Edward Levin’s Public Comment at the Planning Commission is a ‘reality check’.

At this past week Planning Commission meeting the commission received an update on the Housing Element. The discussion of housing policies followed. The staff report provided an overview of the current process and moved into strategies to meet the projected housing needs. Edward Levin, a West Hollywood Resident, and Historic Preservation Commissioner, and Architect spoke during Public Comment and brought forward a ‘reality check’ that is needed for many to understand the development process. A copy of his full letter to the planning commission can be seen here.

To follow is Mr. Levin’s public comment with <context> additions for clarity.

6 May 2021, Item 13.A – Housing Element Discussion.

The City shouldn’t make promises it can’t keep. And it shouldn’t make promises the community can’t understand. The community takes the City’s words literally – understandably so. So if the City makes statements that cannot be read literally, the predictable result is that the community ends up with unrealistic expectations. And that guarantees that the community will continue to get upset at land-use decisions they don’t understand. This is where we’ve been for many years – with the City and the community talking past each other. It’s not working. 

It’s time for the City to deal with the community in a way the community can understand. So it’s essential that the Housing Element doesn’t promise anything the City isn’t prepared to deliver. The City has to speak openly and directly about its intentions – and about the constraints on its ability to realize those intentions. 

There are three kinds of problems in the proposed draft: 

The first is a promise the City can’t deliver; 

The second is a promise that doesn’t reflect reality; and 

The third is a promise that no one really understands. 

<displacement of residents due to development and the Ellis Act> Goal H-1 is a promise the City can’t deliver. The draft adds the phrase “and avoid displacement.” The City can’t deliver on this, and they know it. It’s legally impossible. The word “avoid” can’t be taken literally so it shouldn’t be used. “Avoid displacement” should be changed to “Minimize displacement.” 

<permit processing for development permits> Goal H-5.4 is a promise that doesn’t reflect reality. “Continue to provide for timely and coordinated processing,..” implies that we currently do provide timely processing, when in fact we don’t. Processing time has doubled over the past years. Let’s be honest: strike “Continue to…”, start “Provide for…” 

<providing adequate sites for development> Goal H-4.2 is a promise that no one really understands. And this is the most serious of the issues.  <how can this be possible to understand the physical implications of making decisions)_

Page 15 of your Staff Report asks the Commission “Where should future development potential be concentrated?” And you’re supposed to answer that question based on an unintelligible Site Inventory Chart on Page 14.

And you’re supposed to answer the question based on an unintelligible Site Inventory Chart. It’s not unintelligible because the numbers don’t make sense. The Inventory Chart is unintelligible because no one understands its urban design implications. We can’t translate the aspirations of the Housing Element into a Zoning Map – unless you understand what that Zoning Map means in physical, urban form. You can’t answer the question, “Where should future development potential be concentrated?” without understanding how the Site Inventory Chart translates into – How many stories? in What areas? on Which commercial streets? or in Which residential neighborhoods? 

Because the question you’re really being asked is, What will the city look like? And “we didn’t think about it in those terms – we just looked at the numbers” is not an acceptable answer. 

So you need to have the Urban Design and Architecture Studio model your options. UDAS was created to help you make informed decisions about land-use policies. And I know there’s a deadline for the Housing Element. But you can’t do this blind, and that’s what you’re being asked to do.

I ask you to make the changes to H-1 and H-5.4. More importantly, I urge you to insist that UDAS provide you with the tools you need to have an informed discussion of the urban design implications of the housing goals of the city.

Publishers Note: It’s important to note State Law and Federal Law guide many of our broader housing policies. Residents such as Edward Levin speak for the public good and deserve our appreciation.

Thank you Edward Levin.