June 23, 2010 - From the June, 2010 issue

L.A. City Planning Reorganization Is ‘Game Changing'

The following article, written by Paul Hastings Partner Mitch Menzer and originally printed in the Stay Current newsletter published by Paul Hastings, details the institutional changes at the L.A. Department of City Planning-a wholesale reshuffling of depleted staff resources that will directly affect all developments making their way through the city planning process. Quite simply, these changes are the fulfillment of long-promised, consequential city development process reforms.


Mitch Menzer

The Los Angeles Department of City Planning recently announced an ambitious and potentially far-reaching reorganization based on two principles: First, entitlement projects will be staffed by a single Planning Department staff member who will handle all the entitlements work on a project, from advising the applicant before the case is filed, through the public hearings, and to issuing the final sign-offs for building permits. Second, all of the Planning Department's case processing will take place within one of four Geographic Divisions organized within the Community Planning Bureau in order to allow staff members to focus more closely on particular communities. The department-wide change follows the first step in the geographic reorganization that began during the summer of 2008 and included the San Fernando Valley area.

Currently, the Planning Department processes cases using a centralized structure in which certain types of cases, such as tract maps, variances, or conditional use permits are processed by specialized units according to the type of entitlement sought. For example, all subdivision cases are handled by a single unit, without regard to the geographic location of the project. Variances requested by the same applicant would be handled by another office. A zone change required for the same project would be handled by yet another unit in the Planning Department.

While this centralized system allows planners to develop expertise in a particular type of entitlement, it has been criticized for being time-consuming and inefficient, requiring separate and sometimes redundant reviews by multiple planners for a single project, and often frustrating applicants who are required to deal with multiple points of contact within the Planning Department.

The new organizational structure employs a decentralized approach to case processing in which a single planner will handle all entitlements for a project from beginning to end. Instead of separating cases by type of entitlement, one planner will be responsible for all entitlements on a case. The Planning Department believes this approach will result in a more efficient case processing system.

Cases will be assigned to a Geographic Division based on the location of the project. For example, a project located in Westwood would be assigned to the West Harbor Geographic Division and the Westside Subgeographic Section. By organizing around geographic regions, the Planning Department expects planners to gain a breadth and depth of knowledge about a particular community, which it believes will ensure high-quality, localized project review in all regions.

Case Processing and the Community Planning Bureau

Case processing will now take place within the Community Planning Bureau's four Geographic Divisions, each of which will be led by a Senior City Planner. Each Geographic Division (Valley, Central, West/Harbor, and South/East) will handle all projects lying within its boundaries. Each Geographic Division will be assigned a Zoning Administrator, who will be the decision maker for its zoning administration cases and will act as Deputy Advisory Agency for subdivision cases.

The four Geographic Divisions will be further divided into 17 Subgeographic Sections, each of which will be headed by a City Planner.

The only cases not processed by the Community Planning Bureau will be those handled by the Expedited Processing Division or the Historic Preservation Overlay Zone section of the Office of Historic Resources.

CEQA/Environmental Review

In addition to handling all entitlements required for a particular case, planners will also be responsible for conducting basic environmental review under the California Environmental Quality Act (CEQA).

Thus, planning staff will handle all Initial Studies, Categorical Exemptions, Negative Declarations, and Mitigated Negative Declarations. However, the citywide Environmental Review Division, which will be housed within the Community Planning Bureau, will continue to review all Environmental Impact Reports and will oversee the consistent application of CEQA policies in all areas.

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Plans and Policy

Planning staff within each Geographic Division will also work on major planning efforts applicable to its Geographic Division, such as Community Plan Updates, Specific Plans, and any locally specific overlays, such as Community Design Overlay Districts.

However, policy programs that are citywide in scope will not be managed by these geographically based planning staff, but will be handled by the new Office of Citywide Policy within the Citywide Planning Bureau. For example, periodic updates of General Plan elements or the adoption of citywide policy matters (such as the Industrial Land Use policy or the comprehensive revision of the City's sign ordinance) will be managed by the Office of Citywide Policy. The Urban Design Studio will continue its present function and will be part of the Citywide Planning Bureau, as will the Office of Historic Resources.

Implementation

Implementation of the new organizational structure will proceed in three phases, from May 2010 to January 2011. From May 2010 through July 2010, Planning Department staff will receive the new assignments and begin training for their new responsibilities. During Phase Two, from mid-July through September 2010, staff members will transition to their new assignments, and some cases that are in the early stages of review will be transferred to the appropriate Geographic Division. Finally, Phase Three, lasting from October 2010 to January 2011, will consist of a final round of training and oversight.

Horizontal Consistency

In addition, applicants may be concerned as to whether Planning Department recommendations on individual projects or the application of citywide policies will vary by Geographic Division. Aware of the potential for inconsistent case processing and policy application across Divisions, the Planning Department will create a "Horizontal Consistency" system in which senior managers will monitor and address consistency issues across eleven major areas, including Community Plans, Specific Plans, Area Planning and City Planning Commission cases, density bonus cases, subdivision cases, and environmental review. As part of the system, the Planning Department will try to ensure consistency in writing new plans, policies, and implementation tools. Nevertheless, the potential for cases to be processed and decided inconsistently across regions is significant, especially in a city as diverse as Los Angeles and where the purpose of the geographic organization is to allow planners to work more closely with individual communities.

Next Steps

The new organization poses many challenges, of course. Cases in progress will either be rerouted to the appropriate Geographic Division or remain with the originally assigned planner, depending on the case's stage of review, which could lead to added burdens on transitioning staff and could affect project timelines. In particular, project applicants will be very interested in how the handling of their projects might be affected by a transfer to a Geographic Division and new Planning Department staff.

In the short term, the Planning Department reorganization will undoubtedly affect many cases and will require close monitoring and management. The reorganization represents another step in the continuing evolution of planning in Los Angeles that merits continuing attention.

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