November 30, 1991 - From the November, 1991 issue

CHAS Chastised as Misguided by Homeowner Alliance

The Comprehensive Housing Affordability Strategy (CHAS) was released in early September of 1991 by the City of Los Angeles' Housing Preservation and Production Department. The LA CHAS comes after the Federal HUD NIMBY Report by Jack Kemp, accusing NIMBY sentiments as the leading blockadge against affordable housing in the nation. Bill Christopher, founding member of PLAN/LA and a member in the City's Board of Zoning Appeals, presents the PLAN/LA's criticism of the CHAS for sharing ideas from the Kemp Report.

In early September, the City of Los Angeles’ Housing Preservation and Production Department (HPPD) released an innocuous little (125 pages) blue document, called the Comprehensive Housing Affordability Strategy or CHAS. 

CHAS is essentially a six point policy document designed to promote the development of housing in Los Angeles over the next five years. It was chock full of ideas on how to solve the affordable housing crisis in the city. And the city’s neighbor­hoods went nuts. Why would a hous­ing policy statement make such an impression? 

The NIMBY Report 

It made a mark because it was the most glaring in a string of attacks on homeowner and community groups that trace back to the Kemp Report titled “Not In My Back Yard (NIMBY),” issued in July by HUD. This report claims that the NIMBY syndrome has become the “rallying cry” all across the country to prevent affordable housing through the use of codes and regulations which prolong the permitting process. Remove these “barriers,” this latest theory goes, and affordable housing ills will be no more. 

Using the Kemp report as a basis, Mayor Bradley joined the fray. In remarks to both the Planning Department’s Staff and the Affordable Housing Commission, he issued stunning attacks on homeowner as­sociations, naming them as a primary cause for the lack of affordable housing in Los Angeles. 

In the meantime, Congress en­acted the National Affordable Hous­ing Act of 1990,which requires communities wishing to receive HUD funds to submit a Comprehensive Housing Affordability Strategy (CHAS) by November of this year. Los Angeles has submitted a request for approximately $60 million. 

Hence the task of quickly preparing a local CHAS, and getting it approved by the City Council, has fallen to the new Housing Department. The original draft CHAS was written in response to HUD, dutifully parroting the idea that “NIMBY” was the root of all evil. And it went HUD one better. HPPD somehow calculated that the city was about to run out of zoning capacity. According to the early draft, the City had merely seven years of capacity left and then it was all over. Hence, CHAS prescribed an all-out assault on the zoning code and the General Plan. It argued that the only viable alternative was to “densify” the City, and to do so quickly. 

By the Numbers 

The Planning Department, how­ever, appeared at the initial public hearing for CHAS and demonstrated that for every two housing units in existence today, we can still build one more without breaking a sweat. Even after the downzoning associated with AB283, we have at least a thirty-year supply of capacity left. 

Contrary to the conclusions reached in Federal reports mimicked in the CHAS draft, Interim Control Ordinances (ICO’s) are not significant impediments to housing production. Most ICO’s are directed at commercial construction and at traffic generation. ICO’s that are targeted toward residential areas are often about preserving affordable housing in place, which is a primary goal of the pro­posed Housing Strategy. 

Downzoning as the principal culprit in the lack of affordable hous­ing is also challenged by a research study, also soon to be published through UCLA, which finds that in California at least, the opposite is true. Cities with the strongest community protection and environmental laws have been found to be leaders in the production of affordable housing. The two appear not to be mutually exclusive at all. 

No one has “cut off the housing supply” in Los Angeles, as the draft suggested. According to Building & Safety figures, we were producing 27,000 units or housing a year as recently as 1986. In the past five years the economic picture has changed and, as a result, the overall production of housing has fallen dramatically. But it hasn’t stopped by any means. 

PLAN/LA In Response

When community members first looked at the original draft of the CHAS, they felt that there was a typo in the title, surely the Housing De­partment was really talking about CHAOS. 

The city was about to adopt a sweeping policy that recommended code changes to permit smaller lots, higher densities, unlimited transfer of development rights, second units on single family lots by-right, extension of multi-family zoning into R-1 neighborhoods, and a host of other misguided directives. The cumula­tive effect of these changes would have gutted the planning function as we know it in the City.


Homeowners and community groups took this misrepresented assault as a call for action. Responding to the proposed CHAS and other attacks, many groups have come together to build a citywide neighborhood force crossing geographic, ethnic and racial lines. This new community coalition, built on the foundations of the locally entrenched Federations, Committees and Alliances, is called People for Livable, Active Neighborhoods in Los Angeles, PLAN/LA.

PLAN/LA includes over 150 community groups, representing residents who live in both single and multiple-family housing, ranging from the Harbor to East LA, and the Westside to the Valley. Until now, homeowners and community leaders have lacked a structure with which to counter the Building Industry Association and other trade groups which centralize lobbying and create a unified force. PLAN/LA is designed to provide community interest with a counter point on citywide policy issues, such as the CHAS.

PLAN/LA has as its goals several key concerns in the citywide arena. We want to protect livability for all the residents of the city. We want to see managed growth take precedence over market driven growth. We want to promote interaction between resi­dents and businesses and encourage participation in the political process. 

The Vision Vacuum 

The affordable housing problem cannot be solved in a vacuum, as the preparers of the CHAS seem to prefer. Given the age and inconsistent nature of the existing planning framework, it is extremely difficult to make far-reaching policy decisions regard­ing affordable housing. 

It is but one piece of a vision which also must include the financing of infrastructure expansion and an increase in middle income employ­ment opportunities. The picture must also integrate transportation policy closing the loop between jobs and housing while addressing a significant improvement in air quality. Some of these issues are raised in the CHAS, but there is no opportunity to test the result against a cohesive backdrop.

The Future of Housing

As the CHAS has evolved, it appears that HPPD General Manager Gary Squier and his staff have addressed several of the concerns raised by the community in the initial airings of the document. While in many cases their responses have alleviated community concerns, there are still strong doubts about some of the programs contained in the policy statement.

Many community leaders still look at CHAS as a means to undo planning protections in the guise of affordable housing. It is PLAN/LA’s intent to safeguard the planning process and not let it deteriorate into a series of ad hoc decisions.

Rather than looking at code changes designed to assist developers of housing projects, we must focus on the livability of the units that are fostering. Building units for the sake of building ignores the needs of the people who will have to live in them. The CHAS is silent on the question of added amenity for housing, fearing that amenity costs money. It doesn’t have to. Sensitive design and trade-offs in other areas of the program can go a long way to making the units habitable to the residents and more acceptable to the community as a whole.

In the next housing battle over the Housing Element of the General Plan and the formation of the Citywide Housing Policy, PLAN/LA’s focus will be on the habitability of housing. We must create units that will contribute to a positive future and we cannot allow the creation of instant ghettos that only provide temporary solutions to a long term problem. 

Since CHAS serves as a state­ment of intentions for these upcoming decisions, we remain concerned that CHAS’ tone implies that NIMBYs and community groups are responsible for the housing shortage. Since we still have a thirty-year supply of housing capacity, it is not necessary to undermine what little planning we have left in place. Good planning in Los Angeles may indeed warrant some further downward ad­justments in the zoning capacity to assure that we can grow steadily and orderly within the means of our infra­structure. 

Housing our population is a critical issue for the City. It will take cooperation and input from all sides. Unfortunately, the CHAS, grounded in the findings of the Kemp Commission, has established a background of suspicion and contradiction that will be difficult to overcome.


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