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GRANADA HILLS - There’s a moment—if you’ve been paying close enough attention to how land-use decisions are being made in Los Angeles—when the process starts to feel less like independent review and more like something already set in motion.
Not obviously. Not at first.
But gradually, as documents appear fully formed, pathways shift, and conclusions seem to precede explanation, it becomes harder to tell where evaluation ends and approval begins.
In theory, the City’s Planning Department is supposed to act as a neutral decision-maker—reviewing applications, analyzing impacts, weighing evidence, and ultimately making an independent determination in the public interest.
But based on publicly available records, something very different appears to be happening.
What we’re seeing now is a system where applicants are not just proposing projects—they are increasingly being guided through the process of getting them approved. In some cases, when a project stalls under environmental review, the path forward appears to shift. Rather than continuing through full Environmental Impact Report analysis, alternative approval pathways are identified—sometimes through statutory exemptions that significantly limit environmental review.
And in some instances, that shift appears to occur through direct coordination between City staff and applicants before the public ever sees it.
That matters.
Because an Environmental Impact Report isn’t red tape. It exists because communities were harmed when projects moved forward without full analysis. It’s supposed to force a hard look at real-world consequences.
Like what happens when you place a nearly 100-unit elder care facility in a Very High Fire Hazard Severity Zone, on a constrained two-lane road that already serves as a primary evacuation route for hundreds of residents.
That’s not theoretical.
That’s life safety.
And yet, the administrative record in the MorningStar of Granada Hills case raises serious questions about whether those risks were ever meaningfully evaluated.
Documents central to the City’s decision—documents used to justify exempting the project from environmental review—appear in the record without clear authorship, without signatures, and without dates. In some instances, materials appear to have been prepared by the applicant and later relied upon as part of the administrative record, without independent analysis clearly documented.
In some instances, the pathway doesn’t originate with the applicant at all.
Internal communications reflect that City Planning staff reached out to discuss “the potential of utilizing the AB 130 Infill Housing Statutory Exemption for the project,” and went further—offering prior examples and noting that “we recently received a similar justification document for another project, which we can provide as a template.”
But it goes further than that.
Those same communications reflect that key eligibility determinations had already been resolved in advance—including confirmation that senior housing “qualifies as a housing development” and that the site meets the required urban use criteria.
In other words, before the public ever saw the project shift pathways, the foundational question—whether a facility of this size, scope, and operational nature qualifies as “housing”—had effectively already been answered.
And once that determination is made upfront, everything that follows starts to look less like evaluation—
and more like execution.
Because when the analysis itself is effectively constructed with City guidance and then carried forward through the process, the role of independent review begins to blur.
At that point, it’s fair to ask what role the City is actually playing.
Because if the conclusions are being assembled before the hearing, and the justification is built to support them, the process starts to look less like deliberation—
and more like endorsement.
All that’s left is the stamp.
The problem isn’t just that the analysis is missing—it’s how the conclusions are presented.
The Justification for Exemption Memorandum reads less like an evaluation and more like a checklist. Statutory criteria are laid out, and then, one by one, declared satisfied—housing? yes. zoning? consistent. urban use? met.
The logic, at times, appears to be reduced to something even simpler: people sleep there, therefore it qualifies as residential.
But that kind of shorthand skips over the very distinctions the law is supposed to examine—whether a use functions as independent housing, or as a managed, institutional environment serving residents who cannot live independently.
That difference matters.
And it’s nowhere meaningfully addressed.
There is no identified methodology. No data. No parcel-level analysis. No discussion of conflicting facts or site-specific constraints.
Instead, the document moves directly from criteria to conclusion, as if the outcome were already known and the exercise was simply to confirm it.
That’s not analysis.
That’s certification.
What makes that failure even more significant is what’s being overlooked.
This is not just another parcel. The site sits within an A1 zone—large residential lots—with a “K” overlay designation intended to preserve equine use and rural character. It is part of the historic footprint of Granada Hills, including land associated with the original Sunshine Ranch.
Those designations exist for a reason. They reflect a planning judgment about the character of the area, the intensity of use it can support, and the need to preserve a specific type of community environment.
Yet none of that appears to be meaningfully evaluated.
Instead, the memorandum simply declares zoning compatibility as satisfied—without explaining how a nearly 100-unit elder care facility aligns with A1 zoning, the “K” equine preservation overlay, or the site’s historic context.
That’s not a minor omission.
It’s the difference between applying planning policy—and bypassing it.
At the same time, the underlying reasoning for the exemption—the actual analysis supporting the conclusion—was not disclosed to the public prior to the hearing.
Residents were effectively asked to comment on conclusions they had never seen.
That’s not participation.
That’s staging.
At a certain point, it starts to feel like public input is no longer part of the decision-making process at all.
Because when conclusions are reached before the hearing, and the record is built after the fact, participation becomes something else entirely.
It starts to feel like if the City wants your opinion, they’ll give it to you.
“Managing” the Community
Internal communications show that coordination extended beyond Planning staff.
A Council office representative described community groups as “challenging” and stated an intent to “proactively help the Developer work with the Community and avoid any misunderstandings” ahead of the hearing.
In a separate communication, the same office noted that the applicant had “continuously kept us informed” and had “always looked to us for help with the local Community Members,” while seeking guidance from Planning staff on how the project would proceed under new CEQA rules.
Taken together, these statements suggest that community input was not just anticipated—but actively managed as part of the process.
Even the Notice of Exemption—the document that is supposed to reflect a final determination—can appear in the record fully executed, with conclusions already stated, before the hearing officer has rendered a decision—raising serious questions about when that determination was actually made.
If that’s the case, then the hearing isn’t where the decision is made.
It’s where it’s announced.
And once that happens, everything downstream becomes suspect.
Because memory care isn’t just another land use. These are residents who cannot self-evacuate. They depend entirely on systems, staff, and time—especially in an emergency.
Those realities demand scrutiny.
Not shortcuts.
Los Angeles deserves a planning system that actually plans—one that documents its reasoning, discloses its analysis, and makes decisions in the open.
Because right now, based on the record, the process looks less like independent review—
and more like a conclusion in search of justification.
Los Angeles may be desperate for housing.
But desperation doesn’t excuse abandoning judgment.
Because the question isn’t whether we need housing.
It’s what we’re willing to give up to get it.
Safety.
History.
The character of entire communities.
When those are reduced to boxes checked on a form, the process stops being planning.
It becomes production.
And a city that stops weighing those values doesn’t just lose balance.
It loses its heart.
(Eva Amar is a Granada Highlands community coordinator advocating for transparency, public safety, and accountability in land-use decisions. This analysis is based on publicly available records and documents obtained through the California Public Records Act)
