After Presentations to CRA and Planning, What Next for Industrial Use?
DOWNTOWN LOS ANGELES — The debate over Industrial Land Use can be a tough one for the mere resident to unravel, delving deep into zoning and city documents. The infamous joint memo delivered to staff by CRA head Cecilia Estelano and Planning chief Gail Goldberg got another two hearings in the past week as the document was presented to the pair's respective boards. In the meetings they acknowledged the controversy, made the case for their policy and outlined their view of the solution. Unfortunately for Downtown, the latter two points do nothing to address wide ranging concerns.
Unfortunately for you, this is going to take a lot of words to explain. Feel free to read on, to print the story out for weekend pleasure reading (seriously, you get three days), or to just wait a few minutes until we can post something fluffier.
A Primer on How We Got Here
For those who are new to all of this, it's helpful to understand a few things about the organization of city planning. The development of land is governed first by the city's General Plan. This document outlines a strategy for long-term growth. The City's current General Plan was adopted in 1996, and re-adopted in 2001.
On a more specific level, Community Plans set up guiding principles for each area of the city. There are thirty-five of these plans city-wide. Neighborhoods are broken out, and different preferred uses are laid out.
The bulk of Downtown falls into two Community Plan areas: Central City and Central City North (which is really misnamed -- it runs directly east of the Central City plan). In broad terms, the Central City plan governs the area west of Alameda, while the Central City North plan does the area to the east (Arts District, Industrial District, etc).
While these plans are supposed to be the guiding word of development, they simply have not been in Los Angeles. Our city has a rich history of considering land use on an ad-hoc basis, letting approvals run with the current politics whims. Also, Community Plans have traditionally been updated infrequently, via decade long processes, and are therefore typically out of date. It's a bit of a chicken and egg question, really: do we not use Community Plans because they're out of date, or are they allowed to fall out of date because we don't use them?
New Policy or Old Plan?
One critical part of the current debate is over whether or not the new directives represent new policy. Planning and CRA say that they're just instructing staff on how to fulfill a longstanding goal in the city's planning documents to preserve industrial land. The January 3rd memo starts by saying that
This memorandum provides direction and guidance to staff of the Department of City Planning (DCP) and Community Redevelopment Agency (CRA/LA) regarding industrial zoned land in the City of Los Angeles. It underscores that the City’s adopted policy is to retain industrial land for job producing uses, as established in the adopted General Plan Framework and Community Plans.
... Neither the ILUP Project nor our direction to staff contained in this memorandum takes any action that changes current land use designations or alters the City’s existing policy with respect to industrial land.
Others beg to differ. A letter approved by DLANC succinctly summarizes the opinions expressed by many Downtown stakeholders.
DLANC cannot agree with the departments’ assertion that the ILUP Memo effects no change to existing City policy. The study of industrial land uses was prompted by a long-standing practice – including decisions made by Planning and the Agency – in favor of allowing residential or mixed-use conversion of industrially-zoned land in certain areas of Downtown and elsewhere. Whether or not this trend was the result of case-by-case decisions versus a formal general or community plan update, those decisions reflected the City’s de facto policy.
In a city where formal policy is often ignored, precedent becomes policy.
Presented Solution Falls Way Short for Downtown
In a January 10th letter that the Mayor sent to the Planning Commission (and later sent to the CRA board as well), he points to Community Plan updates as the vehicle for addressing neighborhood change.
I understand that there are arguments for the continued parcel-by-parcel conversion of industrial lands. There are some good points raised here, however, this conversation should take place in the context of the Community Plan updates. This public process is designed to address planning and land use policy on a holistic neighborhood level.
This remedy has been similarly promoted by Goldberg and Estolano. The two have highlighted a much quicker Community Plan process, where plans can be prepared in three years instead of the thus-typical ten. They also praise the fact that a dozen of the thirty-five community plans are currently funded for update, meaning that a large chunk of the city can get a fresh look at land use.
Unfortunately, work has yet to begin on the funded Central City plan, and the Central City North Community Plan is not even funded for update. Given a three-year update timeline, that means that it would take longer than three years for a large chunk of Downtown to have any sort of chance for redress against this policy.
The bottom line is that CRA and Planning will (and have) immediately started basing their decision making processes on this new plan, effectively chilling any development in the affected areas for three years or longer. Given the pace of development, that's a long time.
The plan also creates a three year window for unwanted industrial development. Recyclers, pallet yards, and strip clubs are all allowed by-right in industrial zones, and new such uses will take additional time to recover from should the expected eventual changes take place.
This is a very fluid situation. As we reported on January 7th, the city council has already stepped in to decide the fate of AMP Lofts, a specific project affected by these new rules. Councilman Jose Huizar and Councilwoman Jan Perry introduced a motion on January 11th asking the City Attorney to draft language forbidding the departments from implementing the January 3rd memo. That motion is expected to reach the Planning and Land Use committee by the end of this month.
We'll keep on top of this one, and perhaps compile everything into a book when we're done.