We have been deeply engaged on the DTLA 2040 Community Plan Update since City Planning first began the project in 2014. It is one of the most important issues that will define the future and character of DTLA, and we have been collaborating with our members and City Planning to evaluate draft proposals in depth over the past year. With the support of our members, we worked with our City partners to push for a plan that allows for flexibility and the greatest growth. With each step of the plan's progress, we have been refining our advocacy and goals. In January 2020, we submitted a letter to City Planning detailing concerns about the plan, summarized in an earlier edition of CCA Reflects. And this week, we submitted a letter commenting on the plan's Draft Environmental Impact Report (DEIR), raising key issues that we believe hinder housing production and economic recovery. Importantly, we emphasize that the DEIR was prepared in a vastly different context than today -- prior to the COVID-19 pandemic and resulting economic depression, before the City was assigned a housing production goal of over 455,000 for the next eight years to help solve the persistent housing and homelessness crisis and apart from state and federal funding considerations for transit-oriented growth.
Downtown sets the precedent for the rest of the city, and it is critical that the plan considers the current economic environment, DTLA's ongoing transformation and its future growth. We believe much of the plan is a great improvement to DTLA's land use and planning framework, and we are appreciative of City Planning's outreach and engagement, and the important changes already made over the course of its development. However, we believe that DTLA 2040 must go even further to promote a bold, exciting and resilient future for our city center. We believe the recommendations offered in our letter will help create a more connected, equitable and inclusive DTLA with various housing options for all income levels, park space, education and childcare facilities, and diversity in mobility and employment opportunities. They also account for the conditions that currently affect DTLA and the city at large, and what is at stake for our future.
Building off our January letter, we've broadly categorized our recommendations as follows: 1) maximizing opportunities for housing at all income levels, including middle-income housing, and 2) creating flexibility within the plan to be adaptable over the next two decades. Underpinning this all, we are focused on ensuring the plan can support financially feasible development, which is critical to yielding the housing growth and maximum community benefits envisioned in the plan as well as depoliticizing development in DTLA. We lay out 22 detailed recommendations in the letter -- ranging from the Community Benefits System, building height limits, reimagining industrial areas and more -- and we encourage you to read through the details.
We know that DTLA 2040 will serve as the guiding framework for DTLA's growth over the next two decades. This plan is also being considered at a time when DTLA faces incredible adversity due to an unthinkable combination of circumstances including a global pandemic that has resulted in economic uncertainty and questions about the fundamental values of dense urban living, development-related corruption charges against our neighborhood's former City Councilmember, and a housing and homelessness crisis. The moment for leadership and a bold, visionary plan for DTLA could not be more important or necessary.
We believe City Planning has already proactively made several positive refinements to the plan, which is a credit to their partnership and thanks to the collaboration, expertise and leadership of our coalition. We thank all of our members for engaging with us to help create a vibrant region. On December 8, 2020, there will be a virtual public hearing, and over the next year, the plan will be heard by the City Planning Commission and the City Council. We will continue to engage with the City and hope to see many of our recommendations reflected in the next version. Despite these difficult times, Downtown continues to innovate and strive for success, and we hope DTLA 2040 reflects our efforts to ensure a better future. If you are interested in joining our advocacy efforts, please email CCA's Director of Economic Development, Michael Shilstone, and CCA's Policy Manager, Clara Karger.
Summary of Recommendations From Our Letter
1. We strongly encourage the adoption of Alternative 3 in the DEIR to allow for the greatest development capacity and flexibility to spur DTLA's recovery and best position the heart of our city for private and public investment.
2. Provide a more substantial FAR increase for Level 1 of the DTLA 2040 Community Benefits Program to support the feasibility of high-rise construction, and maintain the ability for in-lieu payments or partnering with affordable housing providers to provide affordable units off-site, which offer necessary flexibility.
3. Maintain base FARs as they were proposed prior to the Fall 2020 changes to the plan as it's clear that recent reductions in base FAR would jeopardize development feasibility.
4. To promote context-sensitive growth and density near transit, respect neighborhood character and appropriately preserve historical assets in a way that reflects the economic realities of development, building height maximums should be removed and instead FAR, setbacks and frontage requirements should govern building height and massing, and historic communities considered instead through established historic preservation processes.
5. Remove minimum building height requirements to avoid unintended outcomes like limiting the potential for vacant or underutilized land to be redeveloped into desirable uses like affordable housing, schools or mid-rise mixed-use developments.
6. Expand the Transit Core General Plan land use designation to include all areas close to existing, entitled and future transit to maximize development opportunities.
7. Adopt an amendment to the Framework Element in tandem with DTLA 2040, which will allow for far greater flexibility to plan hybrid industrial areas as mixed-use neighborhoods with a diversity of housing types.
8. In the absence of an amendment to the Framework Element, for projects that include more conventional multi-family housing, set the commercial space requirement as 10% of building area, which will create fairer rules for all projects than the current requirement that is based on lot size, especially those that don't use a site's full FAR.
9. Remove requirements dictating construction types -- DTLA 2040 is seemingly the first community plan that has attempted to dictate construction types and we believe such a determination is out-of-scope for zoning codes to mandate and should be left to building and safety codes.
10. Remove the ban on market rate housing from 5th to 7th Streets and San Pedro Street to Central Avenue, and instead consider ways the area's zoning can be tailored to produce mixed-income developments and socioeconomic integration and inclusion.
11. Allow affordable units to be a different mix than market rate units in the same mixed-income buildings, but still require the same amount of affordable floor area as a percentage of overall residential floor area.
12. Provide very clear, administrative clearance processes that are CEQA-exempt for deviations and relief mechanisms like alternative compliance, variances and adjustments.
13. Whether using the base zoning or the Community Benefits System, projects should not be subject to Site Plan Review or other discretionary review processes if they comply with a site's allowable zoning and are not seeking any additional changes.
14. Continue to explore ways of modifying the Arts District and Historic Core Frontage Districts to strike a balance between fostering contextual design with the potential for creative approaches and innovation -- our members welcome the opportunity to collaborate to further consider how this can be accomplished.
15. Do not zone areas exclusively for industrial uses -- these areas should instead provide more flexible zoning to allow them to gradually convert to other uses, including housing, over the long term.
16. To increase usage of the ARO, apply it to buildings constructed after 1974 on a rolling basis going forward.
17. Remove the 49-room limit on hotels in Chinatown and Little Tokyo as there is no clear rationale for this limit, and it is antithetical to strengthening DTLA's role as a major visitor destination.
18. Allow hotel rooms to include kitchenettes.
19. Remove tenant size limits in Chinatown and Little Tokyo, and use other urban design tools to provide for a small commercial look and feel in targeted areas while working with other City agencies to develop economic development tools to support small business in DTLA.
20. Expand the language regarding public on-site open space to state that it must be "clearly accessible" to the public, rather than required to be on the ground floor.
21. Apply the TDR system more broadly across DTLA and more closely tie the criteria for historic resources to official historic designation.
22. Include a policy goal to coordinate DTLA 2040 land use planning with EIFD planning being led by LA Metro and the Economic and Workforce Development Department (EWDD) and include the creation of a Downtown Development Corporation to plan, manage and implement large-scale public benefit projects and support funding for affordable housing within policy objectives.