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# The New Hollywood Community Plan ‘Update’ is Legal Garbage … Here’s Why
June 26 2017
Written by Richard Lee Abrams.
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CORRUPTION WATCH-The Hollywood Community Plan has no Environmental Impact Report (EIR) for the June 2017 Update. This means that all these super-mega projects being proposed in Hollywood are based on data from the 1960s and the mid-1980s.
Do not be confused by the City’s release of a new Hollywood Community Plan – it is not an effective legal document without an Environmental Impact Report (EIR). Until there has been a Draft EIR and a comment period, a Final EIR and *another comment period,* and then it goes to City Council, there is no EIR -- nothing, nada, zip, zilch. This June 2017 Update being touted by the City is legal garbage. The gigantic Crossroads Project and all the super-projects proposed and built since 2010 are based upon census data from 1960 through1980 that is legally worthless.
**A Look at Hollywood’s Census Data from 1960 through 2010**
In 1960, Hollywood’s population was had 160,383, an increase of about 400 people.
In 1970, Hollywood had 156,335 people, an increase of 16,000.
In 1980, Hollywood had 181,002 people, an increase of 24,667.
In 1990, Hollywood had 213,858 people, an increase of 32,856.
In 2000, Hollywood had 210,824 people, a ***decrease*** of 3,034 people.
In 2010, Hollywood had 198,228 people, a ***decrease*** of 12,596 people.
**Why the Developers and Garcetti Like the 1988 Hollywood Community Plan**
One can readily see why the City wants to base all their new mega-projects on the outdated 1988 Hollywood Community Plan (1988 HCP) -- it was written during Hollywood’s boom time. In the intervening twenty-five years, however, everything has changed. Hollywood became increasing unlivable and the people began to leave. In fact, based upon the U.S. census data, the biggest exodus was after the Community Redevelopment Agency (CRA) began its so-called Smart Planning and the Hollywood subway opened. There is now demographic evidence that current Family Millennials are being driven out by the dense construction. This is decimating our tax base. And giving millions of tax dollars to these projects like 5929 Sunset Boulevard does not help the City’s tax base. (That project is closed as it was illegal. See *CityWatch*, May 13, 2014, [*Big Developer Looking for Another Handout from LA Taxpayers*](http://www.citywatchla.com/index.php/archive/6871-big-developer-looking-for-another-handout-from-la-taxpayers), by Ziggy Kruse.)
The entire 1988 HCP was based on the expectation that hordes more people would come to Hollywood; everything in it is based on that antiquated premise. But if today’s developer wants to construct a gigantic project next to the Palladium or some billionaire favors the Millennium Earthquake Towers or the humongous Crossroads Project, a community plan written in 1988 looks ideal.
Not so fast there!
**The 1988 HCP is Legally Defective**
There is a huge obstacle there. In 1988, the City knew that it would be folly to rely on the 1988 HCP for too long and therefore set the Commerce section to expire in 2010. Thus, its Commerce component, *on which all these projects are based*, was valid only through 2010. That expiration provision makes the entire 1988 HCP worthless to justify any of these projects. The basis for Hollywood commercial development between La Brea and Gower has not existed for close to a decade. When Judge Allan Goodman officially invalidated the June 2012 Update to the HCP on February 11, 2014, his order did not revive the Commerce component because it was no longer part of the 1988 HCP, having expired in 2010. The City’s own website acknowledges that it reverted to the 1988 HCP as it “**existed immediately prior to June 19, 2012,”** that is, without any Commerce section.
As a legal matter, the City has no valid Hollywood Community Plan. Had Judge Goodman considered that the1988 HCP had sunset its own Commerce section four years earlier, Judge Goodman could have addressed this issue. No one knows what decision he would have made after his finding that the City was intentionally using “fatally flawed data” and “wishful thinking” which “subverted the law.”
CEQA gave the judge no authority to resurrect the defunct Commerce section. Hollywoodians tried to make Judge Goodman address this gigantic problem in September 2014, but he closed his eyes and looked away.
The only reasonable avenue open to Judge Goodman was to set a time table for the City to prepare a new EIR, but he refused. Thus, seven and a half years after the 1988 HCP ceased to be valid, we Hollywoodians are left with no operational Hollywood Community Plan. That makes all these mega projects illegal.
The developers who believe that they can steam roll over us in Hollywood should stop and realize that Garcetti is following the same game plan with the Hollywood Community Plan as he did with the Target Store. And just how did that work out?
*(Richard Lee Abrams is a Los Angeles attorney and a CityWatch contributor. He can be reached at:* [**Rickleeabrams@Gmail.com**](mailto:Rickleeabrams@Gmail.com)*. Abrams views are his own and do not necessarily reflect the views of CityWatch.) Edited for CityWatch by Linda Abrams.*
*-cw*
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