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Greater Griffith Park Neighborhood Council
Position Statement on LA Proposed Inclusionary Zoning Ordinance
(9/21/04)

Community Impact Statement (Submitted August 30, 2004):

The Greater Griffith Park Neighborhood Council supports the City's efforts to create urgently needed affordable housing. We oppose the proposed Inclusionary Zoning Ordinance (IZO) because of its one-size-fits-all approach to addressing this issue throughout city neighborhoods with their widely differing abilities to support increased population density while preserving quality of life.  This proposal appears to be a presumptive preemption of local control and community plans that undermines the very purpose of Neighborhood Councils.  We would like to work with the City, other NC's, developers and other city stakeholders to craft a solution to address this critical community need.

Findings:

We find that the City has not made a case for why an Inclusionary Zoning Ordinance is the next best step in creating affordable housing in Los Angeles.  There appears to be no one set of agreed-upon goals to support the direction of the proposal, and it appears that insufficient information has been gathered relative to the success or failure of inclusionary programs in other cities.

The components of the IZO policy matrix (April 4, 2004) are apparently based on the City-commissioned Rosen Report (September 2002), which presented important findings about the impact of inclusionary programs on housing production in other cities from the perspective of financial feasibility for developers.  In conjunction with the IZO proposal, however, there has been no apparent study that provides an analysis of voluntary incentive programs as an alternative, evaluation of the impact of inclusionary programs on the quality of life in communities, or evaluation of additional requirements for water, schools, open space or public transportation created by such programs. 

We find there are important outstanding questions such as:

- Considering previous programs in Los Angeles and other cities' experiences, is inclusionary zoning the next best step in addressing the issue of affordable housing?

- In other cities, have there been successful voluntary incentive programs to encourage housing construction that is profitable for developers and that preserves the quality of life for all stakeholders?  If so, what were the success factors?

- Has a one-size-fits-all program in other cities allowed for the preservation of individual neighborhood character?

- What degree of discretionary action can be provided to enable community input on inclusionary developments?

- What impact have inclusionary programs had on communities in other cities?  What program components in other cities have created negative or positive impacts on the quality of life in neighborhoods?

- How have other programs implemented monitoring and accountability for compliance and what was the cost?

We have heard various goals attributed to the IZO, but we have not seen an agreed-upon summary of these goals or objectives.  We feel that detailed goals and objectives are critical to formulating any program and for justifying individual program components. 

As one example in this proposal, if a goal of the IZO is to achieve the fair sharing of affordable housing throughout all areas of the City, which program components support that goal?  Also with specific objectives, the potential risk in program components can be examined, such as how in-lieu fees might be abused to undermine program goals.

Without explicit goals to set and support direction, and without additional information on the success or failure of housing programs in other cities, we feel that City Council and City stakeholders cannot reasonably formulate a next-best-step policy on affordable housing that fairly weighs community interests with developer incentives.

Recommendation:

The Greater Griffith Park Neighborhood Council fully supports continued funding for the Affordable Housing Trust Fund.

We recommend that a cross-stakeholder task force including neighborhood council representatives be assembled for the following purposes:

  1. Summarize and report on the progress made on the recommendations contained in the 2000 Housing Crisis Task Force report, which provided detailed recommendations for addressing the affordable housing issue in Los Angeles.
  2. Update that report for factors that were not addressed or did not exist then (factors such as immigration, birth rate and the outsourcing of jobs overseas), and to make proposals for addressing these issues where possible.
  3. Identify and reassess any unmet objectives of current City housing programs.
  4. Develop specific goals and objectives for further affordable housing development in Los Angeles.
  5. Develop criteria (including concerns about community impact and infrastructure needs) with which to commission a further study of affordable housing programs in other cities (including, but not exclusive to inclusionary housing).
  6. Based on best-practice findings, develop a detailed, next-best-step proposal for Los Angeles, be it inclusionary zoning or otherwise.

We further recommend that any housing program implemented by the City respect current zoning that is intended to preserve public safety or the special character of neighborhoods.  Specifically, a program must not override the Hillside Ordinance whose purpose is to preserve public safety in Hillside areas.  It must also not override specialized zoning such as Specific Plans, Historical Overlay Preservation Zones and Community Design Overlay Districts that are intended to preserve the historical nature or unique character of neighborhoods.