This is part II 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.

DTLA 2040 expands opportunities for mixed-use development but proposes to keep large areas of DTLA zoned for industrial and hybrid-industrial uses. Hybrid-industrial areas would allow housing but with various restrictions. Industrially-zoned areas would not allow new housing. 

DTLA 2040's proposed approach to industrial and hybrid industrial areas would have the effect of freezing existing conditions in place, stunting new housing and perpetuating the politicized, discretionary project-by-project approval of new housing. 

Industrial Zoning Does Not Create Industrial Jobs
The number of job-intensive industrial uses, like manufacturing, have converted to less productive uses, like wholesale, in DTLA even though land uses have not been changed in much of DTLA's industrial areas. As shown in the chart below, among employment in industrial uses, between 2002 to 2018 (the most recent available data) jobs in manufacturing decreased by 66 percent and jobs in transportation and warehousing decreased by 19 percent, while jobs in wholesale trade increased by only seven percent within DTLA 2040 boundaries.¹

DTLA's economic success over the past two decades has been defined by increased livability, with the introduction of substantially more housing, public investments in transit and open space and accompanying amenities like shops, restaurants and hotels. This change has attracted new residents and visitors and encouraged more job-intensive and higher-paying businesses to locate here, which replaced industrial-oriented jobs that largely disappeared over the past two decades. As those jobs shrunk between 2002 to 2018, jobs have increased by nine percent in information industries, 28 percent in professional, scientific and technology services, 47 percent in arts and entertainment, 81 percent in accommodation and food services and 116 percent in health care industries, also shown in the chart.

Hybrid-Industrial Is Not a Solution to Promote Housing or Jobs
The City has proposed to rezone areas like the Arts and Fashion Districts from exclusively industrial to hybrid-industrial. The goal of this zoning is to enable new housing to be introduced to transitioning industrial areas while still retaining a focus on "jobs-producing" uses through an emphasis on elements like live/work housing, and office and light industrial uses but not retail. 

Although well-intentioned, proposed hybrid-industrial requirements for housing are highly specific and rigid, ultimately limiting the financial feasibility of and potential for new housing. Requirements in hybrid-industrial areas include:

• Arts District: Live/work units (of an average minimum unit size of 1,000 square feet) are the only housing type allowed, and every project must have a baseline of 1.5 FAR of office or light industrial uses.
• Fashion District: In the central area, every project must have a baseline of 1 FAR of office or light industrial uses, and in the eastern portion the only housing allowed is live/work created via adaptive reuse (i.e., newly constructed housing is prohibited).

These requirements present many challenges for housing:

• Live/work: Live/work units are large and inefficient, making them more costly to build and are poor options for families as they lack walls and partitions. The City has not provided evidence that these units actually support jobs and/or pay city business taxes.  
• Baseline office and light industrial space requirements: Building mixed residential with office and/or light industrial space is challenging. A New York City Department of City Planning study found that "because of the physical and financial challenges associated with industrial mixed-use space, requirements for inclusion of industrial space risk slowing investment."²
• Allowing live/work only via adaptive reuse: It is difficult to make adaptive reuse projects work financially and limiting housing to live/work only presents additional hurdles. Moreover, there has been no analysis of the existing building stock in this area to suggest that adaptive reuse is viable or desirable based on the quality of the buildings. 

On paper, hybrid-industrial zoning would technically allow housing in areas where it is not allowed by-right today. In practice, these hybrid-industrial limitations on housing will be largely infeasible for projects, require discretionary approval and hinder the plan's vision of 100,000 unit growth. It would also work against community development goals of supporting housing around transit and schools and move away from recent Planning approvals like City Market. In the map below, the hybrid-industrial zones would limit housing growth around existing schools and future transit stations. It also treats City Market as an island, allowing more housing opportunities for that site alone but limiting housing in the surrounding areas. 

Focus on What We Know Works for DTLA's Economic Development
Instead of creating unworkable rules that lead projects into discretionary review and are rooted in outdated notions of DTLA's economy, the DTLA 2040 Community Plan should be dynamic, forward-looking and remove barriers to housing in formerly industrial areas. This approach would help: 

• meet our regional housing needs,
• depoliticize DTLA development approval,
• support DTLA's transit-oriented future and
• enable DTLA to grow around and connect with our community's existing schools. 

¹According to data from the U.S. Census Bureau, OnTheMap Application and LEHD Origin-Destination Employment Statistics (Beginning of Quarter Employment, 2nd Quarter of 2002-2018) for the Downtown Community Plan Area.
²https://www1.nyc.gov/assets/planning/download/pdf/planning-level/housing-economy/can-industrial-mixed-use-buildings-work-in-nyc.pdf