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S CON r= ARY SU ~ IISSIONS August 23, 2021 Samantha Millman, President City Planning Commission 200 N. Spring Street Los Angeles, CA 90012 Re: Comments on DTLA 2040 Community Plan Update Dear President Millman and Honorable Commissioners, Established in 1924, Central City Association is an advocacy organization committed to DTLA’s vibrancy and increasing opportunity in the region. We are a membership organization comprised of over 300 members who have played a leading role in transforming Downtown Los Angeles and our city by building over 17,000 units of new housing, and more than 6.6 million square feet of office and retail space and 3,600 hotel rooms that have resulted in hundreds of thousands of jobs and millions of tax revenue dollars to the City.1 We have been deeply engaged on the DTLA 2040 Community Plan Update since it’s initiation in 2014. We are committed to ensuring that it advances DTLA’s robust and inclusive growth and serves as a model for other areas in the city that are proximate to transit. We acknowledge that the Commission may continue this item again in response to a request from Councilmembers, but offer this letter to highlight new issues that have been raised since the June 17, 2021 hearing and to further clarify comments we submitted previously. The numerous detailed items and recommendations we raised in our June 7, 2021 letter still remain, but we are providing additional comments regarding the timing of the plan, the concept of inclusionary zoning and in response to the August 2021 Supplemental CPC Staff Recommendation Report. We have also submitted a letter to City Planning highlighting the relationship between the Housing Element and DTLA 2040 to stress the importance of the two plans working in tandem to meet our Regional Housing Needs Assessment requirements. Timing of DTLA 2040 There has been a significant investment of City resources to craft DTLA 2040 and conduct the associated community outreach. DTLA 2040 is a complex plan, and it is the first in the city to implement the new citywide zoning code and to establish a comprehensive Community Benefits Program (CBP). The CBP is central to DTLA 2040 and all the environmental review, financial feasibility analysis and public input to date has been predicated upon it. DTLA 2040 was initiated in 2014 and made serious progress in 2019 and 2020 with the release of the plan text, interactive zoning map, CBP feasibility study and Draft EIR. City staff and a broad range of DTLA stakeholders have dedicated substantial time and energy to preparing and reviewing these items. It is no small task to complete a Community Plan and we know that updating our long-range planning codes, like Community Plans and General Plan Elements, is vital for our City to move away from 1 https://www.ccala.org/what-we-do/member-development-projects/ 1 politicized project-by-project review. Mayor Garcetti recognized this by issuing Executive Directive No. 19 in March 2017, which directed all 35 Community Plans and all elements of the General Plan to be updated within six years, which came as a response to Measure S, the failed development moratorium ballot initiative stoked by a lack of transparency in the development approval process. The timely adoption of Community Plans supports responsible city growth and depoliticizes approval of development projects by setting an areawide vision and framework for the future – this is an important element that we recommend the Commission consider in its deliberations and action on DTLA 2040. Concept of Inclusionary Zoning Inclusionary zoning became an available tool to the City in 2017 and has been discussed as a way of potentially increasing affordable housing with new development since then. Relatedly, the City established the Affordable Housing Linkage Fee in December 2017 that is levied on new developments to encourage projects to include affordable housing by exempting them from the fee, and to otherwise generate a flexible source of funds to accomplish a wide range of affordability goals. In July this year the city allocated $100,000 to obtain a feasibility study and potential framework on a citywide inclusionary housing policy. That study will be underway shortly and is estimated to take approximately six months to complete. We are aware that policy makers are now considering removing the Community Benefits Program (CBP) from DTLA 2040 and replacing it with an inclusionary zoning policy, although there are currently no details available on how the plan would be structured under that scenario. Imposing inclusionary zoning only in DTLA may create an uneven playing field and constrain growth where it is most appropriate, while also likely delaying the adoption of DTLA 2040 as it would almost certainly require a new financial feasibility analysis. We are concerned that this significant change may further delay DTLA 2040 indefinitely thereby undermining the City’s long-term planning commitments made after Measure S and impact the City’s ability to meet its tremendous Regional Housing Needs Assessment (RHNA) requirements, of which DTLA 2040 is a major component as 20 percent of the City’s future housing growth. We are supportive of efforts to simplify planning rules and streamline mixed-income and affordable housing in DTLA, but it is paramount for DTLA 2040 to be adopted swiftly, fairly and provide certainty to all DTLA stakeholders to create a feasible path to robust growth to meet our housing needs. August 2021 Supplemental CPC Staff Recommendation Report We appreciate City Planning Staff’s continually thorough analysis of the many complex aspects of DTLA 2040 in the August 2021 Supplemental CPC Staff Recommendation Report. There are several items raised in the Supplemental Report that we have consistently commented on and would like to offer our responses and further clarify our comments on these issues. Arts District, Fashion District, Industrial Zoning and Schools In our prior letters, we have emphasized the importance that DTLA 2040’s approach to currently industrially-zoned areas should not be tied to conceptions of the past as job-intensive industrial uses 2 have largely left DTLA and are not poised to return. Instead, we believe the plan should be forward- looking by enabling a broad mix of uses, including all kinds of multifamily housing, and not imposing highly specific requirements (like commercial FAR requirements in the Arts and Fashion Districts) in areas currently zoned for industrial uses as we have seen DTLA’s economic vitality and dynamism over the past two decades be closely connected to its increased livability overall. While the plan’s approach to the Arts and Fashion Districts is an improvement from the current zoning that exists for those areas today, we believe the Supplemental Report misses important details that the CPC should consider: • Live/work units may not support in-unit production or economic activity, and the limitation might only have the impact of constraining future housing to a small share of high-end lofts. Live/work units with an average minimum size of 1,000 square feet are currently the only allowable housing type for mixed-income and market-rate developments in the Arts District under DTLA 2040. This restriction is premised on the supposition that live/work units support business operations, but there are no data points shown to support this, only an assumption. Moreover, 1,000 square feet per unit is large and live/work units have unique spacing requirements, making each unit more expensive while also limiting the number of units that can fit within the building envelope (for example, double the number of 500 square foot units can fit within the same allowable FAR as 1,000 square foot units). The Supplemental Report cites the existence of live/work units in the Arts District today – the City should analyze whether these units support jobs and/or pay City business taxes, or whether they are predominantly used solely as residences.