Aia_la Final Draft Position on the Nii

8/19/2019 Aia_la Final Draft Position on the Nii

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AIA|LA

AIA Los Angeles3780 Wilshire Blvd., Suite 800 - Los Angeles, CA 90010

(213) 639-0777

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AIA|LA Supports Smart Community Planningand Opposes the

“Neighborhood Integrity Initiative”One of the ballot initiatives proposed for this November’s election is touted as the big fixto the City of Los Angeles’ planning and development approval process. The Coalition toPreserve L.A. claims that the so-called “ neighborhood integrity initiative ” will mend theCity’s broken planning system. While the Los Angeles Chapter of the American Instituteof Architects (AIA|LA) has consistently advocated for improvements to the City’sapproach to long-range planning and permitting, we find that this ballot initiative will notfix the City’s planning woes; it will make them worse.

The proposed initiative will not solve traffic congestion, it will actually make trafficcongestion worse. The initiative will not preserve the authenticity and character of oursingle-family neighborhoods, it will actually re-direct the pressures and impacts ofdevelopment from our urban centers and commercial corridors and into our city’s mostcharming enclaves.

In fact, we are concerned that this prospective ballot initiative may adversely impact thehealth, safety and economic vitality of our region by placing a two-year moratorium onsizeable construction projects in the City of Los Angeles and prohibiting neighborhoodsfrom having the power to determine their own unique vision for the future.

The AIA|LA believes that we as city need to invest more resources into updating allthirty-five community plans effectively and comprehensively, with a strong emphasis onthe inclusive community outreach and environmental analysis each update requires.Inclusive and smart community planning becomes the path forward to achieve a safer,healthier, more equitable and delightful Los Angeles – a future Los Angeles thatempowers greater human connectivity, creativity and prosperity for all.

Hence, preserving the Los Angeles of the past with its current inequities is not inanyone’s best interest. The neighborhood integrity initiative will severely restrict theability of communities to determine their own vision for future growth. The initiative takesa “one size fits all” approach to planning and requires all zoning conditions and any

future projects to mimic the existing built environment irrespective of an individualcommunity’s vision for future improvements. A planning process that responds to aneighborhood’s unique aspirations would become impossible if the ballot measurepasses.

This ballot initiative will detrimentally reduce access to good quality housing at affordablerates for young singles, new families and working people throughout the City. It will alsoimpact housing opportunities for the homeless and the working poor, just at the timewhen L.A.'s need for more housing is most dire. The provisions of the initiative all but



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eliminate the planning tools that make the large majority of affordable and homelesshousing developments possible. In fact, the initiative preserves the current inequitablegrievances that we’re all trying to correct.

Instead of jump-starting creative and forward-thinking planning at the grass roots, theinitiative will create a planning logjam that together with a two-year building moratoriumwill put an immediate halt to construction and chase investment away to other cities inthe region.

Many of the initiative’s provisions contradict existing state and local laws. For example, itwould make it impossible for the City of Los Angeles to comply with State housing goals.The litigation that is certain to ensue, should the initiative pass, will cost taxpayersmillions of dollars and create years of gridlock and uncertainty for communities for yearsto come. The complex issues at stake deserve more careful consideration (andsolutions-oriented consensus building) than a simple yes or no vote at the ballot box.

AIA|LA strongly opposes the neighborhood integrity initiative and encourages its 3600+members to actively engage with their neighbors, clients and vendors and share theseconcerns. As a leadership resource, AIA|LA and its members stand ready to assist Cityleaders and the community as a whole to make workable, common-sense changes tothe City's planning and approval process through both community input and thelegislative process.

AIA|LA is formally requesting that Council President Herb Wesson and the Los AngelesCity Council to:

1. Direct the Los Angeles Department of Building and Safety to analyze thepotential fiscal impacts to their enterprise fund, to the city’s general fund, andupon overall construction activity if the potential ballot measure were to be law.

2. Direct the City Attorney to analyze litigation risks to which the city would bevulnerable from lawsuits filed by affected parties and from the City not complyingwith various State of California mandates related to housing, environmental airquality, etc. were the proposed ballot measure to become law.

3. Direct the Department of City Planning to provide an estimate for how much it willcost the City to effectively and comprehensively review and update all thirty-fivecommunity plans within a two year timeframe, including staffing required for

project management, oversight and procurement of contractors necessary toperform the work – with a strong emphasis on the inclusive community outreachand environmental analysis required.



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BACKGROUND ON THE “NEIGHBORHOOD INTEGRITY INITIATIVE”

"The planning fix that isn't one." The ballot initiative claims it will fix a broken and corrupt planning process. It doesnothing of the sort. Instead, its provisions actually restrict planning to mimic what’salready built regardless if the community has another vision for its future.

For instance , Section 5, provision D, paragraph 5 reads, “the proposed amendment willnot permit development at a density, scale or intensity (including floor to area ratio,height and permitted use) inconsistent with the majority of already developed parcelswith a quarter-mile radius”.

That provision, which is a central tenet of the initiative prohibits a community’s ability toevolve from its current existing (and perhaps blighted) condition to a future improvement,which may be more apt for how a neighborhood selects to grow.

"This ballot initiative would halt many multi-family residential development at thetime of Los Angeles' greatest need for more housing." Housing in Los Angeles is more unaffordable than it’s ever been. Many multi-familyresidential developments, particularly those on boulevards away from single-familyneighborhoods, require zoning or General Plan amendments. If passed, the initiativetakes away these tools that are key to addressing the City’s housing affordability crisis.

"This ballot initiative would reduce access to housing for the homeless and theworking poor." Workforce and affordable housing is typically built on underutilized sites that requirezone changes or General Plan amendments. By rescinding these tools, the ballotinitiative makes these sites all but inaccessible for housing for the homeless and workingpoor. Furthermore, it would jeopardize the ability to apply for county, state and federalaffordable housing funds.

"Far from engendering good city planning practice, this initiative would all butfreeze Los Angeles neighborhood revitalization, regardless of the community'spreferences."If passed, the initiative will enact new code provisions that freeze in place an outdatedvision from the past. Instead of capitalizing on the region’s extraordinary investment in

transit, it makes sure Los Angeles can never get away from the congestion and airpollution that comes from over-reliance on the automobile.

"This initiative is not about empowering community; it's about stoppingdevelopment in Los Angeles."While the initiative critiques the status quo of L.A.’s City planning and project approvalprocess, most of its provisions would stop new development. It would rescind alreadygranted planning approvals and place a two-year moratorium on new entitlements.



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"If approved, the initiative's provisions would open every step of the buildingprocess to legal challenge."The initiative requires City staff to make “findings” along every step of the project reviewand approval process down to the City inspector signing off a minor building project.Because findings can be challenged in court, even a sign-off for a simple reroofing jobcould be brought before a judge.

"The proposed initiative conflicts with Los Angeles and California law; instead ofcertainty it would produce uncertainty for years to come." The initiative conflicts with planning law at both the City and State level, which could leadto years of unnecessary litigation. For instance, it would make it impossible for LosAngeles to meet state housing goals contained in the Housing Element.

"The initiative's vague requirements would produce unintended consequences fordecades to come." Too much of the initiative is vague and poorly written. Any changes to it must again beapproved with a popular vote. Even minor corrections would require another ballot. In theabsence of a mechanism to fix unintended consequences the initiative would becontested in the courts, creating uncertainty for decades to come.

For more information, please contact:

Will Wright, Hon. AIA|LA Director, Government & Public AffairsAmerican Institute of Architects/Los Angeles Chapter3780 Wilshire Blvd, Suite 800Los Angeles, CA 90010(213) [email protected]

Documents

Aia_la Final Draft Position on the Nii