Recommendations for Venice Community Plan
We have the following input for the Venice Community Plan update:
1. Protect Housing in Mixed use Areas
One of the most important goals of the Venice Community Plan is to protect housing. Therefore, proposed mixed-use areas must require that individual existing residential structures not be changed to mixed-use. Rent stabilized buildings, which are concentrated on Ocean Front Walk and Rose Ave, must be particularly protected from any height or story increases and changes of use. There must not be any changes of 100% residential structures to mixed-use/commercial, live/work or AIR uses, and there must not be any changes in zoning from residential to commercial.
2. Reserve Height Increases Only for General Commercial Coastal Land Use Zones
The mass, scale and character of Venice’s unique coastal neighborhoods are protected by the Coastal Act and the certified Venice Land Use Plan. Venice is a Coastal Resource in an of itself and was designated by the Coastal Commission as a Special Coastal Community--an area recognized as an important visitor destination center on the coastline, characterized by a particular cultural, historical, or architectural heritage that is distinctive, provides opportunities for pedestrian and bicycle access for visitors to the coastal, and adds to the visual attractiveness of the coast. Therefore, increases in height/stories for Venice’s residential and commercial neighborhoods should be restricted to what are now the "General Commercial" coastal land use designations in the certified Venice Land Use Plan. See areas on the maps on pages 34 - 38 that are General Commercial:
https://planning.lacity.org/odocument/d0a7f30b-87c1-430e-8415-5b5e30d230e7/venluptxt.pdf
These are the areas that currently have a General Commercial coastal land use designation (see maps):
North Venice: 6 parcels on Main street on either side of San Juan.
Oakwood: parcels on the Lincoln end of the neighborhood.
Milwood: parcels on the Lincoln end of the neighborhood & a few parcels north of North Venice around Pisani Ave
Southeast Venice: parcels on the Lincoln end of the neighborhood & several parcels to the north of Washington Blvd from Oxford Ave through Abbot Kinney
Oxford Triangle: parcels along the south side of Washington, between Oxford Ave & Lincoln
3. Maintain Multi-Family Neighborhoods
The mass, scale and character of Venice’s unique coastal neighborhoods, as well as the social diversity, are protected by the Coastal Act and the certified Venice Land Use Plan. Therefore, there must not be any increases in height for the Oakwood neighborhood, to protect from the “unintended consequences" of displacement and further gentrification, mainly of our non-white, lower-income citizens. Existing single- and multi-family housing in these neighborhoods must be protected and preserved. Venice, especially Oakwood, demands that the Venice Specific Plan and be respected and studied before any changes are made. We in Venice demand the respect for our communities and the fact that four stories were even proposed shows the City’s tactics of excluding the neighborhoods in Venice. Oakwood's wishes are being ignored and we the Oakwood Community will not stand for this.
4. Pursue Historic District for the Oakwood Neighborhood
A cultural heritage district does not protect the Oakwood neighborhood from destruction of the historic resources or from over development, loss of character and gentrification. Therefore, the proposed cultural heritage district concept should be changed to pursuit of an historic district for Oakwood, which has innumerable historic sites, many of which were not recognized by SurveyLA. Oakwood has asked for years for Historic status and it has been said over and over, at the community meetings that were held throughout Venice--Mark Twain Middle School and the Venice Library--that the requests from Oakwood would not be overlooked. The community must not be ignored. If these concepts for the Venice Community Plan had been presented to the Oakwood community up front, you would know that we want Historical status, not Cultural Status. L.A. City planning must respect the Oakwood community and all of Venice should stand together on this.
5. Maintain Character and Scale of the Milwood Walk Streets Historic District
The historic character of the Venice Milwood Walk Streets Historic District must be preserved and protected from the impacts of height increases, especially as the Milwood walk streets are much more narrow than other Venice walk street areas and increases in height would create a “canyon effect,” which diminishes the open garden experience for visitors and residents. Therefore, there should not be any increases in height for the Milwood walk streets (photos of the historic area next to the concept that suggests height limits of 1-3 stories).
6. Assess Parking/Access Impacts of Proposals
Venice is one of the most parking challenged areas of the City as well as the California Coastal Zone. Therefore, parking and traffic impacts of live/work uses on Rose and Abbot Kinney must be carefully assessed before going beyond the “concepts” stage, and any conversion of Windward to a pedestrian promenade must be dependent on a corresponding expansion of available parking on the only site available, the Venice median.
7. Implement Community Outreach to Reflect the Diverse Venice Community, Particularly Oakwood
The residents of Oakwood have been excluded, disenfranchised and betrayed in the past (including for the last 20-year community plan proposal). The Oakwood neighborhood is shocked to see a recommendation of significantly increased height as this wasn’t mentioned at any of the Community Plan community meetings, all of which Oakwood neighbors attended. Concepts and recommendations must be informed by neighborhood outreach (and not just developer or business owners’ outreach, i.e. the Chamber and VNC) before being presented to the overall community. The VNC and LUPC do not historically reflect the diversity of Venice. The Oakwood community insists on inclusion and direct communication, and that there are checks and balances and accountability built into this plan, which we will live with for the next 20-25 years. The Oakwood community requests and has been requesting that lot consolidations in Oakwood be limited to two as opposed to three lots, consistent with the rest of Venice. The Community Plan must accommodate this request. Therefore, as part the Community Plan process, the City must initially and on an ongoing basis meet directly with the Oakwood Community and not just LUPC and VNC or business groups such as the Chamber of Commerce. The City must respect and do proper and positive outreach to all of the neighborhoods that could be impacted, particularly the ones that could be significantly impacted, such as Oakwood.
8. Protect Density, Affordability, and Character of Multi-Family Neighborhoods
There is a pervasive issue that we’re experiencing in Venice where decision makers interpret policies to eliminate density and affordability in multifamily neighborhoods. Until recently, the accepted status quo has been to effectively down zone and/or allow projects to strip neighborhoods of existing density, affordable character and sense of community. Venice in particular has been burdened by these unfortunate land use decisions, contributing to de-densification and displacement. The cumulative impact has been measurable and observable over the course of decades, and it must be addressed. Venice is losing density when projects are approved that demolish multi-family rental units for the purpose of single-family dwellings in multi-family coastal land use designations, and thus its multi-family neighborhood character is shifting to single-family neighborhood character. Small-lot subdivisions disrupt the unique subdivision patterns and layout of Venice, change the character of multi-family neighborhoods to single-family in character, exacerbate the affordability crisis, and cause gentrification of the Venice neighborhoods. A recent Coastal Staff Report (5-19-1220) states: “…in light of a persisting lack of housing supply across the state (particularly in the Coastal Zone), it has become apparent that replacement of a full housing unit with an ADU /JADU is likely an insufficient approach to preserving housing density in the Coastal Zone.” and “…due to their size, ADUs are more easily left vacant or used by the residents of the primary single-family residence, rather than rented out.” and “…ADUs do not necessarily provide a meaningful residential unit that is comparable to a unit in a duplex or multi-family structure and, in this case, is not likely to adequately mitigate the impact of removal of a multi-family structure. Thus, the project as proposed with only one residential unit and an ADU is not consistent with Sections 30250 and 30253 of the Coastal Act.” and “However, in light of a persistent lack of housing supply across the state and in the coastal zone, it has become apparent that replacement of a full housing unit with an ADU/JADU may not always preserve housing density in the Coastal Zone in a manner consistent with Chapter 3 policies. ADUs/JADUs are important mechanisms to increase the potential number of independent housing units that can be rented out separately from the primary residence. However, ADUs are dependent on the single-family residence to serve as a housing unit and cannot be sold separately from the primary residence. This differs from a duplex, where the units can have separate utility connections and can be sold independently from one another. In addition, it is more difficult to enforce the continuous provision of an ADU as compared to a duplex, and ADUs are more easily left vacant or used by the occupants of the primary residence. Therefore, there is no guarantee that an ADU will be used or rent out as a second unit, especially [when an ADU]...is a small component of a much larger...house, and could easily be used by the homeowner rather than rented.” Therefore, density and multi-family units must be maintained in the Venice neighborhoods, ADUs must not be considered as a replacement of a full multi-family housing unit, and small-lot subdivisions must not be allowed.
9. Evaluate Growth Projections and Status of Infrastructure Before Proposing Concepts
According to Coastal Commission guidance the update of a Land Use Plan requires updated information on buildout/growth/population and other projections as well as analysis of any public services constraints and limits to the available capacity of public works facilities (e.g. water, sewer, roads and transit systems), along with appropriate documentation. Land use designations and intensities must be commensurate with the level of available infrastructure and if there are current infrastructure constraints it may be necessary to scale back development potential. Per the certified LUP: “Residential land use densities in this LCP have been assigned in the Venice coastal area to reflect the year 2010 Venice population as projected by the Southern California Association of Governments (SCAG). Based on circulation and infrastructure limitations, the assigned Land Use Categories result in substantially lower build out densities than current zoning capacity. The development standards also define for each land use designation a density of housing units and lot coverage to maintain the scale and character of existing residential neighborhoods and minimize the impacts of building bulk and mass. New residential development is linked to the availability of public services and infrastructure, and in addition to traffic consideration, environmental and coastal access concerns as required by the Coastal Act.” Any proposals with respect to the LCP require an analysis of consistency with all Coastal Act policies. When there is an existing certified Land Use Plan an update to that should be more akin to an amendment than a complete new replacement Plan. Therefore, any proposed concepts or any changes to the existing certified Land Use Plan should be explained and supported with evidence, and concepts should not be presented until that information is available.