April 2, 2014 - From the April, 2014 issue

City of Los Angeles' Initiative to Streamline Its Development Process Becomes Clearer

Conversation about merging the Los Angeles Departments of City Planning and Building & Safety began at the end of former Mayor Antonio Villaraigosa’s term, and has continued into Mayor Eric Garcetti’s administration, with Matrix Consulting Group hired to evaluate its feasibility and efficacy. Matrix released a report outlining findings in February, with a cover report by the CAO and CLA. Mayor Garcetti has announced that he does not support a full merger of the departments. Kevin Keller serves as the Director of Planning and Housing Policy under Garcetti, and formerly worked as a senior city planner in the LA Department of City Planning. Keller sat down with TPR to offer his takeaways from the report, provide context, and explain the administration’s likely course of action on development services reform. 


Kevin Keller

"At this point, working with the leadership of the Planning and Land Use Management Committee, with Councilmember Huizar, Councilmember Englander, and Councilmember Cedillo, the full consolidation of departments is being taken off the table. However, the idea remains of consolidating key specific functions where there is utility." —Kevin Keller

Kevin, TPR readers would welcome your assessment of the newly released report by Matrix regarding reform of the City of LA’s development process—a document commissioned by City Council and CAO Miguel Santana, in response to former Mayor Villaraigosa’s proposal to consolidate Planning and Building & Safety. What functions does the report recommend consolidating? Which Matrix recommendations are likely to be adopted?  

The Matrix consulting team has now issued its report. There is also a cover report by the CAO and CLA that was endorsed by the PLUM Committee and will be going to Council on April 2. That’s the report that summarizes the outreach and the interdepartmental team that worked to collaborate and develop these recommendations.

The Matrix report includes overarching goals but also fairly specific strategies. A number of these strategies involve a single department, and a number involve multiple departments. Although the report is pending City Council review, the departments are already working to create an inventory of strategies to be implemented. One of the actions on the joint report, which the mayor supports, is the requirement that the development service departments report back on these more specific departmental-level strategies. For example, we’re working at the mayor’s office collaboratively with the development services departments—such as Building & Safety, the City Planning Department, the Bureau of Engineering, Fire, and DOT—to develop matrices. We are going over each of the implementation recommendations from the Matrix report to find out which ones are doable pretty much as is, and to find out which ones raise additional questions as to how best to implement.

The report is mainly a roadmap. There are specifics recommended by the consultant, but we want to make sure the specifics can also be implemented by each department. To do that, we want to have the departments weigh in, analyze, and start organizing those specific recommendations into an implementation matrix.

Let’s step back. You personally transitioned after the mayoral election from the Department of City Planning to the mayor’s office, with responsibilities for planning. You were tasked with a late-term agenda of outgoing Mayor Villaraigosa—the merger of the development services departments in LA. It wasn’t an initiative that had been vetted before it was advanced in the last months of Villaraigosa’s term. That said, how has this “development reform” initiative impacted your priorities vis-à-vis city planning, as well as the departments’ management priorities?

When Mayor Garcetti took office, there was a proposal on the table to consolidate the departments fully. One of the mayor’s initial thoughts was to step back and take a second look at the entirety of development reform. The concept of development reform itself is not new. We’ve had a series of ongoing attempts at it, and Mayor Garcetti brings experience to the table through his involvement while on the Los Angeles City Council. It was very important to our office to continue the work and continue that momentum, but also to take a new look at exactly how that reform would be implemented and how it would affect the general departments.

At this point, working with the leadership of the Planning and Land Use Management Committee, with Councilmember Huizar, Councilmember Englander, and Councilmember Cedillo, the full consolidation of departments is being taken off the table. However, the idea remains of consolidating key specific functions where there is utility. These are things we heard repeatedly in the outreach meetings the consultant had with community stakeholders, development service entitlement professionals, developers, and also within city family meetings. There are key opportunities that we kept hearing about that could be consolidated, better integrated, and streamlined. I think that what you see before you is a report that recognizes full consolidation at this time is not a viable option. However, there are specific key functions that can proceed immediately with better integration of development services across departments.

Before drilling down into those specific opportunities arising from departmental consolidation, a brief summary of the issues might be instructive. Was the original consolidation proposal truly meant to address and enhance city planning, or was it more about cutting the time needed to approve development projects in the pipeline? Many believe the latter. Is there now more focus in the Garcetti administration on community planning and place making?

Absolutely. I think that you look at the balance of creating and implementing an overall vision—that’s the balance that needs to continue. Mayor Garcetti is working to raise development expectations. On one hand, there are development expectations on behalf of our communities—that we have visions, master plans, and documents about how we want development to better integrate and address local context, and add amenities at a local level.

It’s also about how we as a city need to raise the expectations of our development services, and how a developer moves through our system. That’s where I think this report focused. However, this report also clearly focuses on the need to continue to invest in our community plans, to continue to invest in long-term planning, and to look at strategies to maximize our limited General Fund dollars to maintain that implementation at both the project level and at the long-term planning level. I think that when we say “raising development expectations,” we’re talking about raising expectations on all fronts. 

What are the promised benefits of the functional consolidation recommendations being advanced?

Again, we’re talking about key function consolidation and integration. There are three main items that are very noteworthy in this report. The first item is the idea of co-location of departmental development services staff. Currently, a number of departments are organized around geographic teams and a number of departments aren’t organized around geographies. For a city that’s as geographically diverse as Los Angeles, a responsive geographic team that can be integrated across departments is going to be very valuable. You’ll see in here the idea that we’ll be co-locating our staff from DOT, City Planning, Building & Safety, Fire, and Engineering at a number of our development service centers. Currently, we have a development service center Downtown and in the Valley. Initial report recommendations here suggest we establish an additional full-service development center in West LA, and also study the feasibility of establishing a development service center in South LA and San Pedro. I think with that comes corresponding adjustments to the way departments are organized, to interact in a geographic team format. That’s one of the big, bold moves.

A second noteworthy aspect of the report is to shift the initial zoning review function of incoming development from the Department of Building & Safety to the Department of City Planning. As the consultant has recommended, this is in line with all other major cities and will work to provide a clear and concise road map of the development process for applicants. This means a project coming in would be quickly screened to see if it is a ministerial project or a discretionary project. Is it meeting the codes and can be handled by Building & Safety? Or is there a need for a special entitlement, approval, or discretionary action? Is there an issue with a required yard that would require Planning Department action on a variance? That initial screening will help provide clear, upfront answers to applicants on how to navigate the system.

The third noteworthy aspect of the report is that it doesn’t loose sight of the importance of code enforcement and of ensuring that the regulations that are adopted are the regulations that are executed in the built result. I think you’ll see an expanded emphasis on code enforcement within the Department of Building & Safety, and an integration of this code enforcement function to be closely coordinated with City Planning. There were some talks and discussions in the past about where code enforcement lands, and this report—with the support of the mayor—suggests centralizing and integrating code enforcement in its home of Building & Safety. Those are three main, noteworthy points.

Are there other benefits or noteworthy recommendations? Our TPR readers are terribly interested in how proposed development reforms will be addressed by City Hall.

I think that the next ones are about internal workflows. That’s where you get back to the importance of not only having a concept of development reform, but also dialing down into the internal workflows between departments and more of the internal functions. One of those is an expanded series of interdepartmental agreements to streamline workflows where they may be redundant. For example, right now the Building & Safety Department and Fire Department are working together to integrate how building plan check works and where opportunities lie to streamline how review takes place, so that it can occur in a more efficient manner. That’s certainly one major input.

 A second recommendation of the report is the emphasis on technology and the implementation of the BuildLA program, the initiative recommended in the report to reknit and reconstruct the city’s online and workflow technology systems to talk to each other more effectively. That’s a major effort, where we will see things like digital e-plan submittals. It will also allow routing and transferring of case review digitally across departments with electronic comments, along with and a quicker response and return time.  

In addition, this technology supports greater accountability and tracking. One of the overall goals of this report is to make development review a more transparent process, so that when you file, let’s say at the Planning Department for a project review, you have a better sense of who will be your lead planner, the estimated time to completion, and—using the technology—a better sense of where you are in the process. Instead of filing a report and potentially waiting, the applicant can have much more transparent, step-by-step online feedback. 

Kevin, many in both the development community and neighborhood organizations believe the planning approval process in LA relies too much on Council discretion, and thus, too much on politics. Unlike most other cities in the region, there’s no predictability—by-right development—for most projects in LA, even small ones. How will reform of the development process, as it is now being proposed, address that central concern?

That’s a very good question. I think we need to look at what this report does. It deals with outlining the development services process as it stands today and how it can be improved. I think it also speaks to the importance of investing in community plans—investing in a predictable environment that can welcome economic input and development.

This report stops short of recommending any structural changes to the zoning code or to the city’s general plan structure, etc. That being said, there is a parallel piece of work that the report supports—the re:Code LA project, which is updating the zoning code to examine where there could be opportunities for additional procedural improvements.  

Returning to the timeline for implementation of the Matrix report recommendations, what should our readers expect?

The mayor is working closely with the City Council leadership on this important work, and it is expected to go to the City Council for review on April 2. One of the important concepts of this report is to have it be implementable at a departmental level and to have an active monitoring function. The mayor’s office remains committed to working with the chair of PLUM on implementing these recommendations through our general managers at each individual department.

One of the actions calls for a 30-day report-back from the departments on the implementation of the specific recommended strategies—which ones relate to each departments, which ones are greenlighted to move forward as is, which ones raise questions, and which ones may not be workable. We recognize that this is a roadmap. It’s not a precise path, but it contains specific recommendations that need to be evaluated one by one. I think what you’ll see is a series of reports back to the mayor and City Council, but more importantly, a focus on implementable strategies at a departmental level.

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What will be the ongoing role for the CAO’s office in implementation of development reform?

This is a mayor’s effort and also a Council effort. The CAO played a key role, along with the CLA, in convening the Development Services Reform working group and also in overseeing much of the work of our consultant, Matrix Consulting. The CAO is going to remain involved in this. There is some discussion about retaining a consultant again to assist in making sure that we can continue to implement these strategies. 

Could you share the likely metrics that will apply when measuring the success of development reform and functional consolidation?

The idea of transparency is a key part of Mayor Garcetti’s approach to getting the city focusing on back-to-basics—both being transparent in how we use our funds and transparent in how our development services operate. Along that vein, the report recommends having transparent timelines, transparent case information, and looking at case processing cycle times. The report looks at bringing down our cycle times, looking at average cycle times, having cycle time targets, and being able to recognize where we can use our very scarce resources most effectively as development flows shift and change over time and over geography.

Having real-time data available can direct action. When we’re seeing a great deal of activity, perhaps in the North Valley, better tracking and transparency will allow the department heads, in collaboration with the Council and mayor, to respond at both a budget level and at a staffing level.

The funding of City Planning, some believe, is relevant to how development reform is implemented. One often hears that City Planning has “scarce resources” and “needs to manage them better.” Inform our readers how, for example, the community plans are funded, and how much of Planning’s budget is self-funded rather than derived from the General Fund.

We do rely on the General Fund for the city’s long-term planning efforts—what we call city-initiated projects and city-initiated programs. The city has adopted a policy of full cost recovery, which helps pay for the costs involved with private development permitting activity.  In addition, each private-applicant city planning case contributes a small percentage to a General Plan maintenance fund, to focus on long-range planning.  But we can’t lose sight of the ability or the importance of the long-term vision of the city. Those funds for long-term planning have been, in the wake of the downturn in the economy, severely cut.

Fortunately, the Planning Department has been successful in working collaboratively with other government agencies on securing grant funding for some of the important work around the Metro transit-oriented district program. The Planning Department has received $7.9 million from Metro for this important work.  The long-term planning efforts continue, and are being funded in more creative ways. Taking it back to the consultant’s recommendations, the report suggests revisiting where the General Fund can be used and where our Special Funds can be used, along with calling for some limited additional studies to identify opportunities to really stretch that General Fund dollar, to make sure we can continue to deliver the services that are needed. 

With a number of billion-dollar projects announced recently, will there still be a shortage of funds for the reform agenda you have shared?

Again, although those private applications will pay building permit fees and entitlement fees, the city relies on our General Fund—general tax revenues—to fund our advanced planning programs.

The Matrix report, notes, as you have here, that all but one of eight cities it examined regarding development have transferred development approval functions into a single department. Could you confirm that the trend is, in fact, consolidation? TPR has reported on San Diego and Pasadena, both of which have done just the opposite. Which eight cities are we talking about?

I’d refer you to the report and the findings for specifics, but in general, every city government and every city geography is unique. 

Looking to other cities for guidance on development reform clearly offers a window into the purpose and mission of reform. Is streamlining project approval meant most to afford predictability and speed? Or, alternatively, is it to afford the city an opportunity to process applications in sync with an adopted community plan and comprehensive zoning? It appears from our interviews that San Diego and Pasadena want to assure the latter.

Again, for specifics on other cities, I would refer you to the report. However, the City of LA has a strong Department of Building & Safety that has great expertise in ministerial building permits, and a strong City Planning Department that has great expertise in two things—long-range planning and processing project entitlements. This involves community plans, comprehensive, and also processing entitlement requests: things like discretionary zone changes, large-scale development agreements, and tract maps.

As the Council and mayor look at that arrangement and the recommendations in the report, the mayor endorses retaining those separate departments to allow each to focus on what it does best. But, at the same time, we look to ensure strong integration of these functions to allow better planning. The idea is key function consolidation. The departments will continue to work in their primary roles, but integrating their workflows together can lead to a better outcome.

Kevin, as the point person for Mayor Garcetti, please opine on the future of community planning in Los Angeles, given the recent court decision on Hollywood’s Community plan.

In my prior life, I was a part of the City Planning Department, and I oversaw a number of community plans, including Hollywood.

I think the mayor is committed to continuing our general plan program, and the department is committed as well. I think we’ve had a number of successes—recently the Housing Element was adopted by the LA City Council and Planning Commission. The City Planning Department hosted a series of city-wide workshops this week on our Plan for a Healthy Los Angeles, the Mobility Element—a transportation plan and vision for the city—and re:Code LA, the idea of updating our zoning code. Planning is alive and well but certainly will continue to benefit from support and resources. 

Reportedly there are a number of community plans in process behind Hollywood. Could you update our readers on their status?

Work continues onward—and for specifics I would have to refer you to the City Planning Department. 

If you permit us to come back a year from now to assess the impacts and progress of development reform, what will we most likely be talking about? 

We’ll be talking about the steps the city has taken to better integrate our Building, Planning, Transportation, Engineering, and Fire Departments together. I think we’ll also be talking about how Los Angeles is more geographically responsive across the urban-form diversity of the city.

The City of LA has every type of development pattern, from extremely low-density neighborhoods and hillsides, to regional centers, to the Downtown core. I think that one of the undercurrents of this new focus on development services is to really celebrate that urban diversity, and to have a system in place that can more effectively guide development across the city. 

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