SPEAK OUT: LA County General Plan Lacks Critical Fiscal Impacts Analysis

After working with LA County's Department of Regional Planning for nearly a full year on BizFed member concerns with updates to the County's General Plan - particularly the critical need for a Fiscal Impacts Analysis - and progress still remaining unclear, BizFed has sent a letter to the the Planning Department and Supervisors elevating our request.

Read our letter below, and reach out to let County officials know you support this request.

February 13, 2013

Richard Bruckner

Director, Department of Regional Planning

Los Angeles County

320 W. Temple St., Room 1356

Los Angeles, CA 90012

Re: Formal Request - Fiscal Impacts Analysis for LA County General Plan Update

Dear Richard,

On behalf of the Los Angeles County Business Federation (BizFed), representing over 100 business organizations with more than 250,000 businesses across our region, we are concerned with what appears to be a lack of concrete progress in our discussions to date, and are now submitting our formal request for inclusion of a Fiscal Impacts Analysis in the County’s update to the General Plan.

At its most basic level, a Fiscal Impacts Analysis will bring an essential and objective articulation of the costs and revenues generated by growth projections and assumptions in the draft General Plan 2035. This critical tool will, in essence, provide a snapshot of whether the land use patterns proposed in the General Plan update will be good for the economy as well as the environment.

A Fiscal Impacts Analysis is urgently needed to provide the Board of Supervisors with key information so that all involved in the development process have a clearer understanding of the likely results of implementing the vision of the General Plan.

As you know, BizFed members have been diligently working with your office for the past 11 months on concerns with the draft General Plan 2035, and to develop a way forward on this particular request for a Fiscal Impacts Analysis.

Since our outreach began in March 2012, BizFed has worked collaboratively with the Department of Regional Planning on the necessity of a Fiscal Impacts Analysis and ways in which to incorporate it amid resource constraints and without delaying the General Plan update. BizFed even has connected Regional Planning staff with economic and fiscal experts in this field.

But BizFed has not yet received a definitive answer from Regional Planning on whether a Fiscal Impacts Analysis will be completed. We urgently and respectfully request a reply as to what decision and direction you and your team will be taking in this regard. We will be updating our members in mid-March on the status of the County’s desire and actions to complete the Fiscal Impacts Analysis.

We understand that the General Plan update is a formidable undertaking – the first major update in roughly 30 years. But with the stakes so high for our economic and environmental futures, it is imperative that the County adequately plan for high-value, sustainable future job growth and we believe the draft General Plan should provide adequate space, land use and zoning for such employment for future generations.

Among our concerns that a Fiscal Impacts Analysis could shed valuable data on are major new policies in the General Plan Update including:

Expanding Transit Oriented Districts

The General Plan Update will expand existing TODs from approximately a one-quarter mile radius to one-half mile radius from transit stations. Many of these 11 TOD areas are within older areas that have not seen new development in decades. As a result, the infrastructure is in need of improvements and local services that do not currently meet the County standard for public services and that will be further stressed by adding new population.

All TODs will be implemented by TOD station area plans – which will need to address existing challenges within many of the County's TODs. For example, many of the transit stations that serve the unincorporated areas are located in the middle of freeways, which limit access to the station, expose residents to traffic and noise pollution, and create hostile environments for pedestrians. Another challenge to implementing TODs is the existing development patterns around the transit stations. As many of the lots are small, developments will require lot consolidation and incentives to utilize higher densities, which are proposed to permit up to 150 units per acre.

Expanding Significant Ecological Areas

The Significant Ecological Area (SEA) designation is defined as land that contains biological resources or has a high likelihood of containing these resources. The county has almost tripled the amount of land under this designation, which significantly limits this land for housing and employment centers. A large percentage of land within the SEA is privately held and potentially devalues properties within the SEAs. The Fiscal Impacts Analysis should consider the estimated decline in property tax and sales tax revenues as a result of this expansion, as well as the long-term implications to business and housing in the Antelope Valley and Los Angeles County as a whole.

Down Zoning

The General Plan includes a rural preservation strategy for North Los Angeles County. The Antelope Valley has been reduced from approximately 300,000 dwelling units at build-out to approximately 67,000 dwelling units at build-out. The majority of growth in the rural preserve is planned at very low densities and parcels are spatially separated from each other. This makes access and the provision of services within a reasonable distance a potential challenge. In fact some services, such as schools, become difficult to locate due to the expanse of low-density parcels. The Fiscal Impacts Analysis should discuss the overall fiscal impact that this down zoning has on the entire region due to its magnitude and opportunity cost.

These concerns are not meant to be exhaustive, but are among some of the most critical reasons why we are urging the County to immediately authorize inclusion of a Fiscal Impacts Analysis in its General Plan Update. Below is a proposed minimum scope of work that a Fiscal Impacts Analysis should address:

1. What are the impacts of the proposed General Plan’s land use plan on the county’s stream of revenue from property and sales taxes, considering the change in densities and type of land uses anticipated through 2035?

2. What are the implications under the proposed General Plan on the expected future budget conditions for county decision makers to provide community services at an acceptable level of service county-wide, including expenditures for such items as fire protection, sheriff’s services, parks, and libraries?

3. Given the significant expansion of the SEA program in the county, what is the estimated decline in property tax and sales tax revenues based on this expansion? A large percentage of land within the SEA is privately held and potentially eliminates the future use of this land for residential or commercial benefit.

4. With new growth for a majority of the county proposed to occur in eleven TOD areas, what will it cost to upgrade older infrastructure in these TODs?

5. With significant reductions in proposed growth in North Los Angeles County, what is the impact on the County providing services for existing and future populations? In addition, what is the loss of tax revenues due to devaluation of properties from down zoning and SEA expansion?

6. With the significant reductions in proposed growth to North County, what is the economic impact to regionally significant projects in the pipeline - including California High Speed Rail, the High Desert Corridor and any associated Inland Ports, Desert Xpress, and improvements to the Palmdale Airport? 

As always, BizFed seeks to work in partnership with our government leaders to create a vibrant economic and environmental future for our residents. We look forward to working with Department of Regional Planning staff on immediate implementation of a Fiscal Impacts Analysis in the draft General Plan 2035.