We believe the City has overlooked an obvious alternative. There are several prime development sites in the heart of the City that are zoned T-1, Transportation. This zone only allows railway transportation stations, depots, and related structures. Other than the currently under construction Metro Purple Line, which does not run under the T-1 zoned properties, there are no rail lines in the City.
While surface parking is a permitted use on those T-1 zoned properties designated for parking on the “T zone parking map” approved by the City Council, only two or three properties have been so designated. Moreover, immediately after Governor Newson signed AB 2011 (which permits housing on sites zoned for parking), the City initiated a Zone Text Amendment to allow parking on T-zoned lots only with a conditional use permit. This would disqualify the few T-zoned lots where parking is allowed from AB 2011.
Two of the T-1 zoned sites, Lots 12 and 13, comprising approximately 4.65 acres, are currently undeveloped. If rezoned, these vacant lots could be developed with approximately 350 multifamily units, or over 11 percent of the City’s RHNA obligation. This housing would be in close proximity to jobs, commercial amenities, entertainment venues, and Beverly Gardens Park and would be well served by transit. As such, these lots are ideally suited for housing.
Many years ago, Union Pacific operated a railroad on Lots 12 and 13. These operations resulted in residual arsenic levels in the soils that are above background concentrations. Union Pacific entered into a voluntary cleanup agreement with DTSC to address the arsenic. DTSC has approved a remedial action workplan (“RAW”) to clean up the site to commercial standards.
DTCS has informed us that cleaning up Lots 12 and 13 to residential standards would require more excavation than the RAW currently requires. Our client is prepared to do this additional excavation, which is in any event necessary to construct the below grade parking that would be inherent in any residential or mixed use development on the lots.
The City is currently updating its sites inventory before submitting the revised Housing Element to HCD. We have requested that the City include these lots on its updated site inventory but have not yet received a response. We believe that HCD should consider the City’s response in assessing the Housing Element’s compliance with state Housing Element Law.
We are available to provide additional information upon your request.
Very truly yours,
Dale J. Goldsmith
cc: Holly Fraumeni De Jesus,
Sue the Suburbs.
yimbylaw.org
Chelsea Lee
California Department of Housing and Community Development 2020 W. El Camino Avenue, Suite 500
Sacramento, CA 95833
May 4, 2023
City of Beverly Hills Housing Element Update
Dear Ms, Lee,
After two failed attempts, Beverly Hills approved a second revised Housing Element on February 21, 2023. Like the prior versions, this version assumes that property owners in the mixed use overlay will demolish their existing building and that mansion owners will build and rent ADUs on their estates. No properties are planned to be rezoned, and no new development incentives are proposed.
Nonetheless, Beverly Hills claims that the Housing Element will result in the creation of 2,821 more units than the City’s RHNA obligation of 3,104 units.
The HCD’s November 28, 2022 letter expressed justifiable skepticism that property owners in the overlay will demolish profitable commercial buildings, including medical uses, Class A and B office buildings, and stores including a Starbucks, Neiman Marcus, and CVS. The overlay provides scant development incentives. For many sites, the overlay limits height to three stories, which is no more than what is currently permitted and less than many existing buildings. 1 Despite HCD’s clearly articulated concerns, Beverly Hills has doubled down on the inadequate strategies contained in the prior versions of the Housing Element. Rather than add meaningful measures, Beverly Hills merely proposes to conduct outreach and “educate” property owners regarding the overlay. However, no amount of outreach education will induce property owners to give up a steady income stream to pursue speculative redevelopment projects.
We urge HCD to find that, like the prior versions, the current version of the Housing Element does not comply with state law. HCD should direct Beverly Hills to go back to the drawing board and consider creating real development incentives, including increased height and density. In addition, there are two vacant sites totaling about five acres within walking distance of the retail shops and restaurants in the Beverly Hills triangle, a park, and businesses. The sites should be developed with housing, but the current zoning only allows railroads. Unlike the sites in the mixed use overlay, there are no existing buildings on these sites, so they could be readily developed with needed housing. Only with a more robust, comprehensive, and multifaceted approach can Beverly Hills hope to meet its RHNA obligations Thank you for your consideration.
Rafa Sonnenfeld
Policy Director
YIMBY Law
Sue the Suburbs.
yimbylaw.org 2
MATTHEW GELFAND, COUNSEL
May 11, 2023
Chelsea Lee
California Department of Housing & Community Development 2020 W. El Camino Ave., Suite 500
Sacramento, CA 95833
Email: [email protected]
RE: Comments on City of Beverly Hills Housing Element
Dear Chelsea,
Californians for Homeownership is a 501(c)(3) organization devoted to using legal tools to address California’s housing crisis. We are writing to comment on the amended sixth cycle Housing Element of the City of Beverly Hills, submitted to HCD on March 13, 2023. This letter follows up on my February 22, 2023 email to you, immediately following the City’s adoption of the amended housing element.
As I explained in my email, the housing element adopted by the City is largely identical to the version you previously reviewed and determined was not substantially compliant with state law. Indeed, we believe that the City adopted this amendment not in a genuine attempt to gain certification from HCD, but instead in an attempt to stake out a slightly improved position in our ongoing housing element litigation against the City. In adopting the amendment, the City openly conceded that it would need to do more work, anticipated for later this year, in order to gain certification. This concession is reflected in the staff report presented to the City Council:
May 11, 2023
With the exception of the error involving a double-counted site, the City has not even attempted to resolve HCD’s comments on the issues we previously raised regarding the City’s sites inventory. We are attaching our previous comment letter for your reference.
Thank you for considering these comments as you review the City’s housing element.
Sincerely,
Matthew Gelfand
PRIOR
CORRESPONDENCE
MATTHEW GELFAND, COUNSEL
November 23, 2022
VIA EMAIL
Chelsea Lee
California Department of Housing & Community Development 2020 W. El Camino Ave., Suite 500
Sacramento, CA 95833
Email: [email protected]
RE: Comments on City of Beverly Hills Housing Element.
Dear Ms. Lee,
Californians for Homeownership is a 501(c)(3) organization devoted to using legal tools to address California’s housing crisis. We are writing to comment on the new draft sixth cycle Housing Element of the City of Beverly Hills, submitted to HCD on September 29, 2022. The revised Housing Element still fails to comply with state law and does not adequately address many of HCD’s comments laid out in its review of the City’s prior adopted housing element.
Duplicate and Double-Counted Site
The parcel located at APN 4331-001-049 appears twice in the City’s sites inventory, and has been double-counted in the City’s calculation of its lower-income site capacity. For reasons explained in more detail below, it is unclear exactly how many low- and very low-income units the City attributed to this site, but the removal of the site has the potential to bring the City’s site capacity below its RHNA requirement for low-income units.
Non-Specific Existing Use Information
In HCD’s prior review, the City was specifically told that the column of the parcel listing that describes the existing use of each parcel needed more information to demonstrate development potential. However, the new housing element does not add more information and continues to describe sites using non-specific terms such as “retail” and “office” that do not give a realistic idea of the conditions of each site that would make residential uses likely or not.
Inadequate Support for Nonvacant Sites
The sites inventory in the City’s draft Housing Element does not meet the requirements in Government Code Section 65583.2(g). The housing element does not adequately account for the impediment created by the existing uses on the listed sites, including the possibility that a site will be maintained in its current use rather than redeveloped during the planning period.
November 23, 2022
Many sites listed in the inventory have existing uses that are likely to continue throughout the planning period. A large number are Class A and B office buildings that seem to have been included merely because their fenestration and other key features could allow conversion to residential, without any reason to believe that the existing office use will actually end by 2029— and a lot of reasons to believe they won’t.
In some cases, it is easy to determine from leasing websites that these buildings are (1) mostly occupied, and (2) offering long-term leases to new tenants, foreclosing redevelopment by 2029. For example, based on listings available on LoopNet, 8383 Wilshire Blvd. appears to be an almost-90% occupied office building with a recently renovated lobby, high-quality management, and very active leasing efforts to fill the small amounts of available office space, some of which have brand new build-outs. As another example, 8500 Wilshire Blvd. appears to be a largely-occupied, 2008-renovated medical office building that is offering 10-year leases to new tenants. We do not believe that the City has any evidence that the existing uses in these and most of the other office buildings listed on the housing element will discontinue by 2029.
Because the City’s sites inventory barely provides the necessary number of very low- and low-income units, without any meaningful buffer, the exclusion of these sites will require the City to identify and rezone other sites in order to meet its RHNA allocation.
Medical Uses
The housing element specifically states that when the City was developing its sites inventory, it considered certain characteristics that render a site not likely to be redeveloped and therefore inappropriate for inclusion. One listed exclusion characteristic was parcels with existing medical uses, especially ones that “are occupied by prominent medical groups (i.e. Cedars-Sinai, UCLA Health, etc).” Despite conceding that these types of sites should not be included in the sites inventory due to their lack of redevelopment potential, the City nevertheless included 8501 Wilshire Blvd., which contains a major pediatrics care facility operated by Cedars-Sinai, and 8641 Wilshire Blvd., which contains a primary care practice and 8 specialty care practices run by UCLA Health. These sites have existing uses that preclude their redevelopment as housing.
Misalignment Between Development Potential and Unit Count Calculation Because the City’s inclusion of many of its larger sites is based on the potential conversion of large office buildings, or the partial redevelopment of parking podiums and the like, it is important to understand whether the unit counts included in the City’s housing element account for the type of redevelopment being contemplated. This does not appear to be the case, but the housing element contains so little information about how the unit counts for each site were calculated that it is impossible to say for certain.
For example, 8949 Wilshire Blvd. is home to the Motion Picture Academy’s Samuel Goldwyn Theater, which houses movie screenings and other public events. By all appearances, the theater will remain throughout the planning period, and we understand that the City may have included it with the understanding that the theater would remain and the rest of the building would November 23, 2022
be converted. But the assigned unit count does not appear to account for this form of redevelopment.
Similarly, we understand that a number of office buildings have been included based on their potential for conversion, or for partial redevelopment of a parking podium or portion of the site. But there is no information to suggest that the unit counts used for these sites account for the fact that redevelopment would encompass only part of the site, or be limited to the envelope of the existing structure.
Lack of Redevelopment Potential for Sites to Meet Lower Income RHNA The housing element concedes that “it is unlikely that a high percentage of the parcels within the MU Overlay Zone would be developed with mixed-use projects during the planning period” (C-11). The City nevertheless contends that its RHNA can be satisfied through a development of a “portion” of the listed sites.
Perhaps this is true for the moderate and above moderate RHNA allocations. But the surpluses of sites for the very low and low income categories are so small that it is unlikely that the City would be able to meet its requirements even assuming development of the City’s sites at nearly 100% of the maximum unit potential. The City must provide more evidence of the likelihood of development at the unit counts listed in its housing element, as well as more sites to ensure it meets its lower income RHNA requirements.
Lack of Clarity for Distribution of Units Between Income Levels Almost the entirety of the housing element’s sites inventory to meet the City’s RHNA is made up of underutilized sites in the City’s Mixed Use (MU) Overlay Zone. However, the sites inventory does not provide enough information to understand how each parcel was assigned to its income category. The housing element states that since the allowable density is greater than 30 units/acre in that zone, all sites are suitable for lower-income housing unless other factors apply, such as the state law minimum size requirement, but there is no analysis of factors that make a site more or less likely to redevelop at a certain income level. Indeed, the housing element appears to assume without evidence that all of the sites not suitable for lower-income development will be developed at 100% moderate-income levels.
Consistent with these assumptions, Table C-3 lists the number of lower income or moderate income units that can be accommodated on each site. But Table C-1 breaks down the underutilized sites into very low, low, moderate, and above moderate income categories. We have been unable to ascertain how the numbers in the two tables relate to one another, and there is no information in the document as to how the sites were assigned to particular income levels, nor does the housing November 23, 2022
element identify which sites are being counted as very low instead of low, or being counted as above moderate instead of moderate.
Instead, the City seems to have simply distributed the numbers in the manner necessary to determine that its RHNA requirement has been met. This bootstrapping approach is legally inadequate and we urge HCD not to accept it.
* * *
Thank you for considering these comments as you review the City’s housing element.
Sincerely,
Matthew Gelfand
060
October 31, 2023
via email
Dep’t of Housing & Community Development, [email protected] Re: Beverly Hills Housing Element Update
To the Planning & Land Use Management Committee:
The City of Beverly Hills (“City”) had adopted three versions of its General Plan 2021-2029 Housing Element (“Housing Element”), respectively dated October 2021, September 2022, and February 2023. None of these versions included any real development incentives or rezoning of any underutilized site. Instead, each relied solely on the assumed redevelopment of currently developed sites in the City’s Mixed Use Overlay Zone (“Overlay”) and the construction of new accessory dwelling units (“ADU’s”) in single family zones. The City adopted the Overlay in 2020, but according to the Housing Element, the City has only approved one project in that zone.
The California Department of Housing and Community Development (“HCD”) rejected all three versions of the Housing Element, finding they did not meet the requirements of State Housing Element Law. In its letter dated May 12, 2023, HCD specifically found that:
[T]he City should implement significant program actions and policies that incentivize the use of the overlay and adopt secondary measures, including rezoning of additional sites, should an evaluation of the overlay reveal ineffectiveness. In addition, during its review, HCD received public comments from local stakeholder groups that highlighted the present limitations of the overlay’s effectiveness (e.g., three story height constraints in select areas, incentives limited to developer outreach and consultation, and the presence of many existing and viable non-residential uses along these corridors).
The City recently submitted a draft Housing Element published on October 10, 2023 to HCD. This version also ignores HCD’s clear direction; no new real development incentives are proposed, and no sites are planned to be rezoned. Instead, the City again merely proposes to conduct “outreach” and “educate” property owners regarding the dubious benefits of the Overlay. While the current draft purports to incentivize conversion of commercial buildings to residential use, the only specific measure is to amend the Overlay to allow conversion projects to calculate density with the use of the minimum unit size of 500 square feet. The other purported measures (“consider” modifying the Overlay to allow mezzanine levels to existing buildings if they meet “certain 2 specified criteria;” amend the Overlay to provide more “flexibility” regarding legally nonconforming uses) are too vague to be meaningful. Moreover, there is no meaningful analysis of the feasibility of converting existing buildings. Due to the high costs of conversion (cost up to $500 per square foot) and unsuitable floor plates, office to residential conversions are rare and generally limited to smaller, older office buildings.1
We urge HCD to find that, like the prior versions, the current version of the Housing Element does not comply with state law. HCD should direct the City to revise the Housing Element further and add real development incentives, including increased height, floor area, and residential density. In addition, underutilized sites should be rezoned, including two vacant sites totaling about five acres within walking distance of the retail shops and restaurants in the Bevely Hills triangle, a park, and businesses. These sites can and should be developed with housing, but the current T-1 zoning only allows railroad uses. Unlike the properties in the Overlay, there are no existing buildings on these sites, so they could be readily developed with needed housing. Only with a more robust, comprehensive, and multifaceted approach can Beverly Hills hope to meet its RHNA obligations.
Thank you for your consideration.
Sincerely,
Keith Diggs (
Attorney, YIMBY Law
1 The Rise and Fall of Office to Multifamily Conversions: A Real Estate Investigation, CBRE, March 14, 2023, https://www.cbre.com/insights/viewpoints/the-rise-and-fall-of-office-to-multifamily-conversions-a-real-estateinvestigation 1 Chloe Chen
From: Lee, Chelsea@HCD <[email protected]>
Sent: Friday, August 4, 2023 12:43 PM
To: Mendoza, Kathyren@HCD
Cc: Housing Elements@HCD; McDougall, Paul@HCD
Subject: Fw: Beverly Hills Housing Element
Good Morning Kathyren,
Please file with Beverly Hills public comments.
Warm Regards,
Chelsea Lee (she/they)
Senior Housing Policy Manager, Housing Policy Development Housing & Community Development
2020 W. El Camino Avenue, Suite 500 | Sacramento, CA 95833 Work Cell: 916.820.1254 Cell: 916.284.4847
From: Darian Bojeaux
Sent: Friday, August 4, 2023 12:39 PM
To: Lee, Chelsea@HCD
Subject: Beverly Hills Housing Element
Hello Ms. Lee.
I am an attorney and resident of Beverly Hills. I reviewed the housing element rejection letter dated May 12, 2023, and signed by Paul McDougall who indicated that you are the person to contact on this matter.
I would very much like to speak to you for 5 to 10 minutes to share some information with you which concerns our city’s continued failure and refusal to make it easier for residents to build ADU’s, despite promises in housing element reports that the city will do so. and now our city’s attempt to make SB 9 completely ineffective in our city, which is scheduled to take place during a city meeting on August 10. Basically the city intends to adopt an ordinance containing parameters and rules which will make it difficult to impossible for anyone to build anything authorized by SB 9.
I am actually between a rock and a hard place because I want our housing element to be approved so we will not have unwanted developments which conflict with our zoning. But it is difficult to tolerate our city officials' continued failure and refusal to consider residents’ interests and to follow applicable laws.
Would you please call me or let me know when I may call you at your phone number as listed on an HCD directory.
2 Thank you.
Best regards,
Darian Bojeaux
1 Chloe Chen
From: Lee, Chelsea@HCD <[email protected]>
Sent: Friday, May 12, 2023 3:49 PM
To: Mendoza, Kathyren@HCD
Cc: McDougall, Paul@HCD
Subject: Fw: City of Beverly Hills
Attachments: May 2023 Comment Letter to HCD on Beverly Hills Housing Element.pdf Hi Kathyren,
Could you please save this to public comments folder for Beverly Hills? Thank you! Warm Regards,
Chelsea Lee (she/they)
Senior Housing Policy Manager, Housing Policy Development Housing & Community Development
2020 W. El Camino Avenue, Suite 500 | Sacramento, CA 95833 Work Cell: 916.820.1254 Cell: 916.284.4847
From: Matt Gelfand on behalf of Matt Gelfand
Sent: Thursday, May 11, 2023 2:07 PM
To: Lee, Chelsea@HCD
Cc: McDougall, Paul@HCD ;
Subject: RE: City of Beverly Hills
Hi Chelsea,
Attached is a letter formalizing our comments on the City of Beverly Hills’ adopted housing element. Matt
From: Matt Gelfand
Sent: Wednesday, February 22, 2023 10:06 PM
To: 'Lee, Chelsea@HCD'
Cc: 'McDougall, Paul@HCD' ;
Subject: RE: City of Beverly Hills
Hi Chelsea,
The City has chosen to basically ignore your most recent letter, and we expect the City to take the position that the housing element is compliant as-is with no further changes. The purpose of the City’s action last night was probably to attempt to moot our existing lawsuit against the City and build an argument that it is no longer subject to the builder’s remedy. It sounds like the City is planning on doing some more work on the housing element and re-re-adopting in a few months, with the aim of eventually getting HCD certification to free up access to grants, etc. Happy to discuss further if it would be helpful.
2 Matt
From: Lee, Chelsea@HCD <[email protected]>
Sent: Wednesday, February 22, 2023 10:17 AM
To:
Cc: McDougall, Paul@HCD <[email protected]>
Subject: City of Beverly Hills
Good Morning Matt,
I hope this email finds you well. I received your letter and notification on BH last evening. I am now monitoring the CC hearing, but I'm curious if you have any updates/insight that I should know about? It seems like they took into account the duplicated parcel, but I haven't seen any revisions from the City to date from their last letter. Many thanks.
Warm Regards,
Chelsea Lee (she/they)
Senior Housing Policy Manager, Housing Policy Development Housing & Community Development
2020 W. El Camino Avenue, Suite 500 | Sacramento, CA 95833 Work Cell: 916.820.1254 Cell: 916.284.4847
[landlordtenant.dre.ca.gov]
2/14/24, 12:48 PM Mail - Chloe Chen - Outlook
https://outlook.office365.com/mail/id/AAQkAGFkZmJhNGZhLTY3MDktNGRiMi04NjU4LTczYjU5NjMxZWE1OQAQAGW%2Bg6w%2F%2FTdOlDgH2et… 1/2 CAUTION: External Sender
Use caution when clicking links or opening attachments
Re: Housing Element Update - Revised Version Available Online Leo Pustilnikov >
Tue 2/6/2024 8:40 PM
To:Chloe Chen <[email protected]>
Cc:Masa Alkire <[email protected]>;Cindy Gordon <[email protected]>;Michael Forbes <[email protected]>;Ryan Gohlich <[email protected]>;Dave Rand You don't often get email from [email protected]. Learn why this is important FYI, appendix B page 25 412 n oakhurst doesn't match the numbers of page 26 (9 v. 42 units)... and 9600 wilshire doesn't add up (70 v 68 units)....also, if you don't mind, i'm curious how 244-256 n clark is getting to 55 units?
On Tue, Feb 6, 2024 at 8:05 PM Chloe Chen <[email protected]> wrote:
Hello,
You are receiving this email because City records show that you are on the interested parties list for the topic of the 2021-2029 Housing Element update. The City has been working to revise the Housing Element in response to the most recent comment letter received from the State Department of Housing and Community Development (HCD), dated 12-15-2023.
The revised version of the Housing Element, including the clean (non-track changes) and redline (track changes), is now available for review at: www.beverlyhills.org/housingelementupdate under the header "Important Updates". All other documents related to the Housing Element update are also available on this webpage for viewing.
The City will submit this revised version of the Housing Element to HCD on February 14, 2024. Please feel free to reply to this email with any comments you may have on the Housing Element. Thanks! Chloe Chen
(She/Her)
Senior Planner
Long Range Planning
Community Development Department
p (310) 285-1194
e [email protected]
Dear Planning Commissioners,
Having perused the housing element, I found an error on page 1-235 entitled Summary of Sites and AFFH Variables.
On page 1-235 it was misstated that Tract 7008.01 from north of Wilshire to south of Santa Monica Boulevard and west of Doheny is "predominantly zoned for muli-family and commercial uses”. In fact the majority of that area consists of single family residences from Wilshire to Burton Way and from Rexford to and including Doheny. Please see the map page 1-246 and the large swath of yellow single family residences compared to the much smaller areas of brown multi-family and lilac commercial property areas north of Burton Way.
In fact even Tract 7008.02 to the east, which starts with a couple of rows of single family homes and then changes to brown multi-family residences, includes a much larger area of multi-family buildings and about half as many R-1 homes. Yet that tract is described as being “predominantly zoned for single- and multi-family residential uses.”
I do not know how the misrepresentation of the Tract 7008.01 area affects the 621 RHNA units which have been allocated to it, but certainly Tract 7008.01 should more accurately be described as "predominantly zoned for single-family residential use together with some multi-family and commercial uses.”
On page 1-238, the map sets forth “clean criteria”, the meaning of which is unclear and although it may or may not be explained elsewhere, it should and could be easily clarified on the map key.
On page 1-247 at the right bottom, the stated densities seem inaccurate as well as missing.
Off topic, I and other neighbors want to thank all of the planning commissioners for their efforts concerning the 9229 Wilshire project, and especially co-chair Terri Kaplan and chair Gary Ross for inquiring into the accuracy of the state density bonus calculation on that project. Also, please know that we understand that on such technical matters commissioners feel constrained to follow the directives of the city attorney's office and planning department, and thank you for caring.
Best,
Darian Bojeaux
Honorable Chair, Vice Chair, and Commissioners:
I wish to bring up the subject of “Objective Design Standards.” I was quite surprised to learn that there was not a much greater emphasis upon “Objective Design Standards” in the amended Housing Element of the General Plan.
What are “Objective Design Standards”? A webpage from the Association of Bay Area Governments in 2021 described “Objective Design Standards”:
"California state laws, including 2017’s Senate Bill No. 35 and 2019’s Senate Bill No. 330, require housing development projects to be reviewed against objective design standards. Certain projects may only be denied approval by local governments if they violate these objective standards, which must be verifiable and measurable.
"The California Department of Housing and Community Development (HCD) created this toolkit to help local governments establish clear objective design standards in their plans and codes. The toolkit includes definitions, best practices and examples, as well as an overview of several key topics." * (https://abag.ca.gov/technical-assistance/objective-design-standards-toolkit) The City of Santa Barbara adopted their Objective Design Standards on May 11, 2021, as did other cities such as San Luis Obispo, which segregated downtown multi-residential from other areas.
If the City of Beverly Hills “Objective Design Standards” had been in place, following the Santa Barbara and/or San Luis Obispo models, neither 227 Tower Drive nor 9299 Wilshire would have had to be approved.
For 9299 Wilshire, the issues raised by residents relative to on street parking, delivery traffic, noise, modulation, shade and shadow, use of the alley, etc. could have been addressed.
In addition, “Objective Development Standards” also allow for progressive thinking.
One Commissioner queried about the 9299 Wilshire project of turning the square footage assigned to affordable one-bedroom units into singles, potentially doubling the number of affordable units. Another asked about the possibility of incorporating “purple water” systems.
Both would have been achievable if “Objective Design Standards” had been in place.
The “Objective Design Standards” could examine Transportation Network Companies (TNCs) delivering both passengers and packages, as it applies to “Complete Streets,” “Curbside Management,” as well as Climate Action initiatives.
Stated simply, “Objective Design Standards” can be designed to have tremendous latitude and return local control to the Planning Commission.
For example, Gruen Associates, a City contractor, updated the County of Los Angeles municipal code, and stated:
“Gruen developed flexible, objective design standards for building types found in and desired for unincorporated county areas.”
Unless “Objective Design Standards” are adopted immediately, the Planning Commission will continue to feel that their hands are tied.
In closing, the Planning Commission should urge the City Council to immediately adopt an “Objective Design Standards” Urgency Ordinance.
Steve Mayer
(310) 275-8423
* “Approaches and Considerations for Objective Design Standards” (HCD – January, 2021):
https://hcdarcgisdata.blob.core.windows.net/arcgis/Objective%20Design%20Standards%20Toolk it-%202021.pdf