REQUEST FOR SUPPORT
The City Department of Planning has posted the Negative Declaration for the adoption of Citywide Urban Design Guidelines (Guidelines) which has a comment deadline of August 25, 2010. These Guidelines will be an Appendix to the General Plan Framework Element for Multifamily Residential, Mixed-Use, Commercial and Industrial land uses (see project description below). The purpose of the Design Guidelines is twofold: to implement the design values in the 10 Urban Design Principles, a part of the Framework Element, on individual projects; and to consolidate basic Design Guidelines common throughout most Community Plans in one document. The Design Guidelines will establish design expectations for new development based on Citywide goals, policies and objectives.
In response to our complaints, the Planning Department has extended the public comment period on the Negative Declaration to September 7, 2010 in lieu of August 25. This update will be published in Thursday’s date LA Times classified section.
Reportedly, the draft guidelines will be released shortly along with the invitation to participate in public discussion meetings. It is time for Neighborhood Council (NC) land use committees to agendize, review and comment.
In our ongoing efforts to promote judicious communications, openness, and citizen participation in this and all planning processes, we would suggest that NC comments address both procedural and content issue concerns:
First, the date extension does not negate the primary concern that the Negative Declaration was released before the Guidelines; and, secondly, adequate time was not provided to stakeholders (community) for review of the Guidelines, after their release and before the Negative Declaration comment period closed.
Most important, we are concerned that although the letter of the law may have been followed, the process has included only a token outreach, notification and stakeholder (community) involvement and no Neighborhood Council involvement. We advocate a more open process and adequate time to review the actual guidelines. For this and all land use matters, in order for each Neighborhood Council to have the opportunity to review these materials, we urge the Planning Department to allow for and build into the schedule a minimum of 60-days for NC review and comment. In order to understand the process; to be sure NC comments are incorporated into the staff report that ultimately goes to the City Planning Commission and to allow for expanded stakeholder outreach and for participation in the process. It is important to open the dialogue and realize that the NCs not only need to see the actual product that they are commenting on, but also need time to bring stakeholders into the discussion.
The goal should be for a place for stakeholder involvement in the discussions during development of planning products so that community thoughts are incorporated into the proposals making for stronger draft documents. This could also mean that NCs are no longer placed in the position of criticizing Planning Deptment initiatives; but rather would serve as a source of support as initiatives move through the review process. NC contributions should be incorporated into the staff report that ultimately goes to the City Planning Commission. It is important to open the dialogue and realize that the NCs not only need to see the actual product that they are commenting on, but also need time to bring the discussion to their stakeholders. Too often, time is not incorporated into comment periods that allow NCs to meet Brown Act requirements, to say nothing about convening a robust community dialogue.
Below is a sample resolution and additional background information on this proposed project and related process.
The City of Los Angeles Planning Department’s contemplated Policy Motion regarding Mitigated Negative Declaration does not allow adequate time for Neighborhood Councils’ to deliberate and input,
The City of Los Angeles Planning Department has failed to post all background research documentation related to this issue (project),
The City of Los Angeles Planning Department has failed to fully disclose the precise text of these proposed changes and how they fit into the General Plan Framework Element;
The [your name] Neighborhood Council endorses the resolution to require the Planning Department to post all background research documents related to NEGATIV DECLARATION-NG-10-280-PL: ENV-2010-715 online; to provide full disclosure of the precise text of these proposed changes and how they fit into the General Plan Framework Element; and to restart the Negative Declaration process at the time these documents are posted to provide for full review of the Guidelines and the Negative Declaration in accordance with CEQA notification and review requirements.
The City Planning Department has released the Negative Declaration on Urban Design Guidelines that have not been completed. It is their finding that these Guidelines have no environmental impacts. The Notice includes a close of public comment on the Negative Declaration as August 25, 2010. This date is before the Guidelines are projected to be completed and available for review.
To put out a Negative Declaration before the proposed Guidelines (the Project) are circulated is not good planning practice. They must be circulated concurrently. How can one comment on or review potential impacts without seeing the actual Guidelines? Further, if the actual guidelines differ from that described in the environmental document, then there is a real problem. In that case, the environmental document will have to be updated and re-circulated for public review. It is better planning practice to circulate the environmental documentation concurrently with the actual project description in order to avoid confusion and lack of public trust. While the published environmental notice has an August 25, 2010 deadline for comments, the Negative Declaration is not adopted until the City Planning Commission takes an action on it. Accordingly, there is opportunity to comment on the environmental document up to and including the public hearing before the Planning Commission. The date has not been set for that hearing, but is projected to be either mid-September or October.
Cindy Cleghorn, PlanCheckNC and Lucille Saunders, La Brea Willoughby Coalition, met with Michelle Sorkin and the assigned Intern at the Department of City Planning who are the lead planners assigned to this project. Sorkin said that Los Angeles does not have urban design guidelines as other jurisdictions do and that Guidelines are long overdue in the City of Los Angeles. They have studied 20 or so other guidelines as part of their research. The guidelines will be a tool in addition to Community Plans, Specific Plans and other existing design guidelines. We have been told that two public meetings are being scheduled for August 30 and 31. This is a short time window for scheduling and we would suggest these meetings not be held until the Guidelines have been released and NCs have had an adequate opportunity to review them. Public comments on the environmental aspects on the Citywide Guidelines cannot be addressed without adequate citizen input into the Guidelines. And then, the basic planning process to judge environmental impacts on those Guidelines would follow.
This has been a project of the Department of City Planning as part of their “Do Real Planning” policy for two years, but the process of the release of the Negative Declaration and Guidelines and expected adoption by the City Planning Commission in 2010 are now moving very quickly particularly given how long the City has been working on the Draft Guidelines. They also tie in with the City’s Urban Design Studio that Emily Gabel-Luddy (now retired) and Simon Pastucha established. Gabel-Luddy and Pastucha introduced their design concepts at PlanCheckNC and several neighborhood council groups and coalitions a couple of years ago. Upon adoption of the new Citywide Urban Design Guidelines they will form the basis for a checklist for all projects.
NCs have an opportunity to get involved now but we must do so quickly and work together to get the word out. By sending out this notice, we are alerting NC Land Use Committees so they can agendize and discuss the Guidelines. Attend all public meetings and weigh in at that level and encourage participation by our land use committees and stakeholders. PlanCheckNC will also continue to work to open the Department of City Planning communication loop sooner so we do not continue to find out about these types of projects and issues at this late stage.
PROJECT DESCRIPTION FROM NEGATIVE DECELERATION
NEGATIVE DECLARATION-NG-10-280-PL: ENV-2010-715 Citywide. The proposed project involves the adoption of Citywide Urban Design Guidelines (“Design Guidelines”) as an Appendix to the General Plan Framework Element for Multifamily Residential, Mixed-Use, Commercial and Industrial land uses. The purpose of the Design Guidelines is twofold: to implement the design values in the 10 Urban Design Principles, a part of the Framework Element, on individual projects; and to consolidate basic Design Guidelines common throughout most Community Plans in one document, allowing individual New Community Plans to provide tailored, neighborhood-specific Design guidelines. The Design Guidelines will establish design expectations for new development based on Citywide goals, policies and objectives. The Design Guidelines will illustrate ways for individual projects to promote walkability, maintain neighborhood form and character, and promote creative infill development solutions. The Design Guidelines will apply to all new developments and substantial building alterations that require discretionary approvals from the Dept. of City Planning. As well, they may also be used by staff in other Departments or community members for advisory review of new development applications. Please call Michelle Sorkin a DAY in advance to review the file: (213) 978-1199. If she is not available, please leave message. Documents are available for REVIEW by APPOINTMENT only at: Los Angeles City Hall, 200 N. Spring St., Rm. 621, Los Angeles, CA 90012. Comments can be faxed: (213) 978-1226. REVIEW/COMMENT period ends: Aug. 25, 2010.