Los Angeles County Proposes Job Creation Ban


Los Angeles County, the nation’s most populous, with 10 million residents according to the 2020 census, is proposing what could effectively ban job creation the unincorporated areas, where the County Board of Supervisors functions as a city council. More than one million people live in these areas

The job creation ban is not stated directly, but would result from the impossibility of meeting “performance objective”of the proposed Los Angeles County Climate Action Plan, which requires a job density of 300 jobs per acre by 2030. Such a job density is well above anything that can be practically achieved. Overall, the Los Angeles urban area (which excludes rural areas, such as the San Gabriel Mountains and undeveloped desert land) has about 6 jobs per acre (Note). With the recently released California Department of Finance projection that Los Angeles County will lose 17% of its population by 2060 (dropping to 8.3 million), job densities are likely to fall as well.

The Impractical 300 Jobs per Acre Objective

To evaluate the practicality of the 300 job per acre objective, I used data from the a special tabulation of the American Community Survey for 2012-2016 prepared for the Census Transportation Planning Program (https://ctpp.transportation.org/), a cooperative project of the Census Bureau, and the (American Association of Highway and Transportation Officials). Among the nation’s 74,134 census tracts (small area data collection districts) in the United States, only 74 had an employment density of 300 per acre or more. This is 0.1% of the census tracts.

Employment densities of 300 per acre existed in only in small parts of the largest and densest downtown areas. Among the 74 census tracts with employment densities of at least 300 per acre, 55 are in New York City (52 in Manhattan and 3 in Brooklyn), 5 in Chicago, 4 in Philadelphia, 3 in Boston and Washington, DC, 2 in San Francisco and one in Honolulu. None are in Los Angeles County! The total land area of these 74 census tracts is small – less than seven square miles, small enough to fit within the boundaries of the East Los Angeles CDP, including open space two thirds the size of New York’s Central Park.

Moreover, these job densities are likely far lower today, due to the near tripling of working from home between 2019 and 2022. Among these downtowns (no data for Honolulu), cell phone activity was reported by to be 47% on average lower in 2023 than in 2019, according to the University of Toronto School of Cities program. At this rate, only 33 of the census tracts would have a job density of 300 or more per acre.

As mentioned above, no census tract in Los Angeles County with a job density of 300 per acre. The closest is the tract in downtown Los Angeles bounded by Second Street on the north, Hill Street on the East, 5th Street on the south and the Harbor Freeway on the west. This census tract had fewer than 270 jobs per acre in 2012-2016.This census tract includes buildings such as the U.S. Bank Tower, which was the tallest in California in 2012-2016, Two California Plaza, the Gas Company Tower, the Wells Fargo Tower, the Bank of America Plaza. 444 Flower, and the KPMG Tower. These buildings include seven of downtown’s 12 tallest operating office buildings in 2012-2016.This excludes the “long empty” 611 Place, which had been the city’s tallest building from 1969 to 1972 (See top photograph).

Similar to the case in other downtown Los Angeles (above), cell phone activity in downtown Los Angeles has fallen 39% in 2023 compared to 2019. This would suggest the job density could have fallen to about 160 per acre, little more than half the 300 per acre objective in the County's densest job density census tract.

Simply put, the proposed 300 per acre job density objective is not practically achievable.

East Los Angeles and Other Unincorporated Communities

East Los Angeles, located just to the east of downtown, stands to lose the most if this proposal is adopted. East Los Angeles is the largest “census designated place” (CDP) in Los Angeles County, which is census-speak for an area of urbanization that is not within an incorporated city or town.

East Los Angeles had a population of 119,000, according to the 2020 Census. Covering an area of 7.45 square miles. East Los Angeles has a population density of 16,000 residents per square mile, nearly double that of the city of Los Angeles. According to the 2020 Census, 96.2% of East Los Angeles residents are Hispanic. Among “places” (incorporated and unincorporated) with more than 50,000 residents, East Los Angeles has the second highest Hispanic percentage in the nation, behind nearby Huntington Park.

Poverty in East Los Angeles is substantial. The just released 2022 American Community Survey shows East Los Angeles to have a non-cost adjusted poverty rate of 19.3 percent, 53 percent above the national rate of 12.6 percent. East Los Angeles needs jobs, not a jobs ban.

For example, a new manufacturing plant would require a “conditional use permit” from the County to ensure that its land use characteristics is “compatible with surrounding land use” and the County General Plan. Unless the application demonstrated a 300 per acre job density or higher, the permit would likely be denied, or if approved, would likely fail the virtually certain legal challenge on the basis of its inconsistency with the 300 per acre objective. The bottom line is that the new jobs would not be created because the manufacturing plant would not open.

Another plant may seek to move to a new location in East Los Angeles, to accommodate business expansion that would require an increase in the number of employees. This would also require a conditional use permit. The same fate would likely await the expansion, the job creation would be denied. The plant might find a more rational regulatory environment in another location, such as in Vernon or the City of Commerce, the Inland Empire or perhaps out of state.

The problem goes far beyond East Los Angeles. There are more than 100 other areas under the jurisdiction of Los Angeles County.The Florence-Graham CDP has a population of 61,000, located in South Los Angeles, stretching from Slauson Avenue to Century Blvd and Central Avenue to Alameda St. Hacienda Heights and South Whittier CDPs have more than 50,000 residents, while, 27 other CDPs had at least 10,000 residents, according to the 2020 Census. In all, there are more than 120 other communities under the direct jurisdiction of Los Angeles County. The same virtual job creation ban could apply in each.

Effectively Banning Job Creation

It is highly unlikely that any job creation project that requires County approval can satisfy the 300 employees per acre performance objective. The performance objective is absurd and its effect is likely to be a ban on job creation.

Note: Employment density estimated using the ratio of employment to population in the Los Angeles urban area.(2020).

Wendell Cox is principal of Demographia, an international public policy firm located in the St. Louis metropolitan area. He is a founding senior fellow at the Urban Reform Institute, Houston, a Senior Fellow with the Frontier Centre for Public Policy in Winnipeg and a member of the Advisory Board of the Center for Demographics and Policy at Chapman University in Orange, California. He has served as a visiting professor at the Conservatoire National des Arts et Metiers in Paris. His principal interests are economics, poverty alleviation, demographics, urban policy and transport. He is co-author of the annual Demographia International Housing Affordability Survey and author of Demographia World Urban Areas.

Mayor Tom Bradley appointed him to three terms on the Los Angeles County Transportation Commission (1977-1985) and Speaker of the House Newt Gingrich appointed him to the Amtrak Reform Council, to complete the unexpired term of New Jersey Governor Christine Todd Whitman (1999-2002). He is author of War on the Dream: How Anti-Sprawl Policy Threatens the Quality of Life and Toward More Prosperous Cities: A Framing Essay on Urban Areas, Transport, Planning and the Dimensions of Sustainability.

Photo: Bunker Hill, Downtown Los Angeles, by Joshua Goodman via Flickr under CC 2.0 License. This area is not dense enough for employment in East Los Angeles and other unincorporated areas per the proposed Los Angeles County Climate Action Plan. Tall buildings from the left: 444 Flower, First Interstate Tower, Gas Company Tower, KPMG Tower (partially hidden by a telecommunications tower), Wells Fargo Tower, Two California Plaza. The census tract job density was approximately 270 per acre in 2012-2016, though is probably considerably less now with so many more people working from home.

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Are such "Climate Action Plans" being adopted in other jurisdictions? This obviously seems to have significant implications. Is it receiving coverage from the Los Angeles Times?