HomeMy WebLinkAboutKent, UCLA Law - Pritzker Briefs. Increasing Access to Green Space & Affordable Housing in Los AngelesPOLICY BRIEF NO. 15
JANUARY 2023
By Beth Kent1
Executive Summary
Los Angeles is known for its beautiful beaches and near-perfect weather, which enable
many Angelenos to enjoy time outside year-round. But millions of predominantly low-income
people of color live in communities that do not have sufficient green space to meet community
needs. Throughout the City and County of Los Angeles, park access varies greatly. Low- and very
low-income areas and neighborhoods with large Latinx, Black, and Asian-Pacific Islander popu-
lations have far fewer parks and significantly lower access to park resources than predominantly
White neighborhoods.2 And the parks in these communities tend to be poorly maintained and
low-quality, lacking basic amenities, such as water fountains.3 Most park-poor communities are
also disproportionately impacted by pollution and other forms of inequity. For example, 78%
of residents in Huntington Park experience very high park need,4 and Huntington Park also has
high levels of air pollution from goods movement and industrial activities, as well as numerous
brownfields.5 Los Angeles’s inequitable distribution of parks and pollution is not a coincidence,
but rather the outcome of systemic racism and redlining dating back to the early 1900s.6 A
1904 City of L.A. zoning code rule prohibited the development of industrial activities in West
L.A., while permitting commercial and industrial activities, as well as higher density housing, in
low-income communities of color in South and East L.A.7 Park development was also concen-
trated in more affluent areas,8 and many of these patterns continue today.
Increasing Access to Green Space
and Affordable Housing in
Los Angeles through Joint
Development Projects
1 Beth Kent is an Emmett/Frankel Fellow in Environmental Law and Policy at the Emmett Institute on Climate Change and the
Environment at UCLA School of Law.
2 Jennifer Wolch, John Wilson & Jed Fehrenbach, Parks and Park Funding in Los Angeles: An Equity Mapping Analysis (2002),
https://lusk.usc.edu/sites/default/files/working_papers/Wolch.parks_.pdf.
3 Leo Duran, One Way to Address LA’s Racial Inequality? Build More Parks in Communities of Color (2020), https://laist.com/news/
los-angeles-racial-inequality-parks-communities-of-color; see Los Angeles Countywide Comprehensive Park and Recreation
Needs Assessment (2016), available at https://lacountyparkneeds.org/pna-home/.
4 City of Huntington Park: Study Area Profile, https://lacountyparkneeds.org/wp-content/root/FinalReportAppendixA/
StudyArea_072.pdf.
5 Communities For A Better Environment, Huntington Park Lives With Pollution, Communities For A Better Environment, https://
www.cbecal.org/organizing/southern-california/huntington-park/.
6 Manal J. Aboelata, Policy Brief: Healing LA Neighborhoods, https://www.preventioninstitute.org/sites/default/files/publications/
Healing%20Los%20Angeles%20Neighborhoods%20Policy%20Brief%20February%202019%20%28002%29.pdf.
7 Los Angeles City Planning, New Code, https://planning.lacity.org/zoning/new-code#:~:text=1904,into%20industrial%20%20
and%20residential%20districts.
8 Wolch, supra note 2.
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Green space provides aesthetic benefits and recreational opportunities, serves ecologi-
cal functions, and is correlated with positive health outcomes. Residents of communities that
lack green space have lower life expectancies and higher rates of obesity, diabetes, and heart
disease.9 The public health and environmental benefits of urban green spaces in Los Angeles
become more critical each year. As the impacts of climate change intensify, urban neighbor-
hoods that lack green space experience higher temperatures, making it uncomfortable and
even dangerous for people to spend time outside during peak sun hours.10 This is largely due to
the urban heat island effect: asphalt, pavement, and hard surfaces absorb sunlight and increase
surface temperatures in urban areas.11 Conversely, grass and vegetation release moisture and
deflect the sun’s radiation, and trees provide shade—all of which help mitigate the urban heat
island effect, keeping neighborhoods cool and community members safe.12
Efforts to improve park equity in Los Angeles emphasize building new parks in low-income
communities of color and improving access to larger open spaces, such as beaches and the
Santa Monica Mountains. However, new park development can increase property values, which
can contribute to the displacement of low-income residents who live near the new park site.13
This unintended consequence is called “green gentrification”.14 Many factors, such as new transit,
market-rate housing, and commercial developments, contribute to rising property values, and
in turn gentrification and displacement. Given Los Angeles’s shortage of affordable housing and
the more than 69,000 Angelenos experiencing homelessness, it is critical that new park devel-
opments do not exacerbate or contribute to displacement.15
While park inequity, housing insecurity, homelessness, and urban heat are all distinct prob-
lems, they are connected, and addressing them requires determining how to use one of Los
Angeles’s most scarce and valuable resources: land. Given Los Angeles’s competitive and lucrative
real estate market, private and nonprofit developers and government agencies have begun to
undertake multi-benefit projects that use land and resources efficiently. For example, Los Ange-
les’s Transit-Oriented Communities (TOC) Program supports multi-benefit projects that combine
affordable housing developments and infrastructure with access to public transit stops.
Building on the TOC Program, nonprofit organizations throughout Los Angeles are piloting
community-driven joint development projects that combine parks and affordable housing to
create access to green space without displacing vulnerable communities. Joint development
While park inequity,
housing insecurity,
homelessness, and
urban heat are all
distinct problems,
they are connected,
and addressing them
requires determining
how to use one of
Los Angeles’s most
scarce and valuable
resources: land.
9 Kathleen L. Wolf, The Health Benefits of Small Parks and Greenspaces, Parks & Recreation Mag. (Apr. 3, 2017), available at
https://www.nrpa.org/parks-recreation-magazine/2017/april/the-health-benefits-of-small-parks-and-green-spaces/; Jon
Christensen et al., California State Parks: A Valuable Resource for Youth Health, UCLA Inst. of the Env’t & Sustainability, at 4,
https://www.ioes.ucla.edu/wp-content/uploads/UCLA-report-on-California-State-Parks-and-Youth-Health.pdf (last visited
August 15, 2022).
10 Clare Heaviside et al., The Urban Heat Island: Implications for Health in a Changing Environment, 4 CURRENT ENVTL. HEALTH REP.
296, 298, 300-302 (2017), https://pubmed.ncbi.nlm.nih.gov/28695487/; Scott A. Lowe, An energy and mortality impact
assessment of the urban heat island in the US, 56 ENVTL. IMPACT ASSESSMENT REV. 139, 141-143 (2016) https://reader.elsevier.
com/reader/sd/pii/S0195925515001043?token=16DC4350673A050C891B1A47ED1456149EDDADAF41397B81855269235D
9365AFACD3D44137D8F5602717FF0EE9C56BEA&originRegion=us-east-1&originCreation=20210331212741.
11 U.S. ENVTL. PROTECTION AGENCY, HEAT ISLAND EFFECT (last visited August 15, 2022), https://www.epa.gov/heatislands.
12 What DPH is Doing, County of L.A. Pub. Health, Climate Change and Sustainability: Stay Healthy in the Heat (last visited June
23, 2021), http://publichealth.lacounty.gov/eh/climatechange/ExtremeHeatDPH.htm#:~:text=The%20urban%20heat%20
island%20effect,the%20urban%20heat%20island%20effect; Reduce Heat Island Effect, Megan Lewis, From Recreation to
Re-Creation: New Directions in Parks and Open Space Planning. 551 Planning Advisory Service Report, American Planning
Association (2008).
13 Alessandro Rigolon & Jon Christensen, Greening without Gentrification: Learning from Parks-Related Anti-Displacement
Strategies Nationwide, in GREENING WITHOUT GENTRIFICATION 1, 1-2 (2000) https://www.ioes.ucla.edu/wp-content/uploads/Parks-
Related-Anti-Displacement-Strategies-report-with-appendix.pdf.
14 Id.
15 LAHSA Releases 2022 Greater Los Angeles Homeless Count Results, L.A. Homeless Servs. Authority, https://www.lahsa.org/
news?article=895-lahsa-releases-2022-great-los-angeles-homeless-count-results-released.
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projects co-locate affordable housing and public green space on a single site or on adjacent or
scattered sites in a neighborhood. These projects have the potential to address park poverty
and housing insecurity concurrently, while maximizing resources and preventing displacement
of low-income communities of color. Community vision is at the center of these projects, and
residents are engaged throughout the process to ensure their needs are met. On a larger scale,
joint development in the context of redevelopment and revitalization projects, such as the L.A.
River Revitalization Master Plan, has the potential to significantly transform communities along
the River, many of which lack access to green space. Joint development projects support public
health, social justice, and environmental goals by producing benefits associated with both
green space and affordable housing projects. Creating a more livable Los Angeles—one where
all Angelenos have access to a healthy environment, high-quality green spaces, and secure,
affordable housing—requires innovation and collaboration, and joint development of parks
and affordable housing is one strategy to achieve this.
This paper provides an overview of the joint development landscape in Los Angeles, focusing
on how to create efficient and successful partnerships among the entities that build and maintain
parks and affordable housing developments. After describing the barriers to building parks and
affordable housing, the paper describes the key entities involved in these types of development
projects, as well as each entity’s funding sources, major programs, strengths, and constraints.
The paper’s recommendations include:
Updating government approval processes and systems to support joint development proj-
ects, including streamlining and updating public grant funding application processes to
prioritize multi-benefit and joint development projects;
Increasing funding for parks and affordable housing joint development projects through
traditional and novel approaches;
Creating and acquiring new sites for joint development projects by utilizing the California Surplus
Land Act and incentivizing the inclusion of green space in new housing development projects;
Facilitating meaningful community engagement and improving coordination among stake-
holders by harnessing the expertise of nonprofit advocates and community members; and
Creating sustainable, long-term sources of funding for park operations and maintenance.
Creating a more livable
Los Angeles—one
where all Angelenos
have access to a
healthy environment,
high-quality green
spaces, and secure,
affordable housing—
requires innovation
and collaboration, and
joint development of
parks and affordable
housing is one strategy
to achieve this.
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List of Abbreviations
ADA Americans with Disabilities Act of 1990
AHSC Affordable Housing and Sustainable Communities
CNRA California Natural Resources Agency
DOI Department of the Interior
DPR Los Angeles County Department of Parks and Recreation
GGRF Greenhouse Gas Reduction Fund
GHG Greenhouse Gas
HACLA Housing Authority of the City of Los Angeles
HCD Department of Housing and Community Development
HOME HOME Investment Partnerships Program
HUD Department of Housing and Urban Development
L.A.Los Angeles
LACDA Los Angeles County Development Authority
LAHD Los Angeles Housing Department
LAHSA Los Angeles Homeless Services Authority
LAUSD Los Angeles Unified School District
LA ROSAH Los Angeles Regional Open Space and Affordable Housing Collaborative
LIHTC Low-Income Housing Tax Credit
LWCF Land and Water Conservation Fund
O&M Operations and Maintenance (for parks)
RAP Department of Recreation and Parks
RFP Request for Proposal
RPOSD Regional Parks and Open Space District
SB Senate Bill
SGC Strategic Growth Council
SMA Subdivision Map Act
TCC Transformative Climate Communities
TOC Transit-Oriented Communities
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Compared to other
major U.S. cities, the
City of Los Angeles
ranks 78th out of 100
in terms of park access,
acreage, amenities,
investments, and
equitable distribution.
Introduction
Compared to other major U.S. cities, the City of Los Angeles ranks 78th out of 100 in terms of park
access, acreage, amenities, investments, and equitable distribution.16 More than 1.4 million city resi-
dents do not live within a 10-minute walk to a park.17 Park inequities extend throughout Los Angeles
County; approximately 50% of residents (nearly five million people) live in neighborhoods with high
or very high park need, meaning these neighborhoods have less than 1.6 acres and 0.7 acres of park
space per 1,000 residents, respectively.18 Public green spaces provide the only outdoor spaces and rec-
reation opportunities for many residents of Los Angeles’s urban neighborhoods, especially low-income
residents and apartment dwellers. In addition to providing social and recreational opportunities, park
access is correlated with better physical and mental health outcomes. Communities that lack access to
green space have higher rates of obesity, type II diabetes, cardiovascular disease, and stress.19
The City and County are also struggling to provide stable affordable housing for individuals and
families who have lost, or are on the brink of losing, housing. The Los Angeles Homeless Services
Authority’s (LAHSA) “2020 Greater Los Angeles Homeless Count,” which was conducted in January
2020, found 66,436 people were unhoused in the County (a 12.7% increase from 2019), 41,290 of
whom reside in the City of Los Angeles (a 16.1% increase).20 Both the City and the County saw sub-
stantial increases in the number of unhoused individuals in 2020, despite successes sheltering and
rehousing over 53,000 individuals and efforts to build new affordable and supportive housing.21 The
City and County did not conduct a Homeless Count in 2021 because of the COVID-19 pandemic,
but given economic strain caused by the pandemic, it is likely the number of unhoused people has
increased.22 While there are many reasons why Los Angeles is seeing an increase in its unhoused
population, high home prices and rents and the lack of affordable and low-to-moderate income
housing are certainly major factors. Housing is one of the primary social determinants of health, and
safe and secure housing is critical for physical, mental, and economic well-being.23
The Los Angeles metropolitan area is also grappling with the impacts of climate change and
working to cope with these impacts as they intensify. Land use-planning strategies, such as efforts to
increase urban greening, are integral to helping Los Angeles mitigate and adapt to climate change. New
park development can help mitigate the urban heat island effect—caused when asphalt and other hard
surfaces absorb sunlight, raising temperatures—which makes many of Los Angeles’s densely-populated
urban areas dangerously hot for children, the elderly, and unhoused people when the weather is warm.24
16 Trust For Public Land, Los Angeles, CA, https://www.tpl.org/city/los-angeles-california.
17 Id.; see also, U.S. Census Bureau, QuickFacts: Los Angeles City, California, https://www.census.gov/quickfacts/losangelescitycalifornia.
18 L.A. County Dep’t of Parks & Recreation, Executive Summary of the Los Angeles Countywide Comprehensive Parks & Recreation
Needs Assessment 5, https://lacountyparkneeds.org/wp-content/uploads/2016/05/Executive-Summary.pdf (demonstrating
high need areas have less than 1.6 acres of park space per 1,000 residents and very high need areas have less than 0.7 acres
of park space, as compared to the County’s median of 3.3 acres per 1,000 people).
19 Ctrs. for Disease Control & Prevention, Benefits of Physical Activity, https://www.cdc.gov/physicalactivity/basics/pa-health/
index.htm?CDC_AA_refVal=https%3A%2F%2Fwww.cdc.gov%2Fphysicalactivity%2Feveryone%2Fhealth%2Findex.
html#reducing-disease; Jennifer Wolch, et al., Childhood obesity and proximity to urban parks and recreational resources: a
longitudinal cohort study. 17(1) Health & PLACE 207-14 (2011) (discussing a 10-year study of over 3,000 children in southern
California that showed growing up in close proximity to parks or recreational facilities strongly correlated with lower
obesity rates for 18-year-olds, than those who did not); see also L.A. County Dep’t of Pub. Health, Parks and Public Health in
Los Angeles County: A Cities and Communities Report 3, http://publichealth.lacounty.gov/chronic/docs/Parks%20Report%20
2016-rev_051816.pdf.
20 L.A. Homeless Servs. Authority, supra note 15.
21 Id.
22 LAHSA released the 2022 Homeless Count results in September 2022, stating an estimated 69,144 people
are experiencing homelessness in LA County and 41,980 people are experiencing homelessness in the
City of LA. LAHSA, LAHSA Releases 2022 Greater Los Angeles Homeless Count Results, https://www.lahsa.org/
news?article=895-lahsa-releases-2022-great-los-angeles-homeless-count-results-released.
23 Diana Hernandez & Shakira Suglia, Housing as a Social Determinant of Health (2016) https://healthequity.globalpolicysolutions.
org/wp-content/uploads/2016/12/Housing2.pdf; Ctrs. for Disease Control & Prevention, About Social Determinants of Health
(SDOH), https://www.cdc.gov/socialdeterminants/about.html.
24 Heaviside, supra note 10, at 300-302.
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Green space reflects and disperses heat, which cools surface temperatures.25 Trees provide shade, while
absorbing carbon dioxide, which can help reduce greenhouse gas (GHG) concentrations.
New parks and affordable housing developments are critical for ensuring environmental, eco-
nomic, health, and racial equity. Park and affordable housing needs largely overlap in low-income com-
munities of color that are negatively impacted by historic and continuing underinvestment, as well as
systemic inequality. In light of the various challenges Los Angeles is facing, elected officials and advo-
cates have sought solutions that can address these challenges concurrently and maximize social ben-
efits, while minimizing displacement and other negative impacts that are commonly associated with
development projects. Joint development of parks and affordable housing is one promising solution.
What is Joint Development
of Parks and Aordable Housing?
Joint development of parks and affordable housing combines public green space and low-in-
come or public housing on a single site, or on different sites in the same area, to simultaneously
address park poverty, housing insecurity, and climate change-related urban heat impacts. Project
sizes can range from small (e.g., a single parcel of land with an affordable apartment building and
a small parklet/pocket park) to very large (e.g., a multi-acre development along the L.A. River with a
large regional park and a multi-building affordable housing development). While joint development
projects can take many forms, the central components include building new (or preserving existing)
affordable housing and creating new (or rehabilitating existing) open spaces in low-income commu-
nities of color without displacing residents. Parks and affordable housing joint development is similar
in concept to the City of Los Angeles’s Transit-Oriented Communities (TOC) Program, which focuses
on building affordable housing near public transit to reduce GHG emissions and increase affordable
housing stocks. As part of the program, L.A. Metro adopted a “35% target for affordable housing devel-
opment on agency-owned land, created a land-discounting policy for those new housing units, and
introduced a loan program—Metro Affordable Transit Connected Housing (MATCH)”—to support
transit-oriented development on privately owned land near transit sites.26 Since the TOC Program
launched in 2017, it has been one of the City’s strongest drivers of affordable housing production.27
Nonprofit and community-based organizations have played a key role in advocating for joint
development. Since 2016, the Los Angeles Regional Open Space and Affordable Housing Collabora-
tive (LA ROSAH) has been working to advance joint development projects and educate stakeholders
and decision makers about the benefits of joint development.28 LA ROSAH coined the phrase “joint
development of parks and affordable housing,” and its members include park, housing, environ-
mental, and social justice nonprofit organizations, as well as California’s San Gabriel and Lower Los
Angeles Rivers and Mountains Conservancy.29 LA ROSAH created five joint development typologies:
1) Infill Development and On-site Greening; 2) Infill Development and Off-site Greening; 3) Large Mas-
ter-Planned Infill Redevelopment; 4) Neighborhood Transformation Scattered Site Approach; and 5)
Transformative Infrastructure with Affordable Housing and Anti-Displacement Strategy.30
While joint development
projects can take many
forms, the central
components include
building new (or
preserving existing)
affordable housing
and creating new (or
rehabilitating existing)
open spaces in low-
income communities of
color without displacing
residents.
25 U.S. Envtl. Protection Agency, supra note 11; see also County of L.A. Pub. Health, supra note 12.
26 Thomas Yee, Sissy Trinh & Natalie Zappella, Pathway To Parks & Affordable Housing Joint Development, at 11 https://
d3n8a8pro7vhmx.cloudfront.net/lathrives/pages/172/attachments/original/1541797472/Pathway_to_Parks_and_
Affordable_Housing.pdf?1541797472.
27 Julia Stein, Learning Lessons From Los Angeles’s TOC Program, Legal Planet (Nov. 20, 2019), https://legal-planet.
org/2019/11/20/learning-lessons-from-los-angeless-toc-program/; Los Angeles City Planning, Transit Oriented Communities
Incentive Program, https://planning.lacity.org/plans-policies/transit-oriented-communities-incentive-program.
28 LA ROSAH, About, https://larosah.org/; Yee et al, supra note 26 at iv.
29 LA ROSAH, Coalition Members, https://larosah.org/about/coalition-members.
30 Yee et al, supra note 26 at ii-iii.
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LA ROSAH Joint Development Typologies31
TYPOLOGY DESCRIPTION EXAMPLES
Infill Development and
On-site Greening
Combines housing and green
space on an urban infill site (<1
acre to 7 acres).
Clifford Beers Housing’s Isla
Intersections32
Metamorphosis on Foothill33
Infill Development and Off-
site Greening
Combines a housing
development on one site
with open space or green
infrastructure on adjacent infill
sites (e.g., public rights-of-way,
alleys, or utility corridors).
Transforms unused or
underutilized public space into
green space.
7th + Witmer34
Whittier & Downey35
Large Master-Planned Infill
Redevelopment
Involves redesigning a single
site consisting of seven or
more acres that is owned by a
single entity; most feasible in
the context of public housing
redevelopment.
Jordan Downs
Redevelopment36
Neighborhood
Transformation Scattered Site
Approach
Coordinates development of
multiple parcels by sharing
infrastructure, thematic or
programmatic elements, and
funding.
Beneficial in a dense or
developed area that lacks one
large vacant site but has several
unused or underutilized parcels
that could provide housing or
open space.
Sustainable Little Tokyo37
Watts Re:Imagined38
Transformative Infrastructure
with Affordable Housing and
Anti-Displacement Strategy
Ensures new infrastructure
or green space projects
include affordable housing
and displacement avoidance
strategies (e.g., value
capture, tenant protections,
and affordable housing
preservation).
Los Angeles River
Revitalization39
31 Yee et al, supra note 26 at ii-iii; Ramya Sivasubramanian, Create Parks & Affordable Homes, Avoid Green
Gentrification, NRDC: Expert Blog (Feb. 27, 2019) https://www.nrdc.org/experts/ramya-sivasubramanian/
tackle-green-gentrification-parks-and-affordable-housing.
32 Clifford Beers, Isla Intersections, https://cbhousing.org/communities/isla-intersections/.
33 Holos Communities, Metamorphosis on Foothill, https://cbhousing.org/communities/metamorphosis-on-foothill/.
34 Steven Sharp, Rendering vs. Reality: 7th & Witmer Supportive Housing, Urbanize Los Angeles (Oct. 10. 2019), https://urbanize.
city/la/post/rendering-vs-reality-7th-witmer-supportive-housing.
35 Meta Housing Corp., Whittier & Downey, https://www.metahousing.com/location/whittier-downey-nw/.
36 Bridge Housing, Cedar Grove at Jordan Downs, https://bridgehousing.com/properties/cedar-grove/.
37 Sustainable Little Tokyo, About, http://sustainablelittletokyo.org/about.
38 KDI, Watts Re:Imagined, https://www.kounkuey.org/projects/watts_reimagined.
39 City of Los Angeles, Los Angeles River Revitalization, https://lariver.org/.
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Benefits of Joint Development
Joint development provides a host of benefits. In addition to building and preserving
affordable housing and creating and protecting access to green space, joint development proj-
ects can maximize resource efficiency and generate revenue for long-term project operations
and maintenance via ground leases.
By combining parks and affordable housing efforts, joint development projects can be
an efficient use of scarce resources, including land and funding for new parks and affordable
housing development. While sites in Los Angeles are generally limited and expensive, there are
properties, including government-owned parcels, that are underdeveloped. Co-locating parks
and affordable housing on a single site or adjacent sites can provide residents with access to
both and reduce park poverty and housing insecurity simultaneously. Joint development proj-
ects can create new opportunities for affordable housing by opening up land, such as underuti-
lized parkland and open space, that would not otherwise be available for housing development.
Moreover, joint development projects challenge developers to think creatively. Outside-the-
box approaches can increase the number of housing units alongside greenspace formed from
oft-ignored roofs, pathways, and alleys (subject to zoning laws and project budgets).
Joint development projects also enable organizations to tap into additional funding pots
and to share acquisition, community design/engagement, and design costs, which can reduce
the total project budget or free up more resources for the construction process. Affordable
housing developers may be able to access parks and greening funds to build open space or
green infrastructure elements on their sites. For adjacent and scattered site developments,
organizations can think holistically about a community’s needs, and each site can be used to
provide a resource or service.
Joint development also provides an opportunity to generate revenue for park operations
TREES IN DOWNTOWN LA. PHOTO BY DANIEL MELLING
By combining parks
and affordable
housing efforts, joint
development projects
can be an efficient use
of scarce resources,
including land and
funding for new parks
and affordable housing
development.
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and maintenance (O&M). O&M is a major expense for nonprofit park and affordable housing
developers, private developers, and government park departments, and it can be cost-prohib-
itive. Some entities may decide not to include green space because maintaining it will be too
expensive, while other entities may neglect to maintain it. Joint development projects create
opportunities for partnerships and management arrangements that can address these issues.
For example, an affordable housing developer can subdivide a parcel and dedicate a portion of
it for parkland that would be operated and maintained by a park entity. Entities that own and
operate open space may be able to generate revenue for O&M via ground leases with affordable
housing developers. The California Surplus Land Act provides opportunities for government
agencies to sell or lease surplus land to third parties, such as other government agencies and
nonprofit affordable housing developers. When the intent is to help create affordable housing,
agencies can sell land at prices below market value.40
Park entities may also be able to subdivide a newly acquired
parcel and sell a portion to an affordable housing developer, gener-
ating revenue for park operations. Because California’s Public Park
Preservation Act places restrictions on developing existing park-
land, a parcel would have to be subdivided before it is dedicated as
parkland. For example, if a State Conservancy acquired a large plot
of land, and a portion of it was unsuitable or unnecessary for park
development, the Conservancy could subdivide the parcel. Once
subdivided, one parcel could be dedicated for parkland. The Con-
servancy could then sell the other parcel, likely using the Surplus
Land Act disposal process or a Request for Proposal, to an afford-
able housing developer. The proceeds from the sale could be used
to cover park operations and maintenance. This is a novel approach,
and it will be important to assess each park agency’s capacity and
willingness to subdivide parkland.
40 Cal. Gov’t Code § 54220.
41 Cal. Pub. Res. Code § 5401(a).
42 Cal. Pub. Res. Code § 5563.
The purpose of California’s PUBLIC PARK PRESERVATION
ACT OF 1971 is to protect public parklands. The Act
restricts the “exchange, purchase, condemnation, or
otherwise” of any public park for any non-park purpose
“unless the acquiring entity pays or transfers to the
legislative body of the entity operating the park
sufficient compensation or land, or both … to replace
the park land.”41 Only land “deemed temporarily
unnecessary for park or open-space purposes” can be
leased for other purposes for up to 25 years.42 The
Act’s effectiveness at protecting parkland largely
precludes the development of affordable housing on
existing park sites and open spaces.
Challenges Associated with Building Joint
Development Projects
Despite the benefits, few joint development projects have been constructed in L.A. or in
other U.S. cities and counties. Infrastructure projects require time and money, and the parks and
housing sectors have historically operated in silos. Bringing together these distinct sectors to
build multi-benefit projects poses several challenges.
Funding
Unsurprisingly, funding is a significant barrier. Given the scale of the affordable housing
crisis, the number of neighborhoods that lack green space in Los Angeles, and the cost of these
types of developments, additional funding will always be needed. However, funding sources do
exist, and these resources have been, and can continue to be, used to make meaningful improve-
ments. There are opportunities to make existing funding sources more stable and accessible,
while using the money more efficiently—all of which could help maximize community benefits.
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Funding for Aordable Housing
Affordable housing financing is unique and complicated. Funding for affordable housing
comes from a few main sources: federal low-income tax credits, federal and state tax-exempt
bonds and loans, state and local loan and grant programs, and bank loans based on a develop-
er’s net operating/rental income.
The federal Low-Income Housing Tax Credit (LIHTC) Program reduces tax liability for devel-
opers, which provides a substantial incentive to build affordable housing. However, because
nonprofit organizations are tax-exempt, they are ineligible to receive tax credits. To take advan-
tage of this valuable program, nonprofit affordable housing developers will often partner with
investors that are not tax-exempt and are therefore eligible to earn tax credits. The State of
California supplements the LIHTC program by providing a one-time state tax credit to federal
tax credit recipients.
Federal, state, and local loan programs provide interest-free funding, have long repayment
periods, and only require developers to repay the loan if the current rents cover the building’s
operating expenses. These programs include Community Development Block Grants, the HOME
Investment Partnerships program, the Affordable Housing Sustainable Communities program,
and the No Place Like Home program. There are a few notable housing grant programs, includ-
ing California’s Multifamily Housing Program and part of the Affordable Housing and Sustain-
able Communities Program. These programs place numerous requirements on grantees and
can be cumbersome.
While housing agencies typically have large budgets, they also experience challenges in
addressing the scale of the affordable housing crisis. The construction of affordable housing
developments is often more expensive than building market-rate buildings because affordable
housing developers are subject to additional construction and labor requirements, such as
hiring union employees and paying prevailing wages.43 According to a February 2022 report by
L.A. City Controller, Ron Galperin, the average per-unit cost for housing an unhoused Angeleno
was $531,000 in 2020 and $596,846 in 2021. Costs are continuing to increase.44 Local and state
housing agencies typically allocate funding for public housing development, loan programs
for nonprofit and private affordable and supportive housing development, supportive services,
and job training. Affordable housing developers are accustomed to piecing together multiple
funding sources, but it can be challenging for them to acquire and hold land while they are
securing project financing.
Housing developers also have difficulty accessing funding for parks and urban greening
projects. Some parks grant programs, such as L.A. County’s Measure A, allow nonprofit afford-
able housing developers to apply for funding to build public park space as part of affordable
housing projects.45 But nonprofit developers often need to partner with public or nonprofit park
developers in order to complete the grant and construct the green space.
43 Caroline Reid, The Cost of Affordable Housing Production, Terner Center for Housing Innovation (March 2020), https://
ternercenter.berkeley.edu/wp-content/uploads/pdfs/LIHTC_Construction_Costs_March_2020.pdf; Thomas Fuller, Why
Does It Cost $750,000 to Build Affordable Housing in San Francisco?, New York Times (Feb. 20, 2020), https://www.nytimes.
com/2020/02/20/us/California-housing-costs.html.
44 Ron Galperin, The Problems and Progress of Prop. HHH, LA City Controller (Feb. 2022), https://lacontroller.org/wp-content/
uploads/2022/02/2.22.23_The-Problems-and-Progress-of-Prop-HHH_Final.pdf.
45 L.A. County Regional Park & Open Space District, Grants Administration Manual for Measure A (April 2021), https://rposd.
lacounty.gov/measure-a-grants-administration-manual/.
Funding for affordable
housing comes from
a few main sources:
federal low-income
tax credits, federal
and state tax-exempt
bonds and loans,
state and local loan
and grant programs,
and bank loans based
on a developer’s net
operating/rental
income.
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Funding for Parks and Green Space
Locally and at the state level, parks departments are underfunded and lack the resources to
maintain and operate existing parks, let alone construct new parks. Park agencies rely on other
funding sources, such as bonds, cap-and-trade dollars, user fees, and tax revenues to fund park
development and operate and maintain existing parks. Funding from these sources varies from year
to year, making it hard for departments to plan for long-term projects. Park agencies can receive
property tax exemptions for parks and open space, which makes it easier for them to hold land.
At the state level, natural resource bonds have provided substantial funding for capital
projects, including new park construction and renovation projects. Bond funding can be used
to build or acquire “capital assets,” which include “tangible physical property.”46 Bond funding
cannot be used for long-term operations and maintenance. Since 2000, voters have approved
seven statewide natural resource bonds: Props 1, 1E, 12, 40, 50, 68, and 84.47 However, bond
funding eventually runs out, necessitating the passage of new bonds. In 2018, California voters
passed Prop 68 to replace the expiring funds of Prop 84, passed in 2006. Prop 68 included lan-
guage to allow up to 5% of bond funding to be used to provide programming at or create
access to the capital asset. The California Department of Finance later determined Prop 68 bond
funding could not be used for programs, activities, or transportation, stalling this potential
funding source.48 Another natural resource bond measure may appear on California ballots in
LA COUNTY BOARD OF SUPERVISORS MEETING TO SECURE FUNDING FOR PARK EQUITY PHOTO BY BETH KENT
46 Legis. Analyst’s Off., Bonds, https://lao.ca.gov/BallotAnalysis/Bonds.
47 Cal. Nat. Resources Agency, Bonds Oversight, https://resources.ca.gov/Bonds-Oversight.
48 Cal. Dep’t of Parks & Recreation, Community Access Program, https://www.parks.ca.gov/?page_id=30053 (Prop 68 included
a Community Access Program that would fund activities and transportation to help community members access parks and
open spaces. Up to 5% of Prop 68 funding could have been used for Community Access Projects. However, the Department
of Finance notified State Parks that Prop 68 cannot fund programs or transportation, and the program has been on hold for
several years).
Park agencies rely on
other funding sources,
such as bonds, cap-and-
trade dollars, user fees,
and tax revenues to
fund park development
and operate and
maintain existing parks.
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the next several years, but it may not pass, or it may prioritize funding different programs, such
as climate change mitigation, wildfire prevention and response, water security, or heat mitiga-
tion. Absent new bond funding, the State would need to find other funding sources for these
projects, such as allocating funding from the state budget. Otherwise, funding for these pro-
grams could be severely reduced.
The State also administers the Greenhouse Gas Reduction Fund (GGRF), which is funded
by proceeds generated from credit auctions under California’s Cap-and-Trade Program. GGRF
funding is allocated to programs that support California’s climate goals and reduce greenhouse
gas emissions, as required by the California Global Warming Solutions Act of 2006.49 GGRF
funding is allocated to over forty state programs, and each program’s allocation varies from year
to year. Of the forty programs that receive GGRF funding, three programs fund housing and/or
green space: the California Strategic Growth Council’s (SGC) Affordable Housing and Sustain-
able Communities (AHSC), SGC’s Transformative Climate Communities (TCC), and the California
Natural Resource Agency’s (CNRA) Urban Greening.50 Collectively, these three programs account
for a significant amount of the State’s climate-focused housing and greening funding. A sizeable
portion of GGRF funds is tied up in continuous appropriations, which reduces the amount of
funding available for grant programs.51 For the remaining funding, programmatic allocations
vary by year and are often influenced by political priorities. For example, in fiscal year 2019-2020,
$100 million from GGRF was allocated for clean drinking water,52 and the 2021-2022 package
49 Cal. Climate Inv., Background: About California Climate Investments, https://www.caclimateinvestments.ca.gov/about-cci;
Assembly Bill 32 (Nunez 2006); CAL. HEALTH & SAFETY CODE §§ 38500-38599 (2006).
50 Cal. Climate Inv., supra note 49.
51 Cal. Climate Inv., Funded Programs, https://ww2.arb.ca.gov/our-work/programs/california-climate-investments/
california-climate-investments-funded-programs.
52 Legis. Analyst’s Off., Expanding Access to Safe and Affordable Drinking Water in California – A Status Update (Nov. 10, 2020),
https://lao.ca.gov/Publications/Report/4294.
OUTREACH MEETING FOR PARK RENOVATION GRANT PHOTO BY BETH KENT
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In short, nonprofits,
government agencies,
and affordable housing
developers face
significant challenges
in piecing together
project budgets for joint
development projects.
included a sizeable GGRF allocation for wildfire prevention, response, and mitigation.53 While
drinking water and wildfire response are critical issues, funding them reduces the amount of
money available for urban greening and forestry, park development, and other climate-related
infrastructure projects. Moreover, GGRF dollars are designed to decrease over time as industries
can earn, sell, and buy fewer cap-and-trade credits. The Cap-and-Trade Program may sunset in
2030, so absent a legislative extension, this critical funding source may disappear altogether. If
and how these programs will be funded when GGRF dollars run out are important and lingering
questions. Creating reliable and consistent funding for climate-related infrastructure projects in
the long-term is critical.
In Los Angeles County, Measure A created a sales tax and Measure W created a parcel tax
that generate revenue for parks and storm water infrastructure respectively. While County-level
taxes can provide stable, long-term funding for green infrastructure construction and mainte-
nance, passing a state-level tax is much more difficult and often a political nonstarter.
Funding for Multi-Benefit Projects
There are dozens of federal, state, and local loan and grant programs that provide partial
funding for parks and housing projects. Most programs want applicants to have multiple funding
sources, and few funders are willing or able to foot the bill for an entire project. Each program
has its own criteria and application process, which requires applicants to expend a substantial
amount of time and energy to create specialized applications for each program. Many programs
are also quite narrow, so park funding and housing funding often must come from separate
sources, which can double the number of grant and loan applications an applicant needs to
complete. Piecing together numerous funding sources delays projects.
A few state programs are designed to fund multi-benefit projects, such as SGC’s AHSC and TCC
programs. However, the only program specifically designed to fund parks and affordable housing
joint development projects is the California Department of Housing and Community Develop-
ment’s (HCD) Housing-Related Parks Program. The program is intended to increase access to parks
and the supply of affordable housing by providing grants for new park construction and renova-
tions of existing parks and financial incentives to cities and counties for newly constructed units
for very low- or low-income households. The program has not been funded in several years.54
In short, nonprofits, government agencies, and affordable housing developers face signifi-
cant challenges in piecing together project budgets for joint development projects.
Coordination
Historically, the parks and housing sectors have operated in silos. This lack of meaningful
coordination has occurred in the nonprofit, government, and private contexts, which can make
the type of cross-sector collaboration needed for joint development challenging. As explained
above, both sectors are working to address large-scale problems, and most nonprofits and gov-
ernment agencies are already doing as much work as they can. Public entities are overworked
and under-resourced, making it difficult for employees of these entities to tackle big-picture
53 Legis. Analyst’s Off., The 2021-22 Budget: Wildfire Resilience Package – Analysis of Individual Programs (Feb. 5, 2021),
https://lao.ca.gov/handouts/resources/2021/The-2021-22-Budget-Wildfire-Resilience-Package-Analysis-of-Individual-
Programs-020521.pdf.
54 Cal. Dep’t Housing & Community Dev., Housing-Related Parks Program, https://www.hcd.ca.gov/housing-related-parks.
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issues beyond the scope of their agencies’ missions. Sometimes, lack of coordination is due
to agency or organization culture, but other times it is because charters, governing principles,
and mission statements restrict an entity to specific activities. For example, a park agency may
be willing to permit a housing department to build a shelter or supportive housing on a park
site, but the park agency’s charter may prevent it from permitting the use of park land for
any purpose other than recreation or park use. The City of Los Angeles’s Recreation and Parks
Department’s Charter includes such provisions.55
Land Acquisition
In Los Angeles, land acquisition can be very expensive; Los Angeles places fifth among the
country’s highest average urban land values.56 Layers of government approval and the assessment
of development and impact fees also make land acquisition costly. Given these high land costs, it
can be difficult for nonprofit park developers and affordable housing
developers to compete with market-rate housing developers. Park and
affordable housing developers often seek out properties in less expensive
neighborhoods and participate in local and state Request for Proposal
(RFP) processes that enable nonprofit developers to acquire and/or build
on land owned by the City or County. In L.A., the City and County own
most of the vacant lots in the region, and several laws and public pro-
cesses regulate how they can dispose of these surplus properties.57 The
Surplus Land Act mandates notices of availability of surplus land to devel-
opers of low- and moderate-income housing and to government park
entities where the surplus land is already parkland.58 The Surplus Land
Act was amended in 2019 to include additional provisions that priori-
tize affordable housing development, and it remains to be seen whether
government parks agencies and affordable housing developers will take
advantage of the Act. Moreover, the Act only works if local jurisdictions
comply with its provisions, which requires oversight and enforcement by
HCD. In practice, a number of sites have been sold to private developers
without giving parks agencies and affordable housing organizations the
option to purchase the property first.
Additionally, many of Los Angeles’s vacant lots are contaminated
because they were previously used for industrial or commercial purposes.
Contaminated sites, or brownfields, require expensive remediation before
they can be redeveloped for parks or housing, and projects that involve
remediation are not eligible for development streamlining benefits, such
as SB 375’s California Environmental Quality Act streamlining provisions.59
California’s SURPLUS LAND ACT (Cal. Gov’t Code §
54221) governs the disposal of “surplus land,” which
are government-owned parcels that are unnecessary
for an agency’s use. Local agencies can dispose of
surplus land by transferring the property to another
local, state, or federal agency or via an open, com-
petitive bid process that gives private and nonprofit
developers the opportunity to acquire the land. The
Surplus Land Act can support the development of
affordable housing and parks/open space. While the
Act allows a local agency to sell or lease surplus land
below fair market value, e.g., to create affordable
housing near transit, nothing prevents an entity from
selling the land at market rate.60 The Act requires
agencies to send a written notice of availability of
land to park or recreation departments, regional
park authorities, and the State Resources Agency and
states that surplus land must first “be made available
for park and recreation purposes or for open-space
purposes.”61 The Act similarly requires agencies to
notify local public agencies of the availability of land
for the purpose of developing low- and moderate-in-
come housing.62 The Act also extends the payment
period for low- and moderate-income housing.63
55 Los Angeles, CA., Charter and Administrative Code § 590 (2022).
56 Richard Florida, The Staggering Value of Urban Land, Bloomberg (Nov. 2, 2017), https://www.bloomberg.com/news/
articles/2017-11-02/america-s-urban-land-is-worth-a-staggering-amount.
57 Cal. Gov’t Code § 54221 (West 2020), County of L.A., Surplus Property https://doingbusiness.lacounty.gov/
surplus-property-2/.
58 Cal. Gov’t Code § 54222(b)(1-4) (West 2020).
59 SB 375 (2008).
60 Gov. Code §54226.
61 Gov. Code § 54222(b)(1-4).
62 Gov. Code § 54222(a)(1).
63 Gov. Code § 54225.
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Operations and Maintenance
Operations and maintenance (O&M) of affordable housing developments and green space
requires funding and skilled labor. Affordable housing developers are responsible for ensuring
their buildings remain habitable. They must hire staff to handle routine and emergency main-
tenance. Parks and green space also require ongoing O&M, including watering, landscaping,
removing garbage, and maintaining park amenities. All of these maintenance tasks take time
and must be performed by trained individuals. Failure to properly maintain developments and
repair broken amenities can pose safety risks and expose landowners to liability. These liability
risks tend to be greater when a park site is publicly accessible, as opposed to on-site green space
that is only open to residents of the affordable housing development. Given these associated
resource requirements and liability risks, affordable housing developers may be unmotivated
or unable to take on park O&M responsibilities. Park entities, especially city and county park
departments, may be able to fill this gap and maintain and operate publicly-accessible parks at
affordable housing developments. But these arrangements would likely require the affordable
housing developer to dedicate or ground lease the park space to a park entity and/or require
the park entity to indemnify the affordable housing developer. These legal arrangements come
with pros and cons for each party and may be complicated to form. In particular, liability, or the
perceived threat of liability, is often a primary concern for a property owner. If an affordable
housing developer owns a site that is open to the public, they may seek to limit their liability
by purchasing insurance or by entering into an indemnity agreement with the manager of the
publicly-accessible open space. Alternatively, a developer may elect to develop a site and then
transfer the property to the park entity to own and operate it.
Scalability
There are only a few completed parks and affordable housing joint development projects
in the L.A. region, and each of these projects has been developed through a unique, multi-year
process. Every new joint development project has required developers to reinvent the wheel
and problem solve as they develop the project.
Other agencies, including L.A. Metro, L.A. Department of Public Works, and SGC, have expe-
rience working on multi-benefit and joint development projects involving transit, housing,
and green infrastructure. By drawing on the lessons learned from analogous projects in other
sectors, developers may be able to create a more efficient and streamlined process for parks and
affordable housing joint development.
Many of these challenges can be overcome through efficient partnerships that bring
together the various entities that are operating in the parks, housing, and joint development
spaces and leveraging each entity’s resources and skills. Additionally, engaging community
members and community-based organizations in these processes can produce creative projects
that best serve the unique and diverse needs of a community.
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Joint Development Landscape
Government agencies, nonprofit organizations, private developers, and private foundations
are all involved in joint development projects, and public-private partnerships are also common
in this space. Each of these entities plays a different and important role, and some entities play
multiple roles. Understanding the joint development landscape and the ways in which these
entities interact (or fail to interact) with each other is key to identifying methods of facilitating
joint development projects.
In general, funding for both parks and affordable housing is limited and competitive, and
the pot of funding for joint development projects represents a small subset of the funding
that exists for either type of development. The parks and affordable housing sectors typically
operate in silos, and both government and non-governmental entities are set up to address
parks or affordable housing, but not both. As a result, joint development implicates a patchwork
of entities that each have unique roles, and most joint development projects are one-offs. Both
public and private funding sources are subject to varying degrees of stability, which presents
issues for expanded development, as well as ongoing O&M for existing and future projects.
The following tables provide a brief overview of the major entities that engage with parks
and affordable housing, as well as each entity’s primary funding programs, the lands or projects
it manages, and its key strengths and constraints.
URBAN GREENING PHOTO BY DANIEL MELLING
Government agencies,
nonprofit organizations,
private developers, and
private foundations
are all involved in joint
development projects,
and public-private
partnerships are also
common in this space.
Each of these entities
plays a different and
important role, and
some entities play
multiple roles.
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Federal Government Agencies
Entity Funding
Programs
Lands/Projects
Managed
Strengths Constraints
Internal Revenue Service
(IRS)
Low-Income Housing
Tax Credit (LIHTC)
N/A Tax credits make
affordable housing
attractive to investors.
Tax credits are highly
competitive, and demand
is far greater than supply.
U.S. Department of
Housing and Urban
Development (HUD)
National Housing
Trust Fund
HOME Investment
Partnerships (HOME)
Program
Community
Development Block
Grant
Annual operating
subsidies to local
agencies
HUD provides
homebuyer resources
and sells single-family
and multi-family
homes.
HUD provides
funding for affordable
housing programs
and subsidizes local
agencies.
Funding programs exclude
moderate-income residents
and other populations that
still cannot afford market-
rate housing.
U.S. Department of the
Interior (DOI)
Land and Water
Conservation Fund
Outdoor Recreation
Legacy Partnership
Program
DOI manages federal
natural resources,
cultural resources,
and public lands,
including the National
Park System.
DOI provides funding
to support natural
resources in states,
including natural
resources in urban
areas.
LWCF funding cannot be
used for housing.
LWCF applications
must be submitted by
state governments;
local governments and
nonprofits cannot apply
directly.
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State Government Agencies
Entity Funding
Programs
Lands/Projects
Managed
Strengths Constraints
California Tax Credit
Allocation Committee
(TCAC)
TCAC administers
LIHTC and the state
low-income housing
tax credit programs.
TCAC ensures
developers that
receive tax credits
comply with federal
rent and income
restrictions.
It distributes federal
tax credits, which
incentivize affordable
housing.
The State’s tax credits
supplement limited
federal funding and
provide an additional
benefit to developers.
The limited supply and
high demand for credits
make it difficult to award
credits to all worthy
projects.
Department of Housing
and Community
Development (HCD)
HCD administers
federal and state
grant and loan
programs, including:
Housing Trust Fund
Multifamily Housing
Program
No Place Like Home
HCD monitors
affordable housing
developments to
ensure they stay
affordable and
comply with state
laws.
It administers projects
for AHSC.
It provides critical
funding for affordable
housing developers
through a number of
programs that support
permanent supportive,
low-income, and multi-
family housing, as
well as multi-benefit
projects.
The agency’s bureaucratic
processes and prevailing
wage requirements are
burdensome.
There is a high barrier to
entry for those without
affordable housing
development experience
and funds are highly
competitive.
California Natural
Resources Agency
(CNRA)/California
Department of Parks and
Recreation (State Parks)
GGRF’s Urban
Greening program
Statewide Parks
Program (SPP)
State Parks manages
California’s state
parklands.
CNRA and State Parks
are excellent at grant
management and
dispersing state funds.
SPP is a major resource
for local government
and nonprofit park
developers.
SPP provides funding
specifically for projects
that are located in park-
poor neighborhoods,
which supports park
equity goals.
State parklands are
protected areas that likely
cannot be developed for
affordable housing absent
new legislation.
Most of CNRA’s grant
funding comes from bond
measures and GGRF, which
are finite funding sources
that will run out.
SPP funding is highly
competitive.
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Strategic Growth Council
(SGC)
Affordable Housing
and Sustainable
Communities (AHSC)
Transformative
Climate Communities
(TCC)
SGC assists the
State and local
governments
with planning for
sustainability, offers
technical assistance
to underserved
communities, and
conducts climate
change research.
SGC’s programs fund
multi-benefit projects
and emphasize
sustainability and
greenhouse gas
emissions reductions,
which are consistent
with joint development
of parks and affordable
housing.
AHSC requires a developer
to apply with a local
agency and makes both
entities joint and severally
liable, which can scare
away investors.
AHSC allows for a range
of green space features,
many of which do not
provide communities with
recreational or physical
activity opportunities or
the same level of physical
and mental health benefits
that parks provide.
TCC implementation grants
are large and can be a
heavy lift.
State Conservancies Conservancies provide
funding for recreation
and habitat restoration
projects, occasionally
land acquisition.
Programs include:
Baldwin Hills
Conservancy Prop 68
grant program
Santa Monica
Mountains
Conservancy and
San Gabriel and
Lower Los Angeles
Rivers and Mountains
Conservancy Prop
1 and Prop 68 grant
programs
They manage 11 state
conservancies and are
responsible for O&M,
programming, and
conservation efforts.
Conservancies protect
state lands.
Many have the ability
to rent their facilities
to individuals and
tax-exempt nonprofit
organizations for events,
which allows them to
generate revenue for
O&M.
They may be able to
lease underutilized land
for affordable housing
development.
The Public Park Preservation
Act of 1971 may serve as
a barrier to subdividing or
leasing land designated for
open space.
Entity Funding
Programs
Lands/Projects
Managed
Strengths Constraints
State Government Agencies (continued)
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L.A. County Agencies
Entity Funding Programs Lands/Projects Managed Strengths Constraints
Los Angeles County
Development Authority
(LACDA)
The majority of
funding comes from
HUD.
LACDA administers
HOME, Section 8
voucher program, and
HCD’s No Place Like
Home programs.
It funds housing
development
and preservation,
community
development,
and economic
development
and provides
rental subsidies in
unincorporated L.A.
County.
LACDA is an
independent agency
that oversees
affordable housing,
community,
and economic
development in Los
Angeles County.
It owns and operates
2,962 units of public
housing throughout
the County.
It dispenses federal and
state housing dollars
providing critical
funding for affordable
housing developers.
LACDA’s funding and
resources are quite limited.
LACDA places strict limits
on the amount of funding
that can go towards
projects in the City of
L.A., which makes it more
difficult to build in the City.
Los Angeles County
Department of Parks and
Recreation (DPR)
DPR administers
grant programs
that provide
funding for local
park development,
including Measure
A, the County’s
largest park funding
program.
DPR manages county
park developments,
including park design
and construction,
land acquisition, and
water and energy
conservation.
It protects over 4,000
square miles of parks
and open space.
DPR has made
substantial efforts to
address park inequity
in Los Angeles,
including publishing
the 2016 Los Angeles
Countywide Parks
and Recreation Needs
Assessment.
DPR has challenges with
community engagement.
Bureaucratic delays, both
internally and when
working with other County
departments, can also
extend project timelines
and delay park openings.
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City of L.A. Agencies
Entity Funding Programs Lands/Projects Managed Strengths Constraints
Housing Authority of
the City of Los Angeles
(LAHD)
LAHD provides rental
subsidies, project-
based vouchers
for permanent
supportive housing,
and funding for
supportive services.
LAHD does not
provide capital
funding.
LAHD is a public
housing developer
and provider that
owns and manages
more than 9,300 units.
It provides monthly
financial support to
over 58,000 families.
LAHD provides public
housing in the City for
some of Los Angeles’s
most vulnerable
residents.
LAHD does not provide
capital funding, so it is
unlikely it will be able to
play a large role in building
joint development projects.
The availability of vouchers
is limited.
The agency currently
cannot receive tax credits
to build affordable housing.
Housing and Community
Investment Department
(LAHD)
LAHD administers
the City’s managed
housing fund and
trust fund, which
are used to finance
affordable housing
development
projects.
LAHD works with
LAHD to oversee
the City’s housing
programs.
It provides social
services and ensures
developers comply
with affordability
and occupancy
requirements.
LAHD administers
important local
funding sources for
affordable housing.
LAHD’s funding is
inconsistent—both in
terms of funding amounts
and application timelines—
which can make it difficult
for affordable housing
developers to plan for, rely
on, and secure funding
from LAHD.
Department of Recreation
and Parks (RAP)
RAP administers grant
programs, including
Prop K.
L.A. City Departments
and nonprofits are
eligible to apply for
funding for urban
greening, park
acquisition, and
school/recreation
projects.
RAP manages the
City’s 16,000 acres of
parkland.
It builds new parks,
renovates, maintains,
and operates the City’s
444 existing parks.
RAP provides
recreational
programming.
RAP excels at
providing recreational
programming.
Many of its sites are
well maintained and
regularly utilized.
RAP prioritizes safety
and expends resources
on park maintenance,
repair, and renovation
projects.
RAP’s biggest challenge
is acquiring land for new
parks because the agency
is not as nimble as private
developers, and City
guidelines and processes
prevent RAP from acquiring
land quickly.
Permitting and approval
processes that are managed
by other City departments
can slow down RAP’s
projects.
The Public Park Preservation
Act prevents RAP from using
or developing parkland for
non-open space purposes.
Like DPR, RAP also has
challenges with community
engagement.
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Nongovernmental Entities
Entity/Type of Entity Examples Funding Sources Lands/ Projects Managed
Strengths Constraints
Los Angeles
Regional
Open
Space and
Affordable
Housing
(LA ROSAH)
Collaborative
Members include:
Clifford Beers Housing,
Community Nature
Connection, Enterprise
Community Partners,
Inclusive Action for
the City, Little Tokyo
Service Center, Los
Angeles Neighborhood
Land Trust, Mujeres
de la Tierra, Natural
Resources Defense
Council, Southeast Asian
Community Alliance, and
The Trust for Public Land.
* The San Gabriel and
Lower Los Angeles
Rivers and Mountains
Conservancy is a
governmental partner.
While individual
members will
typically apply
for grant and
loan funding
from public and
private entities,
the Collaborative
itself has
obtained
funding through
the Strong,
Prosperous,
And Resilient
Communities
Challenge
(SPARCC), and is
exploring other
potential funding
opportunities.
LA ROSAH creates
joint development
strategies for
private and public
agency-acquired
land; advocates
for making joint
development
projects eligible
for public and
private funding
sources; and
supports
innovative
funding
strategies for the
acquisition of
joint development
sites.
LA ROSAH also
supports pilot
joint development
projects that are
built by member
organizations.
LA ROSAH connects
experts from different
fields and bridges
gaps between the
parks and housing
sectors.
It builds partnerships
between community-
based organizations
and parks and
affordable housing
developers.
It supports and
advocates for
sustainable and
equitable policies.
The Collaborative
has limited staff
capacity, so much of
the work is divided
among the member
organizations.
It can be challenging
and time-consuming
to build joint
development
projects, so there
are only a few pilot
projects.
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Affordable
Housing
Developers
Nonprofit developers
include:
Abode Communities
Clifford Beers
For-profit developers
include:
Meta Housing
Corporation
Thomas Safran and
Associates
Affordable
housing
developers
rely on federal,
state, and local
grant and loan
programs, as well
as conventional
loans from
financial
institutions.
They design, build,
and preserve
low-income,
permanent
supportive, and/
or affordable
developments.
A few operate and
manage units.
Some provide
social (mental
health) and
economic (job
assistance,
financial
counseling)
services for
residents.
They excel at building
small and mid-
sized buildings that
provide housing for
low-income families,
seniors, veterans, and
unhoused individuals.
Supportive services
help residents address
health conditions and
find jobs, which can
help break the cycle of
poverty.
They often have
community organizers
on staff who can work
with residents to build
capacity and learn
about community
needs and priorities.
They tend to fare
well in the City’s
competitive Request
for Proposal (RFP)
process, which can
reduce acquisition
costs.
Land acquisition is
a major challenge
because affordable
housing developers
often compete with
market-rate and
luxury developers.
Increasingly high
construction costs
are another major
challenge.
The liability
associated with
owning a site that is
publicly accessible is
high and can deter
investors.
Affordable housing
developers
are subject to
requirements, as a
condition of receiving
funding, that raise
project costs, such
as prevailing wage
requirements for
project labor.
In general, there is
a lack of funding
in light of the
increasing number
of unhoused
individuals in L.A.
Nongovernmental Agencies (continued)
Entity/Type of Entity Examples Funding Sources Lands/ Projects Managed
Strengths Constraints
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Nonprofit and
Community-
Based Park
Organizations
Organizations include:
From Lot to Spot
Los Angeles
Neighborhood Land Trust
Trust for Public Land
Nonprofit park
developers rely
on numerous
funding sources,
including the
Statewide Parks
Program, GGRF,
Measure A, and
foundations.
They design, build,
operate, and
maintain parks
and community
gardens.
They excel in
organizing
residents.
Some provide
recreation and
physical activity
programming.
They can hold land
tax-free.
They excel at
community
engagement and
design, as well as
tailoring projects to
community needs.
Most promote use and
stewardship of park
sites.
They tend to be
nimble and forward
thinking, which
allows them to make
decisions quickly and
participate in creative
and cutting-edge
projects.
They often operate
under fewer
constraints than
government park
entities, which can
allow them to partner
with housing entities
on joint development
projects.
Nonprofits can play an
important advocacy
role.
The biggest
challenge for most
nonprofits is paying
for long-term O&M
because few grant
programs cover
these costs.
They have to
compete with other
developers for new
park sites.
Land acquisition and
construction costs
are high.
They may need to
balance partnering
with a local
government on a
park project with
advocating for the
local government
to adopt more
equitable policies.
Foundations Foundations that fund
parks and/or affordable
housing include:
California Community
Foundation
Resources Legacy Fund
Foundation
funding comes
from various
sources. Here,
the key point is
that foundations
are important
funders of parks,
affordable
housing,
and joint
development
projects.
Foundations
administer grant
programs.
Some may engage
in advocacy.
They provide
general operating
funds, which are
necessary to keep
nonprofits running,
as well as critical
funding for new
park and affordable
housing projects,
renovations, O&M, and
programming.
Foundations fill gaps
in government grant
and loan funding.
Foundation funding
is limited and
competitive.
Funding priorities
may vary based on
internal and external
circumstances.
Nongovernmental Agencies (continued)
Entity/Type of Entity Examples Funding Sources Projects/Lands Managed
Strengths Constraints
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Which Roles Should These Entities Play
When Building a Joint Development
Project?
While the process of building each joint development project may vary depending on the nature
of the site, the local jurisdiction’s planning and permitting processes, funding requirements and restric-
tions, and the developers’ capacity, most projects will involve the following phases: 1) securing funding
and financing; 2) land acquisition and ownership; 3) community engagement; 4) design and construc-
tion; and 5) operations and maintenance. This section provides an overview of each phase and includes
suggestions regarding which entities are best suited to fill certain roles.
Phase 1: Securing Funding and Financing
Before a project can begin, the developers must create a budget and begin securing funding
for the project. As discussed above, funding for affordable housing typically comes from federal
low-income tax credits, federal and state tax-exempt bonds and loans, state and local loan and
grant programs, and bank loans based on a developer’s net operating/rental income. State and
local housing agencies, including HCD, LACDA, HACLA, and LAHD, provide critical funding for
affordable housing development in Los Angeles.
Park developers typically rely on grants from state and local park agencies, including CNRA
and DPR, and donations from foundations.
Phase 2: Land Acquisition and Ownership
Acquiring a parcel to develop is often competitive and costly, especially in L.A.’s fast-paced
real estate market. Owning a joint development site can be valuable, but it can also be risky,
as the liability or fear of liability associated with owning a publicly-accessible site can be high.
Government entities, especially State Conservancies and city and county park departments,
are likely best suited to acquire, hold, and own land for large open space and affordable housing
developments, while affordable housing developers are likely best suited for single-site or scat-
tered-site developments in dense urban areas. Conservancies and park departments are well
equipped to own and protect open spaces of all sizes (pocket, neighborhood, regional) because
this is the core of their work. Conservancies and park departments can hold land tax free,64 and
they are well suited to utilize the Surplus Land Act. City and county park departments may also
be able to partner with an affordable housing developer as part of an RFP process.
After acquiring a new parcel, L.A. City or County could retain ownership of the parcel, dedi-
64 Cal. Dep’t of Conservation, Williamson Act Program, https://www.conservation.ca.gov/dlrp/wa; State Board of Equalization,
Possessory Interests: Nonprofit Organizations and Public Parks https://www.boe.ca.gov/proptaxes/pdf/lta13010.pdf; Cal.
St. Board of Equalization Assessors’ Handbook, Welfare, Church, and Religious Exemptions at 38 (2004) (Section 236.51
exempts “and interest in real property that is leased for a term of 35 years or more by a charitable foundation and used
exclusively by the lessee as a public park.”).
While the process of
building each joint
development project
may vary depending on
the nature of the site,
the local jurisdiction’s
planning and permitting
processes, funding
requirements and
restrictions, and the
developers’ capacity,
most projects will
involve the following
phases: 1) securing
funding and financing;
2) land acquisition
and ownership;
3) community
engagement; 4) design
and construction; and
5) operations and
maintenance.
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cate and develop a portion of it into public green space, and lease a portion of it to an affordable
housing developer for housing. Park departments are subject to the Public Park Preservation
Act, so existing parkland is not eligible for joint development, and newly acquired land would
need to be subdivided before it is dedicated for parkland.
In the case of small affordable housing developments and developments in dense, urban areas,
it may be more practical for an affordable housing developer or a partnership consisting of at least
one nonprofit and at least one for-profit affordable housing developer to acquire land.65 Affordable
housing developers are often unable to purchase a plot of land that will be large enough to include
a traditional public park or open space, but they may be able to include a small parklet, courtyard, or
community garden that provides green space for residents of the development and adjacent prop-
erties. Making a green space accessible to non-residents can increase liability for the owner, which
will often require additional insurance or an indemnity agreement from the park operator.
Phase 3: Community Engagement
Community engagement is critical for ensuring new projects meet community needs. While
city and county processes require community engagement, nonprofit organizations typically
undertake more robust community engagement efforts. Many nonprofits are embedded in the
communities they work in, which helps them build a level of trust with community members
that even the most well-intentioned government agencies are unable to build. Nonprofit park
developers and community-based organizations that have strong community ties and dedi-
cated community organizers are best suited to manage community engagement processes.
Phase 4: Design and Construction
Park Design and Construction
Nonprofit park developers are likely best suited to design and build neighborhood parks
and pocket parks, while conservancies and the City and County park departments are likely best
suited to develop regional parks and large open spaces.
Nonprofits have the time and resources to work closely with residents to design and effi-
ciently build small parks. Nonprofit park developers utilize a community design process that
involves community members in the process of selecting park features and amenities. This helps
create unique green spaces that serve community needs and foster community ownership of
parks. Additionally, given the funding sources available for park projects, nonprofits are often
able to secure funding for pocket and neighborhood parks in high need areas.
City and County park departments typically lack sufficient funding for new park developments,
but they are often competitive applicants for state funding. Additionally, their O&M responsibili-
ties account for a substantial amount of their capacity and resources, which can make it difficult
for them to design and build new, small parks. They can best support large, regional parks that
nonprofits are unlikely to build. Regional parks and open spaces are intended to serve large pop-
ulations, so they are often more expensive, requiring government resources and management.
In the case of open spaces, like nature preserves and trails, there may be few amenities.
While public participation is still important, larger public meetings are often more feasible than
small community design sessions given the number of residents these spaces serve. State con-
65 Community land trusts are being developed in a number of park-poor communities and may also be able to be partners in
joint development efforts.
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servancies typically have large budgets for conservation and preservation projects, which they
can use to make these open spaces accessible to the public for recreation and physical activ-
ity. State conservancies are typically able to rent their facilities for special events to generate
revenue for O&M. They may also be able to lease portions of large parcels to other entities for
affordable housing development, and lease revenue could be used to fund open space O&M.
Housing Construction
Affordable housing developers seem to be best suited to build small-scale, specialized afford-
able housing developments, such as permanent supportive housing and buildings with enhanced
social services, as well as low- and very low-income housing, housing for veterans, and tempo-
rary/emergency housing and shelters. The City and County housing agencies can support projects
undertaken by affordable housing developers by providing funding and helping secure land. They
may also be well suited to build a large-scale affordable housing development on land owned by
a State Conservancy, but an experienced affordable housing developer could fill this role as well.
Phase 5: Operations and Maintenance
Arguably, none of the entities have sufficient resources or capacity to maintain and operate
parks and open spaces, but State Conservancies and the City and County park departments are
likely best suited to do so given their available funding for ongoing O&M. Government park
entities provide stability. Nonprofits may not be able to secure O&M funding, or they could close
down, but government park entities remain constant, even as their budgets wax and wane. In
some cases, O&M is handled by conservation corps, which can play a unique and valuable role
in park maintenance, while also creating job-training opportunities.66
66 The California Conservation Corps, Los Angeles Conservation Corps, and Conservation Corps of Long Beach all train corps
members to work on natural resource and conservation projects, such as park construction and improvements, tree
planting, and trail development and maintenance. The Conservation Corps provides job training for corps members and
affordable labor for city, county, and nonprofit projects.
AFFORDABLE HOUSING CONSTRUCTION SITE PHOTO BY DANIEL MELLING
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Strengths
Phase 1:
Funder
Phase
2:
Land
Phase 3:
Community
Engagement
Phase 4:
Housing
Design and
Construction
Phase 4:
Park
Design and
Construction
Phase 5:
O&M
HCD X
CNRA X
State
Conservancy X X
LACDA X X
DPR X X X X
HACLA X X
LAHD X
RAP X X X
Affordable
Housing
Developer
X X X X*
Nonprofit
Park
Developer
X X X*
Foundations X
*While these types of developers may occasionally provide O&M, it is not typical or preferable.
Developing Successful Partnerships for
Joint Development Projects
Increasing the scale of joint development projects in Los Angeles will involve all of the entities
discussed above, and as discussed, some entities are better suited to play certain roles or build spe-
cific types of projects.
Efficient partnerships that utilize each entity’s strengths can produce more successful proj-
ects. Based on analysis and interviews with stakeholders, the following partnership combina-
tions show the most promise:
Government Housing Agency + Government Park Agency
A government-government partnership may be efficient because all of the agencies will be
on the same team. Such a partnership may be particularly successful if an elected official is
championing the project. For example, a State Conservancy could partner with LACDA or
HACLA to build and maintain a large or regional open space and one large and/or several mid-
sized affordable housing developments. The State Conservancies, relying on state funding
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and ground lease revenue, already acquire and maintain many acres of green space, while
LACDA and HACLA can utilize federal, state, and local funding to build and operate public
housing. A local government could also undertake this type of development. A city or county
housing agency could acquire land or utilize a parcel of surplus land. Then the housing agency
could enter into an agreement with the parks agency regarding which entity would develop
and manage the land; this would likely be the parks agency.
Government Housing Agency + Government Park Agency +
Aordable Housing Developer + Nonprofit Park Developer
This type of partnership would be particularly effective when a city or county agency owns
land and wants to build a development that includes a publicly-accessible park but lacks
the resources or capacity to design and build out the space. The city or county housing
agency could acquire land or utilize a parcel of surplus land and dedicate a portion of the
land as park space. Then the city or county housing agency could partner with an affordable
housing developer to build affordable housing. The city or county park department could
partner with a nonprofit park developer, who receives state or county funding, to design
and build a small park. The city or county parks agency would own, operate, and maintain
the park site, and the city or county housing agency or the affordable housing developer
could own, operate, and maintain the housing development.
Aordable Housing Developer + Parks Nonprofit
This partnership would likely be most effective when dealing with small sites in low-income
communities of color that are susceptible to gentrification or where community members
are concerned about displacement. In this case, either the parks or housing organization
could acquire a small plot of land. The parks organization could lease part of the land to the
housing organization, or the housing organization could subdivide the property and sell or
dedicate it to a nonprofit park developer to build a park or community garden on the site.
The park organization could own, operate, and maintain the park site, while the affordable
housing developer could own and operate the housing site.
Case Studies
The following case studies highlight three approaches to joint development: 1) Infill Devel-
opment and On-site Greening; 2) Neighborhood Transformation Scattered Site Approach; and
3) Transformative Infrastructure with Affordable Housing and Anti-Displacement Strategy.67
While these projects are beneficial and illustrative, they do not include a sizable public park that
will provide recreation and physical activity opportunities for the community. Additionally, Isla
Intersections is still being developed, and the L.A. River Revitalization is only in the planning
stages. Despite these drawbacks, these projects are promising models of joint development
projects, and they provide insights into how other developers can conceptualize and construct
joint development projects.
67 Yee et al, supra note 26.
Efficient partnerships
that utilize each entity’s
strengths can produce
more successful projects.
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Infill Development and On-site Greening:
Cliord Beers Housing, Isla Intersections
Located in South Los Angeles near the 105 and 110 freeway interchange, Isla Intersection is
a 54-unit affordable housing project that opens onto a paseo, a public shared street, and open
space. The project was co-developed by two nonprofits focused on housing for unhoused and
low-income communities: Clifford Beers Housing and American Family Housing. The project
includes one manager’s unit and 53 one-bedroom units for formerly unhoused households,
including 10 units reserved for unhoused veterans.68
The site is owned by the City of Los Angeles. LAHD and the City Administrative Officer orga-
nized a Request for Proposals for an affordable housing development. Clifford Beers submitted
the winning bid and was awarded a ground lease by LAHD.
The developers’ inspiration to add green space to their proposal derived from limitations
of the Isla Intersections site. Located in proximity to major freeways, the site had triangular
dimensions and overlapped with a public street, which served as a right-turn lane onto a major
intersection. By orienting the housing units to minimize noise and air pollution and re-design-
ing the slip lane to reduce dangerous vehicle speeds, the developers’ solution is designed to
improve quality of life for occupants and add new green space for the community. The tree-
lined, shaded paseo is open to the public 24 hours a day as a public right of way. To improve
air quality, the shared street includes a wall of trees and shrubs and vines that act as a “living
lung.” Anticipated public programming for the paseo includes street fairs, pop-up markets, and
farm stands that would connect the project’s edible gardens with the nearby Stanford Avalon
Community Garden, a nine-acre urban farm located one mile east of the project. Additional
private green space for residents includes rooftop terraces, community gardens, and an outdoor
ISLA INTERSECTIONS PHOTO BY DANIEL MELLING
68 Clifford Beers, Isla Intersections, https://cbhousing.org/communities/isla-intersections/.
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courtyard. A greywater cistern system captures water to feed plants onsite. The development
provides residents proximity to rail and bus, with the Metro Green Line and 120 and 45 bus
lines within walking distance. Additionally, a sizeable vacant Caltrans parcel across the street
could be acquired and developed into adjacent parkland. This additional acquisition and devel-
opment, either by the City or a nonprofit park developer, could provide critical parkland for
residents of Isla Intersections and neighboring buildings, aligning with an off-site greening or
scattered site joint development approach.
To minimize construction costs, the developers pre-built apartment units from shipping
containers. The container model also allows the developers to position units exactly to lot and
setback lines, maximizing the number of housing units and available open space. The develop-
ers’ container construction model and paseo proposal won the support of the local City Council
office, which helped coordinate private foundation funding for the green space.
Like other affordable housing developers, Clifford Beers coordinated a variety of funding
sources to finance the project, including government agencies, government bond funds, bank
loans, and corporate and family foundations. Grants and subsidies contributed to different
aspects of the development and operations of the project. For example, construction costs
were financed by tax credits, bonds, Measure HHH loan funds, and the Home Depot Foundation
and Annenberg Foundation, alongside construction loans from Key Bank and predevelopment
loans from the Corporation for Supportive Housing and Genesis LA Economic Growth Corpo-
ration. Rental subsidies for tenants are provided by Section 8 and Veteran Affairs Supportive
Housing vouchers from the Housing Authority of the City of Los Angeles.
Isla Intersections is still under construction, and thus the impacts on the community remain
unknown. However, the inclusion of urban greening and green infrastructure elements is
encouraging. Going forward, other developers could adopt and expand upon this model by
including public park space or sizeable greenspace onsite that residents can use for recreation
and physical activity.
INTERSECTION NEAR ISLA INTERSECTIONS DEVELOPMENT PHOTO BY DANIEL MELLING
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Neighborhood Transformation Scattered Site
Approach: Sustainable Little Tokyo
The emergence of the Sustainable Little Tokyo community initiative in the early 2010s pre-
ceded the concept of joint development, yet it serves as a useful example of the benefits of
a neighborhood-scale development pattern driven by community engagement. Little Tokyo,
located just east of Downtown Los Angeles, has survived as a center of Japanese American
community and culture for more than 130 years, including through the unjust incarceration
and internment of Japanese American residents during World War II,69 and city policies, like the
planned expansion of the Civic Center,70 that often threaten its residents’ autonomy. For over
a decade, a combination of grassroots organizations, public agencies, and developers have
banded together to preserve the neighborhood’s historic culture, while expanding the neigh-
borhood’s green footprint and affordable housing opportunities. Little Tokyo now stands as a
model for joint development of green space and affordable housing.
Little Tokyo has several buildings with affordable housing, including the Far East Build-
ing—a historic building with 16 affordable housing units and two commercial storefronts71—
and the San Pedro Firm Building, which was once threatened with demolition by the City and
now contains 42 affordable units.72 Casa Heiwa provides an additional 100 units of affordable
housing for both seniors and young families.73
JAPANESE GARDEN IN LITTLE TOKYO PHOTO BY DANIEL MELLIING
69 Kenji Liu, How Little Tokyo, Los Angeles is Approaching Community-Led Recovery Through Arts and Culture, in
Placemaking Postcards, Brookings, May 19, 2020, https://www.brookings.edu/blog/the-avenue/2020/05/19/
how-little-tokyo-los-angeles-is-approaching-community-led-recovery-through-arts-and-culture/.
70 Kelly Simpson, Three Waves of Little Tokyo Redevelopment, KCET, July 31, 2012, https://www.kcet.org/shows/departures/
three-waves-of-little-tokyo-redevelopment.
71 Little Tokyo Service Center, Little Tokyo Projects, https://www.ltsc.org/building-affordable-housing/.
72 Id.
73 Id.
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There are several publicly-accessible green spaces in Little Tokyo. For instance, Budokan
of Los Angeles is a multipurpose recreational facility with a rooftop park. The award-winning
James Irvine Japanese Garden features a 170-foot stream, waterfall, trees, and foliage and sits
0.2 miles from the San Pedro Firm Building. Casa Heiwa is a 2-minute walk from the garden.
Another community-led initiative, the Azusa Street Pathway project, has worked to convert a
local alleyway into a parklet and community gathering space.74
The joint development of green space and affordable housing in Little Tokyo is largely
the result of organized community groups, such as Little Tokyo Service Center75 and Sustain-
able Little Tokyo, an initiative encompassing more than 100 community organizations. The
California Department of Housing and Community Development, the Getty Foundation, and
the Federal Home Loan Bank have also supported housing developments, including the Far
East Building.
There are also opportunities for new joint development projects in Little Tokyo. These
include First Street North; the Mangrove block; and the Metro Regional Connector station
site, which is slated to become the City’s second-busiest transit stop.76 They are the last pub-
licly-owned parcels in Little Tokyo. After engagement with the community, the Little Tokyo
Community Council approved a community-oriented plan for First Street North that empha-
sized mixed-use buildings and affordable housing while preserving green open space in
2016. What happens to each stretch of land could further solidify Little Tokyo’s leadership in
joint development.
PUBLIC PLAZA IN LITTLE TOKYO NEAR JAPANESE GARDEN PHOTO BY DANIEL MELLING
74 Sustainable Little Tokyo, Azusa Street Improvements, http://sustainablelittletokyo.org/projects/azusa.
75 Little Tokyo Service Center, Strengthening Little Tokyo, https://www.ltsc.org/strengthening-little-tokyo/.
76 https://www.latimes.com/local/la-me-0316-little-tokyo-history-20140316-story.html (New Metro station in Little Tokyo will
connect the Blue and Gold lines).
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Transformative Infrastructure with Aordable
Housing and Anti-Displacement Strategy:
L.A. River Revitalization
The revitalization of the 51-mile L.A. River is a multi-agency and multi-jurisdictional effort
that presents a significant opportunity for joint development. The revitalization could expand
green space for the more than one million residents who live within a mile of the River, but the
projects’ affordable housing benefits are less defined. Currently, 56 major projects are underway
along the River, including the eight-mile L.A. River Path, led by L.A. Metro, that would connect
existing bike and pedestrian paths from the San Fernando Valley to Long Beach. The Draft 2020
L.A. River Master Plan identifies an additional 22 sites for major projects and 208 sites for smaller
infrastructure improvements.77 For many community leaders and officials, plans to revitalize the
River also present opportunities and risks for ensuring access to affordable housing and green
space for low-income communities of color.
The Draft Master Plan was released in 2021 and is currently being reviewed by relevant
agencies. The Draft Master Plan provides a vision for connected public open space along the
River and includes maps of sites where projects such as parks and water storage might be built.
It also includes a menu of design ideas for communities to implement projects, including river
access points, bridges, pavilions, benches, and biodiversity habitat.
PARK NEAR ENTRANCE TO LA RIVER PATH PHOTO BY DANIEL MELLING
77 Hayley Munguia, Los Angeles County releases draft plan to reimagine all 51 miles of the
LA River, Los Angeles Daily News (Jan. 13, 2021), https://www.dailynews.com/2021/01/13/
los-angeles-county-releases-draft-plan-to-reimagine-all-51-miles-of-the-la-river/.
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Among its main goals, the plan intends to “address potential adverse impacts to housing
affordability and people experiencing homelessness.” This emphasis on affordable housing
reflects longstanding community concerns about disparities in access to public parks and
increasing costs of housing. Community voices have expressed concerns about “green gen-
trification,”78 and community organizers and activists have offered suggestions for how local
officials can support affordable housing along the River. Some of the suggestions include
a land bank to acquire land for development, funds for housing construction, rent control
measures, inclusionary zoning, and support for home buyers’ clubs that subsidize down
payments and provide low-interest loans.79 Advocates point to anti-displacement policies
that County Supervisors adopted as part of guidelines for the implementation of Measure
A. The City of L.A.’s 2016 ballot measure, Measure JJJ, requires affordable housing in proj-
ects seeking significant discretionary approvals from the City. The Measure authorized the
creation of the TOC Program to provide density bonuses for projects including affordable
housing near major transit.80
The draft Master Plan suggests the County could create a land bank or similar entity to make
land purchases along the River to hold for eventual sale or lease to affordable housing devel-
opers. Other affordable housing proposals in the plan include: providing resources for tenant
protections, education, and counseling; identifying funding and land for land banks and direct
acquisition of land for affordable housing; expanding the Los Angeles County Community
Development Authority’s Home Ownership Program, which provides loans for down payments
to low-income households; identifying communities at risk of displacement; and requiring large
L.A. County projects to include housing assessments.
Several proposed and ongoing L.A. River projects will provide access to green space and
affordable housing. One example is Taylor Yard, a retired railyard in Los Angeles that consists of
several parcels owned or managed by city, county, state, and private interests. L.A. Metro owns
portions of the area, and it has issued ground leases to redevelop the land for housing and
green space. A for-profit developer of affordable housing built 305 affordable units across four
projects, drawing on predevelopment financing from Enterprise Foundation, New Economics
for Women, and a $15 million grant from the State’s Infill Infrastructure Grant Program.81 The
City of Los Angeles has led a community consultation process for revitalization of the 42-acre G2
parcel, a riverfront property with pieces owned by both the City and the Mountains Recreation
& Conservation Authority.82
The revitalization of the L.A. River presents an important opportunity to increase access to
green space and affordable housing in the City and County of Los Angeles. This opportunity
should be taken seriously, and it is critical to ensure that projects serve low-income communi-
ties of color and do not contribute to displacement.
78 Comment Letter from Public Counsel & SEACA, LA River Recommendations (Mar. 10, 2017), http://clkrep.lacity.org/
onlinedocs/2014/14-1349_misc_3-10-2017.pdf.
79 Jon Christensen, How to make sure the L.A. River Master Plan fulfills its promise to Gateway
Cities, Los Angeles Times (Feb. 21, 2021), https://www.latimes.com/opinion/story/2021-02-21/
los-angeles-river-master-plan-gateway-cities-frank-gehry-gentrification-equitable-development.
80 Damon Nagami, Planning for Equitable Development Along the LA River, NRDC (Jul. 23, 2019), https://www.nrdc.org/experts/
damon-nagami/planning-equitable-development-along-river.
81 McCormack Baron Salazar, Taylor Yard, https://www.mccormackbaron.com/community-profiles/taylor-yard.
82 City of Los Angeles Engineering, Taylor Yard G2 River Park Project Final Draft Implementation Feasibility Report, https://
tayloryardriverprojects.lacity.org/projects/taylor-yard-g2-river-park-project-final-draft-implementation-feasibility-report-ifr.
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Recommendations
Much can be done to boost parks and affordable housing joint development projects in
Los Angeles. These recommendations, if adopted by key government, affordable housing, and
nonprofit park entities, would standardize and streamline the development process. While
joint development projects require coordination and may be subject to additional govern-
ment approvals, the core work—building parks and affordable housing—fits squarely within
the wheelhouses of government agencies, affordable housing developers, and nonprofit park
developers. The goal is to coordinate existing efforts to produce greater social and environmen-
tal benefits, while using limited resources more efficiently. These policy changes can help make
joint development projects much more common.
The following recommendations are designed to improve funding opportunities for joint
development projects, encourage community engagement, and ensure long-term support for
operations and maintenance.
1.Update government approval processes and increase
funding for joint development projects
From grant programs to development permits, many government processes are not set up
to facilitate multi-benefit projects. These proposed solutions would reward multi-benefit
projects for all of the benefits they provide, while proposing criteria to help decision makers
choose wisely among them.
While joint development
projects require
coordination and may
be subject to additional
government approvals,
the core work—building
parks and affordable
housing—fits squarely
within the wheelhouses
of government
agencies, affordable
housing developers,
and nonprofit park
developers. The
goal is to coordinate
existing efforts to
produce greater social
and environmental
benefits, while using
limited resources more
efficiently.
PUBLIC MEETING TO ADOPT AN IMPLEMENTATION ORDINANCE FOR A MULTIBENEFIT FUNDING MEASURE.
PHOTO BY BETH KENT
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Create a stable, long-term source of State funding for programs that
support joint development: With funding from the Greenhouse Gas Reduction
Fund (GGRF) potentially expiring in 2030, it is important to create a funding source for
State programs that can support joint development, including the Urban Greening and
Affordable Housing Sustainable Communities programs. The State Legislature could
introduce legislation to extend the GGRF program, either by extending California’s cap-
and-trade program or by designating a new funding source, such as a tax on pollut-
ing industries. Alternatively, funding for these programs could be secured through the
budget process. New legislation that removes barriers to funding for both parks and
affordable housing developments by allowing both types of developers to be eligible
for funding for joint development projects, as well as separate parks and affordable
housing funding, would also be needed.
Streamline and update funding application processes to prioritize
joint development projects:A holistic approach to funding multi-benefit proj-
ects—one that considers how all the pieces fit together—could help secure funding
for the whole project, while prioritizing funding for projects that provide the most
benefits. Most grant and loan programs have a narrow focus and funding caps, requir-
ing developers to secure funding from multiple sources. This can create funding gaps.
For example, a multi-benefit project may have a very competitive housing component
and secure funding from the California Department of Housing and Community Devel-
opment, but not receive funding from the California Natural Resources Agency for its
small urban greening project to the detriment of the residents of the development who
may not have any other access to green space. Alternatively, a project could have a very
strong greening component that is awarded funding, but if it cannot secure funding for
the housing development, the entire project could get scrapped.
A universal or common application could help address this problem by noti-
fying all State agencies of a project’s components and encouraging the agencies to
work together and coordinate grant awards. At the State level, the California Natural
Resources Agency, Strategic Growth Council, the Department of Housing and Com-
munity Development, and other administering agencies should consider creating a
universal or common application for all programs that address parks and affordable
housing, including the GGRF grant programs and/or other state grant programs. If an
application that covers all GGRF programs is too cumbersome, the California Natural
Resources Agency, Strategic Growth Council, and the Department of Housing and
Community Development could create a pilot universal application for the Statewide
Parks Program, Urban Greening, Affordable Housing Sustainable Communities, Hous-
ing-Related Parks, and HOME programs. The agencies could coordinate or sequence
their application deadlines and review timelines to create predictability, reduce time
delays, and further streamline application processes.
In L.A., the City and County could also revise their grant and loan application pro-
cesses to recognize and reward multi-benefit projects. This could be as simple as a top
sheet or form that describes the different aspects of the project and identifies the various
City/County funding sources the applicants plan to apply for. The City and County could
each convene a multi-department application review committee for joint development
projects that could meet quarterly or biannually to make funding decisions.
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Award additional points for additional benefits: Building on the concept
that the whole of a joint development project is greater than the sum of its parts, agencies
should award additional points for each project component or benefit and for partnerships.
A group of nonprofits that wants to build affordable housing with supportive services near
transit with on-site, publicly-accessible green space and storm water infrastructure should
be competitive. One way to ensure applications like this rise to the top is by revising grant
criteria to award additional points for these benefits and partnerships.
For new funding programs, an agency would need to include criteria that awards
additional points for joint development projects in its grant guidelines. For existing pro-
grams, each state or local agency that administers a parks or affordable housing grant or
loan program would need to amend its program guidelines to award additional points
for joint development projects. This could be as simple as adding language that says, “X
additional points will be awarded for projects that include at least one of the following
elements from each category: 1) public open space, green space, trees, recreation ame-
nities, or a community garden and 2) low-income, multi-family, or permanent supportive
affordable housing.” Agencies could incentivize and reward partnerships by including lan-
guage stating, “One point will be awarded for each non-profit, government, or affordable
housing developer project partner.” Most agencies are permitted to propose changes to
grant guidelines and make proposed changes available for public comment, periodically.
If any agency is unable to amend its program guidelines, new legislation or a legislative
amendment to the statute that created the grant or loan program may be required.
The California Tax Credit Allocation Committee could also amend its criteria for
awarding low-income housing tax credits to award points for green space or park
co-development. Given how competitive and valuable these credits are, developers
strive to maximize the points they receive on their applications. This change would
incentive the inclusion of green space in new affordable housing projects.
METAMORPHOSIS ON FOOTHILL AFFORDABLE HOUSING AND OPEN SPACE FOR RESIDENTS
PHOTO BY CLIFFORD BEERS HOUSING
Building on the concept
that the whole of a
joint development
project is greater than
the sum of its parts,
agencies should award
additional points for
each project component
or benefit and for
partnerships.
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2.Create and acquire sites for joint development projects
Given L.A.’s competitive real estate market, parks and affordable housing developers may
need to get creative and look beyond market-rate property. These proposed recommen-
dations encourage development on existing affordable housing sites, parks, and public
lands; utilization of surplus land; and the creation of new policies to support green space
development.
Develop a “Parks at Affordable Housing” pilot program:Using the City’s
Community School Parks “25 by 25” program as a model, the City and County park
departments could each establish a pilot program for developing parks on and adja-
cent to new and existing affordable housing development sites. Under the program,
the City and County could notify affordable housing developers of City- and Coun-
ty-owned prospective park sites that are suitable for joint development. The City or
County could own the land and develop an on-site park, while the affordable housing
developer could apply to lease a portion of the site for housing. Additionally, the City
and County could create a process for affordable housing developers to submit project
proposals for park and green space development that the City or County could then
develop on or near existing affordable housing developments.
Strengthen the Surplus Land Act and maximize the use of surplus
land: Vacant or underutilized lots are missed opportunities, but in its current form,
the Surplus Land Act does not do enough to prioritize affordable housing or park devel-
opment. HCD is working on guidelines related to the Act’s new affordable housing
requirements, but even with the amendments to the statute and forthcoming rec-
ommendations for implementing the amendments, it appears that local jurisdictions
will be able to sell surplus land to the highest bidder. Additional amendments, such as
requiring a right of first refusal for affordable housing developers, could ensure surplus
land is used for parks, affordable housing, or joint development projects.
Absent new legislation, there may still be opportunities for local governments to
support the use of surplus land for joint development projects. Local governments can
assess their public land holdings and identify which parcels are vacant and/or underuti-
lized. Government agencies can then choose to pursue their own joint development or
multi-benefit projects on these parcels or dispose of them by selling them to affordable
housing and nonprofit park developers. Local governments could utilize local surplus
land disposal processes, the Surplus Land Act, or a Request for Proposals process to sell
or lease City/County-owned land to nonprofits for joint development.
The City and County of Los Angeles could also expand the Free Lots Angeles’s
Adopt-A-Lot, a collaborative initiative supported by the City that provides communi-
ty-based organizations with opportunities to activate and steward vacant lots.83 Past
Adopt-A-Lot projects have provided access to green space, outdoor recreation, exercise
opportunities, and gathering places for underserved communities.
Given L.A.’s competitive
real estate market,
parks and affordable
housing developers
may need to get
creative and look
beyond market-rate
property.
83 Free Lots Angeles, Inclusive Action for the City, https://www.inclusiveaction.org/free-lots-angeles.
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Create a green space overlay zone: Using transit-oriented development incen-
tives as a model, the City could adopt an ordinance creating a park overlay zone in high
and very high park need areas. The overlay zone could provide density bonuses, reduced
parking requirements, and other development incentives for housing development proj-
ects that include publicly-accessible green space and affordable housing and for com-
mercial development projects that include publicly-accessible green space.
Build joint development projects on public school campuses: There is an
ongoing effort in Los Angeles to build community school parks on Los Angeles Unified School
District (LAUSD) public school campuses. Community school parks are green spaces that are
only open to students during school hours, but are open to the public after school hours, in
the evenings, and on weekends and school holidays.84 In L.A., these efforts have been delayed,
largely by bureaucratic processes within LAUSD, as well as concerns about liability. However,
there is a precedent for community school parks or shared use on school campuses in California;
San Francisco’s Shared Schoolyard Program brings together the City and County of San Fran-
cisco, San Francisco Unified School District, and community partners to make school campuses
accessible to community members for recreation on the weekends.85
Public school campuses are particularly well suited for park development because
they are well-known and frequently used sites that are evenly distributed throughout
Los Angeles. Children love parks and need them for physical and recreational activi-
ties, and by putting them on school campuses, children can use them during and after
school hours. Replacing blacktop playgrounds with green space mitigates the urban heat
island effect, making it safer and more comfortable for children to play outside during
the summer months. LAUSD also offers affordable housing for income-qualified school
employees, mostly custodial staff, on a few of its campuses.86
Existing school housing and community school park efforts could be combined and
expanded to create greater access to both resources. This type of joint development
would be extremely valuable because it would create access to green space for a large
group of park users, while providing affordable housing for school employees and other
income-qualified individuals, such as low-income families with LAUSD students. These
families may have difficulty finding housing near schools in more affluent neighborhoods
but may not be eligible for low-income housing programs. Building parks on school cam-
puses reduces the need for land acquisition for new park development. This is a cost-ef-
fective solution, and it allows limited vacant lots to be used for affordable housing and
other community uses, such as local businesses.
Making progress on this proposal will require overcoming opposition within LAUSD and
streamlining the District’s cumbersome bureaucratic processes. LAUSD School Board members
could serve a critical role in garnering support within the District, because the LAUSD Board
has the authority to permit community school parks and shared use. Absent that support, state
action may be beneficial. The California Department of Education could amend its guidelines to
require or allow for more school greening. Legislation that removes liability for school districts
that make campuses open for public recreation under certain conditions could also be beneficial.
84 The Trust for Public Land (2021), Green Schoolyards for Los Angeles, https://www.tpl.org/wp-content/uploads/2022/09/
Green-schoolyards-for-Los-Angeles-A-Trust-for-Public-Land-special-report.pdf.
85 SFSU, Shared Schoolyard Program, https://www.sfusd.edu/sharedschoolyard.
86 LAUSD Facilities Services Division, Los Angeles Unified Launches Effort To Provide Affordable Housing for Teachers
and Staff, https://achieve.lausd.net/site/Default.aspx?PageType=3&DomainID=4&PageID=1&ViewID=644
6ee88-d30c-497e-9316-3f8874b3e108&FlexDataID=107017.
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3. Improve stakeholder coordination and community engagement
Joint development projects tend to be complex and resource intensive. In order to ensure
the projects are built properly and are responsive to community needs, it will be important
to involve experienced stakeholders and engage community members.
Hire consultants with practical experience: Local agencies should hire non-
profit affordable housing and park developers as consultants to coordinate community
engagement and advise on joint development projects. By hiring nonprofit developers
to organize and oversee community engagement, local governments can strive to make
their community engagement processes more robust and inclusive. Many nonprofit
organizations have established trust with low-income communities of color, which can
elicit better public participation. Nonprofit organizations can also help design projects
that more meaningfully respond to public comments.
Hire interdepartmental liaisons: Employees who are hired or assigned to work
with the relevant housing and parks departments to oversee and support joint devel-
opment programs and projects could foster interdepartmental collaboration. Greater
collaboration across local agencies is needed to build more effective city- and county-
level partnerships. By hiring liaisons or assigning staff to serve in liaison positions, local
jurisdictions can begin to break down silos that prevent the construction of city- and
county-level joint development projects.
Establish city and county commissions/task forces on joint devel-
opment: These entities could convene public, private, and nonprofit stakeholders
and experts and invite them to provide guidance to the City and County. In addition
to assigning liaisons, the City and County can support joint development efforts by
creating commissions or task forces that bring together decision makers, experts, and
stakeholders and facilitate brainstorming and the sharing of ideas and best practices.
Joint development
projects tend to be
complex and resource
intensive. In order to
ensure the projects
are built properly
and are responsive to
community needs, it
will be important to
involve experienced
stakeholders and
engage community
members.
COMMUNITY DESIGN MEETING FOR PROP 68 GRANT APPLICATION. PHOTO BY BETH KENT
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4. Create sustainable, long-term sources of funding for
operations and maintenance
These recommendations are intended to create new sources of funding specifically for
O&M, which is often underfunded and excluded from many traditional funding sources.
Create a new California Special Interest License Plate for parks:
Using the California Coastal Commission and Environmental License Plate programs
as models, California State Parks could work with the Department of Motor Vehicles
to create a parks special interest license plate. A portion of fees would be donated to
State Parks and the funding could be earmarked for public park maintenance. State
Parks could then create a grant program to distribute funding to state conservancies,
local and nonprofit park entities, and affordable housing developers to cover opera-
tions and maintenance costs. License plate programs produce fairly modest funding.
For example, in 2019, the Coastal license plate generated $1.3 million for the California
Coastal Commission, while the Yosemite plate raised $637,000 for the park.87 However,
license plate programs are relatively inexpensive to administer and can create new
funding sources that are earmarked for a specific purpose. They may also be able to
raise awareness about the need for park operations and maintenance.
Create an “Adopt-A-Park” program: Similar to the Adopt-A-Highway program,
State Parks could create an Adopt-A-Park Program. Individuals and organizations could
either volunteer to clean up a park space or make a donation to State Parks that could be
used to cover park O&M.88 As with license plate programs, an Adopt-A-Park program would
likely raise only modest funds, but it would create a new and specific funding source for
O&M, which is chronically underfunded and often excluded from grant programs.
Amend California bond law:Amending current bond laws could allow a small
percentage of bond funding to be used to operate and maintain capital projects that are
funded by bonds. Any Member of the State Legislature could introduce new legislation
that expands the use of bond funding for operations and maintenance. New legislation
should aim to resolve the issues created by Proposition 68’s provision related to com-
munity access programs. The Department of Finance is likely to oppose such a bill, and
opponents may raise concerns about incurring long-term debt to finance temporary,
non-capital assets, such as programs and maintenance. However, ensuring that expen-
sive capital assets are well-maintained and can be used and enjoyed for decades can
protect the taxpayers’ investment and maximize the benefits for community members.
This recommendation is likely to be politically challenging to implement, but it is worth
researching further, particularly with a focus on how that law could be amended to
permit programs like Proposition 68’s community access program.
87 Cal. Dep’t of Motor Vehicles, Consolidated Specialized License Plate Programs Report, at 1, (2019), https://www.dmv.ca.gov/
portal/file/consolidated-specialized-license-plate-programs-report-2019-pdf/.
88 Ca. Dep’t of Transp., Adopt a Highway Sponsor FAQs, https://dot.ca.gov/-/media/dot-media/district-7/documents/sponsor-
faqs-6-3-10-a11y.pdf.
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Conclusion
Creating a more sustainable, equitable, and inclusive Los Angeles requires thinking stra-
tegically and creatively about how to use limited resources. Joint development projects that
combine green space and affordable housing on the same, adjacent, or nearby parcels can
advance environmental and public health goals, while protecting communities from displace-
ment and gentrification. By allocating funding for joint development projects, improving
systems to support these projects, utilizing public land more efficiently, and increasing collabo-
ration among the green space and housing sectors, government agencies and nonprofit organi-
zations can support the development of projects involving green space and affordable housing,
as well as the low-income communities of color that benefit from these projects.
WILMINGTON TOWNHOMES AFFORDABLE HOUSING DEVELOPMENT AND TOT LOT
PHOTO BY ABODE COMMUNITIES
This policy paper is the fifteenth of the Pritzker Environmental Law and Policy Briefs. The Pritzker Briefs are
published by UCLA School of Law and the Emmett Institute on Climate Change and the Environment in
conjunction with researchers from a wide range of academic disciplines and the broader environmental
law community. They are intended to provide expert analysis to further public dialogue on important issues
impacting the environment.
ABOUT THE AUTHOR
Beth Kent is an Emmett/Frankel Fellow in Environmental Law and Policy at UCLA School of Law. She was
previously the Policy and Legal Fellow at the Los Angeles Neighborhood Land Trust. Kent received her
B.S. with Honors in Society and Environment and High Distinction in the College of Natural Resources
from UC Berkeley. She earned her J.D. from UCLA School of Law with a specialization in Public Interest
Law and Policy from the Epstein Program. Kent was a summer law clerk at Earthjustice and the California
Office of the Attorney General in the Land Law Section and a legal extern at NRDC.
ACKNOWLEDGMENTS
The author wishes to thank her Emmett Institute colleagues Cara Horowitz and Julia Stein for their feedback
and support; Matthew Connor, Akif Khan, and Daniel Melling for their research support; Beth Escott
Newcomer for the graphic design; and the following individuals who agreed to be interviewed for this paper
and generously shared their time, knowledge, and insights: Naveen Agrawal, Lance Bocarsly, Alina Bokde,
Jon Christensen, Nicole Deddens, Darryl Ford, Cynthia Guzman, Joan Ling, Robin Mark, Damon Nagami,
Audrey Peterson, Lara Regus, Grant Sunoo, Walker Wells, and Natalie Zappella.
For more information, please contact kent@law.ucla.edu. The views expressed in this paper are those
of the author. All rights reserved.
ABOUT THE EMMETT INSTITUTE ON
CLIMATE CHANGE AND THE ENVIRONMENT
http://www.law.ucla.edu/emmett
The Emmett Institute on Climate Change and the Environment is the leading law school center focused
on climate change and other critical environmental issues. Founded in 2008 with a generous gift from
Dan A. Emmett and his family, the Institute works across disciplines to develop and promote research and
policy tools useful to decision makers locally, statewide, nationally, and beyond. Our Institute serves as a
premier source of environmental legal scholarship, nonpartisan expertise, policy analysis and training.
POLICY BRIEF NO. 15 | JANUARY 2023