September 25th, and October 2nd, 6th and 9th at the
following times and locations:
SOUTH LA
September 25, 10 am - 2 pm
Betty Hill Senior Center
3570 S. Denker Avenue
Los Angeles, CA 90018
(auditorium)
NORTHEAST LA
October 2, 10 am - 2 pm
El Sereno Recreation Center
4721 Klamath Street
Los Angeles, CA 90032
(community room)
WEST LA
October 6, 5-9 pm
Felicia Mahood Senior Center
11338 Santa Monica Blvd
Los Angeles, CA 90028
(auditorium)
VALLEY
October 9, 10 am - 2 pm
Marvin Braude Center
6262 Van Nuys Blvd
Los Angeles, CA 91401
(1st floor meeting room)
Important Upcoming Dates to Remember:
10/7: Last day for formal written comments to Commission Secretariat on Core
Findings & Community Care (Please note that comments are also taken at CPC
on these items both verbal and in writing)
10/14: CPC Meeting, Thursday, after 8:30am, City Hall, 200 N. Spring St.,
Room 1010, 10th Floor, Los Angeles, CA 90012
Please see the attached flyer for more information about these information
sessions.
For questions, please contact Gabriela Juarez at
gabriela.juarez@lacity.org or
(213) 978-1337.
--
Gabriela Juarez
Department of City Planning
Code Studies Section
200 N Spring St, Room #763
Los Angeles, CA 90012
Mailstop: 395
Ph: (213) 978-1337
Fax: (213) 978-1334
Friday, September 17, 2010
Tuesday, September 14, 2010
Comment Letter Re: Core Findings
September 14, 2010
To The City Planning Commission:
Re: CPC-2010-1572-CA
The first paragraph of the Staff report for this Ordinance states:
“Pursuant to Charter Section 558 and Section 12.32-A of the Los Angeles Municipal Code, the Director of Planning has initiated development of six recommended zoning code amendments intended to streamline and simplify the Department's case processing function. The attached Appendix A is the first of these six proposed ordinances to be presented to the City Planning Commission.”
As such, the Director of Planning for the City of Los Angeles has initiated a project that proposes to be implemented in 6 segments, commencing with this first Ordinance. It is impossible for the public to evaluate this Ordinance because of the large unknown scope of the entire project. We disagree that this ordinance is simply changing words and will have no impact on discretionary actions. Changing a finding from “That there are special circumstances applicable to the project or project site which make the strict application of the specific plan regulation(s) impractical to “That the project will enhance the environment in the surrounding neighborhood or will perform a function or provide a service that is essential or beneficial to the community, city or region” is not a small matter to those in the community. It is also hard to understand how eliminating the language in 11.5.7 C 2 (b) dealing with mitigation measures or monitoring helps the community. It may or may not be redundant of CEQA but it should not be omitted given the City’s poor record with mitigation measures as outlined in several City Controller Audits as well as the City’s non compliance with the Framework Element’s monitoring program and Annual Reports on Growth and Infrastructure.
Given that this “project” appears to be a major rewrite of the Administrative code, for whatever reason, the City should not do it in segments. It will be impossible for the public to determine if one finding complements or conflicts with another as the project unfolds. The City must do a through evaluation of the entire code and present one clear, ordinance in the form of a full Environmental Report that the public can evaluate and comment on.
Before it does that, the City must complete the required Annual Reports on Growth and Infrastructure, not compiled and distributed since 2000. The Reports are specific and essential mitigation cited by the City as part of the General Plan Framework. The Report was to inform the city on all environmental approvals. The Statement of Overriding Consideration stated:
Absent the report and its findings on actual versus expected growth, actual versus expected infrastructure improvements and availability of infrastructure, the city cannot provide a statement of consistency with the General Plan, and depending on the area, the Community Plan. Most of the Community Plans in the City rely on the Report. Model language (taken from the West L.A. Community Plan) appears as follows:
“Accordingly, the proposed Plan has three fundamental premises. First, is limiting residential densities in various neighborhoods to the prevailing density of development in these neighborhoods. Second, is the monitoring of population growth and infrastructure improvements through the City’s Annual Report on Growth and Infrastructure with a report to the City Planning Commission every five years on the West Los Angeles Community following Plan adoption. Third, if this monitoring finds that population in the Plan area is occurring faster than projected; and, that infrastructure resource capacities are threatened, particularly critical ones such as water and sewerage; and, that there is not a clear commitment to at least begin the necessary improvements within twelve months; then building controls should be put into effect, for all or portions of the West Los Angeles Community, until land use designations for the Community Plan and corresponding zoning are revised to limit development.”
The City should not approve any project unless and until it has prepared the required Report and can make a finding that there is sufficient infrastructure citywide.
Project-based EIRs and even Community-Plan level analysis is not sufficient to overcome the necessity for the Report. The General Plan EIR stated:
“focusing the analysis at the neighborhood level may be too myopic resulting in a loss of "overview" or "the big picture".
Any projects which rely on a faulty approval may be subject to court rulings in the matter. We reserve the right to challenge any faulty approvals issued by the City.
Sincerely:
James O'Sullivan
213-840-0246
Fix The City
Fixlosangeles.com
Miracle Mile Residential Association
cc. Mayor, City Attorney, City Controller, City Council members, Director of Planning
To The City Planning Commission:
Re: CPC-2010-1572-CA
The first paragraph of the Staff report for this Ordinance states:
“Pursuant to Charter Section 558 and Section 12.32-A of the Los Angeles Municipal Code, the Director of Planning has initiated development of six recommended zoning code amendments intended to streamline and simplify the Department's case processing function. The attached Appendix A is the first of these six proposed ordinances to be presented to the City Planning Commission.”
As such, the Director of Planning for the City of Los Angeles has initiated a project that proposes to be implemented in 6 segments, commencing with this first Ordinance. It is impossible for the public to evaluate this Ordinance because of the large unknown scope of the entire project. We disagree that this ordinance is simply changing words and will have no impact on discretionary actions. Changing a finding from “That there are special circumstances applicable to the project or project site which make the strict application of the specific plan regulation(s) impractical to “That the project will enhance the environment in the surrounding neighborhood or will perform a function or provide a service that is essential or beneficial to the community, city or region” is not a small matter to those in the community. It is also hard to understand how eliminating the language in 11.5.7 C 2 (b) dealing with mitigation measures or monitoring helps the community. It may or may not be redundant of CEQA but it should not be omitted given the City’s poor record with mitigation measures as outlined in several City Controller Audits as well as the City’s non compliance with the Framework Element’s monitoring program and Annual Reports on Growth and Infrastructure.
Given that this “project” appears to be a major rewrite of the Administrative code, for whatever reason, the City should not do it in segments. It will be impossible for the public to determine if one finding complements or conflicts with another as the project unfolds. The City must do a through evaluation of the entire code and present one clear, ordinance in the form of a full Environmental Report that the public can evaluate and comment on.
Before it does that, the City must complete the required Annual Reports on Growth and Infrastructure, not compiled and distributed since 2000. The Reports are specific and essential mitigation cited by the City as part of the General Plan Framework. The Report was to inform the city on all environmental approvals. The Statement of Overriding Consideration stated:
Absent the report and its findings on actual versus expected growth, actual versus expected infrastructure improvements and availability of infrastructure, the city cannot provide a statement of consistency with the General Plan, and depending on the area, the Community Plan. Most of the Community Plans in the City rely on the Report. Model language (taken from the West L.A. Community Plan) appears as follows:
“Accordingly, the proposed Plan has three fundamental premises. First, is limiting residential densities in various neighborhoods to the prevailing density of development in these neighborhoods. Second, is the monitoring of population growth and infrastructure improvements through the City’s Annual Report on Growth and Infrastructure with a report to the City Planning Commission every five years on the West Los Angeles Community following Plan adoption. Third, if this monitoring finds that population in the Plan area is occurring faster than projected; and, that infrastructure resource capacities are threatened, particularly critical ones such as water and sewerage; and, that there is not a clear commitment to at least begin the necessary improvements within twelve months; then building controls should be put into effect, for all or portions of the West Los Angeles Community, until land use designations for the Community Plan and corresponding zoning are revised to limit development.”
The City should not approve any project unless and until it has prepared the required Report and can make a finding that there is sufficient infrastructure citywide.
Project-based EIRs and even Community-Plan level analysis is not sufficient to overcome the necessity for the Report. The General Plan EIR stated:
“focusing the analysis at the neighborhood level may be too myopic resulting in a loss of "overview" or "the big picture".
Any projects which rely on a faulty approval may be subject to court rulings in the matter. We reserve the right to challenge any faulty approvals issued by the City.
Sincerely:
James O'Sullivan
213-840-0246
Fix The City
Fixlosangeles.com
Miracle Mile Residential Association
cc. Mayor, City Attorney, City Controller, City Council members, Director of Planning
Saturday, September 11, 2010
Comments to the Citywide Urban Design Guidelines
From Dick Platkin
I have quickly looked over the three sets of design guidelines and have several reactions.
First, the Framework already has a design chapter, Chapter 5, which is quite good. If these three sets of design guidelines are to augment and update the Framework as appendices, then why is there is no effort to connect these new guidelines with the existing, adopted guidelines? There are obviously many points of connection, yet at no point is there any effort to amend the existing document's design section.
Second, I cannot think of any situations since 1995 where the Framework's Chapter 5 was ever used or invoked to modify a project's design or to make a legal findings. So, why should the Framework now be implicitly updated, if it design role has been continually ignored?
Third, just as the original design chapter was flushed down the memory hole, I would expect the same for these three new appendices. They can't be used for most buildings because they are built by right and only require LADBS-issued building permits. In those cases all the LADBS plan checkers do is review projects for compliance with the LAMC's Building Code and the Zoning Code.
Plus, the appendices can't be used for Specific Plan and CDO projects because these regulations already have their own Design Guidelines, and there is no legal or administrative procedure to supersede those with these three design documents.
Furthermore, they can't be used for Plan Amendments and Zone Changes because those only relate to use, not the structure built on the desired use.
So, even if the three sets of design guidelines were better linked to the existing General Plan Framework, I can't think of many discretionary actions where a Zoning Administrator or Planner would be able to use these design guidelines to modify a proposed project.
Fourth, the problems of the Framework are not addressed by new Design Guidelines. The Framework is the heart of the city's General Plan, yet its horizon year of 2010 is nearly over, with no known efforts to update it or even resume monitoring the General Plan after a hiatus over 10 years. Instead a few Community Plans are being updated to elaborate an outdated planning document. Design Guidelines are totally oblique and peripheral to what is truly needed, and, in effect, are little more than a distraction from serious planning work which Los Angeles desperately needs.
Fifth, we need to remember that design review, even if well done, can never substitute for good planning and good zoning. Though good design obviously is desirable, for the most part it is a distraction to avoid attention of the major planning and zoning issues facing a community. Instead, activists get caught up in secondary questions about window treatments, step backs, and colors.
I have quickly looked over the three sets of design guidelines and have several reactions.
First, the Framework already has a design chapter, Chapter 5, which is quite good. If these three sets of design guidelines are to augment and update the Framework as appendices, then why is there is no effort to connect these new guidelines with the existing, adopted guidelines? There are obviously many points of connection, yet at no point is there any effort to amend the existing document's design section.
Second, I cannot think of any situations since 1995 where the Framework's Chapter 5 was ever used or invoked to modify a project's design or to make a legal findings. So, why should the Framework now be implicitly updated, if it design role has been continually ignored?
Third, just as the original design chapter was flushed down the memory hole, I would expect the same for these three new appendices. They can't be used for most buildings because they are built by right and only require LADBS-issued building permits. In those cases all the LADBS plan checkers do is review projects for compliance with the LAMC's Building Code and the Zoning Code.
Plus, the appendices can't be used for Specific Plan and CDO projects because these regulations already have their own Design Guidelines, and there is no legal or administrative procedure to supersede those with these three design documents.
Furthermore, they can't be used for Plan Amendments and Zone Changes because those only relate to use, not the structure built on the desired use.
So, even if the three sets of design guidelines were better linked to the existing General Plan Framework, I can't think of many discretionary actions where a Zoning Administrator or Planner would be able to use these design guidelines to modify a proposed project.
Fourth, the problems of the Framework are not addressed by new Design Guidelines. The Framework is the heart of the city's General Plan, yet its horizon year of 2010 is nearly over, with no known efforts to update it or even resume monitoring the General Plan after a hiatus over 10 years. Instead a few Community Plans are being updated to elaborate an outdated planning document. Design Guidelines are totally oblique and peripheral to what is truly needed, and, in effect, are little more than a distraction from serious planning work which Los Angeles desperately needs.
Fifth, we need to remember that design review, even if well done, can never substitute for good planning and good zoning. Though good design obviously is desirable, for the most part it is a distraction to avoid attention of the major planning and zoning issues facing a community. Instead, activists get caught up in secondary questions about window treatments, step backs, and colors.
Thursday, September 2, 2010
Core Findings Draft Ordinance - Staff Report
Dear Interested Parties, Please find attached the staff report and draft ordinance for the Core Findings Draft Ordinance (CPC-2010-1572-CA). Of the six code amendments comprising the Code Simplification Work Program, this is the first to be scheduled for CPC. Due to the size of the attachment, the environmental review has not been attached here, however, copies are available upon request. The draft ordinance updates the zoning code’s common findings for conditional uses, adjustments, and other quasi-judicial land use approvals to provide a better framework for analyzing the merits of proposed development projects and eliminate redundancy in case processing. Please contact Tom Rothmann by email at tom.rothmann@lacity.org or by phone at (213) 978-1370 for copies of the environmental review or other questions. Please feel free to share this with anyone you believe would also be interested.
Best regards, Gabriela — Gabriela Juarez Department of City Planning Code Studies Section 200 N Spring St, Room #763 Los Angeles, CA 90012 Mailstop: 395 Ph: (213) 978-1337 Fax: (213) 978-1334
Core Findings Report
Best regards, Gabriela — Gabriela Juarez Department of City Planning Code Studies Section 200 N Spring St, Room #763 Los Angeles, CA 90012 Mailstop: 395 Ph: (213) 978-1337 Fax: (213) 978-1334
Core Findings Report
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