The City of LA's Housing Element Update for 2021-2029 is underway and CCA is pleased to again serve on the Task Force that is helping inform its preparation. While the Housing Element does not change any regulations or laws directly, it can set the vision and policy framework for necessary zoning changes coupled with flexible land use provisions and streamlined development approval processes to increase housing supply for all income levels. One of the key features of the Housing Element is its assessment of the city's current capacity for new housing, based on existing zoning and development rules, which determines how much the City must rezone to create new capacity in order to meet its Regional Housing Needs Assessment (RHNA) goals.
This Housing Element cycle differs from previous cycles as several state laws are in effect and provide greater enforcement for cities to meet their housing obligations, as well as updated federal regulations calling for addressing historic housing discrimination. We believe that accuracy, transparency and a commitment to equitable growth should be the foundation of the Housing Element process.
The Housing Element acts as the foundation for all the City's housing policies including its Community Plans. It is one of the few mandatory elements of the City's General Plan and it must be updated every eight years as required by state law. The document's preparation is on a tight timeline as we anticipate the draft version to be released this spring and it must be adopted by October 2021.
CCA'S VISION FOR THE HOUSING ELEMENT
Plan for LA's ambitious housing goals.
Our City's housing obligations are enormous compared to our previous levels of housing production. The City must plan for more than 455,000 units of housing across income levels to be built over the next eight years, an average of over 57,000 units per year. In contrast, about 430,000 units were built during peak housing production in the city between 1960 and 1980, an average of over 22,000 units per year. This means the Housing Element must provide the path for the City to more than double the amount of units built annually during its historical peak of housing production.
Prepare for realistic housing needs.
We are concerned that the City's preliminary estimates suggest that there is only the need to plan for an additional 90,000 units, after accounting for projects currently in the entitlement pipeline and carrying over sites that were identified in the prior Housing Element but never developed.¹ We urge the City to conduct an honest assessment of the realistic development potential for each site identified for housing, including those identified in the previous Housing Element, which we expect will show the need to rezone for far more than 90,000 units.
Be a transparent process.
To ensure that the Housing Element's capacity estimates are indeed realistic, every specific parcel that is identified in the housing development site inventory should be accessible and communicated to the public prior to its adoption. The criteria that were used to determine the sites' realistic development potential including lot size, maximum allowable Floor Area Ratio (FAR) and other factors should also be made publicly available. Publishing the complete housing development site inventory for public feedback allows experts to provide more information on whether the sites are feasible under existing land use constraints and will help create a more accurate site inventory.
Encourage equitable growth citywide.
The Housing Element should set general housing growth targets for the City's 35 Community Plan Areas based on objective and measurable criteria to affirmatively further fair housing. Despite having citywide housing growth targets set by RHNA, the City currently does not have a publicly available comprehensive strategy for meeting its RHNA needs through rezoning and Community Plan Updates. This has resulted in a process whereby each Community Plan is updated in isolation, seemingly without connection to or coordination with the rest of the City's Community Plans. This approach perpetuates patterns of enabling more organized and affluent areas to oppose new housing while directing most new growth to lower-income areas.
THE HOUSING ELEMENT'S ROLE
The Housing Element and other long-range planning initiatives are important components of our interconnected housing crises, yet it will not solve our housing and homelessness crises alone. The dearth of housing, acknowledged by the current Housing Element's production goal, is at the root of our complex housing crisis. We continue to offer the City detailed policy suggestions to meet its housing needs -- from fostering micro-unit development to enabling mass timber construction to enhancing the DTLA 2040 Community Plan among many other ideas. We have raised various proposals to inform the Housing Element during the outreach period but believe it is critical that the document honestly reflects the housing need, transparently shares the site identification process and inventory and leverages the Update to plan for citywide equitable growth.
¹ plachttps://planning.lacity.org/odocument/1a4e2cf4-7365-4fef-a45e-7f4631f2c132/Initial_Study.pdf