Planning Commission Hears New Draft of Hollywood Community Plan – Part 2: Discussion

On Monday, we wrote about the details of the February 18 City Planning Commission hearing on the latest draft of the revised Hollywood Community Plan.  The Plan, one of 35 throughout the city that sets zoning and development goals for a local area, works in concert with the city’s General Plan to define the types of land use zones for different neighborhoods, and the kinds of tools that will be used in each zone to promote new development, construct more affordable housing, support business development, protect historic resources, and more.

Thursday’s meeting ran 6 1/2 hours, with most of it devoted to discussion of specific points in the draft plan.  On Monday, we looked at the details of the plan itself, and today we’ll review the lengthy discussion of those details, to see who’s speaking out on which issues, and which elements of the plan drew the most scrutiny.

In all, about 75 individual residents, advocacy group representatives, property owner/developer reps, and others provided feedback at the meeting. And then there were comments from Hollywood-area Neighborhood Councils and City Council representatives, and, finally, a lengthy discussion among the planning commissioners…who did not finish their deliberations, and will return to continue the discussion at the March 18 CPC meeting.

Public Comment

Among the more than 75 speakers during public comments, there were representatives from at least five Hollywood-area neighborhood associations, and nearly 20 interest groups focused on housing, homelessness, labor, business, entertainment studios, sustainability, churches, and more.  There were also many individual residents, several street vendors, property owners/developers, and even one current city council candidate.

Housing

In general,the greatest number of speakers during the comment session addressed housing considerations in the plan, and whether or not they go far enough to promote construction of affordable (and not just market-rate or luxury) housing…or go too far and risk destroying Hollywood’s distinctive historic character and existing affordable housing.

Kicking off the public comments, several representatives of local neighborhood associations, who have been working with Planning Department staff for several years to hammer out details of the new HCP, said the hard work has paid off and resulted in a plan they support and would like to see adopted.

Cheryl Holland, president of the Sunset Square Neighborhood Association, said these groups “did their homework,” and successfully worked with the planning department in an “excellent process.”

But many more speakers said they would like the plan to go even further than it does currently to encourage the production of new housing, and particularly new affordable housing, especially along the most dense transit corridors.  Many of these speakers referenced ideas promoted by the Just Hollywood Coalition, Unite Here Local 11, and other housing advocacy groups in what is being called the “Just Hollywood” or “4H” (“Hawks, Housekeepers, Habit and Housing”) Plan.

Among those promoting the Just Hollywood plan were representatives for 4th District City Council Member Nithya Raman, who issued a statement the night before the meeting saying she doesn’t think the current draft of the HCP goes far enough to promote new housing construction.

Raman’s Wednesday evening statement said, “we believe there are several areas within this plan that can be strengthened to ensure equitable and affordable development in Hollywood. Namely, we believe the plan can enshrine more robust protections against tenant displacement, be more ambitious in its offering of affordable housing incentives, and take additional steps to protect open space in the Santa Monica mountains.”

Raman’s statement also said she supports additional measures for the HCP recommended in the “Just Hollywood” plan.  These include:

• Excluding units that replace older affordable housing units from the required percentages of affordable units in new construction
• Making affordability covenants permanent and not limited to 55 years, as they are now
• Allowing increased public input on proposed new hotel projects, and requiring a Conditional Use Permit (which requires a public input process) for any new hotel that would replace residential units.
• Setting required percentages of affordable units under the Community Plan Implementation Overlay (CPIO) higher than those in the city’s current Transit Oriented Communities guidelines
• Eliminating parking requirements for 100% affordable housing projects
• Increasing or at least relaxing height limits for buildings with larger percentages of affordable units in transit Corridor 5 areas on Sunset Blvd., Hillhurst Ave., and portions of Hollywood Blvd. and Melrose Ave.

These points, or similar sentiments, were echoed by dozens of people on Thursday, including numerous representatives of groups such as ACT LA, Unite Here Local 11, Ground Game LA, Heart Forward LA, and LA Voice.

Many of those same speakers also specifically mentioned the topic of hotels vs. housing, with most arguing that housing should be explicitly prioritized over hotels in the HCP,  housing units should not be removed or repurposed for hotels, and new hotel projects in residential areas should be required to have a Conditional Use Permit, which allows the public to weigh in on the merits of the project.

Meanwhile, a few speakers also requested that even less space be allowed for single-family and low-density housing, especially considering the “racist” and “exclusionary” history of such zones.

Preservation

At the same time, however, a large number of other speakers, including some who supported at least a few ideas in the list above, advocated for recognition and preservation of Hollywood’s historic resources.

These speakers said measures to increase density (such as removing height limits in certain areas, and/or allowing the transfer of some development rights from historic properties to nearby new buildings) would increase tension between preservation and new development, and jeopardize the Plan’s preservation goals, actually encouraging the loss of historic resources, including many of the district’s older and most affordable apartments.

Many of these speakers urged adoption of measures promoted by the Hollywood Heritage organization in its Framework for Preservation in the Hollywood Community Plan. These include:

• Clearer documentation of historic resources
• Fewer additional developer incentives if basic Floor Area Ratios and other space-defining provisions are sufficiently generous
• Using the U.S. Secretary of the Interior Standards for historic rehabilitation when dealing with historic properties
• Not allowing demolitions of historic buildings without approved redevelopment plans
• More specific measures to mitigate the impacts of new development
• More consistency in lists of identified historic resources

Brian Curran, president of Hollywood Heritage, said the current draft of the HCP actually incentivizes the loss of historic housing, and asked the Planning Commission not to pit preservation against housing, reminding the commissioners that “historic housing is affordable housing,” and asking for more explicit protections for the area’s many historic housing units.

Also, several other speakers pointed out that affordable housing isn’t the only historic consideration, and that tourism is also important — because many tourists visit Hollywood specifically to see its historic buildings and commercial district, and not, as one commenter said, “Any Street USA.”  Losing that historic character, the speakers said, could be disastrous for the local tourist trade.

Adrian Scott Fine, from the LA Conservancy, also urged the CPC to expand the definition of eligible historic resources, and to extend protections to Hollywood’s historic bungalow courts.  Meanwhile, other speakers noted there are currently more than 300 buildings identified as historic in the Hollywood area, and urged the CPC to consider quality of life for the area’s residents, and saying the city should use vacant and otherwise available land for new construction before tearing down existing older, affordable housing.

Hillside Development

Several speakers who live in or represented various hillside neighborhoods argued that new development in hillside areas should be restricted, especially in high fire hazard zones, and that the city should study fire risks, make specific recommendations for areas where new construction should/shouldn’t be allowed, and require evacuation studies and mapping for hillside areas as well.

Commercial/Business/Studio Development

While a number of neighborhood and preservation advocates urged caution at upzoning certain areas,  a number of property owner and developer representatives argued in favor of larger Floor Area Ratios for new buildings, saying that lower FARs both limit current owners’ ability to sell to developers and developers’ abilities to build profitable new projects, leaving “density on the table” rather than maximizing the number of new units that could be built.

For example, a number of commercial property owner and developer representatives argued that setting a base Floor Area Ratio of 3:1 for the Regional Center area, as this draft of the HCP does, isn’t enough to make affordable housing cost-effective, even with incentives that could increase the FAR to 4.5:1.  The speakers suggested that the base FAR for housing and mixed use projects in commercial corridors be set at 4.5:1, with incentives that could help it reach 6:1 or more, arguing that affordable units only “pencil out” for developers if they’re allowed to build much larger projects.

In addition to the increases in Floor Area Ratio advocated by many business and property owner reps at the meeting, some of these speakers also asked that restrictions for retail and restaurant sizes be removed, and said production studios, in particular, would be hampered by the current 36-foot height limit for buildings in the media district.  Entertainment company representatives said modern office-based production requires larger, more vertical office buildings.

And finally, several business and developer representatives also argued in favor of exempting projects that are currently in the development pipeline from the new plan, because it would slow down their development process.

Open Space and Parks Access

A number of speakers spoke out in favor of greater protections in the HCP for public open spaces, something that was also addressed by Council Member Raman in her letter to the CPC.  Both Raman and the speakers who addressed this topic urged that all new lands acquired by the Santa Monical Mountains Conservancy, and the Mountains Recreation and Conservation Authority, be automatically re-zoned to open space, and that all mountain land owned by the city within the HCP area should be re-zoned as open space, too.

Sustainability

Representatives of several environmental groups requested that the HCP specifically take long-term sustainability into account, with requirements that all new buildings be fully electrified (without natural gas hookups), required to comply with current energy standards, and meet LEED Gold standards for sustainability, as well as offer incentives for residents to use public transit as much as possible.

Street vendors

Several other speakers noted that street vendors, long a part of the Hollywood street scene, are not currently included in the HCP draft, and protections for their activities should be addressed, especially since many street vendors are now competing with brick and mortar restaurants for street and sidewalk space during the pandemic.

Environmental Impact Report

Finally among public comment threads, several speakers noted that a Draft Enviornmental Impact Report (DEIR) for the proposed HCP has been completed, but said approval of the Plan itself should be held until a final EIR is completed, reviewed by the public, and accepted by the city.

Neighborhood Councils

Six different Hollywood-area neighborhood councils were represented at the meeting, with each advocating for or against specific elements of the draft HCP:

Hollywood United NC – George Skarpelis, President of the HUNC, said there is much to be appreciated in the current plan draft, especially its affordable housing goals…but he also said those goals shouldn’t come at the price of unlimited density and building into vulnerable hillside areas.  Skarpelis said HUNC supports most of the Just Hollywood plan, but the lack of a final Environmental Impact Report is a big issue, so the HCP shouldn’t be finalized until the EIR process is finished.

Hollywood Studio District NC – Representative Doug Haines said the HSDNC supports the Just Hollywood Plan, including prioritizing housing over hotels and preventing the loss of residential units to new hotel projects.  But Haines also presented a 2019 letter from the HSDNC advocating against FAR increases within the HSDNC area, contending the increases would undermine production of affordable housing, and advocating for increases in the required percentages of affordable housing in new buildings with more than 10 units.

Mid City West Community Council – Representative Mehmet Berker said the MCWCC supports getting rid of zones where street vending is prohibited, saying such rules are cruel and exclusionary and that no objective data shows it causes any harm.  Berker asked that the HCP also not allow any road widening for new building projects, and noted that the MCWCC also passed a motion in 2019 to support the Hollywood Heritage preservation recommendations.  Berker also raised several new questions about the HCP draft, asking why there are no mansionization protections for multi-family zones, and why there can’t be even more generous incentives (or no restrictions at all) for housing projects that are 100% affordabble.  And finally he advocated for less restrictive storefront restrictions, a higher minimum percentage of affordable units in new projects, and the elimination of all parking providsions in any 100% affordable project.

Hollywood Hills West NC – HHWNC VP Orrin Feldman noted that 75 stakeholders at Wednesday night’s HHWNC meeting were very surprised by Council Member Raman’s last-minute letter on the HCP, and particularly its opposition to height limits for affordable housing.  Feldman said this was the subject of careful discussion for many years at the HHWNC, which worked hard to revise a patchwork of old regulations with the goal of keeping future development at a reasonable scale.  “Last night’s letter landed like a hand grenade,” Feldman said, and there was no outreach by Raman’s office to local associations or residents before she sent the missive, which left many area residents, who have been very involved with the HCP’s development, extremely angry.

East Hollywood NC – Nina Suarez, President of the EHNC, also expressed strong support for Just Hollywood plan, for encouraging the development of housing over luxury hotels, preventing residential displacement for hotels, and requiring a Conditional Use Permit for new hotels, as well as prohibiting hotels in residential districts

Los Feliz NC – Finally, Josh Steichmann, representing the LFNC, said the latest draft of the HCP addresses many points his group opposed in last draft, but they still can’t support the plan because it still doesn’t fully address the “historic, sustainable, affordable Los Feliz” called for in a 1989 Los Feliz design plan, which referenced the special characteristics of the area and called for recommendations to preserve that character.  Steichmann said he would like to see a return to more traditional bungalow and courtyard-style housing, which best represents the historic character and affordability of Los Feliz, and that he also endorses the Just Hollywood plan, with an emphasis on affordable housing and an end to exclusive zoning.

City Council Districts

Meg Healy, representing Council District 4, pointed to Council Member Raman’s letter from the night before (which CPC President Samantha Millman said was the first official council office communications she’s ever received via Tweet), saying their office wants the HCP to provide a roadmap to equitable, sustainable goals.  She said they support the priorities of the Just Hollywood Coalition, and also support removing height limits for 100% affordable projects.

Daniel Skolnik, representing Council District 5 representative Paul Koretz, echoed the HHWNC’s surprise at Council Member Raman’s letter from the night before, noting that it makes recommendations for specific transit corridors in CD5 areas along Melrose Ave.  Skolnik said the “hastily assembled” letter from CD4 should be disregarded, and that any specific recommendations for his district should be fully researched and discussed with constituents. “We would not recommend any of these efforts without fundamental community outreach,” Skolnik said.

And finally, Council District 13 representative Craig Bullock said that his office would like to see the HCP draft evolve further, with further discussions of the FAR issue.  He also recommend an economic feasability study, and contended that preserving affordability, the right for tenants to return to new buildings when their old ones are torn down, transportation incentives, and other such housing policies should be uniform across the city, and enshrined in the General Plan’s Housing Element instead of set district by district in various community plans.

Planning Commission

By the time the Planning Commissioners got their turn to deliberate, time was running short.  But Commission President Samantha Millman organized the discussion into distinct categories capturing many of the main themes from the previous several hours.

Regional Center

Millman began this discussion of the busiest and most dense Hollywood district by noting that land in the Regional Center area is very valuable, and saying she wants to make sure any new incentives will indeed have the intended effect of making it profitable for developers to actually build new affordable housing, and not result in just incentivizing “a bunch of three-story market rate housing projects.”

Planning Department representative Craig Weber said that helping developers move from a base FAR of 3:1 to a much denser 4.5:1, by including more affordable units, does seem to work in other parts of the city, but he’s not sure if it would scale up further from there, for example to a FAR of 6.5 if even more affordable units are included or required…and whether those units would all have to be for Extremely Low Income tenants, or if some could be reserved for tenants at more moderate income levels.  Weber said the question could definitely use more economic analysis to verify whether the proposed incentives in this area would result in more affordable units than the Transit Oriented Communities guidelines now being used in other parts of the city.

The other commissioners, however, were divided on whether a base FAR of 3:1 or 4.5:1 would be better for the Hollywood Regional Center area.

Commissioner David Ambroz said he would prefer raising the base FAR to 4.5 before incentives, which is where it was in an earlier draft of the HCP proposal, and allowing it to rise higher than that with affordable housing incentives.  Ambroz said Hollywood is a very dense area, and that some anti-density remarks during the public comment period were “very provincial.” Ambroz said the commission needs to balance planning needs throughout the city, and because Hollywood is a denser than many other areas, it should continue to encourage growth in its community plan.  “Developers aren’t evil, ” Ambroz said.  “They are investing in Los Angeles, and we should be mindful of that.”

Commissioners Jenna Hornstock and Dana Perlman agreed with Ambroz that base-level Floor Area Ratios should be higher in Hollywood, with Perlman saying a base FAR of 3:1 for the Hollywood Regional Center seems very low, especially when other Regional Centers, such as the Warner Center area, are doing well with higher FARs.

Hornstock also said, “Hollywood has been downsizing for 40 years. It was not right then, and it’s not right now.”  She said raising the base FAR in the HCP to 4.5:1 seems appropriate, at least pending results of a feasability study…though she also noted that linkage fees, which require developers of market rate housing to pay fees to fund affordable housing, are coming soon and could change the picture to some degree.

Meanwhile, Commissioners Helen Leung, Karen Mack and Yvette Lopez-Ledesma disagreed, saying they would support the lower 3:1 FAR as a starting point before incentives.  Leung said moving the basic FAR up to 4.5:1 might undermine regulations working well elsewhere in the city, and Lopez-Ledesma agreed, saying the current 3:1 recommendation is probably an “elegant compromise” given the various factors and challenges in play.

Mack asked if the city knows exactly how much housing we need at each specific affordability level, and Weber said that kind of study will be done for the General Plan’s Housing Element revisions, which are taking place in a separate planning process, so the information is not yet part of the HCP revisions.   But Mack said she wonders, too, about the current pandemic’s effects on future land use patterns.  “No one’s really talking about the pandemic,” she said.  “I feel like we’re in the midst of this very monumental shift” in what is needed in a job center, and employers are now re-thinking the nature of work and job sites.  Mack said value capture is important, but it’s also hard to know right now, given current uncertanties, just how many low income units are needed and where to build them to support job opportunities in Hollywood.

Finally, Millman sided with those supporting a higher base FAR for the Regional Center, saying that ever since the 1986 passage of Proposition U, which deliberately slowed the development of high-rise buildings in most parts of the city, LA has been downsizing its major corridors, which is actually a “tool of exlcusion.”  Millman said changing the base level FAR to 3:1 was done “in the shadow of Prop U,” and that we need to move forward from an “antiquated, exclusive” FAR, and start moving toward an even larger baseline in the Regional Center, perhaps even up to 6:1 FAR.    She did note, however, that the commissioners do still seem very divided on this point, and are probably not ready to reach a consensus recommendation.

Corridor 5 Areas (Especially Sunset and Melrose)

The commissioners’ second major topic of discussion was the specific transit corridor areas – the rust-colored areas in the map above,  mostly along Melrose Ave., Santa Monica Blvd., and Sunset Blvd – called for in the HCP’s Community Plan Implementaion Overlay (CPIO).   The Corridors would be divided into five levels of intensity, each with specific FAR requirements and development incentives for residential and mixed-use projects.

Millman asked the commissioners for their thoughts on the HCP’s base FAR in these areas as well, especially for the Corridor 5 areas along Sunset and Melrose, where some nearby neighbors have asked for lower FARs to protect lower density residential areas adjacent to the Corridors.

Once again, however, Ambroz spoke up in favor of increased FARs in these areas, saying local Neighborhood Councils have been arguing for 20 years for lower densities, but density belongs on major thoroughfares, including Sunset Blvd.  “I don’t think because you’re mostly white and privileged and live in single family homes along Sunset Boulevard…that you are entitled to more protection than those in the core of Hollywood.  I think density belongs on major thoroughfares and Sunset Blvd. should be no exception in my mind.” Ambroz said he thinks buildings in these areas should be at least seven stories tall, and that all neighborhoods should do their share to support greater density.  “Single family zones need to go away,” he said, adding that the city should “stop bending our policy around the preservation of land for white people, and people with more land than other people.”

And the other commissioners, even those who disagreed with FAR increases in the Regional Center area, agreed with Ambroz about FAR increases along Melrose.

Leung, quoting an earlier speaker from the Mid City West saying single family neighborhoods are “anti-ethical,” said the character of single-family neighborhoods shouldn’t triumph over equity, and that the Corridor 5 area should be extended all the way along Melrose to Western Ave.

And Mack said the Melrose Corridor is “exactly where we need to upzone.”

Finally, Millman asked whether this should also apply to the Corridor along Hillhurst in Los Feliz, noting that, “It’s not like we’re talking skyscrapers here,” and that it’s a very walkable area near Griffith Park.  This sparked discussion on whether other Corridor areas could or should be upzoned as well, and in the end, Ambroz suggested restructuring the current five suggested Corridor categories into just two – one combining the current Corridor 1 and 2 areas, and one – with higher FARs – combining the current Corridor 3, 4 and 5 areas…a recommendation that all present agreed on.

Housing vs. Hotels

The commissioners’ third topic of discussion was the conflicts between hotels and housing.  Millman said it’s a “fraught political issue,” but that she thinks Planning Department staff dealt with it well in the current HCP plan draft, which would require that new hotels be restricted to commercial zones, a Conditional Use Permit process, with public input, would be required to turn housing into a hotel in the Regional Center area, and no housing could be converted to hotel uses in residential districts.

Once again, however, Ambroz disagreed, saying he’s “not a fan of ‘nevers,'” and small hotels in some residential areas may make sense, as they do in some places in West Hollywood.  He said it’s important to maintain flexibility for the future, and not fall victim to current trendy ideas.  “I don’t know why hotels are suddenly the bogeyman,” Ambroz said, “or where that change came from.” He was, however, amenable to the idea of CUPs for hotels in those areas, saying local Council Districts do tend to be responsive to residents on issues like this.

The discussion of CUPs raised the question of whether or not hotels require CUPs in other parts of the city, and Weber said they do, in most areas near residential zones.

Other commissioners, including Lopez-Ledesma and Mack, asked how they could keep the focus on housing in these areas, and help developers choose housing over hotel projects.  But Hornstock pointed out that hotel and residential developers are usually different people, so it’s not a matter of convincing individuals to make a choice.

Perlman asked if most hotels don’t already need CUPs, no matter where they are, to get permission for alcohol sales in their bars and restaurants.  But Weber pointed out that those CUPs are only for alcohol sales, and don’t take other elements or impacts into consideration.

Millman said she thinks that the current Planning staff report “splits the baby really nicely,” in requiring CUPs only when a hotel is proposed for a residential zone.  “I’m not comfortable with a CUP for a hotel in a Regional Center, if it replaces a parking lot,” she said, “But we shouldn’t allow the commercialization of residential zones.”

And Ambroz proposed an even more nuanced approach, only protecting existing affordable housing from removal/conversion for hotels.  “Why protect a luxury building?” he asked.  “Do it with a scalpel, not a machete.”  He also pointed out that hotels create jobs, and “We’re in a Regional Center, it’s where jobs should go.”

Again, though, no immediate consensus was reached on this issue.

Access to Public Open Space

The final issue tackled by the Commissioners at Thursday’s meeting was access to public open space, a topic of particular importance to Lopez-Ledesma, who lives in the Griffith Park area (green in the map above).

Lopez-Ledesma said she wants to increase public access to Griffith Park, and the LA River area, for all potential users, including creating contiguous sidewalks, looking at who gets to live nearby, and other mobility issues.  “It’s a shame more people can’t access it easily,” she said, “I live nearby and would like it to be welcoming to those neighbors.”  Lopez-Ledesma said the commison needs to make sure that the HCP is planning to increase access to outdoor spaces, and to think more about how to connect people to those spaces.

The other commissioners agreed, with Perlman noting that both day and night access are important for public spaces, and adding that Mulholland Drive now has almost no public space – it’s currently illegal to pull over there, which is “exclusionary” and “not acceptable” without a good policy reason.  (And he rejected the idea that fire danger is a good reason for keeping out non-residents, saying anyone can toss a cigarett butt out of a car window without stopping.)  He also added that the Franklin Reservoir and Lake Hollywood are hard to get to, too.

When Millman asked if Planning staff could look into elements that could be added to the HCP to address open space access issues, Hornstock noted that the city has been looking into the issue, most recently in its Transit to Parks plan.  But Millman said there are still further considerations, such as whether nearby Los Feliz Blvd., which is already zoned for multi-family housing, could be densified further, how to improve pedestrian and bike connections, and how hillside open space is handled.

Weber closed out the discussion by noting that the city is currently working to convert about 300 acres of hillside area to a permanent open space designation, and is cooperating with the Santa Monica Mountains Conservatory and other groups.  He also noted that the current HCP draft includes a footnote for the city’s General Plan, saying that if land comes under the protection of a specific agency, it can automatically be re-zoned to open space.  Also, he said, there are HCP policies for prioritizing unused land or right of way areas for future open space.

More

As the meeting came to a close, Millman said the commissioners still have many issues to discuss before voting on the HCP draft.  Other topics include:

• Housing stability
• The city’s 55-year affordability covenant
• Hillside development and fire safety concerns
• Preserving/eliminating single family zoning
• CPIO design guidelines
• Signage
• Haul routes
• TFAR (transferred FAR)
• Height limits on Santa Monica Blvd.

…and more.

But Millman also noted that many of these topics can and perhaps should be addressed citywide, through the General Plan’s Housing Element, or with specific city council actions, and not through individual community plans.  In fact, she said, City Council Members could introduce motions on many topics – especially things like affordability covenant lengths, tenants’ right of return, and others – as soon as the next Council meeting.  So she urged people to contact their Council Members about topics like this, and said the Planning Commission will continue its discussion of issues unique to the Hollywood Community Plan at its next meeting on March 18.