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 Instead a few Community Plans are being updated to elaborate an outdated planning document.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.