REVISED RDGS FAIL TO PROTECT EXISTING PROPERTY OWNERS
For 20 years, the ResidenƟal Design Guidelines (RDGS) have served to protect exisƟng neighborhoods from excessive residenƟal and mulƟ-family development. The current revision fails to provide the same protecƟons.
REVISED RDGS MUST INCLUDE SUBJECTIVE LANGUAGE WHERE OBJECTIVE QUANTIFICATION HAS FAILED
The conclusion that those valuable subjecƟve guidelines that failed to be translated into numbers or otherwise so-called “objecƟve” criteria were thrown away is an error. In the case of currently discarded criteria, they must conƟnue to be included as subjecƟve to allow the Planning Commission, City Council and property owners the right that they deserve to protect neighborhoods. The current implementaƟon is a failure.
STRONG PROPERTY OWNER PROTECTIONS HAVE BEEN DISCARDED
Planning states "Guidelines in the 2003 Design Guidelines that cannot be translated into ObjecƟve Standards have been removed and the ObjecƟve ResidenƟal Standards apply." Basically, Planning admits that it simply removed the RDGs that were subjecƟve but funcƟoned effecƟvely for 20 years when it failed to translate those guidelines into objecƟve standards.
The Planning Department has taken the easiest, yet worst performing path for property owners as it aƩempts to update the prior RDGs. Planning is aƩempƟng to develop so-called "objecƟve" guidelines from subjecƟve criteria when convenient. Public comments have been made to use descripƟve staƟsƟcs, staƟsƟcal distribuƟons, and other objecƟve measures to assure compaƟbility, common character protecƟon, mass, volume, view block, among other damaging aƩributes, are avoided in new construcƟon or significant modificaƟons. However, those suggesƟons were discarded and instead that which was too difficult was jeƫsoned instead of being retained as subjecƟve.
Just because a task is difficult, doesn't mean it should be ignored. Furthermore, the obvious alternaƟve aŌer failing to develop objecƟve criteria is to leave the subjecƟve ones in force in order to protect other property owners from wholesale development chaos. There is ample Ɵme to replace them with objecƟve standards in the future when the work has been completed. For now, the exisƟng standards in those areas are far superior to NO STANDARDS as Planning has proposed. That approach has also been suggested in comments.
Planning has removed the strongest criteria in the mulƟfamily residenƟal and the results will allow developers, such as the Catalina project, to have their way with surrounding property. That is clearly not the intent of the RDGs, nor it is appropriate for the billions of dollars of exisƟng property to be degraded due to a lack of standards.
SPECIFIC PROPERTY OWNER SAFEGUARD RDGS THAT WERE CAST AWAY I understand the intent of moving from subjecƟve to objecƟve criteria. I am formally trained in engineering and quanƟtaƟve methods, so I prefer quanƟficaƟon when possible. At the same Ɵme, I recognize that the pornography standard was effecƟvely “I’ll know it when I see it” or “local standards” due to a lack of ability to quanƟfy it.
When faced with hard issues, such as, subjecƟve criteria requiring respect of the surrounding properƟes or avoidance of overwhelming scale, the authors apparently chose not to aƩempt to quanƟfy – and more problemaƟc – they simply abandoned the subjecƟve with no aƩempted objecƟve measure. The next page shows a number of those cases.
As a first step, the document should be redlined and all subjecƟve criteria that were not specifically quanƟfied should be returned into the RDGs. This document can then be circulated for comment and the team and public can work harder at quanƟfying.
Typical staƟsƟcal methods such as means, medians, variances, etc. can you used in many cases to quanƟfy scale, bulk, mass, etc. Respect is a term that is oŌen used in design, such as, respecƟng nearby neighborhoods and structures. Again, a set of characterisƟcs can be used staƟsƟcally such as mean volume, mean height, mean FAR, etc. to provide a semblance of objecƟveness.
Given the work product that is put forward, I recommend the Planning Commission reject it and send the team back to salvage the many places where subjecƟve consistency in character, respect, and scale were cast away with the subjecƟve guidelines unƟl such Ɵme objecƟve guidelines to PROTECT THE PUBLIC are completed.
Mark Nelson
ReƟred VP & Director of Planning for SCE and Subsidiaries Expert Witness
Experienced Developer
Below are prior comments on the draŌ that are sƟll relevant and acƟve. The final version that is proposed carried through with the “threat” of simply ignoring many, highly protecƟve RDGs.
I understand the intent of moving from subjecƟve to objecƟve criteria. I am formally trained in engineering and quanƟtaƟve methods, so I prefer quanƟficaƟon when possible. At the same Ɵme, I recognize that the pornography standard was effecƟvely “I’ll know it when I see it” or “local standards” due to a lack of ability to quanƟfy it.
When faced with hard issues, such as, subjecƟve criteria requiring respect of the surrounding properƟes or avoidance of overwhelming scale, the authors apparently chose not to aƩempt to quanƟfy – and more problemaƟc – they simply abandoned the subjecƟve with no aƩempted objecƟve measure. The next page show a number of those cases.
I would require that all subjecƟve criteria that were “punted” remain in the subsequent document. They can be removed when they are quanƟfied, but unƟl that Ɵme, they need to remain in order to protect both the intent of the RDGs and the public’s very clear intent for protecƟon of character and consistency.
As a first step, the document should be redlined and all subjecƟve criteria that were not specifically quanƟfied should be returned into the RDGs. This document can then be circulated for comment and the team and public can work harder at quanƟfying.
Typical staƟsƟcal methods such as means, medians, variances, etc. can you used in many cases to quanƟfy scale, bulk, mass, etc. Respect is a term that is oŌen used in design, such as, respecƟng nearby neighborhoods and structures. Again, a set of characterisƟcs can be used staƟsƟcally such as mean volume, mean height, mean FAR, etc. to provide a semblance of objecƟveness.
Given the work product that is put forward, I recommend the Planning Commission reject it and send the team back to salvage the many places where subjecƟve consistency in character, respect, and scale were cast away and re-enter them into the RDGs to protect property owners.
Mark Nelson
ReƟred VP & Director of Planning for SCE and Subsidiaries Expert Witness
Experienced Developer
From: RDG Update
To: Sean Scully; Brandy Forbes; Wendy Menendez; Latrice Williams Subject: FW: Comment: The May 2023 Draft has not been updated Date: Thursday, July 13, 2023 7:32:43 AM
All,
Another comment that came in to the RDG/ORDS update email.
FYI, I’ll submit an I.T. service request to have access of this mailbox transferred to Wendy moving forward.
Lina
From: Mark Nelson (Home Gmail)
Sent: Wednesday, July 12, 2023 8:40 PM
To: RDG Update <[email protected]>
Subject: Comment: The May 2023 Draft has not been updated CAUTION: Email is from an external source; Stop, Look, and Think before opening attachments or links.
Absent seeing the recommendations from the Planning Commission, I must object to the May draft.
It ignores many very important issues to residents and makes misleading statements that the draft takes the important issues into account, when it does not.