L.A. County's General Plan Is Without Vision & In Need of Update, Contends Environment Now

By: Terrell Watt, AICP, Kimberly Lewand, and David Myerson

Executive Summary

Visioning, planning and development are the most important issues confronting our community at present. These terms may sound obscure, but at their heart, they encompass the most immediate problems facing the region:

• Traffic congestion;

• Lack of available water sources for large new development;

• Continuing air and water pollution affecting humans, wildlife and sensitive habitat;

• Lack of available park space and recreation areas;

• Lack of affordable housing fairly allocated; and

• High costs of residential sprawl that divert valuable resources from urban areas.

By law, every city and county must have a General Plan document [to guide] politicians, planners, developers and the community at large in all decisions as to the development and maintenance of our cities and counties. As pressure for sound decision-making mounts in the coming years, some cities and counties have taken a proactive role in updating their General Plans to reflect changing trends and values.

• The counties of San Diego&Riverside have begun a process to involve its citizens in workshops to envision the future.

• These same counties, and others, have hired consultants and experts in various fields of community design and planning to assist their internal staffs in creating documents, which will be models for the future.

• The County of Santa Clara has drawn urban growth boundaries to ensure a better quality of life for its residents and a continuing tradition of agricultural uses within its borders.

• Cities such as Santa Monica and Thousand Oaks are taking bold and innovative steps to guide appropriate development for their respective communities.

Sadly, however, Los Angeles County is not among these cities and counties in its approach to updating its General Plan. A County consisting of 88 cities and significant unincorporated areas encompassing almost 10 million people has no guiding document that lays out a clear and effective plan for the future. Its transportation, land-use, open space and conservation elements are badly out of date and its housing element is merely a rubber stamp for theoretical numbers of how much housing may be accommodated within its borders, without any thought as to where that housing might most appropriately be constructed. New development is not planning driven; rather, planning is development specific driven.

It is well past time for a comprehensive review and update of the Los Angeles County General Plan.

A major opportunity now exists for the L.A. County Board of Supervisors to call for a comprehensive update that is inclusive of the public and other governmental agencies. Adequate resources must be made available to County staff to achieve these goals and assistance must be provided from outside consultants and experts where indicated. The Los Angeles County Board of Supervisors are the only elected officials with the stature, position, and bully pulpit to effect such change in the General Plan. No elected officials will be better remembered than those that engage themselves and provide their leadership, experience and guidance to craft the document and vision for the future of Los Angeles County.

L.A. County General Plan Update: Wrong Turn

When the County of Los Angeles issued updated Housing and Safety Elements without benefit of a comprehensive general plan update or analysis of their impacts, it took a wrong turn. Not only was there limited public participation in the update process for the two elements, but CEQA compliance consisted of negative declarations with limited environmental review rather than an EIR. The materials provided at the housing element workshops consisted of a few brief pages of housing trend statistics. No comprehensive materials or maps were provided to facilitate informed dialogue about housing issues. No community leaders or local environmental groups were contacted for input and discussion.

The result was to deprive the public and decision-makers of meaningful input on key public policies, which ultimately affect the overall quality of life for every citizen of L.A. County. It is essential that the public be provided an opportunity to participate fully in the General Plan update because, as William Fulton put it so simply in his Guide to California Planning, "Planning is the process by which our society decides what gets built and where." In its draft proposed Housing Element, L.A. County Staff proposed to build 50,000 new housing units in five years "somewhere" in the unincorporated sections of the County. The Negative Declaration for the draft Housing Element incredibly found that there would be no significant impacts of this new housing. The Negative Declaration also failed to address the cumulative impacts of the proposed 250,000 new units of housing allocated by the Association of Southern California Area Governments (SCAG) in the incorporated and unincorporated portions of the County.

Through quick efforts by L.A.-based environmental organizations, the County withdrew the Housing and Safety Elements. However, the County is again proceeding with its completion of a Housing Element with the limited environmental review of a Negative Declaration (due end of September 2000). The remainder of the General Plan update on the other hand, is not due until the year 2001.

The County's update process has taken a wrong turn in many other respects as described in detail below. What follows is a seven-point plan to put Los Angeles County's General Plan update process back on a proper course:

1. The General Plan Must Be Current

The County General Plan is grossly out of date. The Land Use, Circulation, Conservation, Open Space and Recreation, and Public Facilities elements were adopted in 1980. The Land Use element has been amended countless times since 1980. A number of elements were adopted even earlier, including the Regional Recreation Plans, adopted in 1965 and the Noise and Safety elements adopted in 1975. The Housing Element was adopted in 1989. By law, the Housing element is required to be updated every five years.

The County's Land Use Diagram identifies land uses for [both public and private uses in] unincorporated areas of the County. This element must serve as the central framework for the entire plan and is intended to correlate all land uses into a set of coherent development policies. Yet the land use diagram is out of date and fails to identify proposed land use, as it must. It is so outdated, that the County relies instead on a color land use diagram for processing applications. This updated land use diagram is not available to the public because it is still "a draft."

2. A Work Program Must Guide the General Plan Update Process

Environment Now first learned of the Countywide General Plan update when it received notice the County was requesting proposals for designation of significant ecological areas (SEAs). When asked for the County General Plan update work program, the County Staff produced a work program only for the SEA component . No other publicly available work program for the broader General Plan update has been offered . In the absence of a work program for the update, the update process is obscure and meaningful public input frustrated.

Moreover, when questioned about the nature of the update, County staff responded that the update was merely a "technical" update and that entire areas of the County would either not be subject to review (e.g. Antelope Valley) or would be addressed in a separate update process (e.g. Santa Clarita area is proposed for a joint update with the City of Santa Clarita). In the midst of the General Plan update, the County is proceeding with "Interim" Area Plan updates, such as for the Malibu/Santa Monica Mountains area and the Malibu Local Coastal Program. Thus it appears that the General Plan update will not be comprehensive, but rather will be merely "technical," or updated through a myriad of individual area plan revisions.

It is not clear how the County can emerge with a legally adequate and comprehensive General Plan without a work program, and with multiple disparate pieces of the General Plan being produced independently of one another.

3. Baseline Information Must be Developed to Guide the Plan Update

To kick-off the update of the Monterey County General Plan, the County produced a "workbook" for the public which includes information about existing land uses, population projections, housing stock and needs, economic conditions, local and regional issues that need to be addressed, and existing constraints to development such as water, wastewater treatment and the like. [And Riverside and San Diego counties have provided similar information.]

In contrast, L.A. County staff has distributed a five-page discussion of housing to guide workshops on the Housing Element. No information has been provided on the overall status of the County to guide public input on either the Housing Element or the SEA process. Absent information about the status of the County, or a current land use diagram, it is difficult for the public to provide meaningful input on the elements and area plans as they emerge for public review.

4. Provide for Citizen Participation

Citizen participation is essential to an adequate update process. Riverside County has three General Plan advisory groups staffed by the County and its consultants . [And] San Diego County established two committees [to] discuss major components of the planning process and provide [recommendations] directly to the County Planning Commission and Board .

In contrast, Los Angeles County has not established any citizen participation or other advisory groups to guide the General Plan update. To date, they have held 11 workshops on the Housing Element, which were poorly advertised and therefore, poorly attended, and a few meetings to describe the SEA process and invite proposals for SEAs.

5. Develop a Preferred Plan & Alternatives Based on a Community Vision

The County update process is a black box. It is not clear what the County intends as an outcome of the draft General Plan update. To date, no attempt has been made to obtain community input toward a community vision to guide the development of a Preferred Plan Alternative. Nor have consultants been hired, as they have in San Diego, Riverside and Monterey Counties, to analyze alternative scenarios for growth and determine their relative impacts on the environment and comparative ability to address major issues. To the contrary, the public expects, based on what Staff has said to date, merely to receive a Staff generated "technical" draft general plan update document with a limited public comment period sometime early next year.

6. Include a Comprehensive Environmental Review

The County circulated Draft Housing and Safety Elements in January 2000 for public review and comment. In lieu of an EIR, or even Mitigated Negative Declarations, the County relied on Negative Declarations for each Draft Element. The Negative Declarations were devoid of information about baseline environmental conditions and project impacts.

When asked if the County intended to develop an EIR for the General Plan update, Project Manager George Malone responded that an EIR was likely. However, the County has not yet circulated a Notice of Preparation for the General Plan EIR, despite the fact that the County expected the remaining Draft General Plan Elements to be released in early 2001.

7. Interagency Involvement Is Required

The County has not established any formal approach to interagency involvement. Yet, other agencies, including but not limited to the incorporated cities within the County, the MTA, the Regional Water Quality Control Board, Caltrans, the SCAQMD among others, clearly have a stake in the County. Moreover, it is not clear how the County is involving other departments within the County that are undertaking projects relevant to the General Plan update. For example, in August, the Los Angeles County Department of Public of Public Works created a new Watershed Management Division. The new Division will focus not just on keeping Los Angeles safe from floods, the traditional role of public works, but also on retaining floodwater to bolster aquifers and wildlife habitat. This approach to the County's watershed represents a major shift in public policy and one that must be incorporated into the General Plan update.

Next Steps To a Visionary Blueprint

The role of L.A. County's General Plan and its importance in maintaining and enhancing the quality of life for every County resident is paramount. No short cuts should be taken in preparing a comprehensive General

Plan update with full public and inter-agency participation.

Specifically, the County Board of Supervisors should seize this opportunity to:

• Take a leadership role in establishing the guiding vision for the development of L.A. County for the 21st century.

• Take steps to make the General Plan update process transparent and open to the public and other agencies:

• Develop a comprehensive work scope to update the General Plan and adequately staff the process.

• Limit General Plan amendments and major project approvals until the update is completed, either through an interim ordinance adopted by the Board of Supervisors, or other means.

Conclusions

As citizens, we all have the right and a responsibility to determine what our County, its incorporated cities and the surrounding region will look like as we move into this new millennium. The challenges are significant, as we have abdicated this responsibility for too long. When job growth in the San Fernando Valley stimulates housing construction 40 miles away in the Antelope Valley, our existing transportation network is taxed to the breaking point, and the lost worker productivity, resulting increase in air and water pollution, and the high individual costs of commuting to work and school are definite signs of a degradation of our collective quality of life.

As we have seen in the previous pages, a mechanism does exist that allows the residents of Los Angeles County to begin to remedy this situation. The General Plan is that mechanism. And our elected officials and community leaders should exercise their influence and authority to guide all of us to a better quality of life for ourselves and for future generations.

This report was reprinted with permission from Environment Now. Please contact Terry Tamminen or David Myerson for more information or the full report. Phone: 310-829-5568.