This is part I of III of a special weekly edition within our CCA Reflects series leading up to the DTLA 2040 Community Plan hearing at LA City Planning Commission on September 23. These editions unpack some of the key remaining issues within the proposed plan -- all with the goal of ensuring our members and DTLA stakeholders have the most up-to-date information and analysis of DTLA 2040. Ready to weigh in? Use our template letter here.
The 2021-2029 Housing Element: The Plan to House LA sets ambitious housing production targets of almost 500,000 new housing units by 2029 and sweeping policies, including the need to make capacity for over 200,000 new housing units and create a comprehensive rezoning plan that allocates new growth based on objective criteria like access to transit, jobs and community amenities. However, Housing Elements are broad policy documents, and Community Plans and Specific Plans are the tools to implement the zoning and regulations that dictate future growth. These plans contain highly specific provisions that may limit the potential for feasible housing development in practice. This can lead to Community Plans and Specific Plans showing a higher capacity for new housing than what would be feasible under their respective zoning. This would make it challenging to produce housing in accordance with the Housing Element. The DTLA 2040 Community Plan currently in the approval process is an example.
The DTLA 2040 Community Plan creates significant housing capacity to enable over 100,000 new units as DTLA is set to accommodate 20% of the city's future growth. However, many technical zoning aspects of DTLA 2040, as currently proposed, would limit housing development potential and work against the stated goals of the Housing Element, including:
- New housing developments in the Arts and Fashion Districts would have to include a baseline amount of office or light industrial space, which is not likely sustainable from a market perspective nor practical given the unique conditions of each site.
- Housing in the Arts and Fashion Districts would be primarily restricted to live/work units with high minimum unit sizes, including some areas that would allow housing only via adaptive reuse, which further limits feasibility and density.
- Decreasing zoning capacity in Chinatown by reducing development rights below what can be achieved today under the Transit Oriented Communities (TOC) program, while also introducing building height limits and requirements to dictate a minimum share of two-bedroom units or larger in each project.
- Prohibiting mixed-income housing in the Skid Row area which would limit growth and run counter to the Housing Element's goal of the equitable distribution of affordable housing.
Lessons from CASP
We have seen well-intentioned plans with highly specific requirements diminish potential for housing before. The Cornfield Arroyo-Seco Specific Plan (CASP) envisioned the creation of nearly 9,000 new housing units1 but has failed to produce any new housing due to a complex web of zoning rules that do not facilitate financially feasible housing development since the plan's adoption in 2013.2 Almost a decade later, the CASP is now in what will be a multiyear process of being updated to better align its zoning regulations with project feasibility. Amid a historic housing shortage, this represents nearly a decade of missed opportunity to deliver new housing units in this area of the city, and we must learn from this in our future planning efforts.
The Housing Element should create a way to judge the feasibility of Community Plans and Specific Plans prior to their adoption to ensure that the plans can lead to feasible housing creation. If Community Plans do not produce enough housing to meet our housing goals established through RHNA, it will undermine our long-range planning efforts and the vision set by the Housing Element.
2https://urbanize.city/la/post/chinatown-cornfield-arroyo-seco-plan-update