AIA LA Supports Revising the LID Ordinance – Council File 22-0600-S54

We support LASAN’s efforts to update the Low Impact Development Ordinance by changing the threshold from 500 square foot of impermeable surface area to 5000 sq.ft., with the explicit goal of making housing development less encumbered with the complexity and added-time of obtaining a LID clearance, especially for smaller residential projects and Accessory Dwelling Units.

Originally, back in 2021 when we approached LASAN we advocated to have the LID clearance ‘sunsetted’ for all housing development until we were able to collectively resolve our ongoing housing affordability crisis. In addition, with new regional stormwater strategies in place with funding sources from both Measure A and Measure W, the LID ordinance is often at cross-purposes with those more comprehensive and resilient regional strategies to collect, absorb, and clean stormwater.

Therefore, we’re pleased to see that progress is being made to address this issue in the current draft ordinance and 100% applaud LASAN’s leadership in advancing this initiative.

After reading the proposed updated draft ordinance, however, a few questions remain:

I. Does a mixed-use housing residential project with over 5,000 square feet of impermeable surface area that includes within it a ‘parking lot, a.k.a. parking garage’ now become subject to the LID clearance?

II. What about a mixed-use housing residential project over 5,000 square feet that includes within it a ‘restaurant’?

III. Which begs to question: Why would a 9,999 square foot commercial mall or industrial park NOT be subject to LID, but yet a 5,001 foot mixed-use residential project (with a parking garage or restaurant within it) be subject to LID?

Most likely, I’m just not reading the proposed draft ordinance correctly.  Implicitly, I know what it’s trying to say – but, as a document, it never actually gets around to saying it!

Perhaps it will be helpful to ensure that the ordinance is made more clear by stating as “Where as” clause the objective that is summarized in the June 27th City Attorney’s Report — but is not made explicit within the ordinance: “With the proposed changes in the LID ordinance, a majority of residential land use projects – Small Scale projects – would no longer be subject to LID requirements.”

Let’s work with LASAN and the Office of the City Attorney to have that sentence added to the ordinance (or at least a FAQ memo) to clarify intent and to reduce any unintended ambiguity that the ordinance, as currently written, may accidentally deliver. Additionally, it will be helpful to define “Small Scale Projects” directly in the LID ordinance, as well or the FAQ memo.  Currently, the definition of ‘small scale’ is  only referenced in the MS4 permit application.

We look forward to working with City Council to identify and ‘sunset’ additional departmental clearances that are either no longer necessary and/or creating undue complexity as it relates to the timely and cost-effective delivery of housing.

To read about the existing LASAN Low Impact Development Requirements, CLICK HERE.

LADWP: Project Powerhouse & Amortization of Line Extensions

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