After a second marathon meeting (this one clocking in at seven hours, while a previous discussion ran 6 1/2 hours), the City Planning Commission on March 18 gave its approval to the current draft of the Hollywood Community Plan, with a few suggested revisions, and passed it along to the Los Angeles City Council, where it will receive further deliberation and public hearings.
The CPC first discussed the current draft of the HCP, submitted by the City Planning Department after several years of discussions with neighborhood groups and other stakeholders, on February 18. But after a lengthy Planning Department presentation, and several hours of public comments, the Planning commissioners did not have time to finish their deliberations, and identified several specific issues for further discussion. These included:
- Optimal base and maximum Floor Area Ratio (FARs) for development projects in the Regional Center (the busiest and densest area of Hollywood)
- Housing stability and tenant protections
- Development thresholds for five transit-adjacent Corridor areas identified in the plan
- Hotel development
- Rules for the Media/Studio District
- Street vending
- Historic preservation
- Parks and open space
- R1 residential zones
At last week’s meeting, the Commissioners addressed each of these issues individually, with the Planning Department providing additional background to inform the discussion.
Regional Center Floor Area Ratios
The current draft of the Hollywood Plan identifies a Regional Center area, which covers the part of the Plan area with the most intense land use. The goal in this area is to encourage development of businesses, hotels, and housing – especially affordable housing – while also preserving the resources and character that draw people to the area in the first place.
The plan proposes to do this by setting a minimum (or base) Floor Area Ratio (the ratio of a building’s total floor area to the size of the lot it sits on) for new buildings, with bonuses that can significantly increase the allowed FAR if developers include specific community benefits, such as affordable housing or open space accessible to the community.
At the first Plan hearing in February, there was significant discussion of where to set both the base and maximum allowable FAR for the Regional Center, with the current draft of the plan setting a base FAR at 3.1, and specifying bonuses developers could claim that would move the maximum FAR up to 4.5:1. But some stakeholders and Planning Commissioners argued that those limits might not be high enough to incentivize affordable housing over market rate housing (since building more units overall can also encourage developers to build more affordable units), and suggested setting the base FAR at 4.5:1 and setting a maximum FAR, if developers meet bonus requirements, of 6.5:1 or even more.
To show how this could play out, the Planning Department presented a map at last week’s meeting, showing the maximum FAR currently proposed for the various parts of the Regional Center area…
And how those ratios could change, with increased height and density, if the maximum FAR in this area were increased to 6.5:1 with specific affordability bonuses, as some Commissionsers suggested:
For more specific examples, the Planning Department also provided images of buildings that could be built in one of these subareas with a maximum FAR of either 4.5:1 or 6.5:1. The one below shows the kind of buiding that could be created with a maximum FAR of 4.5:1…
And this one shows a building with a 6.5:1 FAR:
Commission President Samantha Millman led off the FAR discussion by saying she has “zero interest in developer giveaways” when it comes to FAR and possibly increasing the size of new buildings allowed by the Plan. But she said she does want to make sure the city actually incentivizes affordable housing construction, and the way to do that may be to allow more units overall, by setting higher base and bonus FARs. Millman said she worries that keeping building sizes too small would only encourage development of market-rate housing, with no or very few affordable units (as can now be built with current Transit Oriented Communities guidelines). So she proposed increasing the base FAR in the Regional Center area to 4.5:1, with bonuses allowing it to rise to 6.5:1.
Several commissioners agreed with Millman, but others disagreed, noting that it might be better to keep the base FAR at 4.1, but allow smaller units in each building, which could also increase the number of units – including affordable units – that would be built, without creating significantly larger buildings.
In a straw poll after the initial discussion on this topic, the commissioners tied 4-4 on the topic of whether or not to recommend higher FARs than currently specified for the Regional Center area. But later in the meeting, Millman offered a compromise proposal, which would set a base FAR of 4.0:1 in this area, with developer bonus opportunities that could increase it to 6.5:1. And density would be determined only by the size of the building envelope, allowing more smaller units in each building. This proposal won a 5-3 margin of acceptance in another straw poll.
Housing Stability and Tenant Protections
The second major topic of discussion last week was how to maintain or replace existing affordable housing in the Hollywood area, how to assure that designated “affordable” units will remain affordable over time, and what the rules are for allowing tenants of current affordable units to return to similarly affordable units in new construction that might replace their current homes.
Right now, the city handles maintenance of affordable unit counts by requiring developers to replace any affordable units they demolish with at least the same number of affordable units in their new projects. But there are questions about whether those replacement units should or shouldn’t count toward the minimum number of affordable units developers must build to receive certain construction bonuses. Currently, replacement units are counted in the minimums required from developers…but housing advocates say not counting replacement units in minimum requirements would be better, and that this would force developers to build more affordable units at each site, and thus increase the overall number of affordable units in the city’s housing stock, rather than just maintaining it at current levels.
The question of whether or not this change would be better made in citywide development regulations instead of the more local Hollywood Community Plan was raised at the CPC’s February meeting, but Planning Department representatives pointed out at this meeting that both the city’s Transit Oriented Communities guidelines and Density Bonus program were formed under statewide regulations and Measure JJJ, which specifically state that the number of affordable units developers are required to build be “inclusive of” replacement units (i.e. replacement units built under these programs mush count toward developers’ required totals). So this is not something the city can change in those programs, but is something that could be addressed in the HCP…if it applied only to developers working in the HCP area, who are not taking advantage of TOC or Density Bonus rules.
As for the maintenance of affordability status over time, this is addressed through the use of covenants setting the number of years affordability must be maintained. At the moment, the city’s covenant length is 55 years, but some people have proposed it be set at 99 years, or even made permanent. At the moment, said Planning Department presenters at this meeting, the city is considering making these changes citywide, via modifications to the Housing Element of the City’s General Plan, but that process is still in the works and won’t be done for a while. However, they noted that here, too, some statewide rules – setting covenant lengths at 55 years – are also in play, which makes local changes challenging. Also, they said, if covenants are increased under HCP rules, developers might choose to build instead under the less restrictive TOC or Densit Bonus programs, which would also result in fewer new affordable units overall.
Finally, Planning Department presenters also pointed out that statewide laws also govern tenants’ “right of return” when an existing unit is demolished, which – as with the issue of replacement units – makes policy adjustments at the city level more complicated.
In the Commissioners’ deliberations of tenant protections, the discussion centered mostly on whether they would prefer to the issues locally, within the Hollywood Community Plan, or whether they would like to encourage the city to enact wider rules to cover all areas of the city with uniform policies. While most of the commissioners expressed a preference for advocating for citywide rules on these topics, several said that while they agree that is the best solution in the long run, the city may be a long way from implementing better tenant protections through other channels, and they have the power now to address at least some of the problems locally, through the HCP, while the city works things out on a larger scale.
In the end, a straw poll indicated five commissioners in favor removing these measures from the HCP and encouraging citywide action, while three were in favor of addressing them through the HCP.
Height and FAR in Five Transit-Adjacent Corridor Areas
In addition to identifying specific development rules for the most intense Regional Center area of Hollywood, the Hollywood Community Plan draft also sets “base and bonus” policies for Floor Area and height limits for five levels of transit-adjacent Corridors along Sunset Blvd., La Brea Ave., Melrose Ave., Santa Monica Blvd, Vine St., and Western Ave.
According to the Planning Department presenters at the meeting, these Corridors were originally developed with low-density (mostly 1-2 story) commercial buildings, and the goal is to allow some increases in size and height in exchange for including affordable housing in new multi-family construction, while not overwheming nearby lower-density residential areas.
At their February meeting, the Commissioners, united in their quest to encourage as much affordable housing development as possible, agreed on recommending that the five Corridor areas be condensed into just two such areas, one containing the two lowest density areas of this type, and one containing the three higher density areas. And they also discussed whether or not to open up development opportunities Hillhurst Ave., in Los Feliz, by removing height limits there altogether. (Hillhurst is not officially within one of the specific Corridor areas, but the commissioners identified it as being similar in character to the other Corridor areas.)
At this meeting, during which a number of Los Feliz-area residents spoke in vehement opposition to removing Hillhurst height limits, Millman opened the commissioner discussion by noting that “no one wants skyscrapers” on Hillhurst, but saying housing production could be increased there by allowing heights to be determined by FAR base-and-bonuses, rather than imposing strict height limits. And in the end, the other commissioners agreed.
Hotel development, and how it should be handled particularly in residential areas, has been another hot topic during HCP discussions, with large numbers of Hollywood residents and housing activists asking the city to ban hotels in residential areas, to preserve existing housing stock.
According to Planning Department staff at Thursday’s meeting, new hotels are currently forbidden in multi-family zones of the Hollywood Community Plan area, and new hotel projects in the Regional Center area (dark blue portion of the map below) require a Conditional Use Permit, which involves a community input process, if they will replace any residential units. Conditional Use Permits are also required for hotels in other residential parts of the HCP area, including those adjacent to commercial areas.
According to the staff presenters, there are currently 21 hotel projects planned or under construction in the Regional Center, and none have replaced any residential units – just parking lots or commercial buildings. The Planning Department’s recommendation in the current HCP draft is to ban hotels in residential areas, and to require a CUP in other areas if a hotel will replace any residential units.
Moving into the commissioner discussion on this point, Millman said she thinks the recommendations are a good solution to the hotels vs. housing issue. Commissioner David Ambroz, however, objected to the outright ban of hotels in residential areas, saying he doesn’t like absolute rules that don’t allow for future changes as situations evolve. And others questioned whether or not there was language that could be included in the plan to encourage hotels to use more local labor.
In the end, there was unanimous agreement to support the Planning Department’s proposal in the current Plan draft, with some additional language supporting local hiring in hotel projects.
Height Limits in the Media/Studio District
In the Media District section of the Hollywood Community Plan area, Planning staff said the goal of the current proposal is to increase allowable Floor Area Ratios to allow construction of new entertainment production and post-production facilities, while preserving the more historic “theater row” along Santa Monica Blvd., which is home to a large number of small live theater venues.
The major question that came up in previous discussions of the Media District was whether or not to remove a 36-foot height limit for new buildings, which studio personnel testified would hamper their ability to build the kinds of spaces they need for modern office-based production, and representatives of commercial property owners contended would devalue land they might want to sell to developers.
During the commissioners’ discussions, Millman proposed modifying the current height-limiting “Q” condition for this area, but maintaining parking requirements that would help the small theatrical venues. Commissioners agreed unanimously with this proposal.
The question of whether or not street vending should be allowed on Hollywood Blvd., to help enliven the streetscape in this high traffic and high tourist area, came up during the February discussion of the HCP, but the commissioners did not have time to address it at that meeting.
This month, Planning staff explained that StreetsLA controls rules for street vending on Hollywood Blvd., where the activity is currently prohibited altogether. So while technically there is nothing that can be done to change this via the Hollywood Community Plan, it might be possible to propose an additional policy that would support the activity near transit stops, and particularly along the Walk of Fame. (Street vending is legal in other parts of the HCP area.)
The commissioners were generally supportive of allowing street vending, especially along the Walk of Fame, provided that it is within their powers to do so (which several agreed it may not be), and they agreed unanimously to support language regarding street vending in this draft of the Plan.
In general, the HCP draft attempts to encourage preservation of Hollywood’s historic resources by acknowledging established National Historic Register districts, maintaining National Register eligibility for other historic sites and districts that qualify for such recognition, and by allowing the transfer of development rights from historic to non-historic properties in the Regional Center area. Also, within the Hollywood Blvd. National Register District, all new development projects would be subject to review by the city’s Office of Historic Resources, future historic survey data could be considered, and zoning and parking standards would help to facilitate re-use of existing buildings.
The big question remaining for the Comissioners in the discussion of preservation in the current HCP draft was the question of “5S3” properties – individual buildings that are deemed historic according to some criteria but which are not individually designated landmarks or part of a recognized historic district. In the current draft, these properties – about 20 in the Hollywood Community Plan area, according to Planning staff – are not specifically included in the Plan’s preservation protections…but at least some Commissioners felt they should be, especially because, as Commissioner Karen Mack pointed out, most contain fairly affordable, and often rent-controlled, housing units that could easily be lost to new development.
After some discussion, however, most of the commissioners said protecting properties without official designations would be difficult, because terms like “appears” to be eligible for protection are too (in the words of Commissioner Dana Perlman) “squishy.” In the end, seven of them expressed support for the current Plan language, with only Mack continuing to object.
Parks and Open Space
During discussion of Parks and Open Spaces, commissioner Yvette Lopez-Ledesma proposed a small change to the wording of one proposed policy statement calling for improved park access, but there were no other discussions or proposals. All commissioners agreed with Lopez-Ledesma’s suggestion.
R1 Residential Zones
Because the topic of single family zoning, and its historic equity issues, came up at the previous month’s discussion, Planning staff provided an overview of Hollywood’s single family areas at last week’s meeting. According to the presentation, single family zones account for 31% of the total Hollywood Community Plan area, and exceed the amount of space recommended by Southern California Association of Government’s projections for housing growth in the area by 17%.
That said, however, the staff presenters also pointed out that 84% of the Single Family zone areas are in hillside districts, which are not generally appropriate for other kinds of development. Only 16% of Single Family areas are in the “flats” of Hollywood, and Historic Preservation Overlay Zones account for just 6% of single family areas in Hollywood.
Finally, according to the staff presentation, many single family lots have already doubled their original density with the construction of ADUs in recent years:
While discussing single family zones (which Commissioner David Ambroz said at the last meeting “should just go away”), several commissioners noted that while there’s not much that can be done about the hillside areas, the 16% of single family zones in other parts of the plan area should be considered for actions that could help mitigate historic exclusions. Among the tactics suggested were a plan to eliminate single family zones altogether, as some other cities have recently done, creating mitigations (such as sprinkler systems and better access routes) that would allow more multifamily development in hillside areas, and encouraging both ADUs and “junior” ADUs on single family lots.
But while Mack called this “one of the most important conversations we need to have,” and pointed out the importance of making changes locally instead of allowing the state to dictate policy for the city, no specific modifications to the plan language were proposed.
In the end, Commissioner Millman moved that the Commission support the current draft of the Hollywood Community Plan, with the following modifications:
- That the base FAR for the Regional Center area be set at 4.0:1, with affordable housing bonuses that allow it to go up to 6.5:1
- That the originally proposed five levels of transit-adjacent Corridor areas be reduced to just two
- That height limits be removed from Hillhurst Ave., allowing building height to be governed by FAR base and bonuses instead
- That a new policy recommendation to improve park access be included
- That street vending language be amended as discussed above
- That Studio District language be amended as discussed above
- That hotel project prequalifications include a process for hiring contractors based on livable wages and local hiring
The motion passed with five commissioners in favor, and two (Mack and Helen Leung) opposed. (Commissioner Ambroz left the meeting before the vote was taken.) The draft will now move to the City Council for further discussion and possible revisions.