University of Southern California Dissertations and Theses

The social construction of brownfields

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The social construction of brownfields

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THE SOCIAL CONSTRUCTION OF BROWNFIELDS

by

Carol S. Armstrong

A Dissertation Presented to the
FACULTY OF THE GRADUATE SCHOOL
UNIVERSITY OF SOUTHERN CALIFORNIA
In Partial Fulfillment of the
Requirements for the Degree
DOCTOR OF PHILOSOPHY
(PLANNING)

May 2007

Copyright 2007 Carol S. Armstrong

ii
Dedication
For my twister, Carey, who has been there from the very beginning…
thank you for everything; march forth!

iii
Acknowledgements
I am grateful for the insight and assistance of many individuals including first and
foremost my advisor, Dr. Niraj Verma, who never gave up on me even though I
struggled and stalled many times, and to my dissertation committee for guiding me
throughout: Dr. Tridib Banerjee, Dr. Joe Devinny, Dr. Harry Richardson, and Dr.
Dan Mazmanian. I also could never have finished without the loving support of my
parents, Jack and Alice Armstrong, and the invaluable morale-boosting assistance of
my sisters, Kim and Carey, my brother, Joe, and their families. I am indebted to the
U.S. Small Business Administration for recognizing something worthwhile in my
proposal, which gave me the much-needed financial resources to get started. I credit
the City of Los Angeles Environmental Affairs Department with giving me the
professional outlet to explore my research ideas. Finally, I wish to thank my many
friends, including Lenore, Courtney, Juli, Julia, Concetta, Greg, Iris, the Peace Corps
gals, and the Book Club crew, who never let me quit. Fight On!

iv
Table of Contents

Dedication ii

Acknowledgements iii

List of Tables vii

List of Figures ix

Abstract x

Chapter 1: Introduction 1
Overview 1
The Brownfield Process as Ritual Purification 7
The Importance of Social Capital or Community Connectedness 11
Persistence of “Brownfield” within Global Pollution Discourse 13
Global Cultural Context and Social Construction 14
Small Firms and Global Identity vs. Competitiveness 17
Motivations Behind Exalt of the Instrumental and Loss of the 18
Expressive
The Legacy of Superfund and Love Canal 19
Structure of the Dissertation 21

Chapter 2: Literature Review 26
Definitions of Brownfields 27
Brownfield as Environmental Contamination 30
Connections with Land Use 32
Issues of Risk 36
Brownfields as Economic Blight 39
Brownfields as Problems of Social Justice 43
Barriers to Community Redevelopment 47
Environmental Injustice 49
Regional Perspectives: Sustainability, Sprawl, and Smart 52
Growth

Chapter 3: The Constructed Reality of Brownfields 57
The Literature on Social Construction 59
A Constructed Brownfield Culture 66
Uncovering Expressive Meanings in the Instrumental 72
Institutional Adaptations of the Brownfield Problem 75
Articulating an Expressive Meaning for Brownfields 78
Balancing Generic and Contextual Knowledge in Brownfield Creation 80

v
Table of Contents (Continued)

Chapter 4: Brownfields in Los Angeles: How Taboos Are Constructed 82
Historical Institutional Context of Brownfields in Los Angeles 83
Ritual Process: Categories of Site Assistance 87
Brownfield Site Identification and Engagement 91
Environmental Regulation and Brownfields 92
International Standards 93
Local Expression: The Small Manufacturing Business as a Key 95
Brownfield Stakeholder
New Industrial Policy with Brownfield Targets 98
Research Context 101
Research Framework 104
Surveys of Small Businesses 106
Content Analysis of Community Land Use Plans 107
E-Consultations with Neighborhood Representatives 108
Methods and Results 109
I. Small Business Survey Process and Data 109
Data Pool 112
Existing Brownfield Sites 116
Perceptions in Vicinity of Known Sites 120
Community Connectedness 122
Contamination Practices and Perceptions 130
Legal Liability Perceptions 133
Taboo and the Culprit Perception 136
Instrumental Dominance 139
II. Community Plan Content Analysis 146
Data Pool 147
Existing Brownfield Sites 149
Brownfield Perceptions 150
Diversity in Expressed Pollution Perceptions 151
Brownfield Language 153
Reinforcement of Small Business as Critical Stakeholder 154
Community Connectedness 156
Diversity in Expressed Cleanup Approaches 157
III. E-Consultations with Neighborhood Representatives 163
Data Pool 165
Brownfield Perceptions 167
Expressed Pollution Ideas 168
Conclusion 170

vi
Table of Contents (Continued)

Chapter 5: How Taboos Are Transferred: Brownfields in Malaysia 173
A Brief Note on Method 175
Brownfields in Kuala Lumpur 176
Data Sources 177
Historical Geopolitical Context of Brownfields in Malaysia 179
The Small Manufacturing Sector in Malaysia 186
Ritual Process: Brownfields and the Environmental Policy Context 193
Research Results 204
Data Pool 205
Community Connectedness 210
Contamination Practices and Perceptions 212
Legal Liability Perceptions 213
Cultural Context 217
Imposition of Foreign Values 218
Institutionalizing the Exclusion of Local Expression 220
Splintering of a Key Stakeholder Group 222

Chapter 6: Summary and Directions for Future Research 225
Policy Directions 229

References 234

Appendices 257
Appendix A: Survey Instrument 257
Appendix B: Analysis of City General Plan Elements 264
Appendix C: Neighborhood Council Survey Responses 368
vii
List of Tables

Table 1: Example Policies in the Los Angeles Brownfield Program 88

Table 2: Stakeholders and Research Methods 105

Table 3: Respondents Near Existing Brownfield Sites 118

Table 4: Age (in years) of Respondent Businesses 123

Table 5: Owner’s Commute to Business (in miles) 123

Table 6: Owner’s Commute to Business (by mode and trip length) 124

Table 7: Perceptions of Community 125

Table 8: Percentage of Employees Living within Specified Distance of 127
Business

Table 9: Business Relationships in Neighborhood 128

Table 10: Types of Neighborhood Participation 128

Table 11: Indications that a Property is Contaminated 132

Table 12: Perceptions of Contamination 133

Table 13: Regulatory and Liability Perceptions 135

Table 14: Business Willingness to Relocate to a Former Brownfield 136

Table 15: Small Businesses as Culprits 138

Table 16: Expected Action on Contaminated Site in Neighborhood 140

Table 17: Lead Actor in Brownfield Cleanup 141

Table 18: Identified Sources of Contamination Information 142

Table 19: Recipients of Contamination Reports 142

Table 20: Time Required to Clean a Property and Return it to Use 143

viii
List of Tables (Continued)

Table 21: Participation in Business Network Groups 144

Table 22: Sources of Land Use Information 145

Table 23: Distribution of SME Manufacturers (by type of products) 188

Table 24: Malaysia SME Export Market Countries (with 50 or more 206
SME relationships)

Table 25: Age (in years) of FMM Member Businesses 208

Table 26: Size (by number of employees) of FMM Member Businesses 208

Table 27: Community Perceptions of Respondent Businesses in Malaysia 211

Table 28: Perceptions of Contamination by Respondent Businesses in Malaysia 212

Table 29: Regulatory and Liability Perceptions of Respondent 214
Malaysian Businesses

Table A1: Conservation Element of the General Plan 264

Table A2: 35 Community Land Use Plans 264

Table A3: Neighborhood Council Responses 368

ix
List of Figures

Figure 1: Map of Small Business Survey Respondents 114

Figure 2: Map of Brownfields Near Survey Respondents 117

Figure 3: Aerial View of Kuala Lumpur Skyline 179

Figure 4: Map of Malaysia in the Southeast Asian Region 180

Figure 5: Map of SME Manufacturers by State 189

Figure 6: Tin Mine in the State of Perak, Malaysia 195

Figure 7: Malaysian Waste Dump Site: Example of PCB Pollution Problem 197

Figure 8: Examples of Dangerous Practices at Waste Dump Sites 198

Figure 9: Examples of a Reliance on Civic Vigilance in Reporting 200
Contamination

Figure 10: Example Public Notice Describing Punishment for Fire-Related 201
Crimes (including illegal dumping of hazardous waste)

Figure 11: Malaysian Students Wear Masks at a School in Kuala Lumpur 202

x
Abstract
This dissertation illustrates that the concept of “brownfield” in defining and
organizing the discourse on contaminated land is a social construction of Western
origin, e.g., in the rapidly-industrialized economies of North America and Western
Europe, that serves to focus the understanding of the problem on instrumental
(legalistic, technical) meanings at the cost of the expressive (cultural), which
systematically removes decision-making authority from local communities.
Ultimately, this scenario robs communities of the opportunity to engage in important
aspects of social expression in the form of what Mary Douglas (Purity and Danger,
1996/2002) calls “ritual purification” and the creation of “taboo” in ordering societal
responses to pollution.
Using an international comparative case study analysis, the dissertation
demonstrates that brownfields, like all pollution ideas, are culturally-bound and
therefore socially-constructed, and rests upon an inquiry regarding how pollution
ideas, like brownfields, become “socially established as ‘reality’.” (italics in
original, The Social Construction of Reality, Berger & Luckmann 1966, 3) This
perspective suggests that understanding the social processes that underlie the
formation of the concept “brownfield” provides insight into how best to address the
problem and prevent its future occurrence. A qualitative cross-cultural analysis is
employed, which reveals that brownfields in Los Angeles, California, U.S.A. have
arisen in response to a legacy of wide-scale contamination from deindustrialization
and have been shaped by a highly-bureaucratic, regulatory response to notorious
xi
cases, such as Love Canal in upstate New York, which spurred the creation of
Superfund legislation. Conversely, an evaluation of how an approach to brownfields
is emerging in Kuala Lumpur and Selangor, Malaysia, demonstrates that an
indiscriminate replication of the U.S. brownfields model is inadvisable because it is
instrumentally-based and would not reflect local-level expression or knowledge,
since the understanding of brownfields is not socially-constructed in the same way.
A key conclusion is that by making the cultural, expressive, aspects of the
brownfield problem endogenous to remediation in both contexts, community
stakeholders may be more fully-engaged in brownfield prevention than in the
avoidance and antagonism that has prevailed under the existing, more fully-
developed and highly-regulated policy and planning contexts.
1
Chapter 1:
Introduction

Overview
Brownfields, or polluted lands, are a widely recognized problem for planners
and policymakers because of their pervasiveness and the issues they raise concerning
risk and uncertainty. The U.S. Environmental Protection Agency, which implements
federal law pertaining to brownfields, estimates that there are approximately 450,000
brownfields throughout the United States. (USEPA 2005a) The current, prevailing
definition of a brownfield derives from Public Law 107-118 (H.R. 2869), the "Small
Business Liability Relief and Brownfields Revitalization Act" of 2001, which states
that a “brownfield site” is “a real property, the expansion, redevelopment, or reuse of
which may be complicated by the presence or potential presence of a hazardous
substance, pollutant, or contaminant.” The intention of legally defining “brownfield”
in this case is to explicate federal funding eligibility for sites in the U.S.; however,
the term is now used all over the world.
The main contribution of this dissertation is to show how the social context
surrounding the brownfield problem is enmeshed with the technical and legal, but
that this context is largely marginalized in brownfield policy. Understanding
brownfields as socially-constructed is critical because, in both the literature and in
practice, the technical or instrumental meaning of brownfield has become
dominant—to the point that local communities have lost the ability to define for
themselves what constitutes pollution in their midst. Using Mary Douglas’s
(1966/2002) dichotomy of “instrumental” and “expressive” meanings, I argue that
2
the instrumental has so devalued the expressive that brownfield policies and
programs have lost much of their relevance and are becoming ineffective at the local
level. Douglas makes the distinction between these two types of meaning in her work
on comparative religions and, specifically, in explaining how different religious
cultures create and embrace ideas of pollution. This perspective uncovers important
implications of translating the idea of brownfields not only across diverse
communities in the U.S., but also internationally because it demonstrates how local
expressiveness is marginalized in the quest for institutional expediency.
Brownfields are considered challenges because of the unknown extent of
their potential contagion and the implications this might have for public health and
the environment. Policies designed to protect communities from brownfield pollution
have resulted in inactivity when sites are abandoned or left idle because many
owners and potential new purchasers fear expensive liability if they try to transact a
brownfield property. The high costs related to cleanup liability result in long periods
of land market dormancy—what Geltman (2000) has called “brownfield paralysis”
which results in “mothballing” properties. (6) The results are predictable: such
properties are usually fenced or otherwise physically cordoned off from the
community becoming at “best” a “neighborhood black eye” and at “worst” a
“neighborhood ‘cancer,’ spreading its disease to surrounding properties and causing
people and businesses with any options to leave the neighborhood.” (Greenberg
2003, A75)
3
The subject of brownfields has an established academic as well as
professional literature; however, both focus almost exclusively on the legal, technical
or instrumental meaning of a brownfield property rather than on the societal aspects
that have caused the “brownfield” label to be applied. While the professional
literature focuses on soil remediation methods and technologies, real estate,
insurance, and financing aspects and the academic literature primarily examines
economic development and environmental justice implications of brownfields, both
generally take the idea of brownfield as given—as it is defined in the prevailing laws
and regulations. This means that a large volume of research on brownfields focuses
upon statutorily-defined properties, thus further underscoring the instrumental
meaning.
Even though states and cities are developing their own brownfield programs
that address more locally-relevant needs—such as those tailored to former mining
areas, military bases, or corner gas stations, the term “brownfield” remains familiar
to technical experts, including lawyers, financiers, engineers, soil chemists, planners
and other government officials, but is still quite foreign to ordinary citizens. One of
the findings is that, in practice, the internal dynamics of the exclusive community of
experts—what we might call an “expert knowledge community”—has the effect of
keeping residents in the dark about how to approach the problem. When the
regulatory complexity and expertise required to address the brownfield problem
become so far removed from local communities—coupled with the physical
separation of these properties in their midst—citizens are not only disenfranchised,
4
but also discouraged from attempting future change. Put in the context of Mary
Douglas’ work, we might say that they are deprived of an opportunity to express
their own ideas about what constitutes “pollution” in their community and how it
might be ordered or managed. And, in this way, brownfields lose their expressive
meaning.
This problem is certainly not new, but what is striking is that it persists.
Rachel Carson first raised the idea of Americans being unaware and uninformed of
environmental problems in their midst in the 1960s when she pointed out a
disconnect between ordinary citizens and the decisions of scientists and
policymakers to facilitate environmentally-harmful practices. In what is arguably the
most influential work in 20
th
Century American environmentalism, she chronicled in
Silent Spring (1962/2002) that the U.S. government’s attempt to eradicate insect
pests with wide-scale chemical spraying resulted in devastating ecological
contamination and threats to human health. Her focus on the interrelated nature of
environmental elements (earth, air, water, and soil) and species throughout the food
chain demonstrated that manipulating one aspect of the environment would have far-
reaching and unintended impacts on the entire web of life.
Her work raised at least three key points that are critical to the discussion of
brownfields: (1) soil contamination can lead to groundwater contamination (which is
a major threat vis-à-vis brownfields because the problem cannot be isolated to one
property); (2) the public often exhibits an unchecked trust in the government (in her
case, the U.S. Department of Agriculture) to make the right decisions in solving the
5
problem; and (3) focusing on cures to problems that we have created is not good
enough if we are also “neglecting the golden opportunity to prevent, even while we
seek to cure.” (242) While her finding that pollutants move across media (soil, water,
air, etc.) shows the need for a holistic brownfield policy that is careful and deliberate
about establishing boundaries across problems, her empowerment of citizens
becomes the vehicle to achieve such an outcome. Certainly, legislation on citizens’
“right to know” about environmental hazards is directly traceable to Carson’s work.
1

At the same time, Carson understood the importance of institutional arrangements to
counter some of the most serious problems. Her work eventually led to the creation
of our current system of environmental governance, the cornerstone of which is the
U.S. Environmental Protection Agency (U.S. EPA). But, somehow in the case of
brownfields this “right to know” lesson of Carson’s has been forgotten not only by
others, but even by the very same U.S. EPA, which is responsible for defining and
enforcing the brownfield problem. Indeed, “brownfield” gained its legal meaning in
the original Superfund legislation that the “right to know” act amended. Since the
EPA pursues a technical understanding of brownfields, the problem is further
disconnected from communities and the sole emphasis on a cure does little to involve
communities in preventative behaviors that would avoid future brownfields.

1
The Emergency Planning & Community Right-To-Know Act (EPCRA) 42 U.S.C. 11001 et seq.
(1986) was passed by Congress as part of the Superfund Amendments and Reauthorization Act of
1986 (SARA) and is also called SARA Title III. The Act called for creation of a program with two
goals: (1) to increase public knowledge of and access to information on the presence of toxic
chemicals in communities, releases of toxic chemicals into the environment, and waste management
activities involving toxic chemicals; and (2) to encourage and support planning for responding to
environmental emergencies. (USEPA 2005b)
6
The issue, however, is not just about local mistrust of experts; rather, it
involves how expert control of a problem results in communities’ inability to
understand and therefore to assume ownership of the problem. An example is the
environmental remediation industry that has grown in response to brownfield
cleanup needs. A closer examination reveals that although there is more brownfield
work now than ever before, much of this is implemented via technical subcontracts
to governments or private sector clients. These technical cleanups are carried out
largely divorced from community participation and understanding and therefore
community stakeholders do not take ownership of the cleanup process and do not
come to understand the social processes that brought the brownfield problem about
in the first place.
Today, the existence of an expert knowledge community that directs and
dominates the brownfield redevelopment process functions as a barrier to
understanding the brownfield problem for citizens at the grassroots level because the
language used, methods of its transmission, formulation of the problem, and the
goals of the process are different. This would have concerned Rachel Carson because
it goes against the grain of genuine citizen empowerment. On the one hand,
technical, regulatory-based terminology prevails and is reinforced via government
funding and legal channels. From this perspective, the problem is formulated as one
of needing to rapidly force remediation of strategic, high-profile properties with a
goal of catalyzing economic development.
7
On the other hand, although the brownfield term is largely unknown to local
citizens, they understand land pollution, but communicate it in terms of vacant,
underutilized parcels that have attracted illegal dumping of trash, illicit activities
such as drug trafficking, and visual blight including poor structural maintenance,
closed shops, and graffiti. While local communities also seek economic development
to catalyze revitalization, they do not necessarily understand the brownfield problem
the same way.
The risk in persisting with two very different meanings of the brownfield
problem is that it could result in implicitly and systematically devaluing the potential
contribution of local knowledge, which is a critical aspect of social capital or
community connectedness. An obstacle to community self-determination arises when
brownfield cleanup is seen as a process of community “ritual purification” (Douglas
1966/2002), but one that is driven by outside forces. In this scenario we can almost
say that the involved parties are reading from a script instead of communicating
freely.

The Brownfield Process as Ritual Purification
Mary Douglas made a distinction between “primitive” and “modern” cultures
in her analysis of pollution ideas, claiming that “dirt avoidance for us [modern
culture] is a matter of hygiene or aesthetics and is not related to our religion” and
that “our idea of dirt is dominated by the knowledge of pathogenic organisms.”
(Douglas 1966/2002, 44) However, she noted that even though cultures experiencing
8
different stages of development had different ideas about pollution, what they had in
common was the notion of systematically attempting to impose order on the control
of pollution: “our ideas of dirt…express symbolic systems and…the difference
between pollution behaviour in one part of the world and another is only a matter of
detail.” (43) Equating dirt with disorder, Douglas wrote that when we chase dirt
away in the quest for tidiness, “we are not governed by anxiety to escape disease, but
are positively re-ordering our environment, making it conform to an idea.” (2) In
doing this, Douglas saw societies as engaging in “rituals of purity and impurity” that
serve to “create unity of experience.” (3) More specifically, the process of ritual
purification, she claimed, relies upon symbolic understandings of what is dirt or
pollution and what is not and these ideas are culturally-bound: “The analysis of ritual
symbolism cannot begin until we recognize ritual as an attempt to create and
maintain a particular culture, a particular set of assumptions by which experience is
controlled.” (158)
In the case of brownfields, the term has become the symbol around which the
U.S. and other industrially-advanced nations order their environments—via punitive
action and the attribution of pollution responsibility often at the expense of the local
social perceptions—particularly of the human costs of rehabilitation and cleanup. If
the roots of the brownfield problem are planted in the ideas of Rachel Carson, their
ritualization has happened in our bureaucratic federalism via the U.S. EPA and in its
statutory naming. One of my goals in the dissertation is to show that for brownfields,
the “instrumental” focus implies a dominance of only the scientific, technical or
9
bureaucratically-institutionalized understanding of the problem and the resultant
marginalization of the culturally-based “expressive” meaning. This plays out when a
community engages in “ritual purification” whereby it expresses what it values as
“pure” and “dangerous.” (Douglas 1966/2002)
In countries where the idea of brownfields may be just emerging, this makes
for laws and policies that emulate the instrumentally-focused literature, but which
remain on paper only because they are ill-suited for implementation. Douglas’s
work tells us that a community’s ideas of pollution are internalized and culturally-
bound. By extension, I argue that expressions of culture are ignored when a pollution
concept—such as brownfields—is imposed on a community by external agents or
agencies without engaging it in the process of identification and definition. The
casualty is local involvement in the problem. Without incorporating local knowledge
and participation, the danger is that brownfield cleanup becomes akin to Carson’s
criticism of the use of a uniform, blanket action (chemical spraying over millions of
acres to kill insect pests) without regard to local characteristics and needs (other
species, water bodies, interaction effects, etc.). What resulted in Carson’s story is an
increased prevalence of insect pests when their predators were also eliminated and,
over time, emergence of chemical-resistant pest species (a worse problem). This
correlates to the brownfield problem because the focus on indiscriminate, top-down,
external solutions can mean that the solution becomes focused on a short-term cure,
but overlooks important means to prevent the problem’s future spread.
10
The idea of ritual is critical because it implies an expected, familiar,
replicable, and socially-embraced process. The typical brownfield redevelopment
process begins with site identification and continues until a particular site is assessed,
remediated, marketed and resold. The remediated site’s impacts may be felt in the
community, but the process itself ends and only begins again when a new site is
found that matches what governmental funders are seeking. This is a very
fragmented, piecemeal process.
Instead, looking at the brownfield process as ritual purification helps us to see
that brownfields always exist and in varied forms—both today and tomorrow—and a
systematic way of understanding and managing them is needed, whereby
communities are on the lookout for actions that might create or exacerbate future
brownfields, on a continuing basis. This would represent an expressive process,
relying upon institutional flexibility—one that is facilitated by local involvement—
and one that is echoed in both Douglas and Carson, suggesting that ideas of purity
and impurity are sensitive to change: “The same impulse to impose order which
brings them into existence can be supposed to be continually modifying or enriching
them” (Douglas 1966/2002, 5) and, “what the public is asked to accept as ‘safe’
today my turn out tomorrow to be extremely dangerous.” (Carson 1962/2002, 224)
Ultimately, this dissertation articulates that the quest for the instrumental
meaning of brownfields serves to strip away the expressive meaning and, in so
doing, de-emphasizes the brownfield prevention process, which results in a cycle of
decline in communities. Put differently, a redeveloped brownfield site that is a
11
successful case study in terms of the prevailing governmental regime may still fail if
the community it exists within does not embrace it in its resurrected form. Or, a
brownfield may meet both economic development and environmental thresholds and
goals, but still be a failure in terms of social capital, leading eventually to both
economic development and environmental problems. Identifying this pathology and
giving a coherent account for it is the focus of this dissertation.

The Importance of Social Capital or Community Connectedness
The success of a brownfield project is largely dependent upon its acceptance
within its surrounding community and this is certainly influenced by preexisting
conditions in its social environment. One of these is what scholars have called
“social capital” or community connectedness. Social capital derives from an
individual’s level of participation within society through both formal and informal
networks or associational linkages, which depend upon many things, notably, levels
of trust and norms of reciprocity. (Fukuyama 1995 and 2000; Hayashi et al. 1999)
Social capital is known to be a vital indicator of community and societal health and
an important contributing factor to the creation of civil society. (e.g., Etzioni 1994;
Fukuyama 2000; Putnam 2000; Selman 2001)
Distinctions are made between “bonding” and “bridging” forms of social
capital (Putnam 2000), which are relevant to the understanding of brownfield
cleanup in communities. Generally, the “bonding” characteristic of social capital
means that a community has strong internal networks that strengthen it and the
12
“bridging” aspect implies that a community is able to network outside itself to
become stronger through export and import relationships. The way brownfields play
out in communities today, those that already have the wherewithal, power, or
bonding social capital to attract attention to their brownfield problems (in the form of
external technical assistance, grants or bridging social capital) do so and those that
do not experience worsening pollution in the form of more brownfield sites and
related disinvestment.
Although the brownfield literature recognizes that local support for
redevelopment is important, it is clear that communities are often barred from taking
advantage of brownfield funding and institutional assistance because they “suffer
generally from lack of organization, inexperience with complicated projects...and
mistrust of outside parties” as well as a “lack of understanding and sophistication
about what is needed to accomplish brownfield redevelopment and to address deep-
seated economic development challenges.” (Brachman 2004, 77)
This suggests that social capital conditions in neighborhoods are important to
the brownfield cleanup process and that those with the poorest levels of social capital
are likely the most needy and cannot attract attention under the prevailing brownfield
policy regime. This, in turn, certainly affects how and why stakeholders may either
participate in or ignore brownfield projects. The literature on social capital provides
an interesting context to understanding the social construction of brownfields;
however, a main focus of the present discussion is uncovering how local
stakeholders—or specific constituents of a community’s social capital—specifically
13
express their understanding of the brownfield problem. In particular, I suggest that in
order to define a brownfield problem certain stakeholders become understood as
“culprits”—those that are responsible for the problem—or “clients”—those whose
“buy in” is necessary to achieve successful brownfield redevelopment. Seeking out
these culprits and clients then provides an opportunity for uncovering community-
level expression from diverse perspectives.

Persistence of “Brownfield” within Global Pollution Discourse
Contemporary research on pollution in terms of the remediation of polluted
land has coalesced around the concept of brownfields. The origin of the term itself is
unclear, but it has attained legitimacy through widespread adoption, including
internationally. (Alker et al. 2000; Brebbia et al. 2002; Moss 2003; Meyer, Williams
& Yount 1995; Eighth Malaysia Plan 2000) Yet, there remains no universal
consensus on its definition. (Alker et al. 2000; Greenberg et al. 2000; Yount 2003)
A considerable portion of the literature on brownfields has taken a regulatory
and legal path, with many scholars engaged in explaining the intricacies of the law
and in illustrating its applications to various contaminated sites. The U.S. regulatory
definition is only one example of how brownfields are seen purely in instrumental
terms and, although the legal definitions are different in the European Union, the
United Kingdom, and elsewhere, all are tied to this kind of instrumental meaning
dictated by governments.
14
The management of brownfield sites is centered around a culturally-
reinforced system of land use and understanding of what constitutes “pollution.” For
action to be taken on a polluted site, some consensus must be forged to legitimate its
status as polluted—this may be done formally, such as by governments, or
informally, by groups of individuals; however, the brownfield label is generally
applied only when a polluted site achieves some kind of regulatory attention. The
actions taken regarding polluted sites are also culturally-dependent according to a
number of factors: who is blamed for polluting, who is responsible for cleanup, at
which point is a site considered “clean enough” and what is determined to be the
appropriate reuse. However, the cultural aspects of brownfield redevelopment get
overlooked as the practice has been translated into the literature, where the legal
definition dominates textbooks and other works (e.g., Rafson and Rafson, 1999;
Tease and Long, 1999; and Coffin, 2003). This is problematic because it divorces
brownfields from the mainstream literature on pollution, which clearly emphasizes
the importance of cultural context in understanding the identification and cleanup of
pollution as socially-constructed.

Global Cultural Context and Social Construction
Social construction implies that each society does not have the same
“culprits” and “clients” in creating or reusing brownfield sites. Moreover, each place
does not have the same ideas about what constitutes a pollution problem and how it
should be managed because such expressions are tied up with issues of culture—
15
“Like beauty…dirt is in the eyes of the beholder” (Argyrou 1997, 162) and
“judgments of causality, responsibility, and culpability made in a particular case are
affected by more widely held cultural values.” (Shaver 1985, 2)
The social construction of pollution values has been discussed in a number of
different perspectives in the literature—from the individual person to the
organizational and national levels. In discussing the formation of the multi-nation
1975 Mediterranean Action Plan, Haas (1989) noted that negotiation was difficult
because “Countries disagreed about which pollutants to control. Developed countries
wanted to control all sources of pollution, whereas many of the less developed
countries…saw this as a thinly veiled attempt to control their industrialization
practices and thus opted for the control of only municipal and tanker wastes.” (379)
In a different context, Argyrou’s (1997) evaluation of perceptions of litter by
Cypriots and foreign visitors was based upon the case of an Austrian United Nations
officer stationed in Cyprus who expressed his disapproval of the littered streets—as a
sign of the Greeks’ inability to “de-Ottomanize” themselves, suggesting that they
should learn to respect the environment and keep their country clean. (159) Such
assertions, Argyrou claims, are examples of how discourse about the environment is
also about identity, and that litter is a “cultural construct” that “emerges as a truth
under determinate social conditions” (160), which suggests a hierarchy of power and
control: “The struggle over litter…goes far beyond cleanliness, spatial order, or
protection of the environment. On the one hand, it represents the unequal distribution
of possibilities of access to an aesthetics and analytics of public space. On the other,
16
it expresses symbolic confrontations between antagonistic groups for social position
and power.” (161)
Clearly then, these issues of power and struggle have been largely absent
from discussions of brownfields, but they are explicitly uncovered when the
dominance of the regulatory prescriptions and socially-unjust consequences of
redevelopment are overtly recognized. The problem persists as the larger, most
economically-viable brownfield sites are those preferred for redevelopment, while
smaller sites in already-disinvested communities remain untouched. This points to
how the role of culture is evident in different settings in the U.S.; for instance, the
scale of brownfields is quite different in the Southwest, where sites are often smaller
and dispersed among operating businesses, whereas those in the Upper Midwest and
Northeast are often large, Superfund-like tracts spanning whole city blocks.
Pollution perceptions within the same community also differ significantly;
Hershey and Hill (1978) surveyed more than 2,000 children and teenagers (grades
two to twelve) in Florida (U.S.) and found that black pre-adults were less likely than
whites to “express active concern about pollution, and [were] less favorable to
limiting economic development ([examples given were]…a landowner’s right to
develop his [or her] land and a business’s freedom to sell the fur of an endangered
species) for the sake of environmental protection.” (456) Much of the difference in
perception they suggested was due to “subcultural” socialization—whereby children
“learn distinctive evaluations of the political process—distinctive because they are
shaped by the subculture’s special political interests, values, and experiences…as the
17
larger society’s values are learned: through transmission from parents, community
leaders, and other informed persons, peers, and schools.” (Ibid.) This example
underscores the danger of assuming that communities have the same idea of what
constitutes a brownfield and how it should be cleaned and reused.

Small Firms and Global Identity vs. Competitiveness
At the level of the business or firm, Collins and Harris (2002) conducted a
survey of metal manufacturing businesses in the U.K. and found that non-E.U.
[European Union] foreign-owned firms were more likely to invest in pollution
abatement than domestic firms, which implies that—in some contexts—one set of
firms may have more expertise to share regarding brownfields, especially regarding
their prevention. In an evaluation of environmental standards adoption by country,
Neumayer & Perkins (2004) found that “far from being a complement to tougher
public law and enforcement, self regulatory codes such as ISO 14001 are more likely
to be acting as a substitute.” (31) This may indicate that some countries, which have
not yet implemented strict regulatory regimes to direct brownfield redevelopment,
may have more flexibility in adopting more informal and inclusive practices.
Taken together, these examples tell a story about pollution perception that is
important for understanding the international transmission of the brownfield concept
because they illustrate how pollution—and the means to control it—are culturally-
bound and thus, socially constructed. For this reason, I suggest taking a step back
from the instrumental, institutional meaning of brownfields toward the expressive or
18
ritualistic meaning of how the concept of pollution in general and brownfield in
particular may be interpreted or prioritized in diverse venues.

Motivations Behind Exalt of the Instrumental and Loss of the Expressive
The preoccupation with the instrumental meaning of brownfields has resulted
in an uncritical replication of its use—with almost no inquiry into the social nature of
its expression. With some exceptions, there is little discussion in the literature of
whether the prevailing brownfield system reflects our evolving ideas of pollution, its
characterization, responsibility for it, and why we approach the problem the way we
do. Instead, much of the literature is concerned with encouraging communities to
take advantage of the prevailing policy system and in showing how this might be
possible. A large number of case studies dominate the literature and these show the
applications of policies (e.g., Simons et al. 2003 and Simons & Pendergrass 2004),
methods of site identification/characterization (e.g., Coffin 2003; Murray and Rogers
1999), stakeholder involvement (Adams et al. 2000 and Silverstein 2003), financing
(Simons 1998 and Wernstedt et al. 2003) or cleanup technologies (e.g., Troquet &
Troquet 2002; Rabah & Lekmine 2002 and Nusimovich 2002).
The literature’s focus is often on a community’s ad hoc involvement—once a
brownfield problem has already been defined and dictated to a community—and how
the community responds within that institutional framework. Moreover, because
history has determined that brownfields are bad and understood only by experts, few
incentives exist that would encourage development of local expression and
19
ownership of the term. This is ingrained via the perception of a brownfield stigma,
one that serves to make sites untouchable physically and psychologically.

The Legacy of Superfund and Love Canal
A landmark event in the legislative and regulatory history of brownfields is
the creation of Superfund, which was instigated by Love Canal. Love Canal refers to
a case in upstate New York during the 1940s and 1950s, when a chemical company
created a 16-acre landfill where it disposed of more than 21,000 tons of hazardous
waste, which it subsequently covered prior to selling the property. Over time, the
area was extensively developed, including the construction of an elementary school
and numerous homes. Subsequent studies indicated that toxic chemicals had
migrated into the surrounding area directly adjacent the original disposal site and
runoff had drained into the Niagara River (approximately three miles upstream of the
intake area of the nearest water treatment plant). Thus, contaminants had migrated
from the landfill to the sewers that had outfalls into nearby creeks. This problem
resulted in evacuation of approximately 950 families from a 10-square block area
surrounding the landfill. In 1980, the neighborhoods adjacent the site were identified
as an “Emergency Declaration Area” (nearly 350 acres divided into seven “areas of
concern”). In total, approximately 10,000 people were living within one mile of the
site and 70,000 within three miles. The contamination problem at Love Canal
ultimately led to the passage of federal legislation, including Superfund. (U.S. EPA
2004b)
20
Love Canal illustrates how, despite concerns for local health, the legislative
environment can end up centralizing and distancing the problem from communities.
In the United States the bulk of programs for brownfield remediation, such as those
outlined in Superfund/SARA, CERCLA, RCRA, and SBLRBRRA,
2
are provided by
federal legislation or through the works of federal agencies, such as U.S. EPA, DOE,
EDA, HUD, and ATSDR.
3
The literature analyzes state-level consequences of these
and other programs (e.g., Geltman 2000), but it is well known that the
implementation of these policies at the local level is largely accomplished through
training, technical assistance, or policy guidance and advisement (e.g., CCLR, ELI,
ICMA, the Lincoln Institute of Land Policy, and NEMW) or by universities (e.g.,
brownfield research centers at Rutgers, Carnegie Mellon/University of Pittsburgh,
and Michigan State University).
The literature is also largely about cities in the Western hemisphere and deals
with issues that are germane to these areas. So, for instance, one branch of the
literature focuses on Western cities’ priorities, “primarily on issues surrounding
decontamination and cleanup, including risk and liability.” (Greenstein 2004 and
Sungu-Eryilmaz 2004, 7) Whole works have been devoted to describing,
interpreting, and navigating regulatory systems (Meyer, Williams & Yount 1995;

2
The Superfund Amendments and Reauthorization Act (SARA) amended the Comprehensive
Environmental Response, Compensation, and Liability Act (CERCLA) on October 17, 1986; RCRA
is the Resource Conservation and Recovery Act of 1976, intended to protect public health and the
environment in regard to the management of hazardous waste; SBLRBRRA is the Small Business
Liability Relief and Brownfields Revitalization Act of 2002.
3
The United States Environmental Protection Agency, Department of Energy, Economic
Development Administration, Department of Housing and Urban Development, and the Agency for
Toxic Substances and Disease Registry.
21
Bartsch and Collaton 1997; Geltman 2000; Meyer and Van Landingham 2000),
further evidence of the removal of this conversation away from the grassroots level.
As mentioned previously, case studies tend to address sites that have been
identified within the established regulatory system (i.e., they have obtained external
funding or governmental assistance) or they evaluate stakeholders who have been
coalesced around one of these sites. The brownfield literature reflects an example of
when communities whose brownfields are non-standard—and thus do not conform to
the one-size-fits-all solution—get marginalized or ignored in both practice and in
scholarly discourse.

Structure of the Dissertation
Following this introductory chapter, Chapter Two comprises a literature
review, which demonstrates that the prevailing brownfield literature lacks a socio-
cultural focus, one that, if more overt, would allow the expressive meaning of
brownfields to become explicit in planning and policy-making. The chapter discusses
how the literature on brownfields is divided into three major themes: one concerned
with environmental contamination that serves to discuss regulatory and technological
fixes, another that sees brownfields as economic blight and approaches the problem
from a revitalization and fiscal reform perspective, and finally, one that understands
brownfields as products of social injustice. The chapter suggests that what is lacking
within the literature is an investigation of why the problem of brownfields has
become a preoccupation of planners and policymakers worldwide.
22
Chapter Three asks how does abandoned, unused or polluted land acquire
social meaning as “brownfield” and why brownfields get prioritized in American
political culture? Moreover, the chapter investigates how these questions of origin
and political context explain not only the emergence of brownfields, but how they
are also probative for the persistence of brownfields in the future. This chapter
focuses on several important social aspects of the brownfield problem, such as the
language used to communicate about brownfields, the stakeholders who speak the
language and validate the body of knowledge that upholds the concept, and the
institutionalization or societal ordering of how the problem is defined and addressed.
Moreover, Chapter Three invokes societal ideas—as described by Douglas
(1966/2002)—of both what is “pure” and what is “dangerous.” The chapter suggests
that making the expressive meaning of brownfields endogenous to planning and
policy processes would allow communities to recapture social elements that have
been declining, including civic vigilance.
Specifically, this contention rests upon the understanding of brownfields as a
social problem—that when citizens do not understand the decline of properties in
their neighborhoods as brownfields and are therefore not vigilant in pursuing
opportunities to identify brownfields in progress (e.g., by reporting structural code
violations, abandonment, illegal dumping, graffiti, questionable activities on vacant
parcels, etc.), they are abdicating responsibility for engaging in their own process of
ritual purification.
23
Chapter Four—using the case of Los Angeles—argues that the idea of
brownfield may be seen as what Douglas calls “taboo.” It discusses how the
brownfield problem has played out in the City of Los Angeles, an extremely
multicultural urban society. The argument rests upon a case study discussion of the
brownfield institution or “instrumental” interpretation of the problem in the City.
This involves the identification of a key brownfield stakeholder—small
manufacturing businesses—and an evaluation of them as both “culprits” and
“clients” in brownfield redevelopment. The Chapter also relies upon a content
analysis of the City’s 35 community plans and electronic consultations with
representatives of the City’s Neighborhood Councils, which elicit grassroots level or
“expressive” sentiments regarding brownfields. Ultimately, the argument
demonstrates that there is no consensus understanding of the term “brownfield” and
that communities within the City have very different ideas about what constitutes a
land pollution problem and how to solve it. The case calls into question the
prevailing brownfield process in Los Angeles—seeing it as possibly irrelevant and
ineffective—because it masks these differences and overlooks the importance of
local knowledge and culture as integrated and fundamental to solving the problem.
In Chapter Five, the power and danger of exporting the brownfield taboo
internationally is examined. A qualitative summary of the brownfield process in
Kuala Lumpur is used to illustrate how the concept’s uncritical replication in diverse
settings may be harmful on three key levels: (1) by assuming and imposing
foreign/external values regarding land use, stewardship, and cleanup/remediation
24
roles and responsibilities; (2) by removing decision-making from the local level; and
(3) by splintering stakeholder groups that are necessary to prevent the creation of
future brownfields.
Chapter Six concludes the dissertation by drawing implications from the
social construction of the brownfield problem into implications for institutional
reform, including a new view of brownfield site ownership as communal rather than
privately-held. A caution emerges that the term brownfield is pervasive
internationally yet it retains a powerful instrumental meaning and results in the
masking of local socio-cultural aspects of land use (and reuse). In understanding
brownfield redevelopment as ritual purification, we see how societies embrace and
suppress ideas of purity and danger, which, in turn, influence the prosperity of
communities vis-à-vis their social capital generation.
As nations and cities grapple with a way to find a solution to the problem of
brownfields, a lesson emerges that developing countries should use caution in
replicating the Western industrial model because, as Douglas asserts in her reference
to assuming ideas of dirt/pollution/defilement are the same:
Defilement is never an isolated event. It cannot occur except in view of a
systematic ordering of ideas. Hence any piecemeal interpretation of the
pollution rules of another culture is bound to fail. For the only way in which
pollution ideas make sense is in reference to a total structure of thought
whose keystone, boundaries, margins and internal lines are held in relation by
rules of separation. (51)

Ultimately, a contention is offered that to continue the trend of focusing upon
the instrumental meaning or professionalization of brownfields at the expense of the
25
expressive—in both the literature and in practice—is potentially harmful because of
the long-term social costs, when communities are denied the opportunity to express
their own ideas of purity and danger.
26
Chapter 2:
Literature Review

The literature on brownfields is divided into three major themes: one
concerned with environmental contamination that serves to discuss regulatory and
technological fixes, another that sees brownfields as economic blight and approaches
the problem from a revitalization and fiscal reform perspective, and finally, one that
understands brownfields as products of social injustice. But, while these perspectives
illuminate the problem of brownfields in insightful ways, each of these literatures
relies upon a legal or more broadly a technical or instrumental meaning of
brownfields. Notably lacking within the literature is an investigation of why the
problem of brownfields has become a preoccupation of planners and policymakers
worldwide. What is, for example, the intellectual milieu within which brownfields
come to be recognized? How does “ordinary” land become a brownfield? What are
some social and cultural processes that go into the making of brownfields?
This review will show that while the literature on brownfields is considerable
and varied in its geographical scope, it is still limited in its perspective. Regardless
whether the literature is European or American, science-based or economic
development-based, abstract or grounded in cases, it takes brownfield to be an
instrumental and often legal problem of cleanup. In this view a brownfield emerges
because of a discrepancy between land as it should be and land as it is, the
discrepancy usually measured by scientific or legal measures of contamination.
Cleaning a site consists of removing the contaminants, a process that might yield
27
economic benefits and which must be tempered by sensitivity to who profits and who
loses. Such a “how to” or technique-oriented approach is hardly unusual for a
professional literature. Its consequence, however, is that even when the literature
strays into social issues, for example, in case of brownfields as problems of
environmental justice, it does not question the more fundamental personal and
cultural forces that mediate the understanding of contamination, the fundamental
social values that explain the origins of brownfields, their treatment as taboos, and
the pathologies that they engender. Rather in its instrumental approach, the social
context becomes something to be manipulated in the task of cleaning up brownfields.
Reconstructing the understanding of brownfields by tying it to something
other than a technical perspective will be the task of the next chapter. For now this
review will attempt to demonstrate how the technical or instrumental understanding
plays out in each of the three themes that comprise the brownfields literature.

Definitions of Brownfields
Although there is no consensus on a definition of the term “brownfield”
(Alker 2000; McCaffery 1997; Yount 2003), use of the term is widespread in the
U.S. and internationally in referencing contaminated parcels of land (e.g., Brebbia et.
al 2002 and Meyer et al. 1995). D. Adams et al. (2000, 135) refer to brownfields in
the U.K. as “vacant urban land” and “obsolete urban property” with “derelict
structures” or “outmoded infrastructure and contamination.” Elsewhere brownfields
have been referred to as: contaminated “former industrial” properties (Greenberg and
28
Lewis 2000, 2502); “postindustrial-use properties” (Lange and McNeil 2004a, 101);
“essentially abandoned or underutilized sites, typically industrial, which are
environmentally-contaminated and often located in urban and economically
depressed areas” (McCaffery 1997, 154); “abandoned contaminated” (Pagano and
O’M Bowman 2000, 3); “lands with a legacy of toxic uses” (Pastor 2001, 15);
“‘contaminated’ lands that have become difficult to recycle to new uses” (16); “lands
contaminated by past industrial and commercial activities” (Tam and Byer 2004,
184); “derelict land” or sites “for potential redevelopment that have been previously
used, but are not now in productive use” (Page 1997, 198). Alternatively, the term is
used but not defined at all (Hornsby and Sawchuck 1999; Johnson et al. 2002;
Kantor 2000; Meyer and Lyons 2000; Royal 1999).
Writing about the redevelopment of the Dublin Docklands in Ireland, Moore
(2002) claims that the “most widely used” definition of brownfield is the European
Union’s: “derelict or underused land that have real or perceived contamination
problems. They are one of the negative results due to the breakdown of core
industries during the periods of industrial changes in Europe.” (EU CLARINET
Working Group 1 2001 cited in Moore 2002, 325).
The most recent definition in the U.S. derives from federal legislation and
hinges upon the understanding that a brownfield may be either actually contaminated
or perceived to be so: “real property, the expansion, redevelopment, or reuse of
which may be complicated by the presence or potential presence of a hazardous
substance, pollutant, or contaminant” (H.R. 2869, the Small Business Liability Relief
29
and Brownfields Revitalization Act of 2001, Section 211 (a)(39)(A)). This definition
is used in the more recent literature, such as by Amekudzi and Fomunung (2004), in
reference to the strategic positioning of transportation improvements around
identified brownfield sites in order to catalyze their redevelopment and by De Sousa
(2004) in evaluating American cities’ attempts to redevelop brownfields as parks and
open space.
An older legal definition of brownfield is also widely used. Here, a
brownfield is “abandoned, idled, or underused industrial and commercial facilities
where expansion or development is complicated by real or perceived environmental
contamination”
4
(e.g., Amekudzi et al. 2003; McCarthy 2002; Schoenbaum 2002;
Wernstedt 2001; Zarcadoolas et al. 2001 and paraphrased versions of this in Attoh-
Okine and Gibbons 2001; Gorman 1997; Lange and McNeil 2004a and 2004b;
Reddy et al. 1999). In a few cases a combination of both the former and current
regulatory definitions is used (e.g., Burnham-Howard 2004 in discussing liability
aspects of federal and state laws in implementation and Solitare 2005 in presenting
“situational prerequisites” that must exist to attain “meaningful participation” in
brownfield projects).
Taken together, these works point to the problem of brownfields as a land use
issue. Typically, the label applies to a specific property, with “brown” as the rough
approximation of pollution and “field” as the associated parcel. Indeed, the term
originates in the literature discussing government-led cleanup responses to toxic
30
exposures as an environmental contamination issue and later emerges in the
economic development literature in reference to community blight and physical
decay. The term was most likely coined in the English language and it has become
institutionalized in the English-speaking public policy communities of both the U.S.
and the European Union.

Brownfield as Environmental Contamination
Brownfields trace their emergence in law to the case of Love Canal, called
“the ‘original’ brownfield” (Fletcher 2002, 311), and its instigation of CERCLA, the
Comprehensive Environmental Response, Compensation, and Liability Act of 1980,
or “Superfund”, which first defined brownfield liability as “retroactive,” “strict,”
“joint and several.” This provided a legal basis for identifying “potentially
responsible parties” of contamination at brownfield sites. (U.S. EPA/Office of Solid
Waste and Emergency Response, undated) Strict, joint, and several liability means
that any past owner of a property may be held liable for all or part of the
contamination found at a site—as a potentially responsible party. Thus, once a
brownfield site is identified, next steps involve characterizing its pollution status and
assigning blame for this. The identification of potentially responsible parties may
precede pollution characterization in some cases, because the testing involved is
usually expensive and governments cannot afford to fund analysis at all brownfield
sites.

4 This definition is from U.S. Code, Title 42, Chapter 103, the Comprehensive Environmental
31
Testing at brownfield sites is governed by the American Standards for
Testing and Materials (ASTM) via Phase I and Phase II procedures.
5
Phase I
investigations are noninvasive and do not require access to a property; instead they
involve archival searches of past uses of the site and research regarding any
historical environmental concerns within a determined radius (generally one-half
mile) of the subject property. Phase II investigations involve soil analysis and
therefore an access right to the property must be obtained. Governmental funding of
brownfield cleanup is often contingent upon proof that a site is contaminated and has
been characterized in accordance with ASTM standards. ASTM-compliant site
investigations are expected to be conducted by certified or registered environmental
professionals.
6
This may be seen as evidence of the professionalization of
brownfields and its control by an expert knowledge community.
What Love Canal, “Superfund” and the attendant processes also demonstrate
is that a defensive policy regime was set in motion to respond to disastrous
conditions. This has resulted in a top-down regulatory system for managing

Response, Compensation, and Liability Act of 1980, Subchapter I, Section 9601.
5
Specifically, for properties acquired after May 31, 1997, the law requires the use of procedures
developed by the American Society for Testing Materials—standard E1527-97, or "Standard Practice
for Environmental Site Assessment: Phase I Environmental Site Assessment Process". However, in
the final rule "Clarification to Interim Standards and Practices for All Appropriate Inquiry Under
CERCLA and Notice of Future Rulemaking Action," EPA establishes that the current ASTM
standard, E1527-00, will also meet the "all appropriate inquiry" requirement for site characterizations
and assessments. (U.S. EPA 2003)
6
Specifically, for properties acquired after May 31, 1997, the law requires the use of procedures
developed by the American Society for Testing Materials—standard E1527-97, or "Standard Practice
for Environmental Site Assessment: Phase I Environmental Site Assessment Process". However, in
the final rule "Clarification to Interim Standards and Practices for All Appropriate Inquiry Under
CERCLA and Notice of Future Rulemaking Action," EPA establishes that the current ASTM
standard, E1527-00, will also meet the "all appropriate inquiry" requirement for site characterizations
and assessments. (U.S. EPA 2003)
32
contaminated land via a history of centralized oversight, which distances the problem
from local communities.
When we come to empirical work on brownfields, a large number of case
studies show the applications of policies (Begley 1996; Schoenbaum 2002; Simons
et al. 2003), methods of site identification or characterization (e.g., Coffin, 2003;
Murray and Rogers, 1999), stakeholder involvement (Adams et al., 2000; Silverstein,
2003; Solitare 2005), financing and insurance (Simons, 1998; Wernstedt et al.,
2003), and the application of cleanup technologies (e.g. Steele & Pichtel 1998,
Reddy et al. 1999, Manar et al. 2001, Steinhauser et al. 2001, Nusimovich 2002,
Rabah & Lekmine 2002, Troquet & Troquet 2002, Ramsden & Gardner 2003, Dyken
& Crellin 2004, Ferreira da Silva et al. 2004, Snider et al. 2004). However, the bulk
of this work is informed by a technical, regulatory, or economic perspective. Much
of the literature is site-specific and addresses issues after brownfields have already
been identified. Even in the case of an environmental justice perspective—a clearly
social phenomenon—the literature primarily focuses on the consequences of
brownfields that have been identified through the regulatory policy regime.

Connections with Land Use
Implementation and enforcement of brownfield laws is rooted in the works of
federal agencies such as the U.S. Environmental Protection Agency, the U.S.
Economic Development Administration, the U.S. Department of Housing and Urban
Development, and, more recently, the Agency for Toxic Substances and Disease
33
Registry (of the Centers for Disease Control).
7
Some of the brownfield literature is
concerned with analyzing state- and local-level consequences of these and other
programs. (Glass Geltman 2000; Solitare and Greenberg 2002) As mentioned in
Chapter 1, local level brownfield policy implementation is often facilitated through
training and technical assistance of a variety of nongovernmental organizations, such
as the California Center for Land Recycling, the Environmental Law Institute, the
International City/County Management Association, the Lincoln Institute of Land
Policy, and the Northeast-Midwest Institute and universities (e.g., brownfield
research centers at Rutgers, Carnegie Mellon/University of Pittsburgh, and Michigan
State University, the Brownfields Research Consortium at the University of
Wisconsin-Milwaukee).
Invocation of the term brownfield generally arises when a land use on a
particular site has generated negative social consequences that have attracted the
attention of an outside party—an occurrence that is tied up in notions of the quality
of land stewardship as well as land ownership. Within the environmental literature,
this places brownfields in the anthropocentric realm whereby both stewardship and
ownership reflect a human-centered perspective. This is appropriate given the
understanding of brownfields as socially-constructed and therefore as a product of
human impact on the environment.
Ownership is most often understood as a monetary claim to a parcel of land
and, in contrast, stewardship is intended as an amorphous yet powerful, possibly

7
Each of these implements brownfield redevelopment policies and programs; however, the U.S. EPA
34
spiritual, claim of responsibility for care of the land. Use of the term “stewardship”
in American literature stems from the works of naturalists such as Henry David
Thoreau (Walden (1854)), John Muir (Our National Parks (1909)), Aldo Leopold (A
Sand County Almanac (1948)), and, most notably in modern environmentalism,
Rachel Carson in Silent Spring (1962/2002). Stewardship has been tied to the history
of the natural resource conservation and preservation movements in the U.S. and is
often used in reference to forestry.
Here, the importance that derives from the tension between ownership and
stewardship is that the concept of brownfields must be understood in the nexus
between them. For instance, an individual property owner’s negligence that
contributes to the creation of a brownfield may be seen as impinging upon the
community’s ability to function as effective stewards of the land for posterity. The
tension is realized when society’s regulations regarding the treatment of a brownfield
site restricts the ability of a private landowner to do whatever he/she wishes with
his/her land. Friedman (2003, 9) makes a similar distinction in regard to property
rights, “extensive property rights govern what people can own as property; intensive
rights govern what they can do with it.” Dixon (2003) talks about this in terms of
“asset ownership” in her discussion of brownfield cases and recognizes in one
scenario that, “Though the community does not hold title to the property,
it…[still]…gained significant control over the asset by winning the right to help
determine the direction of the redevelopment process.” (68) Asset ownership lends

is the primary agency for overseeing the implementation of federal laws pertaining to brownfields.
35
credence to the idea that there is a stewardship value as well as a traditional
monetary ownership value that influences the condition and plight of brownfield
properties.
The assignment of property rights then affects how brownfields are
recognized and redeveloped; this implies that societies with highly regulated
property markets would have a potentially greater governmental influence over
brownfield control while those that are less formal would not, since ownership and
responsibility might be otherwise hard to assign and enforce. For instance, since the
meaning of “brownfield” is tied to law both in the U.S. and in Europe, activities that
identify, evaluate, and clean up a property become associated with an articulated
regulatory process. However, in other places where these activities happen (or do
not) organically—without a corresponding official label—there is no precedent for
following a regular, ritualized procedure in implementing cleanup. Value judgments
may still be articulated about what is clean and what is not, but they are not
instrumentally-formalized to the extent that rights will be upheld or relinquished in
an expected way. Since the term “brownfield” arises from the legacy of Superfund
and became reinforced in the literature via discussions of the remediation of
Superfund (e.g., Wernstedt 2001) and other legally-identified sites, it has acquired a
status whereby a property that has been acknowledged by the term is devalued and
correspondingly, the party or parties responsible for that property when it was so
named are devalued also for irresponsible management of that property.

36
Issues of Risk
The institutionalization of the brownfield term in law means a recognition
that the rights of an individual land owner may be called into question because
his/her property has become a threat (or potential threat) to the public in which it
exists. This places brownfields within the realm of risk. Moreover, naming a site,
property, or parcel a “brownfield” implies that the government or someone other
than the property owner has rights as well.
According to Section 128 of the 2001 Small Business Liability Relief and
Brownfield Revitalization Act, U.S. states must develop lists of their brownfield sites
if they do not otherwise have a formal agreement to administer their brownfields
programs—such as a Voluntary Cleanup Program. The requirement of a brownfield
register is also the case in the United Kingdom under its 1990 Environmental
Protection Act. (Walton 1997) These prescriptions force the issue of brownfield
definition, which sets the redevelopment process in motion. Once sites are identified
by governments, they are then eligible for assistance via funding and technical
advisement from higher levels of government.
The U.S. regulatory system has developed its own language in regard to
brownfields, which includes a requirement that “all appropriate inquiry”
8
into the

8 According to Subtitle B of Title II of the 2001 Small Business Liability Relief and Revitalization
Act, the following parties must conduct all appropriate inquiry: (1) Bona fide prospective purchasers
who buy property after January 11, 2002 must perform all appropriate inquiry prior to purchase and
may buy knowing, or having reason to know, of contamination on the property while still enjoying the
limitation on liability provided by the new definition; (2) Contiguous property owners whose property
is not the source of the contamination, but is "contiguous" to a facility that is the source of
contamination found on their property must perform all appropriate inquiry prior to purchase and buy
not knowing, or having reason to know, of contamination on the property; and (3) Innocent
37
past contamination history of a site or “due diligence” be conducted prior to
acquisition of a property and it endorses the feasibility of using an “innocent
landowner defense” if “all appropriate inquiry” can be proven—in order to protect
those who acquire a brownfield property and can thereby prove they are unaware of
and therefore not responsible for its contamination.
9
Additionally, the provision of
“comfort letters,”
10
“No Further Action”
11
or “closure letters,” “prospective
purchaser agreements,” and “covenants not to sue” are possible strategies to provide

purchasers/landowners must perform all appropriate inquiry prior to purchase of a property and must
buy without knowing, or having reason to know, of contamination on the property. (U.S. EPA 2003)
New standards were release further articulating requirements in regard to due diligence in November
2005.
9
The 1986 Superfund Amendments and Reauthorization Act or SARA (Pub. L. No. 99-499, 100 stat.
1613) amended CERCLA by creating an "innocent landowner" defense to CERCLA liability. It
provided a defense to CERCLA liability, for those persons who could demonstrate, among other
requirements, that they "did not know and had no reason to know" before purchasing a property that
any hazardous substance (characterized as the subject of a release or threatened release) was disposed
of on, in, or at the property. In order to prove that they had "no reason to know", innocent landowners
must have undertaken, prior to, or at the time of acquisition of the property, "all appropriate inquiries"
into the previous ownership and uses of the property consistent with good commercial or customary
practice. In 2002, Brownfields Amendments added potential liability protections for "contiguous
property owners" and "bona fide prospective purchasers" who are also held to the all appropriate
inquiries standard, among other requirements, in order to benefit from the liability protection. (U.S.
EPA 2004?)
10
From the U.S. EPA’s “Policy on the Issuance of Comfort/Status Letters”:

[The] EPA hopes to provide a measure of ‘comfort’ by helping an interested party
to better understand the potential for or actual EPA involvement at a brownfield
property. This policy describes the most common situations about which parties
inquire and the type of information or comfort EPA may provide to parties to assist
them in assessing the probability of incurring liability under…CERCLA or
Superfund…It is not EPA's intention to become involved in typical private real
estate transactions. Rather, EPA intends to limit the use of such comfort to where it
may facilitate the cleanup and redevelopment of brownfields, where there is the
realistic perception or probability of incurring Superfund liability, and where there
is no other mechanism available to adequately address the party's concerns. The
policy contains four sample comfort/status letters which address the most common
inquiries for information that EPA receives regarding contaminated or potentially
contaminated properties. (U.S. EPA 1997)

38
protection against liability for property owners.
12
And, the system offers an option
of “risk-based corrective action”
13
which allows cleanup to be compatible with the
planned next use of the property (For instance, a property that would be reused as a
parking lot would not need to be cleaned to the standard of a property that was going
to be reused as a daycare center or community garden.).
Clearly a complex ritualistic process has emerged in the way that the U.S.
addresses the problem of brownfields. Starting from a science-based understanding
of brownfields, a language has been constructed around the problem and various
actors and agencies have emerged as powerful within the decision-making process
that affects how brownfield pollution is controlled within society. These are

11
NFA letters “Represent an official regulatory affirmation that a site adequately protects human
health and the environment for the intended use of the site” are intended to “Note the end to corrective
action” and to “Document any property use restrictions”. (Clarke 2002)
12
Agreements known as “Prospective Purchaser Agreements or PPAs have been negotiated by the
U.S. EPA since 1989, which “provide a covenant not to sue for certain prospective purchasers of
contaminated property prior to their acquisition, in order to resolve the potential liability due to
ownership of such property”. (U.S. EPA 2002) In 2002, CERCLA was amended to provide additional
protection that provides “a limitation on liability for persons who qualify as bona fide prospective
purchasers…Congress’ intent in enacting this provision was to remove certain liability barriers to
purchases of property and encourage redevelopment.” (Ibid.)
13
Generally, “corrective action” applies to RCRA facilities. RCRA is the Resource Conservation and
Recovery Act of 1976 and its amendments, which gave the U.S. EPA the authority to control
hazardous waste from "cradle-to-grave", including generation, transportation, treatment, storage, and
disposal of hazardous waste. Accidents and other activities at RCRA treatment, storage and disposal
facilities have occasionally resulted in the release pollutants into soil, ground water, surface water and
air. Thus, RCRA sites are a kind of brownfield that involves federal oversight. The RCRA Corrective
Action Program allows facilities to address the investigation and cleanup of hazardous releases
themselves. The RCRA Corrective Action Program is different from Superfund (which applies to only
the most severely contaminated sites that are not in use) in that it deals with sites that have viable
operators and ongoing operations. (U.S. EPA 2005) Risk-based corrective action (RBCA) is now
more widely used in the case of other brownfields, such as petroleum sites with leaking underground
storage tanks or LUSTs.

39
examples of a hierarchical institutionalization of the brownfield issue, which
mediates the involvement of individuals, grassroots groups, and communities.

Brownfields as Economic Blight
Brownfields are frequently considered an economic development issue
because they are valued in terms of lost property taxes, foregone revenues and
unrealized wages. They are seen as opportunities to developers and government
officials because they can catalyze revitalization in a neighborhood. (e.g., Simons
1998; Adams et al. 2000; Meyer and Van Landingham 2000) Navigating liability
protection available through the existing regulatory system is also a means of
capitalizing on the economic development potential of brownfields (Burnham-
Howard 2004; Tam and Byer 2004).
Green-Leigh (2004) discusses the use of special economic zones as a
brownfield cleanup strategy. In addition to federal Empowerment Zones or
Enterprise Community designations, states also have enacted enterprise zones to
“concentrate redevelopment efforts in areas of distress, decay and blight.” (125) At
the sub-city level, community redevelopment agencies are state agencies with local
control over land use in special redevelopment areas.
In conformity with the Redevelopment Law of the State of California, the
City of Los Angeles’s Community Redevelopment Agency (CRA) was established
by resolution of the Los Angeles City Council in 1948 and granted with the powers
to combat blight and ensure the provision of quality low-income housing; blight is
40
defined as “Deterioration of an area caused by physical, economic and social forces.”
(CRA 2003) CRA may exercise eminent domain once the City Council approves a
redevelopment plan for a project area. Eminent domain is the authority (of a
government agency) “to acquire property when it can be shown that the property is
acquired for a public purpose and for the public good and that the owner has received
a just compensation.” (Ibid. italics in original)
Condemnation is another strategy of the government’s ability to acquire
private property for public or private use; however, this may be seen as a more
controversial means of acquisition. Tax delinquent properties may also be acquired
by public agencies and this is how many brownfields first come to light. The CRA is
particularly interested in brownfield sites because of their contribution to blight and
because of their ability to be reused to meet community development needs in
challenged areas. The scenario of CRA involvement in a brownfield may be
understood as falling within the realm of a technical or instrumental meaning
because it is an example of an external bureaucratic agency controlling the land use
process for an already disenfranchised community. And, particularly, these are
communities that have been labeled as belonging to a “redevelopment area”
boundary, which may or may not correspond to historic identity as understood and
expressed by residents themselves.
The literature’s focus on the impacts of brownfield projects tends to be
articulated in economic terms; as supported in McCarthy (2002), “Most analyses of
the potential costs and benefits of brownfield redevelopment versus greenfield
41
development examine the economic costs and returns for hypothetical developers.”
(293) The economic development approach to brownfields tends to divorce the
environmental stewardship aspect from community decision-makers. This is echoed
by Greenberg and Lewis (2000) in asserting that the “specific role of the public in
brownfields redevelopment is unclear.” (2502)
The brownfield property is generally gated and the remediation is
administered by remediation technology experts who make decisions about strategies
and achievable standards that correspond with the CRA’s (or other public agency’s)
intended reuse of the site. Agency staff or consultants manage the environmental
documentation and the project moves forward. This process leaves little room for
more than highly-structured community involvement. More recently, the issue of
public involvement has emerged in the brownfield literature since communities often
need to be informed and engaged in identified brownfield projects. (Bartsch 2003;
Wernstedt 2001; Zarcadoolas et al. 2001)
A recent California court case provides insight into the social construction of
brownfields—particularly how concerted community actions may result in
brownfield creation. In Bakersfield Citizens for Local Control vs. the City of
Bakersfield (December 13, 2004), the Court of Appeal of California (Fifth Appellate
District) invalidated two environmental impact reports (EIRs) that the City of
Bakersfield had certified because they failed to consider the cumulative impacts of
their projects. Each EIR included retail development with two large Wal-Mart stores
as their anchor tenants; however, the projects were only 3.6 miles apart. Although
42
the Bakersfield City Council was aware of the close proximity of the two projects,
they considered them as separate and approved each in different closed-door
sessions. This is in violation of the California Environmental Quality Act, which
requires that related projects and their cumulative effects be considered in evaluating
each project’s impacts.
What is most unusual about the case is that the Court cited future blight
(conditions precipitating brownfield creation) as a potential negative consequence if
both projects were implemented; specifically, the court “determined that the EIRs
did not fulfill their informational obligations because they failed to consider
the…projects' individual and cumulative potential to indirectly cause urban/suburban
decay by precipitating a downward spiral of store closures and long-term vacancies
in existing shopping centers.” Another unusual aspect of this decision recognizes a
condition that may be understood as “malice aforethought” (most commonly used as
a necessary occurrence to prove premeditated murder) in economic development
planning, which—in this case—assigns liability for future brownfield creation to
government officials via the environmental planning process.
The decision likely would not have come about if it did not emerge from an
extensive American history of blight creation as big companies move in and out of
towns, dominating their economies. This is directly related to the history of
brownfields in the Midwest and Northeast, where brownfields gained currency in the
wake of industrial boom periods that left legacies of contamination—including GE in
Massachusetts (Hynes 2003), U.S. Steel in Gary, Indiana (Hurley 1995), the Hooker
43
Chemical Company (Love Canal) in New York, the Koppers Seaboard Coke and By-
Products plant in Kearny, New Jersey (Hornsby & Sawchuck 1999), chemical
companies in Neville Island, Pennsylvania (Gorman 1997), a variety of auto-related
industries in and around Detroit and Flint, Michigan and countless others.
What is startling is that this kind of decision has taken so long to arise from
the courts—given that the cleanup obstacles facing communities in the aftermath of
wide scale blight (including literal contamination and human health effects, the
difficulties of marketing and reselling contaminated properties, and welfare-related
investments detailed in the vacant land literature) are likely much more expensive
than the short-term economic development boosts provided by the short-lived
corporate land uses. What this history serves to show is that the economic
development context of the brownfield problem is an important piece of its social
construction and is critical to its understanding not only as a local issue, but one
which has far-reaching regional and global impacts.

Brownfields as Problems of Social Justice
The literature on the Industrial Revolution provides insight into how
production processes and utility operations that fueled the industrial growth of cities
became magnified in the aggregate, which not only caused regional pollution
problems, but also raised issues concerning adjacent land uses. Today, the land use
literature would include these as locally unwanted land uses (LULUs) (see, e.g.,
Popper 1981) or, more recently, as contributors to toxic hotspots (areas of
44
concentrated pollution created from multiple sources). (Bansal & Davis 1998) The
temporal context of these two land use conditions may differ because LULUs can be
a future case—when an environmentally undesirable use such as a landfill is planned
for a neighborhood—but a toxic hotspot usually arises because of a confluence of
undesirable uses in a single area which were not previously anticipated, such as
when a dry cleaning plant, gas station, autobody paint shop and freeway combine to
cause an air pollution problem.
Brownfields may be considered both LULUs and/or toxic hotspots, but as the
professional and academic literatures demonstrate, they are identified after-the-fact
of the discovery of contamination or perceived contamination. Lange & McNeil
(2004a) support this in their characterization of the brownfield literature as largely
anecdotal or “reflective in content.” (109) TOADS (Greenberg and Popper 1994;
Bright 2000) are an example of a particular kind of brownfield—temporarily
obsolete abandoned derelict sites—which are more obvious, but still identified as
such after-the-fact of contamination.
The literature on vacant land (e.g., Bowman and Pagano 2004) is also
relevant to discussions on brownfields; however, brownfields are not always vacant.
Vacancy is likely a better indicator of brownfields in the Northeast and Midwest U.S.
where former industrial facilities have been abandoned and where cities have
experienced population outmigration and disinvestment. In the Southwest, there
tends to be less vacant land because the cities within the region are experiencing
phenomenal growth and investment, which means that developers are capitalizing on
45
brownfield redevelopment opportunities. The understanding of vacancy as a
characteristic of brownfields in one area versus another within the U.S. may be seen
as demonstrating how the reality of the brownfield problem has been socially
constructed differently along regional lines within the same national culture.
Whether considered a LULU, toxic hotspot, or evidenced by abandonment or
vacancy, brownfields usually become known as such to communities through
notification by redevelopers (public or private) who have taken an interest in the
property. There are no well-known cases of comprehensive brownfield programs or
policies that seek to involve communities in identifying future brownfields in
progress—to intervene at the prevention stage. Instead, the large majority of
strategies are ad hoc and piecemeal. This, of course, has occurred out of necessity as
governments have crafted responses to address the problem of hundreds of thousands
of brownfields across the U.S. alone. However, after almost two decades of work to
address brownfields, the implemented solutions have done little to reduce the
magnitude of the problem—both in number of sites remediated/returned to
productive use and in prevention of new brownfield sites.
Like toxic hotspots, brownfields may be seen as arising from fragmented
urban development, which allows environmental problems to crop up unnoticed
within communities. Fragmentation is likely encouraged under the private market
system, which often results in frequent property turnover in urban areas.
Fragmentation may be exacerbated by political power (or lack thereof) when
communities exercise influence to either attract or repel certain land uses. This issue
46
is pivotal to the environmental justice movement, which encompasses specific
reference to brownfields (e.g. Byrne and Scattone 2000; Litt et al. 2002; Pastor
2001a, 2001b, 2003; Rowan & Fridgen 2003), because many polluted sites exist in
historically poor, minority neighborhoods with little political power. The notion of
environmental justice as social justice has recently emerged more powerfully in
planning as connections to land use are explored in more meaningful ways. For
instance Goldsmith (1999) argues that issues of race are not simply added on over
and above land use problems, but are so integral to them that without attending to
problems of race in a fundamental and direct way, planning will fail as metropolitan
areas will become even more socio-economically inequitable and the environment
will continue to be degraded. Similarly, Pastor (2001a and 2003) suggests an
important feedback loop between achieving environmental justice by understanding
and strengthening social capital: “our understanding of the EJ movement and its
positive spillover effects can be enhanced if we highlight the central role of social
capital in both triggering environmental inequity and producing environmental
justice.” (2) This direction toward an overarching emphasis on social justice to
implement environmental justice lends credence to the idea that there is a need to
understand the social construction of the brownfield problem instead of simply
responding to its current demographic identity.
Brownfields differ from the not-in-my-backyard (NIMBY) community
development literature because the communities around them identify their potential
harm after-the-fact as opposed to NIMBY cases where communities fight to prevent
47
the placement of a LULU in their midst. Brownfields also may differ from NIMBY
cases because they often result from a situation of weak social capital whereby the
community either lacks the capability or the will to act on a problem property
whereas a NIMBY case arises from a community that exhibits strong social capital in
its activism on the property/site/facility. Although they never mention the term
brownfields, Pollock et al. (1992) posit that a community’s acceptance of LULUs,
particularly hazardous waste facilities, has a great deal to do with attitudes, beliefs,
and values. Their work reveals related public values of what they call “Yes in My
Back Yard” or YIMBY and “Not in Anyone’s Back Yard” or NAMBY. Such
expressions, they find, are tied to public perceptions of risk as well as “views toward
the environment, fundamental views about corporate capitalism, and traditional
concerns about the possibility of successful human control of technology.” (501)
This research approach helps elucidate the different, constructed realities that shape
public perceptions of a pollution problem by recognizing that these arise via a
complex network of influence channels. This method could benefit the body of
research on brownfields.

Barriers to Community Redevelopment
A variety of social barriers exist which contribute to a community’s
reluctance to act on a brownfield site. Apart from obvious pollution concerns vis-à-
vis the threat of the spread of contagion, reluctance may also arise from the
prevailing economic market’s prioritization of private property rights whereby
48
neighboring property owners are hesitant to judge or become involved in another’s
land use decisions. This idea is central to a discussion of the roots of brownfields
because it may help to explain why brownfield redevelopment approaches are largely
government-motivated and -driven. McCarthy (2002) contends that brownfields
present a dual land use challenge that must be addressed simultaneously: reducing
barriers to private sector redevelopment and going beyond “just job and tax base
regeneration” by connecting to broader community goals. (287-288) Recognizing
this influence helps to decouple aspects of the social construction of the reality of
brownfields by revealing a tension between respect for individual property
ownership, but a need to uphold the surrounding community’s stake—if not in actual
ownership of the property, in stewardship of its oversight so that discord is not
created in the form of blight, illicit activity, declining property values, or pollution.
The literature documents a decided stigma associated with brownfield
properties, stemming from high costs related to cleanup liability that result in long
periods of land market dormancy—what Geltman (2000) has called “brownfield
paralysis” resulting in a process of “mothballing” properties (6) and what Greenberg
(2003) has called at “best” a “neighborhood black eye” and at “worst” a
“neighborhood ‘cancer,’ spreading its disease to surrounding properties and causing
people and businesses with any options to leave the neighborhood.” (A75)
As these cases become more well known, the stigma of brownfields becomes
more powerful and is manifested in very real behavioral responses within and among
communities. In particular, it sends a negative message to certain stakeholders that
49
are critical to the long-term success of brownfield redevelopment: small businesses.
This reaction is supported in the literature, where Geltman (2000) describes this in
the stages of brownfield evolution as “brownfield traps” when business owners are
afraid to sell or expand their operations and they subsequently mothball or abandon
their properties. (5) Similarly, Bartsch and Collaton (1997) describe the brownfield
creation process as a “vicious cycle of decline” whereby a property owner, unable to
sell a contaminated property, simply abandons it, and such vacated sites attract
robbery, vandalism, arson, and “midnight dumping”; these brownfields devalue
neighboring properties. (2)

Environmental Injustice
Brownfields are closely aligned with the literature on environmental justice
because they arise from a situation of disparity in social capital—between the people
who have the power to take action on a site and the people who have to live with it,
“where social capital is strongest in a region or a state—as measured by the equity in
the distribution of income and power—the environment is in better shape.” (Pastor
2003, 91) However, as the ensuing case discussion of Los Angeles will demonstrate,
city brownfield programs, which are designed to rectify this problem, often
exacerbate it because they take ownership of the solution (an important element of
social capital and, particularly, of assigning expressive meaning to the environment)
away from communities. This happens in a top-down manner when problem
properties are taken over by local governments until determinations can be made
50
regarding their ownership status, level of contamination, liability assignment,
cleanup regimen, and redevelopment potential. The government then dictates how
this process will be conducted, but a long delay can result while public entities seek
the necessary funding and technical resources to redevelop the site in accordance
with the law and the market. This scenario, when repeated, may reinforce a variety of
beliefs, including that government can and should be responsible for solving
pollution problems, that highly-technical solutions are beyond the understanding of
local residents, and that areas left with long-standing brownfields are not important.
The environmental justice literature examines issues arising from the
distributional consequences of pollution (both in the U.S. and internationally, e.g.,
Martinez-Alier 1998) that has resulted in the greater likelihood of poor, minority
residents to live in close proximity to environmental hazards, including brownfields.
In the U.S. it is well understood that environmental justice communities often lack
political advantage; however, what is less well known is the timing associated with
disadvantaged communities and the occurrence of environmental risks, such as
brownfields. Pastor (2003) recognizes that, in some cases, poor minorities might be
drawn to communities with environmental hazards because property values are
lower; however, he finds it more significant that communities within the vicinity of
facilities with records of toxic releases are generally in flux—experiencing rapidly
changing demographics and tenures—which contributes to weak social capital
conditions. This lends credence to the argument that many communities with
brownfield problems may not have the social capital assets necessary to take
51
advantage of regulatory assistance as it exists today. However, it also implies that the
social construction of brownfields in minority communities may be quite different
because knowledge of the problem is arrived at, by, and for different reasons.
Regardless of racial implications, a notable characteristic of brownfield
works on community impacts and involvement is that they focus upon brownfield
cases after-the-fact. For instance, Solitare 2005 examines the “prerequisite conditions
for meaningful participation in brownfields redevelopment” but her case studies
analyze participation at already identified sites. While this is valuable information,
there remains a paucity of information concerning how local residents perceive the
brownfield problem (if at all) without first being informed of it. Current cases
indicate that citizens would become involved in brownfield projects if given the
opportunity; however, the opportunity generally comes about because they are
presented with an identified problem that has at least some funding and technical
assistance support. Or, as is often the case with environmental justice examples,
health impacts are traced back to specific facilities and locations. What remains to be
articulated is whether citizens are willing or able to identify and prevent brownfield
problems without having these dictated to them. Thus, the focus in the literature
tends to be on analyzing community involvement around already-identified
brownfield projects, which is important, but does not lend insight into how much
communities understand about how brownfields are created in the first place.

52
Regional Perspectives: Sustainability, Sprawl, and Smart Growth
At a regional land use scale ideas about the “sanitary city” (e.g., Melosi 1999
and 2004), which chronicles the development of public waste disposal practices to
curb disease as urban dwellers began to live in increasingly closer proximity, also
provide context for brownfields. As cities grew, issues of waste disposal became
paramount because trash and sewage could not be safely disposed of on individual
parcels. Modern infrastructure was developed to handle these in the aggregate and
the negative consequences were thereby physically removed from communities and
concentrated at a much larger scale in water treatment plants, incinerators, and
landfills. In this way, environmental pollutants were combined, magnified and
hidden. This meant that risks were not reduced, but moved away from population
centers. The brownfield problem reflects an understanding that pollution is no longer
distant, but very much in our midst and the general lack of understanding
surrounding brownfields indicates that, like toxic hotspots, they have caught us by
surprise.
A key similarity between brownfields and toxic hotspots is the scale of their
spatial effects. The pollution (or potential pollution in the case of brownfields) is felt
most acutely at the local level; however, the problem is best understood at the wider
community or regional level. Using the example of the toxic hotspot referenced
previously, the gas station, freeway, autobody shop and dry cleaning plant serve a
wider regional community, but the local community in the vicinity pays
disproportionately in terms of environmental pollution resulting from these land
53
uses. In regard to brownfields, the local community may pay a similar cost in terms
of actual contamination—such as soil or groundwater contamination—or in terms of
blight when a property is left idle and attracts illegal dumping or other illicit
activities. However, seen on a regional scale, undeveloped brownfields contribute to
urban sprawl when greenfield land is preferred for development. This scenario is
often addressed in reference to smart growth (e.g., Green-Leigh 2004), which views
brownfields as urban infill opportunities—a strategy to combat urban sprawl (See,
e.g., Lopez & Hynes 2003; Steinacker 2003; McCarthy 2002), which is understood
as a challenge to achieving sustainable development.
The most widely-cited definition of sustainable development is that of the
World Commission on Environment and Development—known as the “Brundtland
Commission” because of its chairperson, Gro Harlem Brundtland—which presented
the definition in the now-famous 1987 report, Our Common Future: “development
which meets the needs of the present without compromising the ability of future
generations to meet their own needs.” (WCED 1987, 43) This definition, established
as an overarching goal for planners and policymakers, was formally endorsed by
many nations at the 1992 Rio de Janeiro Earth Summit through their pledges to enact
Sustainability Plans by 1996 as outlined in the United Nations document, Agenda 21.
(Newman and Kenworthy 1999, 21) Sustainable development, particularly how it is
implemented in urban areas, is a visible and ubiquitous trend in worldwide urban
development policy and planning. (World Resources 1996-97; Haughton and Hunter
1994) Sustainable development is relevant to the problem of brownfields because it
54
allows application of a regional lens, “it is futile and indeed virtually meaningless to
attempt to create a sustainable city in isolation from its broader hinterland area.
Moreover, it is necessary to see that cities make other contributions to global well-
being that make a purely local focus on their environmental impacts potentially
unhelpful.” (Haughton 1999, 234)
Brownfields may be viewed as a quintessential sustainable development
problem because they clearly evoke its major elements: the economy (when property
is left idle, tax revenues are lost, and neighboring properties are devalued), the
environment (when land, air, and/or water contamination result), society (when
blight is generated or social capital is depressed) and regionalism (when they are
posed as the antithesis of greenfield development, which catalyzes sprawl).
Generally speaking, the literature on smart growth has emerged as a means to
encourage planning that will achieve sustainable development objectives. The
redevelopment of urban infill in general and brownfields in particular is understood
as a smart growth strategy because it capitalizes on development in areas with
existing infrastructure and market amenities (e.g., Green-Leigh 2004). McCarthy
(2002), among others, advocates that governments need to create incentives that
make brownfields more attractive than greenfields, “required is a fundamental
change in federal, state, and local policy and spending to benefit metropolitan
regions as a whole by equalising or perhaps even tilting the balance in favour of
brownfields and away from greenfields.” (294)
55
Seen this way—as a regional problem and solution—brownfields have the
potential to be addressed more systematically, which would counter the piecemeal
nature of current redevelopment trends; however, larger-scale approaches like zoning
and redevelopment districts, because of their stress on the instrumental aspects of
cleanup success (vis-à-vis economic indicators), have not proven effective in
resulting in socially-just outcomes. The answer likely lies somewhere in between—
when brownfield redevelopment can be connected to community goals (McCarthy
2002), land access rights (Dixon 2003) and plan development (e.g., Hynes 2003 in
her discussion of citizen involvement in the cleanup of the Chelsea River near
Boston, Massachusetts: “the best chance for the community to gain better river
access remains participation in the overall master-plan development process.” (292)).
In their statistical analysis of surveys evaluating brownfield redevelopment,
Lange and McNeil (2004b) pose a question to determine how successfully
brownfield remediation results in positive new outcomes as, “Clean it and they will
come?” They conclude that environmental concerns are not the only factor in
determining the success of brownfield redevelopment. Instead they suggest that
“time to occupancy, total development costs, community support, proposed land use,
condition of the local infrastructure, willingness of lending institutions to participate
in the financing, support of local politicians, availability of financial incentives, and
number of jobs to be created” are also influential factors and conclude that,
“successful brownfield development cannot be accomplished by simply addressing
the environmental issues.” (101)
56
Taken together, these elements point to a need to examine the social
construction of brownfields and they underscore the importance of articulating the
expressive meaning inherent in them.
57
Chapter 3:
The Constructed Reality of Brownfields

How does abandoned, unused or polluted land acquire social meaning as
brownfield? Why are brownfields prioritized in American political culture? How do
these questions of origin and political context explain not only the emergence of
brownfields but how are they also probative for the persistence of brownfields in the
future?
Perhaps because of an emphasis on technical meaning, there is an assumption
in the scholarly literature that once contemporary science certifies a property as
clean, the problem is solved and a brownfield is replaced by clean land. Anecdotal
references to a legacy of industrial development and its resultant contamination and
brownfields’ connotation with major cleanup programs, such as those falling under
Superfund, have helped to reinforce this view. Yet, today’s reality of small,
abandoned, overlooked brownfields tells a different story that is about much more
than clean soil. To find a successful new use, these smaller, overlooked brownfields
must not only be scientifically clean, they must also successfully fight against
entrenched pollution beliefs that have stigmatized them as taboo.
This chapter will focus on several important social aspects of the brownfield
problem, such as the language used to communicate about brownfields, the
stakeholders who speak the language and validate the body of knowledge that
upholds the concept, and the institutionalization or societal ordering of how the
problem is defined and addressed. Drawing from Berger and Luckmann’s (1966)
58
thesis that all realities are socially constructed as well as Douglas and Wildavsky’s
(1982) modification that the risks and methods to address those realities are not only
socially constructed, but culturally-biased, I suggest that brownfields are traded as a
cultural currency that few people understand in the same way. Therefore genuine
improvement cannot happen unless underlying social motivations of the problem and
how they are expressed are uncovered and made explicit.
In other words, the task is to bring the expressive meaning of brownfields to
the planning and policy processes. Such a development would certainly help
communities to take ownership of the brownfield problem and to assist in the
implementation of solutions. The tension between instrumental and expressive
meanings is, however, fundamental. And so while recognizing the importance of
expressive meaning would allow intentions to be aligned in the right direction, still
needed would be an understanding of how the values and beliefs concerning
brownfields arose, why instrumental meaning is venerated while the expressive lost,
and why the social construction of brownfields ends up consistently privileging
instrumental over expressive. My approach in thinking through these issues is to
take community brownfield redevelopment as a recurring process of what Douglas
(1966/2002) refers to as “ritual purification” that encourages communities to reflect
upon and revisit the values and beliefs underlying their knowledge and practice
concerning brownfields. The literature on social construction is particularly helpful
in this regard.

59
The Literature on Social Construction
Brownfields trace their roots to complex social processes, including
deindustrialization, that have left degraded, neglected land in primarily urban
neighborhoods. Although they never invoke the term “brownfield” it is clear that the
“landscape dereliction” Jakle & Wilson (1992) describe is relevant to understanding
the root causes of brownfields. They contend that this process involves a concerted
societal neglect, “Americans generally ignore dereliction in commonly used places.
As a result, Americans have come to accept whole categories of decline as somehow
natural, when decline is in fact a societal construction.” (xvii) Similarly, Lynch
(1990), who also does not reference the term “brownfield” documents the land
degradation process as “wasting away” and offers it as an evolutionary cycle:
“Landscapes shift from one function to another, are abandoned and reoccupied, take
on new forms, revert and occasionally are changed irretrievably. The wastes of
successive occupations accumulate and become part of the nature of the land.” (103)
In both cases, human agency is highlighted—in the first for neglect and
irresponsibility and the concept of decline as natural is mocked while in the second
human shaping of the landscape, including waste generation, is not viewed as
nefarious at all, but natural. In brief, Jakle & Wilson separate social construction
from what is considered natural and Lynch sees the two as symbiotic. Although each
perspective elicits something of the social origins of brownfields, to date no research
has truly questioned these in a systematic way. Many accounts have addressed the
emergence of brownfields in certain neighborhoods or cities, e.g., Gorman’s (1997)
60
“Manufacturing Brownfields” in Neville Island, Pennsylvania. However, the term
itself and its widespread acceptance remain to be analyzed. For instance, there has
been no inquiry into the semantic underpinnings of the term, such as why there is a
pejorative connotation of the color “brown,” which is arguably culturally-
subjective,
14
or the spatial reference “field” which may indicate a blank slate, a
tabula rasa, for policy and planning involvement in a piece of land (although very
few brownfields are actually open fields).
There is, however, a vibrant literature on social construction outside the
discourse on the brownfield problem and some of this literature can be used to
inform the understanding of brownfields. For instance, Evernden’s (1992) work on
the social construction of nature is useful as is the work on pollution (Hawkins 1984;
Edelstein 2004) and risk (Nelkin 1989). Evernden (1992, 6) discusses the “social
creation of nature” and in so doing alludes to its converse—that which degrades
nature or pollution—with the idea of pollution being “used as a means of social
control.” Like Douglas (1966/2002), he makes an overt link between pollution, its
instrumental understanding (vis-à-vis measurement standards) and corresponding
moral implications:
…‘unnatural’ behavior can be discerned by the consequences to nature itself
of environmental pollution, consequences that can be expressed in the
manner most persuasive to contemporary society: quantitative measurement.

14
In Analyzing Cultures (1999), Danesi and Perron refer to the predisposition of speakers of certain
languages to classify colors in a certain way and they discuss colors as a “signifying order,” stating
that “meanings captured by one signifying order in no way tell the complete story about the world”
since the order “always leaves gaps, offering up only a portion of what is potentially knowable in the
world.” (99) The reference to colors in language is also certainly influenced by other cultural
traditions and beliefs, such as the association of purple with royalty or funerals (e.g., ceremonial
robes), white with purity (bridal gown) or surrender (flag), red with anger (to see red), and black with
poison or danger, (black magic).
61
Being able to determine the ‘parts per billion’ of a contaminant enables the
environmentalist to argue that pollution has indeed occurred, and thus to infer
that the entire position of the polluter is untenable—the polluter has clearly
done something ‘unnatural’ and in so doing has placed nature, and ourselves,
at risk. The polluter is condemned not only for a physical pollution but also,
implicitly, for a moral pollution that is revealed by the physical pollution. (6-
7; italics in original)

Here we see the link between a technical or instrumental understanding,
quantitative measurement, and moral sanction. Moving from pollution to the
specific case of brownfields suggests a hierarchy of blame, which is borne out in the
rhetoric concerning actors, such as the suggestive references to “potentially
responsible parties” and “innocent landowners.” Hawkins (1984, xiii) also supports
a moral understanding of pollution, claiming that enforcement of pollution control
“is a consequence of moral rather than technical evaluations.” The moral
foundations are “recognizable to people, and a perceived identity of values shared by
the enforcer, the regulated, and their interested publics grants the enforcement of
regulation a more secure footing in an environment of ambivalence.” (Ibid.) This
implies a need for common understanding and a need for the reduction of uncertainty
so that mutual trust may be forged between the regulators and the regulated as well
as the parties affected by them. Brownfields, then, may be considered a type of
pollution—particularly a kind of human-generated pollution that involve moral
decisions regarding perpetration of a wrong by certain organizations and individuals
against others.
The social understanding of pollution has been addressed in the literature as
a highly-institutionalized construct, such as by Hawkins (1984), who claims
62
pollution is “an administrative creation” (23) and, more recently, by Edelstein (2004)
who identifies a “societal meaning of pollution” associated with modern Western
culture. He describes this as a “culture of contamination” and constructs a frame
around four “pillars of denial” (245) as follows:
(1) The Water Closet Model: an “ease of flushing human wastes
mysteriously ‘away’ and viewing waste streams as “easily
transferred downstream to become someone else’s worry” (245);
(2) Mal-Consumption: increased “consumption and waste way
beyond…actual needs” adopting a “culture of obsolescence”
(246);
(3) Technological Optimism: following a period of “disillusionment
with politicians and their inability to cope with a world of
increasing complexity, Americans came to revere engineers’
awesome insight into the world of hard facts” (247), which also
resulted in a fallacy involving “the assumption that problems can
be solved unto themselves, isolated from the complicating factors
and uncertainties of an overly complex world (Ibid); and
(4) Normative Complicity: “people collude with the establishment”
and they “define their welfare in terms of economic well-being,
not in terms of public health” which derives from a “greater desire
to bury the bad news than to bury the pollution.” (251).

63
Each of these pillars sheds light on the social construction of brownfields in a
Western setting because the very existence of brownfields often means that they are
properties that have become “someone else’s worry” and their frequent abandonment
represents excess in the sense that their ownership value is perceived to be less than
their abandonment value (exhibiting “consumption and waste way beyond…actual
needs”). Moreover, their control by instrumental processes and actors reflects a
technological optimism (reverence for technical or legal fixes) and they often occur
in economically-depressed areas. These qualities of brownfields indicate that they
may be compatible with Edelstein’s idea of the Western social idea of pollution;
particularly his telling question “What is the meaning of pollution, not just for
society but about society?” (246)
Similar sentiments appear in other writings, e.g., Dunlap et al. (1993, 250),
who discuss the issue of toxic facility siting decisions and propose an account that is
reminiscent of the instrumental-bias inherent in brownfield policy:
Defining a problem as scientific or technical sets the stage, arranges the
props, and casts the actors who are ‘qualified’ to take part in its solution.
Because citizens lack an understanding of the scientific details of complex
technological problems, they are pushed off the stage of key decision
making—viewed by some insiders, if not publicly, as idiots, at least as
unqualified to make informed judgments.

Indeed, the idea of brownfield as a pollution problem—and particularly the
reliance upon technological solutions—moves it into the realm of risk and how risk
is socially-perceived. Indeed some studies of risk (e.g., Nelkin 1989, 96) have also
come to recognize that “risk is in part a social construction” and “evaluating risk is a
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social process.” Nelkin echoes Edelstein’s claim of an “unquestioned faith” in
technological progress since World War II and claims “most risks are intrinsically
uncertain and therefore the focus of scientific dispute.” (Ibid.) Connecting this to the
asymmetry between experts and laypeople, she argues that some people “define risk
as a problem that requires expert solutions” while “others seek more participatory
controls” (101) and this is, certainly, a product of expressed socio-cultural
preferences.
Thus, by uncovering some of the complexity of the brownfield problem by
understanding it as a potential that is opposite to nature, a proxy for pollution, and as
a signal of risk, deeper questions emerge in investigating the social construction of
brownfields, such as how are they distinct from the idea of pollution itself, what do
they say about society, and why are they relevant now? The lack of answers to these
questions becomes significant when we recognize that brownfields are socially-
constructed because the term, its prolific usage, and the meanings it carries with it
function as contemporary currency in policy and planning circles yet we don’t really
understand what brownfields are and where they come from—and, by extension—
how to prevent them and who may accomplish this. No one has yet questioned
whether brownfields are even worthy of focus. Or, what gets overlooked while we
focus on brownfields? And, what gets automatically exalted in our process of
demonizing brownfields?
Academics are likely to associate social construction with Berger and
Luckmann’s (1966) The Social Construction of Reality which is concerned with how
65
knowledge becomes “socially established as ‘reality’.” (3, italics in original) At a
basic level, this recognizes (p.48) that “the organism and, even more, the self cannot
be adequately understood apart from the particular social context in which they were
shaped.” For Berger and Luckmann language is a critical sign system that fuels
social construction by allowing diverse things and ideas to be captured in a few
words:
Language provides…a ready-made possibility for the ongoing objectification
of my unfolding experience…language is pliantly expansive so as to allow
me to objectify a great variety of experiences, allowing me to subsume them
under broad categories in terms of which they have meaning not only to
myself but also to my fellowmen. As it typifies, it also anonymizes
experiences, for the typified experience can, in principle, be duplicated by
anyone falling into the category in question. (37)

Others have recognized the role of language both in making social
construction possible and in providing clues to the social meaning of concepts. For
instance, Nelkin (1989) discusses the power of metaphoric language in
communicating risk, “Metaphors in science journalism cluster and reinforce one
another, creating consistent, coherent, and therefore powerful images that often have
strategic policy implications” such as when technology is linked to “…‘frontiers’
that are maintained through ‘battles’ or ‘struggles,’” and this imagery of war infers
that “experts should not be questioned.” (107) Parallels may be drawn between the
degraded “brown” field that is construed as the polar opposite to the pristine “green”
field and when contagion is implied through the use of the term brownfield as
“blight” and “cancer.”
66
Conversely, the instrumental language of brownfields in both the literature
and in practice—focusing on soil chemistry, remediation technology, creative
financing/insurance mechanisms, and structured ad hoc community involvement—
serves to rob communities of a regular, ritualized role in defining and solving their
pollution problem for themselves. Instead, the problem is dictated to a community in
technical terms or it is simplified for redevelopment expediency. Put differently, the
accent on regulatory meaning makes the concept of brownfields reductionist: it
reduces the problem, oversimplifying it to see a brownfield only in terms of its
economic development potential. As a result, a property is no longer, for instance,
Joe Maloney’s corner grocery store, but is now a “brownfield” that falls within the
purview of the local government which will clean it and direct its use for economic
revitalization.

A Constructed Brownfield Culture
The placement of the brownfield problem within the legal system and the
attendant liability of owning a brownfield can be seen as the social choices that we
have made to address this particular risk—an idea that has come to us from Douglas
and Wildavsky’s Risk and Culture (1982, 35): “To understand principles of liability,
we have to uncover the kinds of social goals adopted and the strategies used for
reaching them.” In this sense, both the legal and economic perspectives of
brownfields rely on regulatory power to achieve their intended, but different,
outcomes. However, regulatory meaning makes the concept of brownfields
67
exclusionist because it is not as widely understood at the grassroots level. Rather, its
professionalized meaning puts it under the purview of government officials, lawyers,
planners, and engineers, who can easily speak the regulatory language that gave birth
to the idea of brownfields, while distancing it from the non-specialist citizen who has
little understanding of the regulatory world. This helps to see, as Solitare (2005,
920) has pointed out, that the participants in brownfield redevelopment are “those
who already have power, and thus could use participation to further enhance their
position.”
Although local support for brownfield redevelopment is recognized as
important, communities are often barred from taking advantage of brownfield
funding and institutional assistance because they “suffer generally from lack of
organization, inexperience with complicated projects...and mistrust of outside
parties” as well as a “lack of understanding and sophistication about what is needed
to accomplish brownfield redevelopment and to address deep-seated economic
development challenges” (Brachman, 2004, 77). Regardless of the intent, this may
well lead to what Sherry Arnstein (1969) has described as “tokenism” in her “ladder
of citizen participation” and perhaps, in anticipation of this, some in the brownfield
community have called for a greater role for non-profits and community
organizations given the complexity of the development effort and the limited
capacities of CDCs (community development corporations). (Dixon 2003)
This suggests that the term “brownfield” may have become associated with
complicated and distant government and also how the neediest communities likely
68
cannot attract attention. At a basic level, this implies that the cases highlighted in the
literature are not representative of the most challenged brownfield communities.
Too, when already active and engaged communities are consistently rewarded with
external attention and funding for their brownfield projects, it may send a message to
other communities that they are less worthy of this assistance and, worse, dampen
their hopes of even trying to tackle the problem. This perspective allows us to see
that the process could result in “blaming the victim” for less politically-empowered
communities and it suggests that in order to best tackle their brownfield problems,
communities should conform to the type of model that can best attract external grant
assistance. This is problematic because it assumes that the predominant way of
ameliorating brownfields (through lobbying for external assistance) is the most
promising method. It also raises concerns that a pathology will be set in motion
whereby communities will become dependent upon external solutions to their
pollution problems when the term “brownfield” emerges in their discussions of land
use management.
Thus, an important contributing factor to the problem of brownfields is that
people begin to rely on governments to assume problem-solving functions that were
formerly done by individuals and small groups—even when the conditions
surrounding how their brownfield problems have arisen may differ. For instance, in
reference to media coverage of nuclear power plant accidents, Nelkin (1989)
discusses how a series of smaller-scale accidents were treated as isolated events by
journalists, making the risk visible in a certain frame or context—in this case as
69
“isolated events”—which did not make sense in relation to one another until the
high-profile Three Mile Island case occurred. Regarding brownfields, the high-
profile nature of Love Canal resulted in the “Superfund” solution, which then came
to influence the evolution of the brownfield problem as lurking, unseen evils,
although this is hardly relevant today. However, the stigma persists and a pathology
has emerged which prescribes top-down, government-driven solutions that have
served to drive out grassroots alternatives.
This historical perspective also shows how brownfields cannot be divorced
not only from ideas of risk perception, but also from risk acceptability—something
Mary Douglas wrote about in 1985, “Western industrial nations have been roused by
nuclear radiation, chemical wastes, asbestos and lead poisoning. In response, an
important new subdiscipline of the social sciences has emerged which specifically
addresses questions asked by industry and government about the public perception of
risk.” (5) Specifically, brownfields signify risk because of their threatening nature;
they are tied up in a social context that influences risk perceptions and codifies risk
acceptability, “Since the present distribution of risks reflects only the present
distribution of power and status, fundamental political questions are raised by the
justice issue.” (10) In particular, justice and fairness influence how a society chooses
to organize its environmental pollution; such as how modern infrastructure has
allowed cities to move their pollution away from population centers in a magnified
form (e.g., to landfills and wastewater treatment plants), but this, again, raises issues
of morality and ethics:
70
When a greater damage to a larger population can be avoided by
relocating a dangerous industry to a sparsely settled area, fundamental
ethical issues are raised. It is true that in a desert with a thin scattering
of Indian tribes, fewer people will suffer damage. But why ever
should the Indians of the American Southwest, already burdened by
economic and health disadvantages, agree to be sacrificed to the
greatest happiness principle? Should the price of a life be uniform for
all lives? Should the compensation be related to earning power?
Should a young person’s life be counted more than an old person’s
because its expected span of earning has been cut off short? The
earning power principle comes into flagrant contradiction with
equality. Intuitively, giving more risks to those who carry more
smacks of elementary injustice. (10)

Such moral issues are at the heart of environmental justice in general, but this
passage articulates well how societies identify and balance their pollution risks often
without fully understanding the remote spatial and temporal implications. For
instance, we can more easily understand when an environmental justice issue has
arisen because we can point to the moral predicament of a hazard and a victimized
population, but what about a hazard that systematically creeps up on us—like
brownfields—when behavior can be traced to individual agency? Indeed, it is
difficult to think harshly about the many individuals’ decisions to leave a light on in
an empty room, yet this behavior very palpably contributes to an increased demand
for energy that could result in the construction of a new coal-fired power plant in a
distant community. The moral implications of this scenario are not so obvious, yet
they still reflect societal valuations of risk and pollution. In the case of brownfields, a
single, large abandoned industrial facility provides ready culprits and clients, yet
smaller properties left idle for speculative value or vacant because of perceived
71
contamination and a fear of liability can combine to spread a climate of blight that, in
turn, encourages consumption of distant, pristine land.
Also less obvious is the notion of an urban bias whereby the solutions to city
problems are shifted to the hinterlands and disguised in language and practice that
cannot be understood by those in the countryside. This is valid in the case of
brownfields because they are a decidedly urban concern although rural brownfields
have begun to receive attention in recent years (e.g., NADO 1999, Singer 2002). As
the problem plays out, an urban solution becomes the favored one, which gets
transmitted to non-urban settings. Thus it is no coincidence that the most high-profile
brownfield success stories are in prominent urban areas. Seen this way, the context
of risk and fairness helps explain why brownfields are a contemporary problem in
the U.S.—because of a history of discovering and interpreting contamination in a
certain way (societal perceptions of risk) and a federalist governance structure’s
availability to address the issue (determining what is acceptable risk and how to
distribute it), “The public reception of any policy for risks will depend on
standardized public ideas about justice. It is often held that perception of risk is
directed by issues of fairness.” (5) Douglas and Wildavsky (1982) and Douglas
(1985) firmly tied risk interpretation and acceptability to culture, e.g., “the issue of
acceptable risk lies with the principles of valuation itself, that is, with culture.”
(Douglas 1985, 14) Although when she wrote in the 1980s, the brownfield problem
was nascent and took the form of large, obvious contaminated sites such as Love
Canal, Douglas’ premise provides insight into the evolution of the problem today.
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Brownfields are no longer far away and easily identifiable; their culture has changed.
Instead, they are often small and interspersed within existing, operating businesses
and near occupied residences. However, the way that risk has been institutionalized
in the U.S. is incompatible with the contemporary reality of the brownfield challenge
because it has not changed in concert with culture.

Uncovering Expressive Meanings in the Instrumental
Where communities are addressed in the brownfield literature, it is generally
a highly-structured involvement process that has been created in response to an
identified brownfield problem. Here, social construction has an interesting meaning:
the brownfield problem is created and a community is then constructed around the
constructed problem. Indeed, to deal with brownfields a generic regulatory model is
replicated again and again across very diverse communities. A pathology results
when language assumes understanding and recognition that is not indigenously-
generated. Stripping away the bureaucratically-enforced jargon (e.g., Phase I
remediation, responsible parties, all appropriate inquiry, innocent landowner
defenses, comfort letters, no further action agreements) uncovers some very basic
implied messages about brownfields:
(1) Brownfields are bad (They deserve attention.);
(2) Brownfields are pollution (They could spread and therefore, they are not
only of the individual, but require engagement with the environment or
society or the “other.”);
73
(3) Brownfields are dangerous (They must be controlled.);
(4) The government knows what brownfields are and can determine what is
and is not a brownfield (This is law.); and
(5) People must work with government to fix a brownfield problem (They
will be rewarded and punished based on their association and this is law).
Without knowing anything else about the technical practice of brownfields, it
is clear from these messages that important, socially-constructed ideas about
pollution and the ordering of pollution have emerged in the U.S. response to
brownfields. Not only is the nature of construction important, but so are the
methods: technical language, regulatory enforcement, and hierarchical bureaucratic
institutionalization.
The language used in reference to brownfields infers value judgements not
only about brownfield property owners and occupants, but also about the
communities in which they exist. Examples of implicit meanings in brownfield
language are that “derelict” as a descriptor for land implies “irresponsibility” on the
part of the owner/responsible party/community; “vacant” implies “neglectful”;
“underutilized” implies “unwise or ignorant investor” because a better use is
obvious; “abandoned” implies “unwanted and unimportant”; and “contaminated”
implies “infected, impure, and undesirable in its existing form.”
If we begin to breakdown the messages and the methods behind this, it
becomes clear that other influences are apparent as well since the language chosen
signifies a social ordering: “Because of the capacity to transcend the ‘here and now,’
74
language bridges different zones within the reality of everyday life and integrates
them into a meaningful whole. The transcendences have spatial, temporal and social
dimensions.” (Berger and Luckmann 1966, 37) These dimensions in relation to
brownfields may become real as follows: space is controlled by fencing and walls
that physically separate brownfield properties from public access. They often attract
dumping, graffiti, and other visible signs of decay that make them function as
blemishes in the urban landscape. Regarding time, a legacy of slow redevelopment
that follows an entrenched bureaucratic process means that brownfields languish and
establish a very slow cycle of reuse that is felt throughout the neighborhood.
Socially, a problem that is not well understood, but persists over a long period of
time likely fuels frustration in the short-run, but acceptance in the long-run as a
record of unresponsiveness yields a significantly desensitized toleration.
The professionalization of any idea or subject can alienate participation of a
diverse group of people when they begin to feel that they do not understand the
language or that they lack power to influence change, but this can be magnified over
time when an historically alienated population loses faith in even trying to participate
and the professionalized institution does not respond to changes in culture. In this
way, the subject of brownfields has become something of its own culture, “Any
complex of symbols can take on a cultural life of its own and even acquire initiative
in the development of social institutions.” (Douglas 1966/2002, 170)
For environmental problems in the U.S. (including brownfields), an activist
population was the catalyst for change, which took the form of a bureaucratically-
75
institutionalized system of response. However, in the case of brownfields, this
system has proven inflexible since it is still geared to address the large, contaminated
Superfund-type sites of the 1980s and 1990s.

Institutional Adaptations of the Brownfield Problem
Rachel Carson (1962/2002) catalyzed the notion of a public’s right to know
about what government-sanctioned scientists were imposing on them via blanket
pesticide spraying that had damaging ecological consequences. Her assertion was
not that the average citizen should be trained in chemistry, but that scientists and
governments had a responsibility to translate their work into terms the public could
understand—creating and preserving a system or culture of checks and balances that
allowed community input into the practices of environmental impact. Her work
eventually resulted in establishment of the U.S. Environmental Protection Agency;
an organization tasked with ensuring that the public is informed and engaged in
issues that impact their environment. However, in the case of brownfields, the
government has come to dominate the discourse to the point that it is an example of
when the “burden of thinking is transferred to institutions.” (Douglas 1986, 82)
15

The caution here is that the longer the burden of thinking is kept from the
general population, the more they will come to rely upon the government to solve
their environmental problems for them rather than take responsibility for staying

15
Douglas says this in reference to Donald Campbell’s investigation of why “self-knowledge is so
elusive” in trying to understand why psychologists see all conventional and institutional constraints on
individual psychic development as harmful. (pp. 82-83)

76
active and informed themselves. The obvious danger in this is that brownfields will
continue to proliferate and nothing will be done to prevent their continuing
occurrence.
Reflecting upon the earlier work of Douglas (1966/2002) is helpful in
understanding how attitudes towards brownfields become divorced from individual
agency. Her anthropological perspective on pollution ordering as ritual purification
helps to show that (1) the U.S. system of brownfield cleanup is an example of ritual
purification (vis-à-vis regularized, repetitive practice) that has deferred power to a
remote, centralized collective and (2) it does not reflect local knowledge in allowing
individuals within communities to first determine what is pure and what is dangerous
and how to organize these.
Both Rachel Carson and Mary Douglas recognized the importance of
awareness to changing perceptions of pollution risk acceptability over time. Douglas
stated that ideas of purity and impurity are sensitive to change, “The same impulse to
impose order which brings them into existence can be supposed to be continually
modifying or enriching them.” (Ibid., 5) and Carson claimed that “what the public is
asked to accept as ‘safe’ today may turn out tomorrow to be extremely dangerous.”
(Carson 1962/2002, 224) What underlies these contentions is the idea that pollution
systems should be reflexive in order to make sure that new contagion possibilities do
not catch us by surprise. In other words, by focusing our attention on what is or is not
a brownfield diverts our energies away from uncovering what might be a larger,
more complex pollution problem in the future.
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An example of this is the preoccupation with solving the air quality problem
in the U.S. in the 1970s. Vehicle fuel was identified as a major culprit in the problem
and then the solution became altering the composition of fuel so that it would burn
cleaner. The technological fix was the use of methyl tertiary butyl ether (MTBE) as a
fuel oxygenate and it was authorized for widespread use. However, no
comprehensive evaluations of MTBE’s impacts on other aspects of the environment
were estimated and although it may have achieved air quality improvements, it
resulted in water contamination problems through runoff that meant the closure of
many municipal drinking water supplies. Thus, like Carson’s account of widespread
pesticide application in the 1950s, a solution for one problem resulted in a much
worse problem in other environmental constituents.
Similarly, in the case of brownfields the ad hoc, piecemeal approach to
cleaning up one property after another may be seen as a wide-scale but myopic
solution to a much larger problem of community social degradation. In the case of
MTBE, the technological solution was chosen, but why? Was it because it was
expeditious and easy? Or because individuals could not be relied upon to drive less
or identify other ways of reducing air pollution? The answer is certainly very
complex, but it has everything to do with how societal beliefs, attitudes, and values
determined answers to questions such as (1) which risk/pollution problem to address;
(2) who had decision-making power over the solution; (3) what the range of
solutions could be; and (4) what sacrifices would be tolerated. This became the
socially-constructed purification ritual for brownfields.
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Articulating an Expressive Meaning for Brownfields
Douglas (1966/2002) contends that pollution ideas work on two levels: the
instrumental and the expressive. Both are important in establishing cultures of ritual;
both help establish consensus, “rituals of purity and impurity create unity of
experience.” (3) The instrumental recognizes that there are near-universal truths,
“The whole universe is harnessed to men’s attempts to force one another into good
citizenship. Thus we find that certain moral values are upheld and certain social rules
defined by beliefs in dangerous contagion…” (4) But the expressive reflects the
relevance of these truths to individuals and asks that they accept or deny—express
faith or doubt—in the prevailing truths. Brownfields are instrumentally-bound ideas
of what society calls pollution yet they are not often relevant to local citizens
because individuals have not engaged in any expressive understanding or
identification of them. This implies that involving communities in the ritual process
of purifying their own lands on their own terms may be an effective approach to
ensuring that contamination problems are anticipated and avoided.
Fundamentally, this indicates that the problem of brownfields cannot be
solved without examining why they arise in the first place. This may be initiated by
examining issues of property access and ownership. Recently scholars have begun to
look at non-monetary stewardship as types of ownership rights to land; Boyce (2003)
presents this as “access to natural assets” via the contention that both poverty and
environmental degradation can be addressed in concert by encouraging the
democratic ownership of natural assets (e.g., air, water, land, and rights to their
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use/development). His idea is based upon the premise that poverty “is not simply a
lack of income today but also a lack of assets that will yield income and other
benefits tomorrow.” (8) This is related to Amartya Sen’s (1999) idea of capability
deprivation. It becomes relevant to the understanding of brownfields when we see
that a preoccupation with an instrumental meaning of the problem that results in an
external bureaucratically-imposed solution deprives citizens of the capability to
identify, define, and create a solution for themselves.
In particular, although the private property market allows people to freely
own and transact land in the U.S., the emergence of brownfields deprives them of
that capability because the problem grows from social tensions such as: individuals
should do what they want with their land, but individuals make socially irresponsible
decisions with their land (brownfields) and cannot be trusted. Also, individuals
should not tell others how to use their land, but the government should (through
brownfield regulation and enforcement).
The latter may be an alteration of Wildavsky’s “speaking truth to power”
because it is an example of speaking truth through power whereby individuals accept
the dominance and direction of an anonymous outsider (here, a government agency)
in controlling land pollution. They accept this in place of taking action themselves.
In the practice of brownfields it means that neighbors do not interact with neighbors
directly when a brownfield problem arises, but they go through government channels
to act locally—to ensure that their neighbor’s land use behavior is ordered
accordingly. Why would this be the case? One answer is that there is a lack of trust
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inherent in American society that is evident in the brownfield problem—when
individuals do not expect others to be good stewards of the land, but do expect that
others will be held in check by a distant other. This allows us to ask deeper questions
about the reality of brownfields, ones that hint at the quality of life that is constructed
and reinforced every day.
Another way of saying this is that capability deprivation tarnishes the
freedom inherent in a private property market system if its roots are embedded in
institutionalized mistrust. What becomes clear is that much more work needs to be
done in understanding why brownfields persist, why they have become popular in
planning and policy-making discourse now, and, particularly, what they tell us about
the way in which we order what is pure and what is dangerous.

Balancing Generic and Contextual Knowledge in Brownfield Creation
Ultimately, enhancing community understanding of how brownfields come
into being and the role that society and social forces play in the concept’s
construction is important not only for a scholarly analysis of the role of institutions
in this process, but also so that individual stakeholders may understand and thus
affect the creation of future brownfields. However, I do not wish to conclude by
leaving the impression that somehow accenting the literature on social construction
eschews any role for universal standards of pollution and methods of remediation. I
find it instructive here to draw on Amartya Sen’s Romanes Lecture suitably titled
Reason Before Identity, where he argues against the communitarian perspective that
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identity is only detected and not determined. If this is so, Sen (1998) argues that
morality would be parasitic on social identity and would undermine the possibility of
reasoned choice or cross-cultural dialogue, “In a political context, the prioritising of
identity over reason has the effect of rejecting ideas of cross-cultural dialogue.” My
research design (in Chapter 4) engages in cross-cultural insights while making the
case for social construction. This becomes possible even while agreeing with Sen
because of the scholarly context in which the brownfield literature has developed.
The problem with this literature is the disassociation of instrumental and expressive
meanings. Each of these meanings has generic or universal and contextual
underpinnings. Yet, we find that while instrumental meaning has been privileged,
expressive meaning—no matter whether derived from reason or identity—has been
marginalized.
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Chapter 4:
Brownfields in Los Angeles: How Taboos are Constructed

This chapter discusses how the brownfield problem has played out in Los
Angeles, California—an extremely multicultural urban society. Los Angeles was
chosen for analysis because it has a well-developed municipal brownfield program
that includes more than fifty sites in various stages of redevelopment and it has been
consistently recognized by the U.S. Environmental Protection Agency as a model
program through its Showcase Community designation and with continued federal
funding from a variety of sources. Additionally, the Los Angeles Brownfield
Program has been in place for more than a decade and therefore provides a record of
activity adequate for analysis. The case study shows how “brownfield” has become
institutionalized and how its meaning differs at the level of the municipal
government and at the local level.
Three sources of data are used to support the case analysis: surveys of small
manufacturing businesses, which are discussed as key brownfield stakeholders, a
textual analysis of the City’s 35 community land use plans, and survey responses
from representatives of some of the City’s Neighborhood Councils. This approach is
a departure from most of those found in the mainstream literature on brownfields
(e.g., De Sousa 2004; Lange & McNeil 2004a, 2004b; Solitare 2005). These studies
solicit input after brownfields have been identified. In contrast, the stakeholders of
this study may not be aware of the existence of a brownfield or may not recognized
the term “brownfield.” Such a design allows for an understanding of grassroots
83
sentiment toward brownfields among local stakeholders. In turn, this helps identify
and articulate an expressive understanding of brownfields by local residents and
groups. The research asks the following questions: Do local communities define
brownfields in the same way that regulators, planners, and policymakers do? Does
the meaning of brownfields affect the viability of community-level remediation?
Since brownfield policy is usually targeted toward businesses—and is
particularly relevant to manufacturing firms because of their location within
industrial areas—the study is oriented toward these stakeholders, who not only have
a strong economic impact, but an important local neighborhood presence. This
chapter will first present the historical institutional context of the brownfield problem
in Los Angeles, then discuss the emergence of a key brownfield stakeholder—the
small manufacturing business. Ensuing sections will articulate the research design
methodology, results, and summary conclusions.

Historical Institutional Context of Brownfields in Los Angeles
In the City of Los Angeles, the Brownfields Team consists of the Community
Redevelopment Agency (CRA), the Environmental Affairs Department (EAD), the
Mayor’s Office of Economic Development, the Community Development
Department (CDD), City Council offices, and other departments and agencies as
needed. Thus, there is no single agency that controls the brownfields redevelopment
process; each agency transacts a different part. For instance, the Los Angeles Fire
Department regulates the use of underground fuel storage tanks and maintains these
84
records; however, they become critically necessary in assessing a brownfield site’s
potential contamination risk and therefore the LAFD is often consulted in the Team’s
work.
Such a holistic approach is not unusual and it closely reflects the
recommendations of organizations such as the International City/County
Management Association (ICMA). In its review of progress made by Brownfield
Showcase Communities, former EAD general manager, Lillian Kawasaki, succinctly
identified the major barriers to brownfield redevelopment in Los Angeles as
“liability, funds, and city coordination” claiming that the integration of City
functions implied by the last is pivotal:
From a local government management perspective, successful
brownfields programs demand a holistic approach. By itself,
economic development is not new, and neither is environmental
cleanup. But integrating all these objectives with job training,
workforce development, and environmental justice not only is new,
but also is necessary. (ICMA 2001, 214)

The Brownfields Team is evidence of the beginning stages of municipal
integration in the approach toward land remediation and reuse. One advantage of this
approach is the ability to mobilize larger resources in attracting external attention.
The Team works with various federal and state agencies—the USEPA in
Washington, the USEPA Region 9 office, which includes California within its
jurisdiction, and the California Environmental Protection Agency (CALEPA).
Within CALEPA, the agency with primary regulatory jurisdiction over brownfields
is the Department of Toxic Substances Control (DTSC); however other agencies may
85
be included in brownfield projects as needed, such as the State Water Resources
Control Board and its regional affiliates when contaminated drinking water is an
issue. Also, the Office of the State Treasurer promotes the reuse and redevelopment
of brownfields through the California Recycle Underutilized Sites (Cal REUSE)
program of its Pollution Control Financing Authority branch.
Although the USEPA is the federal agency with regulatory jurisdiction over
brownfields, the City Team also works with the U.S. Department of Housing and
Urban Development (HUD), which implements the Brownfields Economic
Development Initiative (BEDI) grant program that has awarded the City grants for
the Goodyear Tract and Cornfield brownfield projects. Also, the U.S. Economic
Development Administration (EDA) and the U.S. Army Corps of Engineers are other
federal sources of support to the City regarding brownfields. In the case of the latter,
as well as the USEPA, federal employees were sent to the City as part of the
Intergovernmental Partnership Act (IPA) whereby they work from City offices to
lend their expertise to the development of the Brownfield Program while their
salaries are funded by the respective federal agencies. Two IPAs have worked for the
Los Angeles Brownfields Program on behalf of the USEPA—one in the
Environmental Affairs Department and one in the Community Redevelopment
Agency.
Another federal resource that has been involved in brownfields elsewhere is
the Agency for Toxic Substances and Disease Registry (ATSDR), which was
established under the federal Comprehensive Environmental Response
86
Compensation and Liability Act (CERCLA or Superfund) as the “principal federal
public-health agency involved with hazardous waste issues and having a
responsibility to prevent or reduce the harmful effects that exposure to hazardous
substances has on human health and quality of life.” (Zarcadoolas et al. 2001, 15)
ATSDR is part of the U.S. Department of Health and Human Services.
The overarching goal of the Los Angeles Brownfields Program and Team is
“to develop effective strategies to enable redevelopment of brownfields throughout
Los Angeles but particularly in disadvantaged communities and to incorporate these
strategies into the City’s normal redevelopment process”. (LABF 2003a) The City’s
brownfield work began to be formalized in 1995 when a federal grant was received
from the U.S. Environmental Protection Agency to fund a USEPA staff person to
convene the Team and develop a work program. Subsequently, in 1997 and 1998
federal grants were obtained to begin work on the large Goodyear Tract and Crown
Coach sites. The Los Angeles City Council adopted a motion recognizing the
Brownfields Program along with the Team in 1997. In March of 1998, the City of
Los Angeles was designated as one of only 16 nationwide USEPA Brownfields
Showcase Communities:

Showcase Communities have three main goals: to promote
environmental protection, economic redevelopment and community
revitalization through the assessment, cleanup and sustainable reuse
of Brownfields; to link Federal, State, local and non-governmental
action supporting community efforts to restore and reuse Brownfields;
and to develop national models demonstrating the positive results of
public and private collaboration addressing Brownfields challenges.
(USEPA 1998)

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Although the City of Los Angeles has been recognized by the federal
government as progressive in its brownfield efforts, the formalization of the program
in the late 1990s may be considered late in terms of implementing CERCLA (1980).
The Brownfields Program budget is comprised of grants from the state and federal
governments along with an allocation of City funds from various sources, including
part of the U.S. Department of Housing and Urban Development Community
Development Block Grant (CDBG) allocations.

Ritual Process: Categories of Site Assistance
Program funds are distributed according to six categories of site assistance
that facilitate various activities such as site assessment, remediation, economic
development, capacity-building, land acquisition, and technical assistance. In the
process of its brownfields redevelopment activities, the City promotes the use of
various tools, such as prospective purchaser agreements, comfort letters, Voluntary
Cleanup Programs, and others. (See Table 1 on the following page.)
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Table 1: Example Policies in the Los Angeles Brownfield Program

Measure Level
Agent or
Agency
Description
Prospective
purchaser
agreements
State DTSC
Agreement issued by a government
body (in this case DTSC) to not pursue
site mitigation enforcement against
prospective purchasers, tenants, or
lessors who become site owners or
operators of a brownfield if certain
conditions are met
Comfort letters Federal
U.S. EPA or
Regional
EPA Office
Government-issued relief, ranging from
a formal legal agreement, releasing a
party from liability for remediation to
policy statements concerning
enforcement discretion
Voluntary
Cleanup
Programs
State DTSC
State-tailored programs to support
property owners that elect to undertake
site assessment or cleanup.
Economic
Zone
Incentives
Local,
State, and
Federal
IRS
implements
Fiscal incentives to businesses/property
owners operating in challenged
neighborhoods to maintain their
operations
Brownfields
Tax Incentive
Federal
IRS
implements
Fiscal incentives to businesses/property
owners to take the initiative in cleaning
up existing contamination
independently
Polanco
Authority
State
CRA,
RWQCB
The Polanco Act authority grants local
redevelopment agencies special,
qualified immunity from state or local
cleanup requirements
Redevelopment
Powers
State/Local CRA Eminent domain

Through prospective purchaser agreements, the DTSC agrees to not pursue
site mitigation enforcement against prospective purchasers, tenants, or lessors who
become site owners or operators of a brownfield if all of the following conditions are
met: they do not exacerbate or contribute to the existing contamination; their
operation will not result in health risks to persons on the site; they allow access for,
and do not interfere with, remediation activities; unauthorized disposal is not
89
occurring on the site; and there are other viable responsible parties who are willing to
conduct any necessary remediation. (DTSC 1998a)
Uncertainty about potential contamination and/or Superfund liability may
keep otherwise interested parties from purchasing or redeveloping brownfields;
comfort letters can be used to “allay the fear of potential federal pursuit of parties for
cleanup of brownfields,” whereby the EPA may provide relief or “varying degrees of
comfort” by drafting in written form the agency’s intentions toward a particular
piece of property. Comfort may range from a formal legal agreement, including a
“covenant not to sue,” releasing a party from liability for cleanup of existing
contamination, to policy statements concerning EPA's enforcement discretion
relating to circumstances or activities of a party at a specific site. (USEPA 2003)
Voluntary cleanup programs are another strategy for managing brownfield
sites. The California program was established in 1993, and it allows DTSC to
provide oversight to motivated parties to assess and/or clean up lower-priority sites.
(DTSC 1998a) These sites are recorded in the “CalSites” database (discussed below)
and reflect a more collaborative process that remains government-driven, but relies
upon more concerted action of the property owner/s.
Economic zone incentives provide brownfield relief based on special
geographic area-based policies. Property owners in Federal Empowerment Zones
(EZ) or Revitalization Zones, State Enterprise Zones, and/or City Renewal Zones
may qualify for tax breaks. The City’s Community Development Department
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provides information about these, but eligible residents must file with the respective
agencies.
To encourage self-motivation in brownfield cleanup, the federal government
offers the Brownfield Tax Incentive. Through this program, environmental cleanup
costs are fully deductible in the year they are expended (not having to be
capitalized). The government estimated that although the tax incentive would cost
nearly $300 million in annual tax revenue, it is expected to “leverage $3.4 billion in
private investment and return 8,000 brownfields to productive use.” (USEPA 2001)
Unique to the State of California, the Polanco Act authority grants local
redevelopment agencies qualified immunity from state or local laws if cleanup is
conducted in accordance with a remedial action plan approved by DTSC, the
Regional Water Quality Control Board or other local agency; liability immunity
extends to property successors and lenders. (DTSC 1998b) According to the Polanco
Act, the CRA of Los Angeles may undertake property contamination assessments
with or without the owner’s consent. This is a powerful challenge to private property
ownership rights and is one of the most aggressive laws concerning brownfields.
Redevelopment powers are a potentially powerful tool that governments can
use to catalyze brownfield cleanup. In addition to its above-referenced Polanco Act
authority, the CRA may exercise eminent domain once the City Council approves a
redevelopment plan for a project area. Eminent domain is the authority (of a
government agency) “to acquire property when it can be shown that the property is
acquired for a public purpose and for the public good and that the owner has received
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a just compensation.” (CRA 2003) In conformity with the Redevelopment Law of
the State of California, the CRA was established by resolution of the Los Angeles
City Council in 1948 and granted with the powers to combat “blight” and ensure the
provision of quality low-income housing; blight is defined as “Deterioration of an
area caused by physical, economic and social forces.” (Ibid.) The CRA is a member
of the Los Angeles Brownfields Team and primarily focuses on those brownfields
with housing reuse potential that fall within redevelopment project areas. There are
more than 30 CRA Redevelopment Areas in the City of Los Angeles; each is
governed by a plan that is referenced in the respective Community Plan.

Brownfield Site Identification and Engagement
Public consultation and involvement is another important component of
brownfield redevelopment and is often made a contingent requirement for the
disbursement of federal brownfield grant funds. The City Team involves the public
in brownfield projects in a variety of ways: through notifications posted at public
libraries announcing certain projects, participation in neighborhood workshops on
site visioning, and in communications with Neighborhood Councils and other
groups. Public involvement may be difficult to achieve especially when it requires
that disparate elements of the community work together for the first time.
The public may be the first source of information about a brownfield site—
when problem sites are reported to City departments or Council District offices.
Residents may notify the City that illegal dumping has occurred on a site or that
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questionable activity is taking place. Sometimes prospective purchasers call the City
to find out if there is something wrong with a vacant property. Finding out if a
property qualifies as a brownfield is a difficult process. The State maintains a
database of brownfields named “CalSites” which records the varying levels of
contamination and development of properties in a wide range of programs—
including Cortese sites (locations of historic hazardous materials releases), Voluntary
Cleanup Program sites, and those sites requiring “no further action.” The City’s
database of brownfield sites is maintained by the Environmental Affairs Department.
The multi-agency Team determines whether or not to include a site in the City’s list.
The City may be notified about a brownfield site from a variety of sources, including
the general public, City Council offices, and other departments. Some
nongovernmental groups—such as the University of California, Los Angeles’
Neighborhood Knowledge Los Angeles (NKLA)—allow members of the public to
obtain neighborhood-level data on properties with past code violations or reported
tax delinquency. Both of these can be indicators of brownfield sites.

Environmental Regulation and Brownfields
The California Environmental Quality Act (CEQA) requires that public
agencies predict how much environmental damage might be caused by their
projects—including brownfields. To comply with this expectation CEQA requires
that environmental impact investigations be conducted for projects—the most
comprehensive of which is an Environmental Impact Report (EIR). The City itself
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does not generally conduct EIRs or Preliminary Endangerment Assessments (PEAs)
or the more intensive environmental investigations that may be required at
properties, such as Phase I and Phase II site evaluations, but instead contracts with
other—often private—organizations. This is an important point because it shows
that, concerning brownfields, much of the expertise and workforce capacity needed
to fully implement redevelopment as required by law exists outside the City
government itself. Not only do these functions demand a certain expertise, there
often are professional certifications required for the individuals that conduct the
investigations.

International Standards
The contractors who perform the major brownfield site investigations do so
according to very specific standards established by the American Society for Testing
and Materials (ASTM). Since 1898 ASTM International has become one of the
world’s largest voluntary standards development organizations; it is a non-profit
organization that provides a mechanism for “development and publication of
voluntary consensus standards for materials, products, systems, and services.”
(ASTM 2003) The largest global standards body is the International Organization for
Standardization (ISO). ISO standards are also voluntary, but may be implemented as
mandatory standards depending upon the country or other jurisdiction’s discretion.
They are increasingly important for firms to demonstrate their global
competitiveness.
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The private sector environmental consulting industry that supports the
implementation of such standards is rapidly growing—particularly in Southern
California —but these changes mean that the brownfield redevelopment process is
becoming increasingly more specialized, professionally dominated, and accordingly,
more expensive. This scenario does not bode well for the small business in Los
Angeles that often cannot afford the extra resources for brownfield investigation—
particularly when additional resources are needed to keep pace with regular, local
environmental compliance. Compliance costs vary widely by industry and location
because they depend upon such factors as the amount of hazardous materials used
and disposed of during the production process as well as the impact of activities on
water resources. Thus, not only is the cost associated with these requirements a local
responsibility, but it is affecting global competitiveness of firms via the convergence
of practices that support both local and international standards, such as ISO:

As a non-governmental organization, ISO has no legal authority to
enforce their implementation. A certain percentage of ISO standards -
mainly those concerned with health, safety or the environment - has
been adopted in some countries as part of their regulatory framework,
or is referred to in legislation for which it serves as the technical
basis. Such adoptions are sovereign decisions by the regulatory
authorities or governments of the countries concerned; ISO itself does
not regulate or legislate. However, although ISO standards are
voluntary, they may become a market requirement, as has happened
in the case of ISO 9000 quality management systems, or of
dimensions of freight containers and bank cards. (ISO 2003)

The State of California offers a streamlined information system for
businesses in any city to find out about their general and environmental permitting
95
requirements. However, the information provided is still complex and
overwhelming—for instance, an electronic/electric equipment manufacturing
business in the City of Los Angeles is given 24 different reference points to secure
permits. Coupled with emerging international demands to comply with standards
such as ISO, the operating climate for small businesses—particularly in regard to
navigating brownfield policy requirements—may be becoming increasingly
oppressive. The next section will focus upon this relationship.

Local Expression: The Small Manufacturing Business as a Key Brownfield
Stakeholder

Manufacturing is important to the State of California; it ranks first of all
states in annual average manufacturing employment and in 2000 Los Angeles
County represented nearly one-third of this total. (Kyser 2001, 16) Within the
County, manufacturing employment has declined by 31 percent relative to total
nonfarm employment since 1988; however, it still accounts for 15 percent of the
total. (LAEDC 2002, 17)
According to the US Department of Labor, the Los Angeles County region
ranks second in manufacturing employment of all metropolitan statistical areas and
ties for ninth when compared with state rankings. (Kyser 2001, 16) In 1999, there
were approximately 28,000 manufacturing firms in Southern California, with nearly
18,000 or 63 percent of those located within Los Angeles County. Of those
manufacturers, one-third were small firms with four or fewer employees, just over
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half had nine or fewer employees, 68 percent had 19 or fewer employees and 86
percent had 49 or fewer employees. (15)
Data from 2001 shows this tendency has become more pronounced—with 37
percent (four or fewer), 55 percent (nine or fewer), 71 percent (19 or fewer), and 87
percent (49 of fewer) respectively. (EDD 2001) Thus, despite a decline in overall
manufacturing jobs, Los Angeles County still depends heavily upon manufacturing
for its economic growth—and particularly upon smaller manufacturing firms.
In 2000, the City of Los Angeles had 360,284 people employed in
manufacturing—nearly 60 percent of the County total (Rodino 2003, 13)—which
indicates the level of industrial concentration and suggests the magnitude of impact
industrial fluctuation has on the City. To further illustrate this concentration, the
metropolitan Los Angeles area contained 87 percent of the employment in apparel
manufacturing, 71 percent in publishing and allied products, 64 percent in
transportation, communication and utilities, 48 percent in durable wholesale trade, 65
percent in non-durable wholesale trade, and 42 percent in motion pictures. (Ibid., 15)
Within the County, the South Los Angeles region has the largest manufacturing
workforce which “surprises people” because of its reputation as a “‘distressed’
area”—obstacles in the area include a “lack of land for expansion of manufacturing”
and because the area is so intensively used, the only land “available for new
construction are brownfield sites.” (Kyser 2001, 10)
Expanding the geographical scope of analysis to a five-county region in
Southern California shows that manufacturing persists as an economic strength: the
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manufacturing employment of Los Angeles, Orange, Riverside, San Bernardino, and
Ventura Counties combined ranks third when compared to all US states. (LAEDC
2002, 16) Moreover, the expanded scope shows that manufacturing jobs have likely
migrated within this region: since 1988, while manufacturing employment declined
in Los Angeles County by 28 percent, nearby Orange County only saw a nine
percent decrease, while both Riverside/San Bernardino Counties and Ventura County
saw huge gains of 50 and 33 percent respectively. (Ibid.) Thus, the City of Los
Angeles has been losing manufacturing jobs to its neighbors.
A loss in manufacturing jobs is seen as problematic because it means the
disappearance of the middle class since small manufacturing firms hire people with
fewer skills and provide critical on-the-job training which helps them to “move up
the income ladder” and speed “assimilation into the overall economy.” (2)
Additionally, most manufacturing jobs offer good pay and benefits, with average
hourly earnings in Los Angeles County ranging from $8.53 in leather goods
production to $19.66 in transportation equipment, with an average annual wage
(across traditional manufacturing sectors) of $32,639 and up to $59,023 for
communications equipment manufacturing (considered in the high-tech range).
(Ibid.) These firms also contribute significantly to international trade—notably in the
satellite, electronic, chemical, and apparel sectors. (3)
Over the past two decades while manufacturing employment has declined in
Los Angeles County, industrial vacancy rates have declined by more than half—
down to 3.9 percent in 2001, which indicates stiff competition for existing space. (8)
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Put in more human terms, manufacturing has played a critical role in providing life
support to challenged communities in Los Angeles:
The shrinking of the manufacturing sector has been a serious blow to the Los
Angeles area not only because of the importance of manufacturing as an
underpinning to the local economy, but also because of the severe effect this
has had on workers in areas of the county that are heavily dependent on
manufacturing firms as a source of employment. These traditional ‘blue
collar’ communities include most of the areas affected by the civil unrest.
According to the 1990 Census, workers in these areas already beset by high
unemployment were more likely to be working in factories than were workers
in more affluent areas of the county. Also, for workers with less education,
manufacturing jobs have offered a relatively high wage compared to other
sectors of the economy, although this differential has been narrowing—in
part because of the disappearance of many large, unionized establishments
over the past several years. (EDD 1993)

This phenomenon has persisted throughout the region and has resulted in the
Los Angeles Economic Development Corporation’s (LAEDC) call for “competitive
industrial sites” including quicker redevelopment of brownfields as part of its “recipe
for survival” of the manufacturing sector. (Kyser 2001, 13) What this tells us is that
the decline of small-scale manufacturing is not just about changes in industrial
concentration, but also about disparate impacts across racial and class lines—
something that provides credence to the idea that any redevelopment policy or
program, including brownfields, needs to have a more holistic approach that
recognizes and addresses the complex social roots of the problem.

New Industrial Policy with Brownfield Targets
Because the City of Los Angeles has seen “an erosion of its industrial base,
resulting in a loss of manufacturing jobs, a reduced tax base and [creation of] idle
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Brownfields sites” over the last few decades, Los Angeles mayor, James Hahn,
introduced the Industrial Development Policy Initiative (IDPI) in January 2003,
recognizing in its Work Plan that “Manufacturing, warehousing…distribution, and
research and development activities all provide needed, well-paying jobs, oftentimes
in areas near where lower-income residents reside.” (MOED/IDPI 2003)
The IDPI was created in response to “a reduction of the powerful and positive
economic multiplier effects of industrial activity” and identifies a number of
challenges it is intended to address, including job loss, a lack of suitable industrial
space in the city that is causing firms to locate elsewhere and “the deterioration of
outmoded industrial properties, the blight that such deterioration fosters, and reduced
tax revenues from underutilized industrial land.” (Ibid.)
The exact condition of industrial land in Los Angeles is unclear and the first
phase of the IDPI initiative entailed issue articulation and a property inventory, with
later phases intended to answer questions such as how the City may reclaim
brownfields sites and to identify the “problems facing existing (mostly small to
medium sized) industrial businesses.” (Ibid., 3)
As demonstrated here, Los Angeles continues to depend upon small-scale
manufacturing and is left with little choice but to concentrate on attracting and
supporting the smaller firm given the space constraints of available industrial land.
Thus, how Los Angeles goes about reusing its industrial land becomes critical—and
an obvious challenge in this process is the reuse of smaller brownfield sites.
Historically, large brownfield sites have been the best at attracting investor interest
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and governmental grants, but Los Angeles is redirecting its focus to make smaller-
scale projects feasible.
Small businesses are connected to their communities in a multitude of ways;
however, they must navigate a vast regulatory system to engage in the brownfields
process—either through identification, assessment, clean up, or relocation to a
former brownfield property. This is highly discouraging if attracting vibrant small
businesses is to be a solution for blighted communities. Los Angeles small
businesses have many sources of support for their commercial operations; however,
there is no single source of reliable information to assist them regarding their role
and responsibilities concerning brownfields.
16

A nexus exists between small manufacturing businesses and brownfields via
the realization that small firms must buy into the brownfield policy process if it is to

16
Some of the more high-profile general business assistance resources are: The California
Technology, Trade and Commerce Agency, which oversees the Small Business Development Centers
(SBDCs) program in conjunction with the U.S. Small Business Administration and its Los Angeles
regional office (There are SBDCs throughout Los Angeles County.); the Service Corps of Retired
Executives (SCORE) association, a non-profit organization offering free technical assistance to small
businesses; the Los Angeles Manufacturing Networks Initiative (LAMNI) of the CDTech Center,
intended to strengthen the industrial base of the Los Angeles economy by encouraging
collaboration among small- and medium-sized urban manufacturing firms in six key industries
(CDTech operates in a collaborative relationship with Los Angeles Trade Technical College
(LATTC) and L.A. PROSPER, a subsidiary of the Los Angeles Community College District.); the
Los Angeles County Economic Development Corporation; the California Manufacturing Technology
Center (CMTC), established to provide high-value consulting services to California's small and mid-
size manufacturers to increase their competitive advantage through improved methods of management
and manufacturing; the Los Angeles Area Chamber of Commerce (founded in 1888); the California
Manufacturers and Technology Association, which works to improve and preserve a strong business
climate for California’s manufacturers, processors and technology-based companies; the National
Association of Manufacturers; and the National Federation of Independent Business.

The CMTC is a fee-for-service organization and the last four are membership organizations. This list
is only the tip of the iceberg concerning the many sector-based associations that small to medium-
sized enterprises (SMEs) in Los Angeles may be involved with; however, it suggests the wide range
of resources potentially available to them. Also, this list hints at the many organizations that may need
to be involved in the brownfields policy dialogue in order to adequately prepare firms for managing
the upheaval associated with contaminated properties.
101
work successfully. However, this means that small firms must understand and
embrace the regulatory requirements and be willing to identify contamination and
take responsibility for it. The case study survey was designed to ascertain if this is in
fact the case in practice.
This overview of the brownfields process in the City of Los Angeles has
served to demonstrate the emergence of the problem and the way its solution has
become institutionalized. While it is obvious that many regulatory and service
support mechanisms are in place, it is unclear how well they are understood by local
stakeholders, and notably, the small business community. The next section outlines
the research context and framework; the latter was crafted to begin to identify such
perceptions.

Research Context
A qualitative case study research method was chosen to investigate the
understanding of brownfields by different stakeholder groups. This is supported in
the literature on brownfields, where Zarcadoolas et al. (2001) found qualitative
research methods “especially useful for exploration and discovery” in their
development of a print guide on brownfields to help members of the public begin to
understand more technical environmental and health issues. (17) The authors used a
method of “cooperative composing” in their collaboration with residents that
identified “perceptions, knowledge, and concerns regarding brownfields” and
constructed the content of the guide and tailored “language and layout to reflect
102
language used by the participants.” (19) This method was chosen because it is
“unlike the end-stage response-and-evaluation activities that are often used to ‘field-
test’ materials with residents.” (19) The approach was designed in response to the
contention that, “Much information about environmental and health issues is difficult
and inaccessible to the public” and is generally “written…at a high reading level”
focusing on “concepts unfamiliar to many”—known as “’high-barrier’ material.”
(20)
In a survey of dozens of US cities, another author found the “overall state of
participation in brownfields to be weak.” (Solitare 2001 in Solitare 2005, 918) Part
of this lack of “meaningful participation” she blames on “The EPA’s limitations”
which are “confounded by the fact that there is a spectrum of how public decisions
are made. At the one end of the spectrum, a small group of experts makes decisions
through an act of guardianship” or “technocratic decision making.” (919) Knowing
that “Citizens’ perceptions of how committed the local political regime is to having
them involved directly affects whether or not they participate” (922), she chose to
use a case study methodology to explore how situational prerequisites influenced
residents’ participation in brownfield redevelopment decisionmaking in their
neighborhoods. Her case study involved eight brownfields projects located in two
cities, Boston, Massachusetts and Houston, Texas. Her research design included a
blend of observation—vis-à-vis attendance at public meetings and interviews—with
neighborhood/community groups representing residences, local business
103
associations, developers, local government officials, and other stakeholders who
“either were effecting the redevelopment or felt they were affected by it.” (924)
These examples lend credence to the present analysis in focusing on different
qualitative methods and language to effectively solicit information from divergent
brownfield stakeholders. They also provide evidence that there are barriers to
understanding the technical or instrumental meaning of brownfields and that, in so
doing, social construction becomes marginalized:
By continuing to frame brownfields redevelopment as an environmental
issue, the EPA is practically guaranteeing that participation will continue to
be less than meaningful overall. Not only does such framing keep citizens
from wanting to participate, it also makes the decision making seem
technical, with experts being the most qualified to make decisions. Such
framing downplays the social construction of decision making; it makes it
appear to be apolitical, which in turn does not support the inclusion of
laypeople. (Solitare 2005, 933, italics added)

In both of these cases, however, the authors evaluate stakeholder perceptions
surrounding already-identified brownfield sites and, therefore, leave out any
exploration of how the brownfield problem itself was socially constructed. The
present analysis is intended to fill these gaps by adding qualitative investigation to
the literature on brownfields; only in this case, existing sites were not first identified
as targets of focus. This allows for understanding whether there is a fundamental
awareness of the problem at all, but most importantly, it allows the meaning of
brownfield to be articulated without prior guidance.
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Research Framework
Here, I am interested in what goes into the making of brownfields or, in
answering the following questions:
1. Are contaminated lands a concern for stakeholders identified in the
brownfield literature—such as small businesses and local
government representatives—if they are not first associated with
the problem?
2. Is the term “brownfield” familiar to such stakeholders?
3. Are land contamination or brownfield problems uniformly
understood, i.e., is there a prevailing acceptance of the instrumental
meaning associated with the legal definition?
4. Is there a stigma or taboo attached to brownfields in making small
businesses feel like culprits?
A qualitative case study methodology was selected to find answers to these
questions—one that adheres to Feagin et al.’s (1991) definition of case study
research as “in-depth, multifaceted investigation, using qualitative research methods,
of a single social phenomenon.”
17
In the present analysis, the social phenomenon is
brownfields and three different qualitative strategies were chosen to support the

17
This method was chosen because of the following advantages:
(1) It permits the grounding of observations and concepts about social action and social structures in
natural settings studied at close hand;
(2) It provides information from a number of sources and over a period of time, thus permitting a
more holistic study of complex social networks and of complexes of social action and social
meanings;
(3) It can furnish the dimensions of time and history to the study of social life, thereby enabling the
investigator to examine continuity and change in lifeworld patterns; and it encourages and
facilitates, in practice, theoretical innovation and generalization. (Feagin et al. 1991, 7)
105
research narrative. In order to uncover the expressed understanding of the brownfield
problem by stakeholders in the community, it was necessary to structure the
strategies to the nature of the groups.
The approach consists of three different methods for the three identified
stakeholder groups and is intended to contribute to a wider understanding of
grassroots perceptions of brownfields. Taken together, these three methods serve to
triangulate local perceptions by targeting stakeholders that have been recognized as
involved in brownfield redevelopment elsewhere (e.g., those identified in
Zarcadoolas et al. 2001 and Solitare 2005, discussed above). Triangulation involves
a researcher’s use of “multiple and different sources, methods, investigators” in a
process that “involves corroborating evidence from different sources to shed light on
a theme or perspective.” (Creswell 1998, 202) Table 2 below details the stakeholders
chosen and questions associated with each method.
Table 2: Stakeholders and Research Methods

Stakeholder Method Question Themes
Small
Manufacturing
Businesses
Long, structured
electronic survey
Is land contamination a problem?
How is land contamination handled (vis-à-vis
identification, liability-assignment, etc.?
How do you handle land contamination issues,
access information, etc.?
Local residents
(Community
land use plans)
Content analysis of
text
Are brownfields an expressed problem?
What are expressed pollution ideas?
What are expressed cleanup ideas?
Local leaders
(Neighborhood
Council
representatives)
Short, open-ended
electronic survey
Are brownfields a problem?
What are pollution priorities?
What are land use priorities?
How is information accessed regarding pollution
and land use issues?

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Surveys of Small Businesses
Secondary research conducted in 2002 and summarized previously identifies
the small business and particularly, the small manufacturing business, as a key
brownfield stakeholder. In brief, the relationship stems from the fact that many Los
Angeles brownfields are located in industrial areas, which have undergone a rapid
decline in recent years. These brownfields are often small and among operating
business, posing a challenge to redevelopers, who wish to return the properties to
productive use. The author hypothesized that a paradox arises when small
manufacturers as a group are antagonized as culprits for brownfield contamination
and then courted as clients when recruited to inhabit a former brownfield or property
within a brownfield neighborhood. Thus, the first attempt at learning about local
expressions regarding brownfields was motivated by a desire to determine if the
“stigma” or “taboo” referenced in the literature is supported in the case of Los
Angeles and, particularly, if a culprit-versus-client paradox does exist among the
small manufacturing business stakeholder group.
To gain the freest access to the small business group, a long, structured
electronic survey was developed. The web-based survey method was designed to
preserve anonymity because of the sensitive subject matter (contamination issues and
legal responsibility) and to increase the level of convenience so that businesspeople
could participate when available. More than sixty completed surveys revealed that
businesses are largely uninformed about land contamination policies and procedures
and they do tend to feel antagonized by the prevailing system. To fill in the gaps left
107
by this experiment, and in keeping with Lofland & Lofland’s (1995)
recommendations, that “conscientious naturalistic investigators not only scan the
immediate data site for words and actions but also are sensitive to the possible value
of a wide range of supplementary information that may come their way” (71),
another method was subsequently added in the research design—one that was less
subjective and more comprehensive: an analysis of community land use plans.

Content Analysis of Community Land Use Plans

Although standardized in format, the land use plans—representing each of
the City of Los Angeles’ 35 distinct communities—are created through a public
consultation process with the City’s Planning Department and updated via additional
consultations every five years. A content analysis of the text of each plan was
undertaken to determine how pollution and cleanup ideas were expressed and if the
brownfield concept was familiar. A text analysis always risks bias because of the
subjective nature of the individual reader. Computer analysis has emerged as a
method to increase reliability (e.g., Gephart 1997); however, in the present case this
was not deemed viable because the idea of “brownfield” is so new and can be
expressed in so many different ways—such as via abandoned gas stations,
dilapidated motels, etc. Still, certain key words were searched automatically—such
as “brownfield,” “vacant,” “vacancy,” “abandon,” “abandoned,” “contaminated,”
“pollution,” and “polluted,” but each plan was read in its entirety. Notably, not one
single plan used the term “brownfield” even though many referenced brownfield-
type problems or sites/areas that would be eligible for Brownfield Program
108
assistance. Although other governmental assistance programs were mentioned
frequently, the Brownfield Program was not included at all. The content analysis
reveals a wide diversity of expressed pollution ideas as well as methods to remediate
problems.

E-Consultations with Neighborhood Representatives
Following the analysis of community plans, a third stakeholder group was
identified in a similar snowball-identification technique, designed to triangulate an
understanding of the brownfield issue at the grassroots level: Neighborhood Council
representatives. These individuals are local leaders that serve at a level well below
the jurisdictions of the community plans. They are stakeholders that belong to a form
of local governance that is very new and still finding its shape and substance. Names
were obtained from the Department of Neighborhood Empowerment’s public
website and represent individuals who are willing to be points-of-contact about their
neighborhoods. A short, open-ended electronic consultation that involved four short
survey questions was chosen as the appropriate method. Unlike the highly-structured
survey used for the small business stakeholders, the electronic mail was designed to
be brief in order to limit the time commitment required for responding and was open-
ended to avoid directing respondent answers—consistent with “’unstructured’
interviewing” that “seeks to discover the informant’s experience of a particular topic
or situation.” (Lofland & Lofland 1995, 18, italics in original) This method resulted
in a number of “What is a brownfield?” responses, which indicates that there may
109
have been others that declined to respond due to a lack of familiarity with the term.
Generally, brownfields were not expressed as a major pollution problem for the
subject neighborhoods. The next section will describe, in turn, the stakeholder
groups and the corresponding methods and results.

Methods and Results

I. Small Business Survey Process and Data
To compile qualitative information from small business stakeholders in Los
Angeles, an Internet-based survey was developed. Web surveys are considered a
very legitimate and increasingly popular method of collecting data (Bainbridge 1999;
Couper 2000), but are subject to unique advantages and disadvantages. For instance,
the Internet population differs from the general population and therefore Web-based
surveys attempting to obtain data across a wide range of demographic groups might
not be representative. However, in this case, small businesses are assumed to be
familiar with the Internet and have easy access to it. Initial telephone calls to
potential respondents revealed that this is, in fact, the case. Responsiveness is also a
problem with Web surveys because it is easy to avoid responding and it is difficult to
know what influences nonresponse behavior.
Initial telephone calls to businesses indicated that many firms did not have
enough time or available staff to participate in a lengthy telephone interview and site
visits that involved questions of land contamination were deemed to be possibly
threatening. Given these conditions, an electronic version of an in-depth survey
instrument was created to facilitate easier acquisition of responses. (Appendix I
110
includes the full survey questionnaire; surveys were distributed in August 2002.)
While the electronic format is not always ideal given that some individuals and
groups do not have equal access to computerized communication, it was appropriate
for this study because of the target audience’s (small businesses’) familiarity with
and easy access to the Internet as a fundamental component of their business
operations. Also, by hosting the survey on an Internet website, the respondents were
free to complete the survey at their leisure.
Moreover, the interactive format of the survey required no physical writing
and only minimal typing from respondents and these factors were deemed important
in assuring a more reasonable time commitment. However, the in-depth nature of the
survey likely reduced the number of potential responses because of its length and the
detail contained in the questions.
The survey required respondents to provide information about seven different
categories: Personal/Respondent; Business; Owner; Site/Property; Neighborhood;
Land Use; and Operations. The personal information was requested to distinguish
between respondents and to ascertain the business location. The survey was designed
for business owners and managers, but was often completed by others at the business
who were able to adequately answer the questions asked. Business information
helped to establish the type of business, its tenure, its organization structure, and its
size. Owner information was designed to elicit information about the kind of owner
relationship to the business—e.g., partnership, family, franchise, etc.—as well as to
find out how close the owner lives to the business and how often he/she is physically
111
at the business. Site information was intended to uncover the commitment level of
the business to its present location and what factors most influenced its decision to
choose that location. This section also introduced the brownfield concept by asking
respondents to address issues of land contamination at their locations. It is important
to note that the term “brownfield” was not used in the survey instrument because
initial conversations with small business owners revealed a lack of familiarity with
the term that then discouraged further feedback on the issue. No survey responses
included use of the term either, which is further evidence of a lack of association of
the term with the policy problem as understood by the City program.
The neighborhood information section further elaborated on the brownfield
concept by asking respondents about the condition of land in the vicinity of their
businesses. Social capital issues were also addressed by asking businesses about their
willingness to stay in the neighborhood and about their participation in the local
community. The land use information directly addressed the brownfield concept by
asking businesses to elaborate on how they perceive that property contamination
issues are managed in their neighborhoods. Operations information was requested in
order to find out if the businesses had any perspective for comparing their operations
internationally and to determine what kind of business networking relationships they
rely upon.

112
Data Pool
Businesses were selected from the 2002 Directory of Business for Southern
California. This data resource was chosen because the data it provides are frequently
updated and because they include physical address, telephone number, business size,
and business type categories. Business owners were contacted by telephone first to
determine their willingness to participate in the study and to obtain an electronic mail
(e-mail) address that was then used to transmit the subsequent explanation of the
study, including directions concerning how to complete the survey. Almost all
businesses contacted had an available e-mail address for this purpose. Many
businesses claimed that they were too busy to complete the survey with some saying
they were not interested or did not find that the survey was relevant to them. Of the
41 companies that provided e-mail addresses, only 29 percent actually submitted
surveys and six addresses were not valid. Approximately 110 telephone calls were
made from a set of approximately 4,100 firms listed geographically in the directory
as City of Los Angeles businesses. From the total number of firms, manufacturing
firms were selected by their Standard Industrial Classification (SIC) codes. A few of
the selected firms did not list telephone numbers, some had incorrect telephone
numbers, and some had numbers that were no longer in service.
In order to contact businesses that might be affiliated with other information
networks, firms were also contacted via the “SuperPages” online directory of
businesses because of the resource’s well-known status and because the directory
included detailed information about industry type, location, and electronic contact
113
information. Of 158 firms contacted through the online directory, 28 responded, 32
had non-working addresses and 3 declined participation because they were not
located within the City or County of Los Angeles.
The U.S. Small Business Administration Pro-Net database yielded over 800
e-mail addresses for businesses within Los Angeles County. Of these, there were
approximately 65 nonworking addresses and some unwillingness to participate—two
were “too busy”, two were not in the geographic area of interest and one was
“uncomfortable” about the sensitive nature of the issues addressed by the survey.
Approximately 35 surveys were completed as a result of this transmission.
The ultimate response pool consisted of 64 surveys, including 28 respondents
within the City of Los Angeles, 34 within the County of Los Angeles, one in San
Bernardino County and one that could not be geographically identified. (See Figure 1
on the following page.)
114
Figure 1: Map of Small Business Survey Respondents
115
One respondent submitted his survey by facsimile and one responded in a
narrative format. While this is not a statistically reliable sample of firms, it is an
empirically important population because it represents never before acquired
information and is adequate for an episodic understanding of the stakeholder group
addressed here.
The following section presents the results of the qualitative survey analysis.
The surveys provide insight into the experiences of individual firms and serve to
show if and how the above-discussed implementation of brownfields is reaching
them. The results also indicate the level of community connectedness of firms and
sheds light on small business stakeholders’ beliefs about the conditions of their
neighborhoods regarding brownfields.
All of the businesses in the sample consider themselves “small businesses”
and 42 of those are family businesses with 21 describing themselves as “minority
businesses.” Twenty-five of the businesses are owned by a group of two or more
people, 33 are individual ownerships and 6 are partnerships.
18
None of the businesses
is a franchise. Fifty-eight of the businesses are manufacturers, seven are related
service providers and one is a retail enterprise. The type of business varies widely—
including food, electronics, plastics, glass and furniture manufacturing, a die casting
company, a metal plating operation, makers of hinges, coils, and pistons as well as
sign, machine, aerospace, and adhesive products. All of the businesses are
headquartered in Southern California.
116
The majority of respondents indicated that their businesses operate on very
small parcels—with 38 or 60 percent on less than one-acre of land; 17 or 27 percent
on 1-2 acres; and less than one percent each on properties of 3-5 acres and 9-10
acres. One metal-plating business reported that it operated on a site of 11-20 acres.
This finding is significant for brownfields research because it implies that small
manufacturing firms would require assistance of a certain, much smaller economy-
of-scale than is traditionally attractive to private real estate developers and funders.
These characteristics indicate that the survey did connect with its target
population of a variety of small- to medium-sized manufacturing firms, however the
geographic spread is wider than the City of Los Angeles. This condition is
acceptable given the large concentration of manufacturing throughout the County—
in close proximity to the City—and the wider region. The map on the following page
illustrates the geographic distribution of the survey respondents.

Existing Brownfield Sites
Some of the respondents on the outer fringes of the County of Los Angeles
and one from San Bernardino County were geographically located by their zip code
and centrally placed within that zone. Using ArcGIS software, it was determined that
14 survey respondents were within one-half mile and 24 respondents within one mile
of a designated Los Angeles Brownfield Program site; however one area had a

18
Other ownership types mentioned were, "C Corporation" (1 respondent), "Corporation" (1),
"Family Trust" (1), "LLC" (1), "S Corporation" (2), and one mentioned that is a "majority woman-
owned" business.
117
clustering of multiple respondents near multiple brownfield sites (See Figure 2
below, where circles represent respondents and the red shapes are brownfield sites.).

Figure 2: Map of Brownfields Near Survey Respondents

118
This clustering is important because it contains very different types of brownfields.
As presented in Table 3, each site has a distinct physical appearance. The abandoned gas
station (Site 1) is a common occurrence; Site 2 is typical of a less-common, large-scale
industrial brownfield; Site 3 is an example of a “dead mall” type of site; and Site 4 is a
community garden on an industrially-zoned site.
Table 3: Respondents Near Existing Brownfield Sites
Respon-
dents
within
1 mile
Site Description Site Photograph
5
Site 1: This is a less than one-acre abandoned
site, which was operated as a fuel station/tire
shop from 1928-1987. The property was tax
delinquent and fenced. The absentee owner
agreed to let the City assess the site. Phase I
environmental investigation completed and
Phase II suggested—removal of 6
underground storage tanks suspected. The
property is zoned commercial, but is across
the street from an industrially-zoned area.

5
Site 2: A 20-acre parcel of vacant
contaminated property owned by the State of
California, originally occupied by 11
industrial buildings, with activities ranging
from food processing to product assembly.
The State purchased the site to construct a
prison—a plan that was abandoned because
of community opposition—and started, but
did not complete remediation of the site,
which has been a significant barrier to its sale
and redevelopment. Zoned for heavy
industrial use and located at the northern
terminus of the Alameda Corridor, a region-
wide target for revitalization that stretches
from the Port to Central Los Angeles.

4
Site 3: This is a 31-acre site and its
environmental status is unknown. Its historic
use is also unknown prior to its operation as a
catalog distribution center since 1927. The
site needs a Phase I, possibly some Phase II
investigation. The site is in a mixed-use
area—it is zoned commercial, but is
surrounded by a manufacturing district near
the Los Angeles River.

119
Table 3 (Continued): Respondents Near Existing Brownfield Sites
Respon-
dents
within
1 mile
Site Description Site Photograph
4
Site 4: This approximately 12-acre site has
been operated as a community garden since
1992, however it is zoned for manufacturing
use. From 1920-1979, activities associated
with furniture, refrigerator, and rug
manufacturing, including the use of
chemicals in paint thinner, adhesives,
varnishes, cleaners, solvents, and flammable
liquids used in die-casting were present on
the site. All buildings were demolished and
the land cleared by 1989. In 1990, some
remediation was done; in 1993 a PSA
concluded it was adequate and that risk of
remnant contamination was “low”; in 1995, a
health-risk survey and geophysical
evaluation were done; “minimal health risk”
was found and a UST located; in 1996, the
UST was removed and the LAFD determined
“no further action” necessary. Additional
assessment is pending.
2
Site 5: This site is a1.7-acre abandoned
police station and garage, currently sitting
vacant. The site is zoned industrial and the
building may either be demolished or
rehabilitated for other industrial uses in
conformity with existing surrounding use.
3
Site 6: This site was previously occupied by
various warehouses, auto repair facilities,
commercial buildings and two gas stations.
The City of Los Angeles owns the land and
the building owner has a ground lease with
the City. The site consists of approximately
25-acres of industrially-zoned land. The goal
of the brownfield project is to help the
business expand its operations.
Source: Adapted from City of Los Angeles Brownfield Program Brownfield Site Information Reports (BSIRs), 2002

120
Perceptions in Vicinity of Known Sites
Following is a brief overview of what the businesses near the City
brownfields thought about conditions in their neighborhoods. The findings for the
entire sample will be discussed afterward.
Site 1: Of the five businesses in the vicinity (less than one mile) of Site 1, all
agreed that they were located in a disadvantaged neighborhood—three strongly
agreed. All agreed that vacant properties were a problem in the neighborhood and all
but one agreed that abandoned properties were a problem. Three agreed that
contaminated properties were a problem; however only two agreed that there were
problem properties (abandoned, vacant or contaminated) within a half-mile of their
businesses, while four agreed that there were problem properties within one block.
Sites 2 and 3: All three sites that were located within a one-mile vicinity of
Sites 2 and 3 strongly agreed that they were located in a disadvantaged
neighborhood. Surprisingly, 2 strongly disagreed that there were vacant or
abandoned properties in their neighborhood; however, the respondent closest to both
sites (situated between them) strongly agreed that there were problem properties both
within a block and a half-mile of the business neighborhood. Since both Sites 2 and 3
have been vacant for a long time and the businesses have been in the neighborhood a
long time, this raises questions about what businesses consider to be brownfields, but
also what they may consider to be the boundaries of their neighborhoods.
Site 4: Of the two businesses within the vicinity of Site 4, one strongly
disagreed that there were vacant or abandoned properties in the neighborhood and
121
one disagreed somewhat. One strongly disagreed that the business was located in a
disadvantaged neighborhood and one agreed somewhat. Their opinions were split on
the distance measures with one disagreeing somewhat that problem properties were
in the vicinity and one barely agreeing.
Sites 5 and 6: Three survey respondents were within one mile of two other
brownfields—Site 5 and Site 6 below—and this is significant because these sites
appear from the street to be operating businesses, which is common in Los Angeles
where many small brownfields are located among active enterprises and where
contamination may be discovered in the course of business operation (which could
then convert a property to brownfield status).
Of the three businesses within the vicinity of Sites 5 and 6 all agreed that they
were located in a disadvantaged neighborhood, but two strongly disagreed that there
were any vacant, abandoned, or contaminated properties in their neighborhoods.
Both sites are in downtown Los Angeles near the freeway and exist in a dense
commercial environment—and in the case of Site 6, it is an operating business.
Although it is difficult to ascertain what the rest of the neighborhoods look
like, we do know that Sites 1, 2, and 3 were or have been vacant for a significant
period of time and that Site 2 in particular is very large. Thus, it would be expected
that businesses in the vicinity of the more obviously blighted sites might have less
favorable images of the neighborhood and might indicate agreement with the idea of
blighted properties existing nearby. Given the visually appealing green space on Site
4, it is expected that it would not stand out as a blighted property to nearby property
122
owners although it is still considered a brownfield. Anecdotally at least, this appears
to be the case. The message to be drawn from this is that community stakeholders
and here, small businesses in particular, cannot always recognize brownfields and
therefore may require further information to understand the scenarios involved for
identifying, cleaning up, and reusing different kinds of properties. This suggestion of
limited understanding on the part of businesses is further supported in an
examination of the responses from the full sample.

Community Connectedness
One caution emerges when reviewing the community tenure of the businesses
studied in the response pool because 25 or nearly 40 percent reported that their
businesses were more than 20 years old; however, they may have relocated during
that tenure. This implies that these businesses are likely not the typical case. Because
they are well-established enterprises, they may be more willing and able to
participate in the survey, more familiar with land use information in the City, and
would not reflect the opinions of the younger, more vulnerable businesses. However,
it is important to document the established business perspective because of their
community history and familiarity with neighborhood and policy evolution. Only six
of the respondents said their businesses were less than one year old:

123
Table 4: Age (in years) of Respondent Businesses

Number of Firms Reporting in Each Category
Less than one year 6
1 to 5 years 9
6 to 10 years 8
11 to 15 years 11
16 to 20 years 5
More than 20 years 25
TOTAL 64

The youngest business reported was less than one year and the oldest was
founded in 1909. The average age of the businesses that reported “more than 20
years” was 47 years—implying strong community commitment.
While the businesses themselves have existed in the communities for a
significant period of time, their owners generally do not live nearby, with 56 percent
living more than 11 miles away (See Table 5.).
Table 5: Owner’s Commute to Business (in miles)

Less than one 10 16%
1 to 2 1 2%
3 to 5 10 16%
6 to 8 2 3%
9 to 10 5 8%
11 to 15 10 16%
16 to 20 10 16%
21 to 25 5 8%
26 to 30 5 8%
More than 30 5 8%
TOTAL 63 100%

In terms of commuting time, most commutes were by vehicle and were more
than fifteen minutes, but less than one hour (See Table 6 on the following page.).
124

Table 6: Owner’s Commute to Business (by mode and
trip length)

At business 6
Walking distance 1
Less than 15 minute commute by vehicle 13
16 to 30 minute commute by vehicle 22
31 to 60 minute commute by vehicle 19
More than one hour commute by vehicle 3
Other answers included "Boston" and "same city."

In Los Angeles, given the ease of freeway access, this likely means that
owners live in very different neighborhoods than those where their businesses are
located. Another indicator of owner commitment to the business neighborhood is the
number of days the owner actually spends at the business. According to the survey
respondents, 20 percent spend fewer than five days per week at the business, while
more than half spend at least five days there and 22 percent spend six. The overall
message implied is that most business owners do spend time in the neighborhoods
where their businesses are located, but may have a commuter-style relationship to the
community.
Additional survey questions were included to gauge respondent perceptions
of the communities in which they operate. Since survey respondents tended to
answer toward the middle, less-extreme categories, the categories were totaled
according to all on the “agree” side versus all on the “disagree” side to see if any
attitudinal patterns emerge. (See Table 7 on the following page.)
125
Most respondents consider that their businesses operate in disadvantaged
neighborhoods, where crime is a notable problem. According to the respondents’
perceptions, more than 30 percent believe that there are vacant properties in their
neighborhoods and more than 20 percent believe there are abandoned properties in
their neighborhoods.
Table 7: Perceptions of Community

SA AS BA
AGREE
DIS-
AGREE
BD DS SD Total
My business is located in a
disadvantaged neighborhood.
26% 24% 11% 61% 39% 2% 13% 24% 62
Crime is a problem in the
neighborhood where my business
is located.
19% 31% 10% 60% 40% 6% 21% 13% 62
Vacant properties are a problem in
the neighborhood where my
business is located.
11% 15% 13% 39% 61% 8% 15% 39% 62
Abandoned properties are a
problem in the neighborhood
where my business is located.
8% 6% 13% 27% 73% 5% 21% 47% 62
I know by name many of the
residents in the neighborhood
where my business is located.
10% 10% 10% 30% 70% 12% 18% 40% 60
I know by name many of the other
people who operate businesses in
the neighborhood where my
business is located.
10% 28% 16% 54% 46% 18% 15% 13% 61
I would like to keep my business
in the same neighborhood for the
next five years.
47% 22% 7% 75% 25% 8% 7% 10% 60
I would like to keep my business
in the same neighborhood for the
next ten years.
43% 20% 11% 74% 26% 5% 7% 15% 61
I would like to keep my business
in the same neighborhood for the
next twenty years.
34% 20% 12% 66% 34% 7% 7% 20% 59
Conditions are improving in the
neighborhood where my business
is located.
13% 34% 18% 66% 34% 10% 15% 10% 61
Conditions are deteriorating in the
neighborhood where my business
is located.
5% 13% 10% 28% 72% 15% 25% 32% 60
*Note: SA=Strongly Agree; AS=Agree Somewhat; BA=Barely Agree; BD=Barely Disagree; DS=Disagree Somewhat;
SD=Strongly Disagree; Total=the number of respondents who answered the question
126
When asked if they know by name many of the residents in the
neighborhoods where they do business, 70 percent of respondents disagreed, which
implies a potentially important element of social disconnect considering that many of
the businesses have operated in their neighborhoods for more than twenty years.
When asked if they know by name “many of the other people who operate
businesses” in the neighborhood, 54 percent of respondents agreed with the
statement; however, this still indicates a less than substantial amount of face-to-face
communication.
Respondents were much more positive when asked about their future plans of
neighborhood commitment: 75 percent agreed that they would like to keep their
business in the same neighborhood for the next five years; 74 percent for the next 10
years; and 66 percent agreed for the period of twenty years. Respondents were also
positive about the future of their neighborhoods—with 66 percent supporting the
statement that “conditions are improving” in the neighborhood and 72 percent
disagreeing with the idea that “conditions are deteriorating” in the neighborhood.
These expressions of commitment are to be expected from businesses that already
have experienced a long tenure in their neighborhoods, but the wide variation in the
attitudinal responses about knowing people in the neighborhood imply that the nature
of the businesses’ connection with the community demands further attention. It also
implies that it might be difficult to engage local citizens in brownfield projects
involving small businesses since there is not a strong, supportive relationship
between them.
127
A further indication of a business’ neighborhood commitment is the number
of local residents that it employs (See Table 8 below.):
Table 8: Percentage of Employees Living within Specified Distance
of Business

(Number of Respondents)
Percentage of Employees One Mile Five Miles
1 to 5 % 43 25
6 to 10 % 4 5
11 to 15 % 4 6
16 to 20 % 4 4
21 to 30 % 1 0
31 to 40 % 1 1
41 to 50 % 1 13
51 to 60 % 4 3
61 to 70 % 0 2
71 to 80 % 1 1
81 to 90 % 0 1
91 to 100 % 0 3

The survey results indicate that very few businesses employ people that live
within one mile of the business—43 respondents indicated that only 1 to 5 percent of
their workers live within the immediate vicinity of the business. Only six businesses
claimed that more than 40 percent of their workers live within one mile of the
business, but 23 claimed that more than 40 percent of their workers lived within 5
miles of the business. This may imply a commuter-style relationship between the
employees and the business neighborhood as well. Although the surveyed businesses
mainly operate in industrially-zoned areas, there are mixed use residential areas
nearby, but these findings imply that workers likely do not come from such areas.
Other indicators of community-connectedness or social capital are the
amount of business networking and community outreach a firm experiences.
128
According to the survey respondents, 67 percent of the businesses do not engage in
regular business relationships with other firms in their neighborhood (See Table 9.).
This is surprising given that manufacturing firms are supposed to stimulate local
economies as a catalyst for other commercial growth.
Table 9: Business Relationships in Neighborhood

Number of Other Firms with which
Respondents Engage in Relationships
Number of Respondents
0 Firms 26
1 Firm 1
2 Firms 11
3 Firms 8
4 Firms 3
5 Firms 4
More than 5 Firms 10

When asked to identify the kinds of neighborhood participation they engaged
in, the most commonly referenced category was sponsoring or donating to
neighborhood groups or causes; however, the proliferation of “Other” descriptions
indicates that the categories provided were not inclusive enough (See Table 10.).

Table 10: Types of Neighborhood Participation
Sponsoring or donating to neighborhood groups or causes 17
Participating in neighborhood groups 11
Advertising neighborhood events 4
Training local residents 3
Hosting local events/activities 2
Note: Respondents could select more than one attribute.

Other neighborhood participation activities listed by respondent businesses
were: Chamber of Commerce participation (3); local business association(s);
allowing the use of parking lot and trash bins when closed; allowing an employee to
129
run a regular garage sale in parking lot; serving as a precinct pollworker; eating at
local restaurants (2); running errands at local businesses (2); using the local bank;
working with local schools, offering assistance, donating time services, field trips,
etc.; and cleaning up trash and graffiti in front and back areas
A few respondents took the opportunity to discuss reasons why they did not
participate more in the local neighborhood: the area is deemed unsafe at night by the
police department; no interaction has been necessary; no residences are in the
neighborhood—it is all industrial; and “there is no neighborhood here”…it is strictly
zoned for industrial parks…the closest neighborhood is 2-3 miles away.
These last responses shed light on some important facts regarding a
business’ community connectedness, which are that areas with no residences nearby
or mixed land uses with varying levels of social use intensity—such as many high-
rise downtown business districts—become ghost towns at night when workers go
home and this not only opens the door for crime, but creates a sterile social
environment that may encourage further neglect. Also, it indicates that the quality of
a business’ social capital contribution is certainly affected by the physical
environment in which the firm operates. These kinds of answers point to problems
with designing industrial estates and business parks that are not connected to the
wider community.

130
Contamination Practices and Perceptions
Of the 61 businesses that answered the question about experience with land
contamination, only 5 replied in the affirmative, with 77 percent stating no
experience with contamination and 16 percent claiming they did not know.
Explanations of the land contamination problems were: One company is located in
the vicinity of an EPA Superfund site and the EPA tried to put the business “in the
same category”; One business stated that the previous owner poured oil/gasoline
down a drain into an unmarked/unknown underground sump and the County came to
check the sump, but the business had previously been unaware that it existed; One
business stated that prior to taking ownership/occupancy, the main sewer line failed,
flooding the grounds contained within that section of the foundation, but the
information had been disclosed by seller; and One company is located near a
Superfund site and stated “our property is clear, but [undergoing] ongoing testing.”
These responses suggest that businesses do not think much about land
contamination until it affects them directly, but once it does they understand that
problems on nearby properties affect them. The instance of the unknown
underground sump is an example of a problem that long-standing businesses may
encounter more frequently since former property transactions likely did not involve
the scrupulous attention to subsurface contamination that exists today.
Approximately 13 percent of respondents said that they monitor the soil
conditions at their business on a regular basis, while 82 percent said they did not and
less than one percent said they did not know. The reasons given for these responses
131
were that they undertook monitoring every few years as per insurance requests, were
required to very often at one point in time and now not as often, that visual
inspections for abnormalities were practiced and one said that it was done
preventatively for fear of liability: “We're in California, home of ten million lawyers,
better safe than sued.” One respondent implied a strong familiarity with regular
monitoring: “Intense and extensive State regulated tests and procedures maintained
constantly 7 days a week, 365 days a year.”
When asked if the soil conditions at their businesses had ever been assessed,
48 percent said this happened at the time of purchase, less than one percent said this
was done during new construction and 44 percent said this had never been done.
Other answers provided were: “1 year ago,” “5 years ago,” during “annual water
runoff testing,” during laying of “cement foundation,” when an underground storage
tank (UST) was removed at time of purchase, to fulfill an EPA requirement, “within
the State required timeframe,” and “when refinanced.” These findings indicate that
operating businesses are not likely to be the sources of brownfield identification
since soil monitoring is not commonly practiced, but also that small businesses do
not associate their testing requirements with brownfields.
When asked how they would identify a contaminated property, the most
frequently occurring answer is that a sign would be posted at the property (See Table
11.); however, this is not often the case. The second most popular answer was “I
don’t know” followed by “Other.” The explanations for “Other” answers were
widely divergent: a letter from the city or business owner prompted by the city; ask
132
the neighbors; if remediation equipment is on site (2), lack of vegetation (2),
presence of “empty drums” or containers on site (2), “slimy, oily slick on ground
surface,” you cannot know by sight (2), soil testing required, and if there is a smell of
fumes or evidence of discharge from drains or other outlets.

Table 11: Indications that a Property is Contaminated

Signs posted at the property 34
I don't know 17
There is a fence around it 13
Other 10
It is vacant 9
There is trash/debris on it 9
Note: Respondents could select more than one attribute.

The diverse nature of the answers implies that there is little consensus on
what constitutes a contaminated site, but there is considerable suspicion that it might
not be possible for a business to know if it occupies a contaminated site.
As presented in the Table 12 below, the majority of respondents—80
percent—disagreed with the statement that “contaminated properties are a problem”
in the neighborhood. When asked whether “abandoned, vacant, or contaminated
properties” were located at a one-block distance, 69 percent disagreed and 58 percent
disagreed at the half-mile mark. This implies that firms think there are troubled
properties, but not very close to their businesses. However, the suggestion that more
than 30 and 40 percent respectively think that these properties may exist in the
neighborhoods is still of significant concern.
133
Table 12: Perceptions of Contamination

SA AS BA
AGREE
DIS-
AGREE
BD DS SD Total
Contaminated
properties are a
problem in the
neighborhood
where my business
is located.
2% 8% 10% 20% 80% 21% 16% 43% 61
There are
abandoned, vacant,
or contaminated
properties within
one block of my
business.
13% 11% 7% 31% 69% 7% 15% 48% 61
There are
abandoned, vacant,
or contaminated
properties located
within a half-mile
of my business.
15% 12% 15% 42% 58% 5% 14% 39% 59
*Note: SA=Strongly Agree; AS=Agree Somewhat; BA=Barely Agree; BD=Barely Disagree;
DS=Disagree Somewhat; SD=Strongly Disagree; Total=the number of respondents who answered the
question

Legal Liability Perceptions
A large majority of the survey respondents (nearly 70 percent) agreed with
the statement that they are knowledgeable about the land use regulations that apply
to their neighborhoods; however, they were less confident that other businesses in
their neighborhoods were as well-informed. Whereas this may be an artifact of the
question itself—if respondents would not want to express their own ignorance—it
could also indicate a lack of trust. (See Table 13.) More than seventy percent
supported the idea that the land use regulations that apply to their businesses are
“reasonable,” but a large number (66 percent) indicated that they were “concerned
about the liability” that applies to businesses regarding land cleanup in the
neighborhoods where their businesses are located. More than sixty percent concurred
134
that the applicable costs of complying with land use regulations are too high and 70
percent supported the statement that “land use regulations, including cleanup
liability” would significantly influence their decision should they decide to relocate
their businesses. More than half of the respondents expressed concern that land use
regulations “contribute to business failures” in the neighborhoods where they do
business and more than half also supported the statements that land use regulations
affect the competitiveness of their businesses locally, nationally, and internationally.
Lastly, a very significant majority of respondents (82 percent) disagreed with the
statement that businesses like theirs receive a lot of assistance in cleaning up land
that may become contaminated during their operations.
Taken together, these findings imply that businesses feel that they know
enough about land use regulations, but the information they have causes them to see
land use regulations as a threat in the case of discovered contamination. Further,
though hypothetical in nature, the last question implies that businesses do not think
they would be able to attract assistance should they discover contamination and
therefore might be unwilling to disclose its discovery. This, if actualized, does not
bode well for already struggling, blighted communities.

135
Table 13: Regulatory and Liability Perceptions

SA AS BA
AGREE
DIS-
AGREE
BD DS SD Total
I am knowledgeable about the land
use regulations that apply to my
neighborhood.
20% 38% 11% 69% 31% 3% 11% 16% 61
Other businesses in the
neighborhood where my business
is located are well-informed about
land use regulations.
2% 31% 29% 61% 39% 10% 14% 15% 59
The land use regulations that apply
to my business are reasonable.
9% 38% 26% 72% 28% 12% 5% 10% 58
If I decided to move my business
to another location, land use
regulations, including cleanup
liability would significantly
influence my decision.
30% 22% 18% 70% 30% 7% 5% 18% 60
I am concerned about the liability
that applies to businesses
regarding land cleanup in the
neighborhood where my business
is located.
23% 25% 18% 66% 34% 7% 13% 15% 61
The costs of complying with land
use regulations that apply to my
business are too high.
17% 22% 23% 62% 38% 8% 15% 15% 60
I am concerned that land use
regulations contribute to business
failures in the neighborhood where
my business is located.
10% 19% 24% 53% 47% 10% 16% 21% 58
Land use regulations affect the
competitiveness of my business
locally.
12% 20% 19% 51% 49% 8% 17% 24% 59
Land use regulations affect the
competitiveness of my business
nationally.
24% 15% 17% 56% 44% 12% 10% 22% 59
Land use regulations affect the
competitiveness of my business
internationally.
25% 12% 15% 53% 47% 8% 8% 31% 59
Small businesses like my business
get a lot of help to clean up land
that may become contaminated
during their operations.
4% 2% 13% 18% 82% 14% 29% 39% 56
*Note: SA=Strongly Agree; AS=Agree Somewhat; BA=Barely Agree; BD=Barely Disagree; DS=Disagree Somewhat;
SD=Strongly Disagree; Total=the number of respondents who answered the question

136
Taboo and the Culprit Perception

When asked if they would consider relocating their business to a former
(remediated) brownfield should they decide to move, the answers of the respondents
were almost evenly split among the three response categories (See Table 14.):

Table 14: Business Willingness to Relocate to a Former Brownfield

Yes 20
No 21
Don't Know 20

These results imply that only one-third of the respondent pool would
definitely be willing to relocate to a remediated brownfield. Given that much of the
push in Los Angeles is to clean up contaminated industrial land and attract new firms
to such sites, these results are not promising. However, the explanations given for the
answers offer some important insight about the need for firms to have assurance
from external sources in order to (1) guarantee the health and safety of themselves
and their workers and (2) protect themselves from liability:
“As long as all assurances have been made that I would not be responsible for
any additional clean-up as a result of the prior owners and the property is safe
to use”; “Employee liability”; “How well it was cleaned up does matter”; “I
would be concerned about future liability”; “I would be too concerned about
the health and well-being of my employees both short-term and long-term”;
“I would not like to deal with other people's problems”; “I would not know if
the contamination was properly cleaned up: “I might move if I would have a
geologic report that stated it was cleaned up”; “If I had solid proof that it had
been cleaned up I would have no problem”; “If the price was right and the
area suitable”; “If the proper authorities inform me that the property is safe,
and the price is right, I would be willing to relocate”; “In order to move into a
once contaminated property I would need to talk with a lot of people who are
familiar with this topic”; “Insufficient information given: how much
contamination; of what kind; what was the remediation; how reliable is the
remediation?”; “It would depend upon perceived future liability”;
137
“Not ‘living’ there, I believe any exposure would be minimal”; “Potential
long-term health problems with employees”; “Potential additional clean-up
costs”; “Providing that no health hazards were present”; “Why not?”; “Would
need more information”; and “Wouldn’t want to take a chance to expose
myself and my employees to possible ‘leftovers’ of harmful contamination.”

The detailed answers also provide information regarding the level of trust that
businesses have in the brownfield redevelopment process—that they are unaware of
“proper” levels of clean, the “proper” authorities to contact, that they need “proof”
and are concerned about “possible leftovers” of contamination. The frequent
contention that some kind of evidence from an external party would be required may
be an indication that small firms understand there is a complex regulatory
environment associated with brownfield cleanup and liability.
At the conclusion of the survey, respondents were asked to discuss what they
think of as the most important environmental issue concerning the operation of their
business. Responses were open-ended and tended to focus on concerns regarding
compliance with regulations and their associated cost and time demands. Air quality
regulations were mentioned in nine cases, Occupational Safety and Health
Administration (OSHA) regulations were mentioned twice, but the primary
compliance concerns were with the disposal of hazardous waste, which was
mentioned 14 times. There was concern expressed about the difficulty of following
“ever-changing” regulations and the fact that they can unnecessarily overlap across
levels of government. Many of the comments distinctly underscored the notion that
small manufacturers are often made to feel like culprits in regard to environmental
management (See Table 15 on the following page.):
138
Table 15: Small Businesses as Culprits

CATEGORIZATION OF OPEN-ENDED COMMENTS
Sentiment/Theme Verbatim text
Culprit—other
regulations
Effect of ever-changing government regulations affecting the products we sell
(paints, adhesives, sealants, and miscellaneous chemical products, etc.)
Culprit—pollution
control
compliance/regulations
The cost of having to purchase new process equipment and less toxic products
when regulations change.
Culprit—likely
regulations
It is very difficult to manufacture in California, therefore we manufacture
internationally via contract manufacturing resources.
General recognition of
environmental
compliance issues
Mold and possibly other effects by urbanization on the deterioration of the rental
buildings I own.
General dissatisfaction
with aged
infrastructure
Lack of infrastructure because as a manufacturer we must interact with materials
processors and the travel and delivery times are making it very expensive to meet
customer deadlines.
General recognition of
environmental
compliance issues
Proper disposal of chemicals used in our manufacturing processes.
Culprit—pollution
control
compliance/regulations
Subcontractors (degreasers, platers, etc.) are limited in the processes they can use
and their prices skyrocket due to environmental regulations.
Culprit—regulations in
general
Taxation by all the government organizations that overlap in regulation
Culprit—pollution
control
compliance/regulations
The discontinuation of paints and adhesives even in deminimus amounts. All the
replacement products are inferior causing customer dissatisfaction and money
loss.
Culprit—pollution
control regulations
The excessive cost of permits, excessive cost of necessary equipment to assist in
pollution control, excessive regulation without the necessary help to comply, the
excessive power of agencies like Cal OSHA which are wholly punitive and not
helpful for owners
Culprit—regulations in
general
The sizes of taxes levied on our company when governmental agencies decide to
fund new regulations or increase current fees
Culprit (size bias)
The very small business owner who generates the least amount of contamination
is still treated as though they are a major contaminator.
Culprit—liability,
proliferation of
litigation
Trial lawyers, frivolous lawsuits from people looking to cash in on the anti-
business sentiment in California…File and settle.
Culprit—compliance
inspections
Working with over burdensome "inspecting" agencies.
Culprit—pollution
control
We are taxed by the city, city fire department, county and its various
departments, state and its many departments, for the same environmental
regulations, this clearly impacts our bottom line and in the end may force many
businesses (in order to stay competitive). Manufacturing is being squeezed out of
this state due to the state and local government and its agencies. It is one of the
most business unfriendly states. This continuing loss of businesses creates a loss
of jobs and hurts the economy. Regulatory agencies are only punitive and small
business owners need help and advice instead of fines which are totally excessive
and not only put businesses out of business but also put American workers on the
bread lines.

139
One respondent mentioned a brownfield policy in particular—the process of
obtaining a “no further action” letter from the USEPA which provides a measure of
protection to a property owner against further liability claims. This individual
mentioned that the process of obtaining a NFA was not expedient. These comments
are instructive examples of the way small manufacturing firms have come to feel
antagonized by the governmental infrastructure concerning environmental
compliance and may suggest that there is a disconnect between how regulators and
policymakers understand the problem and how small businesses do—since they are
not aware of existing programs and have a widely divergent understanding of the
brownfield issue. Given these conditions, since small firms are presently treated as
culprits in regard to brownfields, they then may be less likely to engage as willing
clients in cleaning up brownfields. Moreover, a stigma or taboo associated with the
cleanup of contaminated land appears to exist and, lastly, governments—or the
distant and instrumental “other”—are seen as the drivers of brownfield
redevelopment.

Instrumental Dominance
When asked what would happen if a contaminated property was found in the
neighborhood where they do business, respondents were largely supportive of the
owner cleaning up the property independently, but indicated that the government
would become involved in the process at some point (See Table 16 on the following
page.):

140

Table 16: Expected Action on Contaminated Site in Neighborhood
It would be discovered prior to resale and the owner would clean it up 32
It would be reported to the government by someone in the neighborhood 17
The owner would clean it up his/herself 15
The government would discover it during inspection 15
Nothing 13
It would be discovered prior to resale and the new owner would clean it up 9
It would be reported to the government by the property owner 8
It would be discovered after resale and the new owner would clean it up 6
The government would provide help to the old owner in cleaning up the property 6
It would be cleaned up by the government 3
The government would provide help to the new owner in cleaning up the property 2
Note: Respondents could select more than one attribute.

Explanations for the “Other” answers were “I don’t know,” “the property
would be used as-is,” “it is discovered after sale and then the owner has to sue the
prior owner,” “the government would force the current owner to clean it up at a very
high expense, regardless of fault” and “I only assume the government would find out
during inspection…cannot speak for businesses besides my own.” Altogether these
answers imply confusion on the part of small businesses regarding how contaminated
properties are transacted.
Approached differently, the businesses were asked who would “take the lead”
in cleaning up a contaminated property in the neighborhood where they do business
and they answered as follows (See Table 17 on the following page.):
141

Table 17: Lead Actor in Brownfield Cleanup

The government 33
The business 18
Insurance company 13
The community 12
Other
19
9
Real estate developer 8
Consultants 1
Note: Respondents could select more than one attribute.

This perspective shows a decided expectation on the part of small businesses
that the government will become involved in the clean up of contaminated properties
in their neighborhood yet, as shown previously, they are largely unfamiliar with the
“proper authority” or procedures involved. Also, this set of responses paints the
government into an antagonistic role regarding its interaction with the business
community concerning brownfield cleanup, but shows that there is an expectation of
an instrumental meaning of brownfield—even if they are unfamiliar with it.

19
The “Other” category included: AQMD and other regulatory agencies; depending upon
contamination; depends on the type of contamination; if there is a special group that cleans up
asbestos for example, I think they would take the lead; I do not know; I don't know, maybe the
government (superfund) if it was abandoned, or maybe the owner if they were found liable; I really
don't know; lawsuits would be filed and the taxpayers would pay for it all; no one in the neighborhood
seems to be too concerned about property. In fact, they contribute to the problem by dumping trash,
graffiti; nobody; the clean-up would occur only if the business was forced to take action and the
business had enough money to clean the property; government would make the business who was
responsible for contamination clean it up, in most cases; the property owner (3).
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Table 18: Identified Sources of Contamination Information

Actors/Agents Businesses would Approach to Find Out if Contamination
is Present on a Neighborhood Property

The government 37
The owner of the property 18
Consultants 15
Real estate agent 12
A community organization 11
Other 5
Real estate developer 4
Insurance company 0
Note: Respondents could select more than one attribute.

Table 18 confirms the perceived importance of government’s role in
information-sharing about brownfields. “Other” responses offered included
contacting the Air Quality Management District, neighbors and two said they did not
know. Again, this reinforces the idea that businesses are unclear about how to go
about dealing with brownfields; this is further reinforced by the following (See Table
19.):
Table 19: Recipients of Contamination Reports

Actors/Agents Businesses would Approach if They Suspect Contamination
on a Neighborhood Property
The government 25
Real estate agent 21
Consultants 20
Real estate developer 14
Other 14
No one 2

Among the “Other” responses, eight said they would contact the previous
owner of the property and three mentioned they would enlist an attorney, one
143
mentioned they would first contact the local government and then the federal
government, and two concluded that the sale would be annulled.
According to the Community Redevelopment Agency in Los Angeles, it can
take up to 15 years to return a brownfield to productive use because of the difficulty
in determining contamination levels, identifying responsible parties, and financing
redevelopment. Although private sector brownfield projects may turn over more
rapidly, the private sector often does not go after small parcel projects in
disadvantaged industrial neighborhoods. According to the survey responses (See
Table 20.), the firms in the respondent pool have a wide variety of expectations (but
notable underestimations) concerning the amount of time it takes to redevelop a
brownfield:
Table 20: Time Required to Clean a Property and Return it to Use

Less than 6 months 20
7 months to 1 year 22
1 to 2 years 11
3 to 5 years 7
6 to 10 years 0
11 to 15 years 0
More than 15 years 4
Don't Know 2

Regarding business networking, manufacturing associations were the most
commonly cited organization for this purpose, followed by Chambers of Commerce
and technology groups (See Table 21 on the following page.). Few respondents
indicated a direct connection with a community group, but in general there was a
diverse representation across the potential networking options.
144
Table 21: Participation in Business Network Groups

Manufacturing association 32
Chamber of commerce 22
Technology group 14
Lobbying group 9
Community group 8
Other 8
Government group 4
University research group 1
Note: Respondents could select more than one attribute.

The firms also mentioned participation in distribution associations, executive
forums, a Hispanic business association, a police group, and trade and business
magazines.
Regarding where they obtain most of their land use information, a notable
majority listed local government as the primary source (See Table 22 on the
following page.), which makes sense given that they must work with the local
government to secure licenses and permits related to their business operations;
however, the lack of consensus concerning the understanding of the brownfields
issue means that they are not receiving this kind of information in concert with the
other. This also suggests a dominance of the instrumental meaning, since this
information is expected to come from local governments.

145
Table 22: Sources of Land Use Information

Local government 30
Newspaper 18
State government 16
Federal government 12
Manufacturing association 11
Television 11
Internet 11
Trade publications (journals, etc.) 11
Radio 9
Other 5
Lobbying group 4
Technology group 4
Community group 2
University research group 1
Chamber of commerce 0
International sources 0
Note: Respondents could select more than one attribute.

The small business survey helped to articulate the perceptions of small
manufacturing businesses regarding brownfields. However, their expressed
understanding of the problem—via embracing the instrumental or government
dictated meaning—may be different than that of other community stakeholders. To
obtain information on broader community perceptions, a content analysis of
community land use plans was conducted. This will be discussed next.

146
II. Community Plan Content Analysis
California law (Government Code Section 65300) requires that each city
prepare and adopt a long-term general plan to guide its development. There are seven
mandatory elements within the general plan: land use
20
, circulation, housing,
conservation, open space, noise, and safety. The City of Los Angeles General Plan
includes 35 Community Plans, which comprise the its required Land Use Element.
State law requires citizen participation in the preparation or amendment of
the General Plan (including its elements)
21
. Each community plan includes a
demographic profile, history, and growth projections. Community plans are
periodically updated and citizen participation is required in evaluating proposed
changes. Both public and private development propositions are evaluated for their
consistency with the community plan and approval decisions are linked to this.
Since they derive from a governmental requirement, are guided by the City
Planning Department,
22
and conform to a predetermined format, Community Plans

20
The land use element regulates how land is to be developed and is required to “designate the
proposed general distribution and general location and extent of uses of the land for housing, business,
industry, open space, including agriculture, natural resources, recreation, and enjoyment of scenic
beauty, education, public buildings and grounds, solid waste disposal facilities, and other categories of
public and private uses of land.” (City of Los Angeles Planning Department Granada Hills-
Knollwood Community Plan 1996, II-1)
21
From California Government Code 65351, “…the planning agency shall provide opportunities for
the involvement of citizens, public agencies, public utility companies, and civic education, and other
community groups through public hearings and any other means the city or county deems
appropriate.” (Ibid., I-3) A typical community plan’s drafting involves members of the community
who “identify and define the needs, desires, resources, and the unique nature of the community.”
(Ibid.) The role of a community plan is “to provide a guide to the future development of the
Community for the use of the City Council, the Mayor, the City Planning Commission; other
concerned governmental agencies; residents, property owners, and businessmen of the Community;
and private organizations concerned with planning and civic betterment.” (Ibid., II-1)
22
For example, the public involvement process of the Southeast Los Angeles Community Plan
development is described here:
The appointment of Staff, consultants and parcel level survey of the Community Plan area
was completed by 1992. After the disturbances of April/May of that year, the local
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are by their nature not ideal representations of community expression—in fact they
may be seen as products of an instrumental process. However, because each
community engages in the plan development and update process, they are useful as
proxies for local expression with the caveat that they reflect local land use priorities
in a structured way, “...it is necessary to update the Community Plan to not only
reflect current conditions, but to accurately reflect the prevailing visions and
objectives of the area's residents and property and business owners.” (Sylmar
Community Plan, II-2) The plans were evaluated to determine how (if at all) they
included brownfields.

Data Pool

The General Plan’s Conservation Element and Land Use Element (comprised
of the 35 Community Plans) were evaluated to determine (1) how brownfields were

organizations from within the Community were empowered to create neighborhood plans
and to establish implementing organizations to see that these plans were put into effect.
These organizations offered City Planning Staff a unique opportunity to interact with citizens
as they developed creative planning solutions for their neighborhoods. Concurrently,
Citywide Staff were conducting a series of Community meetings to gather information as
part of the Citywide General Plan Framework revision program. Plan Revision Staff were a
part of this process, which offered further opportunities to access the community through
public meetings and through smaller group meetings organized by homeowners associations,
Chambers of Commerce and other neighborhood organizations. In addition to these
opportunities to gather public information, Staff was invited to several of the CRA CAC
meetings to meet with both those appointed committee members and the wider public as they
discussed issues pertinent to the revitalization of the Community. As a result of these
activities Staff was provided the following opportunities: To gather information and insight
concerning the needs, desires, resources and unique nature of the community; To inform
residents and business interests about the planning process; To allow members of the
community an opportunity to participate in the planning process; To build consensus for
approval of the plan and strengthen the ability of the citizens of the community to be
involved in the implementation of the plan. Upon preparation and approval of the
Community Plan or any amendments thereto by the City Planning Commission, the approved
changes are presented by the Director of Planning, together with the Commission’s report
and recommendations to the Mayor and the City Council for adoption. (Southeast Los
Angeles Community Plan, I-3-I-4)

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interpreted (if at all), (2) how pollution ideas were expressed, and (3) how solutions
to pollution problems were prescribed. A content analysis was performed and
language addressing each Community’s expressed pollution ideas was extracted.
These excerpts are included in the table in Appendix II; a summary of the priorities
expressed in the Plans are provided next.
The term “brownfield” is not used in any of the 35 Community Plans;
however, it is included in the Conservation Element in reference to hazardous
materials, “The city has a primary regulatory, informational and catalytic role in
hazardous materials management, clean up and brownfields site revitalization. (46)
The Element also references the outdated definition of brownfield: “abandoned,
inactive or underutilized industrial and commercial properties where expansion or
redevelopment is complicated by real or perceived environmental contamination.”
(44) This is from Section 101 of the Comprehensive Environmental Response,
Compensation, and Liability Act of 1980 (42 U.S.C. 9601).
The Conservation Element indicates that the U.S. EPA provides funds for
brownfield site assessment and “revitalization of sites that are contaminated with
hazardous materials.” (44) The City’s brownfield program is described as “a
collaborative approach to redevelopment of individual or groups of old industrial
parcels” and contentions are made regarding the challenge of brownfield
redevelopment, “Soil contamination often is a major deterrent to redevelopment
because owners lack the funds to clean up the contaminants which are impeding
property sale or improvement. (Ibid.) The Element articulates that most brownfields
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are found in “communities which grew up around industries, some of which were
established before World War I” and outlines the goal of the City’s program, “The
goal of the city program is to assist property owners in resolving contamination
related problems (e.g., legal, financial, bureaucratic) so that contaminated properties
can be cleaned up and redeveloped, thereby providing a catalyst for community
revitalization.” (Ibid., 44-45)

Existing Brownfield Sites
In addition to describing the City’s involved agencies and services (to
provide technical expertise, help secure funding, coordinate infrastructure
improvements and assist in site redevelopment), the Conservation Element discusses
two of the City’s most publicized brownfield sites: the Goodyear Tract, a 208-acre
industrial area in South Central Los Angeles near the Alameda rail corridor and the
former Crown Coach site, a 20-acre vacant, contaminated site owned by the State of
California and located less than three miles from the Los Angeles civic center
downtown (Site 2 discussed above.). Both sites have been identified by the City
program as polluted, but their chosen method of cleanup differs. The Goodyear Tract
was designated as a redevelopment project area, to be administered by the Los
Angeles CRA and redeveloped for industrial use. The Crown Coach site remediation
was initiated via a special agreement between the City and the state through which
the City took responsibility for assessing the site, cleaning the soil and issued a
request for development proposals that would “maximize community and economic
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benefit of the site.” (46) The selected developer is expected to collaborate with the
state to accomplish the required groundwater remediation.

Brownfield Perceptions
The Element presents the City’s responsibility as “a primary regulatory,
informational and catalytic role in hazardous materials management, cleanup and
brownfields site revitalization” and identifies the following as ongoing priority
issues: the need to reduce the amount of release of toxic waste into air, land and
water; the need to clean up existing contaminated sites that pose a threat to public or
environmental health, or discourage site redevelopment; to eliminate the improper
use, storage, transport or disposal of hazardous materials; and to prevent the
accidental release of hazardous materials. (45)
In terms of the interpretation of the meaning of “brownfield” at the City
agency level (as expressed in this Conservation Element), brownfields are considered
a hazardous materials problem and the focus is on large sites with a governmental
solution. This is a restrictive, instrumental definition that is not reflected in the
Community Plans at all. While there is a familiarity with the federal government
roots of the brownfield problem as well as the City program in the Conservation
Element, these are not referenced in any of the 35 Community Plans. The community
plans do discuss brownfield sites (e.g., the Cornfield and Terminal Annex sites in the
Central City North Community Plan and the Sears site in the Boyle Heights
Community Plan), but never call them brownfields. Some of the brownfield sites
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mentioned in the plans are included within CRA project areas since the CRA is
tasked with improving blighted communities. (As required by California Community
Redevelopment Law, these project areas are designated as blighted by the CRA
Board, the Mayor and the City Council and a redevelopment plan is approved for
each.) This is an economic development zone type of approach to community
revitalization. Within a CRA Project Area, both public and private developments
require the additional review and approval of the CRA. However, this separation
from the Community Plan articulation of the brownfield problem may further
distance the problem from citizens as it is drawn further into the purview of
governmental experts.

Diversity in Expressed Pollution Perceptions
The content analysis of the Community Plans indicates that there is a wide
range of what the communities consider pollution (e.g., deteriorated housing stock,
vacant and underutilized historic structures, graffiti and dumping of litter, obsolete
strip malls, unsightly industrial areas, soil contamination, etc.), yet each of these may
fall within the purview of the legal definition of brownfield. (See Appendix II for the
excerpted references from each Community Plan.) For instance, the following are
examples of pollution priorities in different plan areas, and their diversity indicates
that focusing upon the instrumental definition of brownfield risks masking
differences such as these:

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1. Industrial hazardous waste contamination in Arleta-Pacoima;
2. Visual and physical pollution from auto-related land uses in Brentwood
Pacific Palisades;
1. Blighting impact of vacant and obsolete commercial development on adjacent
residential neighborhoods in Canoga Park- Winnetka-Woodland Hills-West
Hills;
2. Perceived lack of safety and cleanliness and high vacancy rates in older
office buildings in Central City;
3. Deteriorated and blighted residential rehabilitation needed in Hollywood;
4. A need to preserve historic structures through rehabilitation and adaptive
reuse in North Hollywood-Valley Village;
5. Costs of abating soil contamination or underground tanks prior to expansion
or redevelopment of industrial sites in Northeast Los Angeles;
6. The demolition of buildings damaged by the earthquake that have been
abandoned by property owners, and determined to be a public nuisance in
Northridge;
7. Absentee ownership with little or no commitment to neighborhood values
that has resulted in blight in South (Central) Los Angeles;
8. Port-related contamination, illegal dumping and other criminal activities have
occurred in some industrial areas of Wilmington-Harbor City;
9. Contamination from gravel mining and cement production operations in Sun
Valley-East La Tuna Canyon; and
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10. Land uses that result in contamination of coastal wetlands and the Santa
Monica Bay in Westchester-Playa del Rey.

Brownfield Language
Recalling the instrumental definitions of “brownfield” discussed in Chapter
Two,
23
it is clear that even though the community plans do not reference the term
itself, they still use language related to it; for instance: “industrial hazardous waste
contamination and costs of cleanup” (Arleta-Pacoima Community Plan), the “cost of
mitigating any hazardous waste contamination” (Mission Hills-Panorama City-North
Hills Community Plan, North Hollywood-Valley Village, Westlake Community
Plan), “cost of abating soil contamination or underground tanks prior to expansion or
redevelopment of industrial sites” (Northeast Los Angeles Community Plan), “cost
to mitigate any hazardous waste at old industrial sites” (Reseda-West Van Nuys
Community Plan), and the “cost to clean up some sites, which include hazardous
wastes, contaminated soil, or abandoned oil wells” (Wilmington-Harbor City
Community Plan).
The plans’ language also underscores the relationship between a history of
industrial use and land contamination, e.g.: “industrial pollution from petroleum and
marine supply uses” (San Pedro Community Plan), “abandoned or underutilized

23
The most recent definition, “real property, the expansion, redevelopment, or reuse of which may be
complicated by the presence or potential presence of a hazardous substance, pollutant, or
contaminant.” (H.R. 2869, the Small Business Liability Relief and Brownfields Revitalization Act of
2001, Section 211 (a)(39)(A)) and, arguably, the most widely used definition, ““abandoned, idled, or
underused industrial and commercial facilities where expansion or development is complicated by
real or perceived environmental contamination” from Superfund (U.S. Code, Title 42, Chapter 103,
154
industrial structures and properties” (Silver Lake-Echo Park-Elysian Valley
Community Plan), “because many industrial facilities use or have used toxic
materials, industrial sites may need toxic waste ‘clean-up’ to OSHA or
Environmental Protection Agency standards before they can be used for other
purposes such as retail, office, residential, educational or even new industrial”
(Sylmar Community Plan), and “industrial sites especially the larger sites often need
extensive toxic remediation before they can be used” (West Adams-Baldwin Hills-
Leimert Community Plan). Using very similar language, some of the plans advocate
new industrial recruitment that attracts, “desirable (‘clean’) industrial uses, thus
generating less harmful pollutants and lower noise levels” (Reseda-West Van Nuys
Community Plan, Canoga Park-Winnetka-Woodland Hills-West Hills Community
Plan, Encino-Tarzana Community Plan, North Hollywood-Valley Village
Community Plan, Sherman Oaks-Studio City-Toluca Lake-Cahuenga Pass
Community Plan, Silver Lake-Echo Park-Elysian Valley Community Plan, Van
Nuys-North Sherman Oaks Community Plan). This provides evidence that new
industrial businesses are key future clients in these areas.

Reinforcement of Small Business as Critical Stakeholder
The importance of smaller parcels to redevelopment is also reinforced, e.g.:
the industrial sector is “characterized by smaller parcels, piecemeal development and
substandard streets, restricting the potential for site expansions to increase storage or

the Comprehensive Environmental Response, Compensation, and Liability Act of 1980, Subchapter I,
Section 9601).
155
production space, or the rehabilitation and reuse of structures” (Boyle Heights
Community Plan), “...small and medium-sized individual businesses offer continued
economic vitality and job growth opportunities despite an often blighted and
uninviting work environment, aging infrastructure, insufficient parking as well as
strong regional and international competition” (Central City Community Plan), and
an industrial sector “characterized by smaller parcels, piecemeal
development…restricting the potential for site expansions to increase storage or
production space. New industrial development is further discouraged by the absence
of vacant land” (Westlake Community Plan).
In the Wilmington-Harbor City Community Plan area, the problem is
described as resulting from “Fragmented absentee ownership of small industrial
parcels, leaving many scattered land sites either vacant or underutilized, and leading
to difficulty in assembling usable industrial sites.” Also, a “Lack of proper screening
controls and enforcement of open storage and salvage operations and the substandard
maintenance of various industrial sites and structures” has contributed to an erosion
of the area's image and has generated nuisance complaints from residents. (Ibid.)
Most of the community plans recognize the need to maintain existing
industrial land designations because they are unlikely to see an expansion of this use
due to competition from commercial, residential and other uses, e.g., “There are few
large, vacant parcels in the community. Most changes are likely to occur from
modification or adaptive reuse of buildings. The majority of new development is
expected to be small scale, unless parcels are assembled and existing structures
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demolished” (San Pedro Community Plan). Assemblage or aggregation of smaller
parcels into larger developments is considered a viable redevelopment option in
many of the community plans. This is supported in the Palms-Mar Vista-Del Rey
Community Plan, where “Assembly of small parcels to create industrial parks is
encouraged” and in others that encourage assistance in “the aggregation of smaller,
older sites to facilitate revitalization or reuse, where appropriate…[encouraging]
economic revitalization and the reuse of older industrial properties for industrial uses
through City, State and Federal programs” (Mission Hills-Panorama City-North Hills
Community Plan, Northeast Los Angeles Community Plan, Northridge Community
Plan, Palms-Mar Vista-Del Rey Community Plan, Reseda-West Van Nuys
Community Plan, Silver Lake-Echo Park-Elysian Valley Community Plan, South
(Central) Los Angeles Community Plan, Southeast Los Angeles Community Plan,
Sun Valley-East La Tuna Canyon Community Plan, Sylmar Community Plan, Van
Nuys-North Sherman Oaks Community Plan, Venice Community Plan, West
Adams-Baldwin Hills-Leimert Community Plan, West Los Angeles Community
Plan, Westchester-Playa del Rey Community Plan, Wilshire Community Plan).

Community Connectedness
Small businesses are also identified as important community elements, e.g.,
“The development of locally-based, small enterprises within the community, should
be encouraged as a vital part of the strategy to revitalize neighborhoods” such as
through the “training of local residents” (Northeast Los Angeles Community Plan),
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“Establish a fund for small business loans to allow industries to update their plants
and equipment” (Central City Community Plan), provide support “for legislation and
administrative actions which allow the City to continue to support small business
development, including but not limited to, small business revolving loan funds and
commercial corridor rehabilitation program, such as those established in the City’s
Commercial Area Revitalization Effort (CARE) Program” (San Pedro Community
Plan), “Support and encourage the expansion of existing programs operated by all
agencies that are designed to assist in the formation and growth of viable small
businesses in the community” (West Adams-Baldwin Hills-Leimert Community
Plan), preserve and promote “existing uses, particularly small businesses and artisans
which characterize Venice various neighborhoods” (Venice Community Plan),
“Ensure the viability of existing neighborhood stores (i.e. ‘mom and pop’) which
support the needs of local residents and are compatible with the neighborhood”
(West Adams-Baldwin Hills-Leimert Community Plan, San Pedro Community Plan,
South (Central) Los Angeles Community Plan, Southeast Los Angeles Community
Plan).

Diversity in Expressed Cleanup Approaches
The plans do not mention specific remediation strategies for cleaning up
pollution; instead, their solutions address the socioeconomic context of land
contamination problems. Indeed, these expressed cleanup approaches indicate that if
the focus was merely on soil remediation, that would commodify the brownfield
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process and marginalize important expressive meaning. The following are examples
of the diversity of community approaches to cleaning brownfields:
The creation of Business Improvement Districts (BIDs); encouraging self-
help preventative maintenance of decaying housing stock (through programs like the
Homeowner’s Encouragement Loan Program, the Residential Rehabilitation Loan
Program, and the Neighborhood Preservation Program), the rehabilitation of historic
structures and the creation of Historic Preservation Overlay Zones; development of
master plans, specific plans, corridor improvement plans, CRA project areas, or
special study areas; promoting interim use of vacant and underutilized sites;
establishing property improvement tax relief; adaptive reuse of existing structures;
implementing design guidelines such as the City’s “Crime Prevention Through
Environmental Design”; the formation of chambers of commerce; improved
community policing efforts; better code enforcement; and public-private investment
partnerships.
Other examples include “Sponsoring industrial and commercial promotional
programs to market new sites” (North Hollywood-Valley Village Community Plan)
and identifying and addressing “the overconcentration of uses which have resulted in
the encouragement of activities detrimental to the health and welfare of the people of
the community.” (West Adams-Baldwin Hills-Leimert Community Plan) In the last
case, the uses specified are auto-related, and the plan recommends “screening of
open storage and auto uses, and prohibit storage of automobile parts and other
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noxious commercial related products in front of commercial development exposed to
the street.” (Ibid.)
Some plans mention adherence to environmental regulations, such as the
California Environmental Quality Act (CEQA), the National Environmental
Protection Act (NEPA), the Clean Air Quality Act, the Clean Water Quality Act, and
the Southern California Association of Governments (SCAG) and South Coast Air
Quality Management District (SCAQMD) Regional Air Quality Management Plan
(e.g., the Mission Hills-Panorama City-North Hills Community Plan), but not in
specific reference to brownfield-type redevelopment. This tells us that there is some
recognition of an instrumental understanding of pollution in general; however, there
is a lack of familiarity with brownfields and a lack of awareness of the City’s
Brownfield Program.
Some plans reference external support for redevelopment, “Encourage and
assist economic revitalization and the reuse of older industrial properties for
industrial uses through City, State and Federal programs.” (e.g., the Northridge
Community Plan, Palms-Mar Vista-Del Rey Community Plan, Reseda-West Van
Nuys Community Plan, San Pedro Community Plan, Silver Lake-Echo Park-Elysian
Valley Community Plan, South (Central) Los Angeles Community Plan, Southeast
Los Angeles Community Plan, Sun Valley-East La Tuna Canyon Community Plan)
Too, this is an indication of a deference to external sources—governments—to solve
local land pollution problems. Ultimately this underscores the disconnect between
160
the expressive meaning of brownfields at the local level and the instrumental
meaning that fuels funding and technical assistance support systems.
To summarize, there is evidence in the community plans that a broader,
richer approach to brownfield cleanup is necessary and that a commodified,
instrumental approach is ineffective. The content analysis suggests that communities
do express ideas about brownfield pollution, but do not connect it with the City’s
Brownfield Program or its resources. Although the instrumental definition itself does
not reach them, there is evidence that the strategies by which they seek to clean up
brownfield problems may indicate that communities expect external guidance or an
instrumental control of the solution. For instance, in some cases, regulatory
processes were mentioned as problems, e.g., “Streamlining of regulations and, where
appropriate, the removal of regulatory barriers/obstacles to economic development
programs” (Northeast Los Angeles Community Plan, West Adams-Baldwin Hills-
Leimert Community Plan), regarding decaying historical housing stock, “The ability
to restore these buildings is hampered by a costly and long regulatory process,
accentuated by the high degree of absentee owners” (Westlake Community Plan),
and “Identify and amend or remove local ordinances that are duplicative and/or do
not offer protection to the community from hazards and nuisances while impeding
appropriate economic development” (Northeast Los Angeles Community Plan).
Some general conclusions may be drawn: communities are aware of land
pollution problems, they relate them to a history of industrial use, they embrace the
retention of small businesses in reuse, they connect cleanup to socioeconomic
161
development programs, and they perceive the regulatory process as a barrier. A
succinct example of this is referenced in the South Los Angeles plans: “Older strip,
industrial parcels present problems related to location close to existing residential
development, the cost of cleaning up toxic soil conditions, the lack of a labor pool
with appropriate skills, community perception and the flight of business from the
area. In addition, the number of agencies involved in regulations over new industrial
development creates barriers to the redevelopment of these older sites.” (South
(Central) Los Angeles and Southeast Los Angeles Community Plans)
The Northeast Los Angeles Community Plan presents the most overt strategy
for revising the instrumental process to integrate more of the local expressive
meaning:

Strengthen contacts and cooperation between public and private sector
organizations engaged in economic development activities within the
community; Determine an appropriate agency or organization to initiate a
regular schedule of meetings and networking activities between public and
private interests in targeted neighborhoods and communities; Continue
implementation of a regular review of local ordinances and their
effectiveness in protecting health, safety, and welfare; Promote more
effective enforcement of all applicable government codes regulating the built
environment and environmental quality; Assist enforcement agencies in
increasing community awareness of existing and proposed building, housing,
and zoning regulations; Encourage greater inter-agency cooperation in
developing zone code amendments and other zoning tools to better define
roles and responsibilities for review and enforcement; Encourage cooperation
in updating and disseminating zoning maps and databases in a timely manner
among regulatory agencies to ensure that regulations are applied more
consistently; Provide inter-departmental training opportunities on an on-
going basis to respond to changing enforcement issues; Identify areas with
soil contamination and underground storage tank problems and promote
abatement programs. (Northeast Los Angeles Community Plan)

162
This plan advocates prevention in identifying land pollution problems and it
calls for institutionalizing a regular process of educating community residents about
those problems and the applicable laws and regulations pertaining to them,
formalizes an accountability process by requiring periodic review of laws and
regulations as well as consultation with public and private sector parties involved in
implementing them.
Regarding the recruitment of new industrial development, the Westchester-
Playa del Rey Community Plan provides a site-specific example of prevention
action:
When a facility is proposed which will involve on site treatment and disposal
of industrial hazardous wastes and mobile hazardous waste treatment
services, and the handling, transfer of storage of commodities categorized by
law as hazardous, it is the policy to require an analysis of risk problems
which may arise within the facility itself and which may affect adjacent
facilities or areas be made and the results used in locating, designing,
constructing and regulating the operation of the proposed facility.
(Westchester-Playa del Rey Community Plan)

Ultimately, the plans indicate that there is a disconnect between community
expressions of brownfield problems and how they are captured or interpreted by the
contemporary governmental institutionalization of the problem. Local communities
do not define brownfields in the same way that regulators, planners, and
policymakers do and therefore are likely not aware of the relevance of the City’s
brownfield program and policies to them. This would affect the viability of
community-level cleanup because sites would go unacknowledged as brownfields
163
and communities would not be able to benefit from available assistance in not only
cleaning up existing sites, but in also preventing the reoccurrence of the problem.
Moreover, there does appear to be a recognition that industrial users are
likely culprits of contamination and there is a palpable taboo associated with trying
to redevelop contaminated sites. Regarding a distinction between the instrumental
and the expressive meanings of pollution, the plans indicate that the instrumental
meaning of brownfield is not understood and thereby not relevant to them even
though there is an understanding that land cleanup must follow an external
instrumental process defined by regulatory prescription.
The content analysis of the community plans enriches the investigation of
how brownfields are perceived at the local level by providing information about how
pollution and cleanup ideas are expressed and institutionalized. This also provides
reinforcement for the understanding of deindustrialization as an important factor in
brownfield creation and in the role of small businesses as key stakeholders. To
further inform the understanding of brownfields at the grassroots level, outreach to
another stakeholder—publicly recognized local leaders—was deemed necessary, in
order to provide a more well-rounded perspective on the problem and its
instrumental versus expressive meaning. These consultations will be discussed next.

III. E-Consultations with Neighborhood Representatives
Neighborhood Council representatives were selected as an important
brownfield stakeholder group because they are the faces of accessible and active
164
grassroots-level institutions with responsibility for interpreting, communicating, and
advocating local residents’ ideas about their neighborhoods in general. Also, these
individuals are not necessarily associated with a particular job or industry
classification (as with the small business stakeholders) or automatically responding
to a certain policy agenda (as with the authorship of master plans—to comply with
the General Plan and the Department of City Planning’s process). Instead, the value
of these stakeholders is in their ability to express local knowledge of their
neighborhoods from the more entrenched perspective of a resident.
According to the City of Los Angeles Department of Neighborhood
Empowerment (DONE), the “centerpiece” of the new City Charter approved by
voters in 1999 was the “vision of a citywide system of independent and influential
neighborhood councils” and the creation of DONE to guide that process. (DONE
2005) DONE oversees the approximately 87 certified Neighborhood Councils
throughout the City of Los Angeles.
Neighborhood Councils are “groups of people that, once certified by the
Board of Neighborhood Commissioners, will elect or select their own leaders,
determine their own agendas, and set their own boundaries.” (Ibid.) The Councils are
intended to be “as independent as possible from government so that they will
have…influence and power to affect citywide and local decision-making far beyond
what neighborhood groups have done” so that individuals could be “truly
empowered to guide the futures of their neighborhoods.” (Ibid.) The mission of
DONE is to “promote public participation in government and make government
165
more responsive to local needs by creating, nurturing, and supporting…[the]
citywide system of grass-roots, independent, and participatory neighborhood
councils.” (Ibid.)
In 1999 DONE conducted a public outreach and involvement process to
begin educating people about The Plan for a Citywide System of Neighborhood
Councils, which was approved via municipal ordinance on May 25, 2001 by the City
Council. Following a period of review and public comment, the Plan was revised and
then approved by the mayor in May 2001. The Plan establishes a framework to guide
local creation of Neighborhood Councils and “sets minimum standards to ensure that
Neighborhood Councils represent all stakeholders in the community, conduct fair
and open meetings, and are financially accountable.” (Ibid.)

Data Pool
DONE serves as the umbrella department which oversees the implementation
of the Neighborhood Council system. One critical function of the department is
information-sharing, which includes the provision of news updates and maintenance
of a Neighborhood Council database. Contact information data from the
approximately 87 Neighborhood Councils were obtained in November 2005; each
Council listed at least one contact with an electronic mail address. These addresses
were used to distribute electronic mail surveys in December 2005. Of approximately
80 surveys sent, 18 responses were received (a response rate of 23 percent), although
not all respondents answered all of the questions.
166
A brief, open-ended questionnaire was selected for the survey format in order
to (1) ensure that respondents would not be inconvenienced by the time required to
respond and (2) avoid limiting response possibilities. Four questions were included
in the survey as follows:
1. Are brownfields a problem in your neighborhood? (If yes, please describe
the problem.)
This question was intended to determine if Neighborhood Council representatives
are familiar with the term “brownfield” at all and, if so, what it means to them.
Answers to this question were expected to reveal familiarity and comfort-levels in
understanding the problem, which provides information into the readiness and
willingness of local stakeholders to participate in the prevailing brownfield policy
process.
2. What are the major pollution problems in your neighborhood (if any)?
This question was designed to uncover what pollution priorities exist in the
Neighborhood Council jurisdiction and, specifically, to see if they might be
brownfield-related even if the term is not invoked. Answers to this question were
expected to provide information regarding how brownfield redevelopment
procedures might be linked to existing, expressed pollution problems.

3. What are the major land use problems in your neighborhood (if any)?
Similar to Question 3 above, this question was designed to see if brownfield-related
concerns might be considered a land use as opposed to a pollution problem. Answers
167
to this question were expected to provide information concerning how brownfield
redevelopment procedures might be linked to existing, expressed land use problems.
4. How does your Neighborhood Council identify and communicate about
pollution and land use problems?
This question was designed to uncover how the Neighborhood Council identifies and
works to resolve problems in order to ascertain whether this process is similar across
jurisdictions. Answers to this question were expected to lend insight into whether the
prevailing brownfield process is viable across diverse jurisdictions and,
simultaneously, if opportunities may exist to enhance its effectiveness in
implementation.

Brownfield Perceptions
Results from the surveys were grouped according to the frequency of answers
by subject. These are presented in Appendix III and summarized here. Three
respondents stated that they were not aware of a brownfield problem in their
neighborhoods and 3 were unfamiliar with the term, asking, “What is a brownfield?”
In the three cases where responses were given, some very large sites were
mentioned: a former missile base, Port tank farm, the Belmont Learning Center and
in one case “not on a large scale” was mentioned and “gas stations” or “light
industrial uses” was offered.

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Expressed Pollution Ideas
Major pollution problems in the neighborhoods included air pollution (3 responses)
with references to diesel emissions (including trucks and ships) from the Port area, light
pollution from the Port, and AQMD's MATES II
24
study showing an “extremely high level of
cancer risk at Point Fermin,” air pollution from nearby freeways contributing to asthma, and
odorous emissions from the City’s Donald C. Tillman Water Reclamation plant in the San
Fernando Valley. Other responses included illegal dumping of trash (2 responses), an
indication that small businesses illegally dump waste into sewers (1 response), water pollution
(including runoff) (2 responses), traffic (2 responses), graffiti (1 response), industrial
pollution (indicating mechanic/auto body shops, gas stations, and garment shops), blight,
specified as “an aesthetic level, such as litter, garbage and abandoned bulky items” (1
response) and noise pollution (2 responses). One respondent indicated that pollution is the top
concern of the neighborhood, but did not specify what kind.
Responses concerning land use problems in the neighborhoods did not indicate they
are overtly concerned with brownfield-type pollution or redevelopment: Overdevelopment
that overtaxes existing infrastructure (3 responses); a lack of consistent planning and zoning
(2 responses); a lack of open space and parks (2 responses); too little viable public
transportation, school overcrowding, parking for commercial vehicles on residential streets,
and increased density through mixed-use housing construction (1 response each). Two of the

24
This refers to the South Coast Air Quality Management District’s Multiple Air Toxics Exposure Study
(MATES-II) for the South Coast Air Basin, originally published in March 2000. The SCQAMD is a regional
district of a state agency.

169
answers could be considered related to brownfield redevelopment: obtaining viable
commercial districts and maintaining historic structures.
In response to the question regarding identification of and communication about
neighborhood pollution and land use problems, multiple answers were provided by
respondents as follows: committees or board (4 responses, including a Port Committee,
Planning and Land Use Committee, the N. Gaffey Steering Committee developing vision for
land use in a specified area, and an Issues and Traffic Committee); community newsletters (4
responses, including e-mail broadcasts and website updates), letter campaigns (letters to
editor, to elected officials, including e-mail), work with the Council Office, hosting meetings
or attending meetings for members of the public, with officials, etc. (3 responses each),
membership in outside groups or task forces (2 responses, including the Western Avenue
Task Force), working with City departments and agencies (CRA, the Department of
Transportation, and Planning were mentioned), hiring an external consultant, and acting as an
individual stakeholder (1 response each).
The survey responses provide important anecdotal evidence that the brownfield policy
message has not reached the Neighborhood Councils in a comprehensive way. The
Neighborhood Council respondents expressed distinct ideas about pollution in their areas and
divergent ways of communicating about them; however, no links were drawn between
brownfields as a specific local pollution or land use problem. Because of the lack of
familiarity with the term, but the understanding that it is an existing problem, there may be a
recognition of an instrumental meaning, but it is not connected to the expressive meaning in
170
the neighborhoods. It is evident that Neighborhood Councils have a somewhat systematic way
of communicating with the municipal government, but this communication does not presently
include brownfields or the City Brownfield Program.

Conclusion
If contaminated lands are seen as pollution or “matter out of order” (Douglas
1966/2002), one might say that contemporary societies have constructed “brownfields” in a
quest to identify that which does not fit comfortably into societal order. Through this lens the
brownfield redevelopment process may be seen as a common mechanism for making dirt
conform to an idea of how society should look via how land should be used and reused.
However, from the case analysis of Los Angeles, we can see that what is ordered in terms of
planners and policymakers is not understood in the same way by other stakeholders.
The accent on the regulatory meaning of brownfield makes the concept reductionist: it
reduces or oversimplifies them so that they are seen simply in terms of their economic
development potential. At the same time, the term is exclusionist because it is not as widely
understood at the grassroots level. Rather, it falls within the purview of an expert knowledge
community of government officials, lawyers, planners, and engineers. Although local support
for brownfield redevelopment is recognized as important, communities are often barred from
taking advantage of brownfield funding and institutional assistance because they are not able
to easily navigate the regulatory process. Thus, “brownfield” may be seen as a taboo when it
restricts participation and suggests harm. The taboo is further dramatized because of the
171
widespread stigma associated with brownfield properties, an unsurprising conclusion given
that brownfields are associated with high costs related to cleanup liability—an idea that is
reinforced in the Los Angeles community land use plans. At the street level, brownfields are
usually fenced or somehow physically cordoned off from the community and this separation,
combined with a social legacy of Love Canal, Superfund and environmental justice concerns,
invokes a more literal understanding of brownfield taboo, as “a challenge to the established
classification is brought under control by some theory of attendant harm.” (xi)
As brownfield cases have become more well known, the taboo becomes more
powerful and it is manifested in very real behavioral responses within and among
communities. In particular, it sends a negative message to certain stakeholders that are critical
to long-term success of brownfield redevelopment: small industrial businesses. In this
analysis, the survey of small business owners in Los Angeles indicates that they understand
there is a negative association between them and land contamination liability, which translates
into their unwillingness to relocate to a former brownfield site. This reaction is supported in
the literature, where there is an understanding that a stigma exists which prevents property
owners from transacting brownfields. Geltman (2000) describes this in the stages of
brownfield evolution as “brownfield traps” when business owners are afraid to sell or expand
their operations and they subsequently “mothball” or abandon their properties. (5) Similarly,
Bartsch & Collaton (1997) describe how a property owner, unable to sell a contaminated
property, simply abandons it, and such vacated sites attract robbery, vandalism, arson, and
“midnight dumping”; these brownfields devalue neighboring properties. (2)
172
As these scenarios play out in communities, the term brownfield assumes a nefarious
meaning that is imbued with ideas of who is blameworthy, i.e., who is the culprit for
brownfield creation. Since a large majority of brownfields are small, urban properties in
commercial or industrial areas, this often means that small business owners are the culprits.
However, if these brownfields are intended for productive reuse, the same stakeholder group
must be approached for that to happen; in this sense they are treated as clients. A paradox
arises when the same stakeholder pool is treated as both culprit and client in the brownfield
equation because they are subject to the “taboo” understanding of brownfields, but are
expected to contravene it.

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Chapter 5:
How Taboos Are Transferred: Brownfields in Malaysia

If brownfields have attained taboo status in the U.S., as exemplified in the
case of Los Angeles, what happens when other countries, particularly culturally
dissimilar ones, emulate American examples of brownfield policy? Does the taboo
get transferred to newer contexts or do the differences in institutions, economy,
history, and context nullify its power? Since a taboo is the devalorization of social
construction by a triumph of instrumental over expressive meaning, the question can
be rephrased in the following way: When cultural and other differences make for
significantly different expressive meaning, as in cross-national comparisons, does the
focus on instrumental meaning still come at the cost of marginalizing or outstripping
the expressive meaning of brownfields? Do “culprits” and “clients” play out in the
same way as in Los Angeles? And if so, what are some processes, historical
antecedents, and contextual variations that make this possible?
These are the key questions of this chapter. Their significance comes from
two parallel realizations. First, many of the countries that emulate American
brownfield policy lag behind the United States in a developmental sense and this
makes for greater possibility of corrective action before development gets to the
point where there is little freedom left. Second, in the act of emulating American
brownfield policy, developing countries run the strong risk of inheriting the “taboo”
of brownfields minus their social context. The policy goals of this dissertation
function in the space between these two scenarios. A focus on social construction is

174
likely to allow the transfer of knowledge to developing countries while appreciating
the need to understand the vastly different institutional contexts within which the
transfer happens.
My comparison country is Malaysia, which has only very recently become
interested in brownfields. Malaysia is ahead of many developing countries in the
sense that it has begun to implement a brownfield policy. The tin mining industry
served as its “Love Canal” in stimulating the move toward a brownfield policy.
However, in Malaysia, the implementation of brownfield policy was not driven by
citizen protest of an environmental problem; instead, it was driven from the top-
down by experts from the Institute of Engineers (IEM) who approached the
Department of the Environment (DOE) to engage in a technology transfer
relationship with the U.S. when they recognized a similarity in the two contexts.
Thus, a notable difference in the two countries’ approach to the problem is the role
that civil society plays in the identification and management of brownfields—a
context that is threatened by an uncritical transfer of the taboo surrounding the
problem. Here, I intend to show by comparison that uncritical acceptance of the
taboo (1) assumes and imposes foreign values regarding land use, stewardship, and
cleanup/remediation roles and responsibilities; (2) removes decision-making from
the local level; and (3) splinters stakeholder groups that are necessary to prevent the
creation of future brownfields.
The chapter first provides an overview of the case study method, including a
synopsis of the brownfield problem in the Malaysian context as well as a discussion

175
of available data. Next, the historical geopolitical context of Malaysia in general and
Kuala Lumpur in particular will provide background to understanding the
urbanization and industrialization processes that have given rise to the brownfield
problem as it exists today. A subsequent exposition of the small manufacturing
sector provides grounds for comparison to the Los Angeles case, which highlights
how the sector is critical to brownfields in both places, but assumes a different role
as brownfield stakeholder in each. A discussion of the institutionalization of
environmental policy shows how there is currently a lack of capacity to address
brownfields in particular, but an active engagement via soliciting civic vigilance in
monitoring and reporting brownfield-type pollution problems. Finally, results of the
small business survey are discussed, which are anecdotal evidence of the current lack
of understanding of the brownfield problem in Malaysia. What becomes clear from
these different approaches to the issue is that Malaysia currently has a less formal
way of dealing with brownfield problems, and because of this, there are no obvious
“culprits” or “clients” that get rewarded or punished in the process.

A Brief Note on Method
Typically, case study comparisons rely upon a parallel definition of a concept
in two or more divergent settings. However, in my case such a design would not be
possible because the issue at stake is the meaning of the concept itself. For this
reason, I have used an alternate sampling—confirming and disconfirming cases—
where one elaborates on an initial analysis and then seeks exceptions, intentionally

176
seeking variation and extreme or deviant case selection whereby one learns from a
highly unusual manifestation of the phenomenon of interest. (Creswell 1998, 119)
These possibilities are encouraging for testing the understanding of the concept
“brownfield” and its taboo status across cultures—in this case Malaysia—where it is
just emerging and where there exists an opportunity to understand the early phases of
identification prior to extensive policy convergence.

Brownfields in Kuala Lumpur
Urban brownfields are considered a problem in Malaysia and they motivated
creation of the Malaysia-Idaho Brownfields Partnership, sponsored by the U.S.-Asia
Environmental Partnership and the U.S. Agency for International Development. (SEI
2002) This partnership developed because of the occurrence of illegal dumping sites
in Kuala Lumpur and other Malaysian cities (Balamurugan 1998; Bard 2002), which
have become known as “brownfields.” Small- to medium-sized enterprises (SMEs)
are often blamed for illegal dumping practices that create Malaysian brownfields
(Bard 2002; How 2002)—and thus issues are raised concerning SME solid waste
management processes as well as hazardous waste disposal requirements and
cleanup liability. The IEM, together with the DOE, has been working with the State
of Idaho Trade and Development Agency and the Idaho National Environmental
Engineering Laboratory (INEEL) to develop a training program for Malaysian
policymakers in enforcement practices and for engineers in remediation technology
and implementation. (SEI 2002)

177
Brownfields regeneration is fast becoming a priority of the Malaysian
government:
The Government will intensify on-going efforts as well as introduce
new approaches to strengthen land use planning…new physical
planning guidelines will be developed to improve environmental
quality and conserve natural resources…these guidelines will cover
urban regeneration, “brownfield” development in urban areas, optimal
land development and development in catchments. (Eighth Malaysia
Plan 2000)

A product of the collaboration to date is the upcoming international conference on
brownfields, “Brownfield Asia 2006” to be held in Kuala Lumpur in September
2006, which demonstrates the prevalence of the term in use (See also Balamurugan
1998.).

Data Sources
The Malaysian case study was developed around archival research, personal
interviews, and qualitative surveys with small businesses. An eclectic mix of
methods became necessary because poor response rates made data acquisition
problematic. For instance, many attempts were made to contact Malaysian firms via
their individual commercial websites as well as via online business directory
resources, such as the “Malaysia Yellow Pages” and the American Chamber of
Commerce in Malaysia; however, this process uncovered many faulty electronic
addresses and out-of-date contact information. An alternate approach using personal
contacts with the Federation of Malaysian Manufacturer’s (FMM) Selangor branch

178
(FMM is a high-profile industry association that has more than 2,000 members and
the branch office has jurisdiction for the entire state of Selangor, including Kuala
Lumpur City.) was somewhat more useful. But, even here despite initiating personal
contact with 80 businesses only 9 completed surveys resulted.
25
Moreover, there is a
tension between soliciting the membership of the FMM for information, which are
likely similar in some important respects such as business networking and land use
information transmission, and the fact that the FMM membership are quite likely the
most well-informed regarding international as well as domestic environmental
compliance policies.
Some of the problems encountered in approaching the Malaysian firms were
surprisingly similar to those in Los Angeles; they included: a few business owners
were too busy, some felt the survey was too lengthy, some felt unfamiliar with the
term “brownfield” and its relevance to them, some felt that they did not have enough
knowledge of the business operations to answer on behalf of the owner/manager, and
a few did not have access to the Internet, where the survey was based. A few firm
representatives felt uncomfortable with their English language skills and therefore
did not feel they could respond sufficiently, despite the fact that the solicitation was
made by a Malaysian research associate. The survey administration process was
designed to contact as many firms as possible and to demand as little of the
respondents’ time as necessary to gather the data. However, despite the low response

25
For language and other reasons businesses were solicited for their participation by Mr. Tan Tang
Ek, a Malaysian research associate.

179
rate the completed surveys were very comprehensive and provided a unique profile
of each firm’s role in the community. All surveys were administered in August 2002.

Historical Geopolitical Context of Brownfields in Malaysia
Kuala Lumpur (See Figure 3.) is the former capital of Malaysia, with a
population of approximately 1.3 million (NST 2002b) and the majority of its
industrial activities undertaken by small enterprises. (UNESCAP 2001)
Although much smaller than the U.S., with a land area of 328,550 square
kilometers (roughly the size of the state of New Mexico) and a population of 22.2
million (CIA 2002), Malaysia is known to be among the
Source: Peninsular Malaysia Travel Pictures
http://www.tropicalisland.de/travel_malaysia.html
Copyright 1997-2006 Manfred Leiter,
Ottobrunner Straße 38, 81737 Munich, Germany
Figure 3: Aerial View of Kuala Lumpur Skyline

180
Thailand
Indonesia
Indonesia
MALAYSIA
Cambodia
Vietnam
Myanmar
Philippines
Kuala Lumpur
South China Sea
Singapore
-
0160 320 80
Miles
Figure 4: Map of Malaysia in the Southeast Asian Region
world’s leading exporters of manufactured goods. The Malaysian brownfields case is
enriched by understanding the industrialization and urbanization of Kuala Lumpur
within the Southeast Asian region and how its growth is affected by such factors as
external trade and large-scale development projects.
Malaysia is located in Southeast Asia between Indonesia, Singapore and
Thailand, encompassing the Malayan Peninsula and sharing the island of Borneo
with Brunei Darussalam and Indonesia. (Dana 1999) (See Figure 4.)

181
Malaysia was formed in 1963 through a federation of the former British
colonies of Malaya and Singapore. (CIA 2002) However, Singapore became
independent two years later. Singapore had been an important trading port under
British colonization and continued to rise in prominence.
In Malaysia, the port cities urbanized first and Melaka, in particular, became
a powerful world trading destination:

The early urbanization of the Malay Peninsula was…the result of
overseas entrepôt trade…It was only with the rise of mercantile
capitalism that full-scale urbanization started on the Malay Peninsula.
Melaka under the Portuguese and Dutch and later Penang and
Singapore under the British became part of the urban colonial
network that eventually extended from Bombay to Hong Kong…up to
the middle of the nineteenth century, the Malay Peninsula itself
produced little for international trade in comparison with
neighbouring countries. It was only with the growing demand for
industrial raw materials, particularly tin, that both urbanization and
colonialism spread to the Malay Peninsula proper. (Evers & Korff
2000, 47)

Kuala Lumpur began its urbanization process this way—as an inland tin
mining camp at the juncture of two muddy rivers; its name translated into English
means “muddy confluence.” (KL City Hall 2003) Kuala Lumpur continued to
urbanize in accordance with its natural resource commodity-trading functions and is
now Malaysia’s largest city and the center of its government and industry.
(Department of Statistics Malaysia 2000) The city was declared a federal territory in
1974 to allow the capital to be administered by the federal government, and thus it
ceased to be part of the State of Selangor. (UNESCAP 1999, I-A)

182
Kuala Lumpur has lived through the same growing pains of many of its
neighboring Asian metropolises—a rapid influx of population that has resulted in
traffic congestion, pollution, an inadequate housing supply, overly taxed
infrastructure, skyrocketing land prices, and increasing segregation of social classes:

Modernization is not limited to economic growth…Especially in
Thailand, Malaysia and the Philippines, and to a lesser degree in
Singapore and Indonesia, strong pressures towards liberalization and
democratization of the political system are being
expressed…Democratization and the rise of the middle classes are
also characterizers of political and social changes in the main
cities…During recent years, as an effect of rapid modernization,
specific quarters, based on social differentiation like the new estates
of the middle classes, have emerged. (Ibid., 1, 4)

While bureaucratic employment is heavily concentrated in the city, the civil
servants and other members of the middle class have been moving to new housing
estates in smaller towns on the urban fringe (53). Evers & Korff (2000) have found
that these members of the middle class have also begun to participate in land
speculation—and are buying land on the urban periphery as an investment thereby
becoming absentee landowners. (54-57) This middle class movement out of
downtowns is similar to the American experience as people seek cheaper greenfield
land for new development, but continue to commute to downtowns for work.
Not only has Kuala Lumpur begun to experience a loss of the middle class, it
also is facing increased deindustrialization to its hinterlands as a result of concerted

183
planning. Two examples of this are its participation in a three-nation trade pact
26
and
its creation of the Multimedia Super Corridor and satellite cities.
Kuala Lumpur has controlled the governing bureaucracy and exists as the
most populous and powerful city in Malaysia, but as indicated earlier, it is beginning
to go through a period of decided deconcentration. A master-planned city was
designed and built on undeveloped greenfield land 25 kilometers from Kuala
Lumpur and declared the new capital, Putrajaya.

Putrajaya is intended to supersede
Kuala Lumpur as the national administrative center and some government offices
have already moved there—including the office of the prime minister. Putrajaya was
designed as a “garden city” and an “intelligent” city—as a model of modernism
offering the latest in infrastructure amenities. The city is an example of a trend in
Malaysia for creating satellite cities and towns—in order to draw population and

26
Since its independence from Malaysia, Singapore has become one of the world’s most competitive
international trade centers—it is the 12th largest trading partner of the U.S. and is one of only five
other countries that have formalized free-tract pact agreements with the U.S. (Palmer 2003)
Singapore’s position as the dominant “financial hub of Southeast Asia” (Ibid.) and its position as one
of the wealthiest nations “with per capita GDP equal to that of the leading nations of Western Europe”
(CIA 2003), coupled with its strategic location at the southern end of the Malayan Peninsula, means
that it has a strong influence on Malaysia and Kuala Lumpur in particular. For instance, because
Singapore is a small, highly urban nation, it is increasingly looking to its “immediate geographic
region for economic interaction and sustenance.” (Yeung 2000, 17) Functionally, this means that it is
reaching into southern Malaysia and drawing manufacturing activity to the state of Johor. (Ibid.)
Singapore’s aggressiveness in its reach for available land and labor has resulted in the formation of a
“growth triangle” including Singapore, Malaysia, and Indonesia, which covers an extended urban
corridor connecting Johor, Singapore, and Riau: “In the JSR Growth Triangle, it was largely a
government initiative taken by Singapore that found favorable reception in Malaysia and Indonesia in
the spirit of ASEAN cooperation. The economic logic for Singapore…was to relocate manufacturing
industries to neighboring territories to remain competitive in the global market.” (65) The concept of
growth triangles is a largely Asian conception and a number of them have been created throughout the
region, exemplifying a wider trend toward interregional trade cooperation. (Ibid.)

184
commerce away from Kuala Lumpur and spread them more evenly throughout the
country.
27

This top down push for land development by the national government is quite
different than the U.S. experience—where cities have sprawled in haphazard fashion
into their hinterlands. Instead, Malaysia is undergoing a controlled form of urban
sprawl—what might be considered “smart growth”
28
but for the potentially negative
sociological ramifications if it ends up creating middle-class enclaves as in the case
of American-style suburbanization. Yeung (2000) cautions that the export-industry
focused growth on the urban fringe in cities throughout Southeast Asia may have
hidden social consequences:
…Bangkok, Kuala Lumpur, and Jabotabek have grown rapidly
in new functions…However, within these urban agglomerations, it is
their fringe areas that have experienced the fastest rates of growth and
the most rapid physical transformation. These areas have relatively
more land and somewhat less stringent regulatory controls on

27
Putrajaya is part of a larger development plan that is called the “Multimedia Super Corridor,” which
extends from the Petronas Twin Towers at the Kuala Lumpur city center in the north to the new Kuala
Lumpur International Airport in the south; the corridor boasts a “world-class physical and information
infrastructure” and is “an integrated logistics hub with rapid rail links to Kuala Lumpur, a smart
highway system…[and a] high-capacity global telecommunications and logistics network built on a
2.5 – 10 gigabits digital fiber optic backbone.” (MDC 2003) Other examples of large-scale projects
that are intended to functionally deconcentrate Kuala Lumpur are Cyberjaya and BioValley.
Cyberjaya was officially launched by Malaysian Prime Minister Mahathir Mohamad in July 1999 as
“Malaysia’s first truly intelligent city”. (Cyberjaya 2003) Located very near Putrajaya, it encompasses
7,000 acres and is considered “the nucleus” of the Multimedia Super Corridor. (Ibid.) The purpose of
Cyberjaya is to attract information technology and other high-technology industries. BioValley is a
similar project designed to attract biotechnology industries; however, this project is being overseen by
the Ministry of Science Technology and the Environment, which houses the Department of the
Environment—the equivalent of the USEPA. Each of these cities was designed to have mixed land
uses so that industry and residences would be compatibly co-located; however they presently exist as
island nodes within the Corridor because development has not yet filled in the spaces between them.
They also are industry cluster specific (i.e., solely information technology and biotechnology), which
goes against the grain of organic industrial development and may prove challenging in the long-run if
subsectors within the clusters innovate or evolve away from one another.
28
Smart growth here refers to development that strives to ensure “neighborhoods, towns, and regions
accommodate growth in ways that are economically sound, environmentally responsible, and
supportive of community livability—growth that enhances the quality of life”. (O’Neill 2000, 2)

185
manufacturing-related growth and investment by TNCs [transnational
corporations]. The rapid growth and transformation of these urban
fringe areas are components of physical and social change that have
not been adequately dealt with by the governments concerned. (38)

With these forces in play on the urban fringe, it remains to be seen what will
happen to the neighborhoods left behind in Kuala Lumpur. Kuala Lumpur is home to
many poor people that would not benefit from living in the new cities, so they will
likely remain.
Presently one of the major obstacles that is constraining SME sector growth
is “the high cost of industrial land and factory space” (Abdullah 1999, 123), but
although prices are currently high in the city, as demand goes elsewhere, existing
businesses might also. There is concern that much of the land in Kuala Lumpur has
already been earmarked for development and that the remaining available land only
exists as “small pockets that do not lend themselves to large-scale development.”
(Ban 2003, 1) This is what has happened in Los Angeles and other American cities—
as developers have gone to the urban fringe where land is less expensive and
available in larger quantities—with less likelihood of contamination problems in
greenfield areas. Unfortunately, the less mobile poor have been left to deal with
deteriorated community conditions, including brownfields. Although this
phenomenon has not yet been empirically validated in Kuala Lumpur, similar
symptoms are evident and therefore warrant further investigation. This is one of the
reasons why a comparison of the two cities is compelling.

186
The Small Manufacturing Sector in Malaysia
According to the U.S. Commercial Service, in 2000 bilateral trade between
the U.S. and Malaysia was $36.6 billion with U.S. exports to Malaysia at $11 billion
and U.S. imports from Malaysia at $25.6 billion—making Malaysia the United
States' 11th-largest trading partner and its 17th-largest export market. (USCS 2002)
Moreover, manufacturing is a significant component of this trade relationship, “the
U.S. in 2000 continued to rank first in foreign direct investment (FDI) approved in
Malaysia's manufacturing sector, with approved new manufacturing investment
totaling RM7.5 billion (U.S.$1.97 billion).” (Ibid.)
Industry accounts for 44 percent of Malaysia’s GDP, with manufacturing
accounting for 27 percent of its workforce—second only to “local trade and tourism”
at 28 percent. (CIA 2002) The U.S. is Malaysia’s top export market (21 percent) and
second import partner (17 percent) behind Japan (21 percent). (Ibid.) As indicated
via investment in its Multimedia Super Corridor, Malaysia is undergoing a
technological innovation push that has helped it become extremely competitive in the
international marketplace. The role of SMEs in Malaysia is critical in this process
and the Malaysian government has concentrated its efforts through the Small and
Medium Industries Development Corporation (SMIDEC) and through hosting
meetings such as the Pacific Basin Economic Council annual conference, which took
place in Kuala Lumpur in May 2002 and stressed the need for “capacity building
among small- and medium-sized enterprises in the Pacific region” through

187
“financing assistance…contribution to technology innovation processes, and
concerted efforts to ensure no sector…was left behind”. (NST 2002a)
In Malaysia, SMEs are defined as “manufacturing companies or companies
providing manufacturing related services with annual sales turnover not exceeding
RM25 million [approximately $6.5 million]” and less than 150 full-time employees.”
(SMIDEC 2003) Seventy-six percent of all enterprises in Malaysia are SMEs and the
manufacturing sector comprises 93.8 percent of those. (Abdullah and Beal 2003,
1417) There is an extensive governmental infrastructure in place to encourage the
growth of SMEs, with “as many as 13 ministries and nearly 30 government agencies
engaged” in a variety of SME support activities. (Abdullah 1999, 58) An example of
this was the 1996 creation of the Small and Medium Industries Development
Corporation (SMIDEC) within the Ministry of International Trade and Industry
(MITI), “in recognition of the need for a specialised agency to further promote the
development of Small and Medium Industries (SMIs) in the manufacturing sector
through the provision of advisory services, fiscal and financial assistance,
infrastructural facilities, market access and other support programmes.” (SMIDEC
2003) While SMIDEC concentrates on serving manufacturers, Malaysia’s Ministry
of Entrepreneur Development functions as the first point of contact for small
businesses from any sector.
Over the past few decades, the Malaysian government has implemented an
export-oriented industrial policy that has encouraged SMEs in certain strategic
manufacturing sectors—such as electronics and electrical equipment

188
manufacturing
29
—that provide important linkages to larger international firms.
(Abdullah 1999, USCS 2001) This focus on manufacturing to spur export-led growth
has been a regional phenomenon:
…many Asian countries have adopted export-oriented
manufacturing strategies with notable success. In 1993, Hong Kong
and China topped the list of developing-country exporters with $135
billion and $92 billion in overseas sales, respectively, followed by
Taiwan ($85 billion), South Korea ($82 billion), and Singapore ($74
billion). Malaysia, Thailand, and Indonesia constituted the second tier
together with Brazil and Mexico. (Yeung 2000, 16)

For Malaysia, this focus has meant that there is a direct and powerful
relationship between the national government and small manufacturing businesses
that is quite different than the more decentralized system in the US. For Kuala

29
Table 23 illustrates the sectoral distribution of SMEs:
Table 23: Distribution of SME Manufacturers (by type of products)

Type of Product Number Percent
Food products 82 3.6
Textile and garment 30 1.3
Wood and wood-based products 14.7 6.5
Paper and printing products 34 1.5
Petroleum products 51 2.3
Chemical products 7 0.3
Rubber and rubber-based products 48 2.1
Non-metallic products 203 9
Base-metal products 103 4.5
Fabricated metal 129 5.7
Machinery 120 5.3
Electric and electrical products 639 28.2
Transport equipment 87 3.8
Poultry farming 3 0.1
Other products 264 11.7
TOTAL (approximate) 2,265 100
Source: Small and Medium Industrial Development Corporation (SMIDEC) 1999,
The Listing of SMES in the manufacturing sector (unpublished) SMIDEC; Kuala
Lumpur. The SMEs are as registered with SMIDEC. This table reproduced in its
entirety from Abdullah and Beal 2003, 1418)

189
Lumpur, this has resulted in a spatial as well as functional concentration of policy
resources and firms within the city—although as discussed previously, this is
beginning to change.

The large number of firms in the State of Selangor, which surrounds Kuala
Lumpur, is evidence of the dispersal of industry into the surrounding hinterland.
Figure 5 displays this information geographically.

Kuala Lumpur
SELANGOR
Negeri Sembilan
Pahang
Perak
Perak
Melaka
Strait
of
Malacca
Johor
2.4 %
5.9 %
3.9 %
11.8 %
2.8 %
3.0 %
35.6 %
Terengganu
1.9 %
SINGAPORE
Kelantan
0.8 %
Kedah
ulau Pinang
4.9 %
11.6 %
-
0 10 203040 5
Miles
gy
Figure 5: Map of SME Manufacturers by State

190
SMEs in Malaysia tend to be “family or significantly sole proprietorship
businesses, utilizing relatively low levels of capital…more labour intensive,
involving simple management and specialization of labour, being run largely as one-
person or family tied operations and with a very simple division of labour.”
(Abdullah 1999, 30) They are generally short in tenure—with half of all
entrepreneurs closing their businesses by the third year of operation. (Dana 1999,
119) They are also usually domestic firms producing goods primarily for the low- to
middle class (Abdullah 1999) and they provide important socioeconomic linkages
through their support to large firms and their employment of low-skill workers.
(Abdullah and Beal 2003) Although many SMEs have operated within the informal
or extralegal sector in Kuala Lumpur, according to Forbes (1996), this sector is
disappearing quickly.
30
Concerning location, manufacturing SMEs tend to locate
within specific “SME Zones” (Abdullah 1999) and now many are located within
planned industrial estates in satellite towns outside of Kuala Lumpur.
To understand the situation of SMEs in Malaysia, it is important to look at
the institutional context in which they operate. Policy programs created to address
the needs of SMEs are an instructive way of finding out what the government and
nongovernmental sector perceive are necessary to support their growth. Abdullah
(1999) in his comprehensive assessment of the policy issues and challenges facing

30
Forbes describes the informal sector in Southeast Asian cities thus: “…the poor still predominate in
Southeast Asian cities, with the notable exception of Singapore. The urban informal sector underpins
the survival of the urban poor…It includes the trishaw riders, the market sellers, the street-side
hawkers, the prostitutes, the backyard manufacturers, the pavement coffee-shops, the sate
makers…[it] is unregulated, it relies on family labour, records are kept in the owner’s head and it is
financed by loans from friends and colleagues…it defies the order we expect of registered
businesses.” (58)

191
SMEs categorized the various governmental support programs into five broad
categories: Financial and credit assistance; Entrepreneurial development and
business management; Human resource development, technical and vocational
programs; Locational and infrastructural facilities; and Fiscal incentives.
31
The
varied foci of these programs recognize the community connectedness of SMEs and

31
Details of these are as follows: 1. Financial and credit assistance: includes special SME loan
programs from commercial banks, finance companies, merchant banks, development finance
institutions (DFIs) that provide loans to those traditionally unable to secure credit, modernization and
automation loans, special financing programs for Bumiputera (indigenous Malays), sub-sector
specific loans, exporter credit, technology or technical knowledge upgrades, new entrepreneurs,
purchase of new factories/equipment or rehabilitation of those; 2. Entrepreneurial development and
business management: includes National Productivity Corporation training courses offered at regional
offices, the Malaysian Entrepreneurial Development Center and the Majlis Amanah Rakyat (MARA)
(both intended to assist Bumiputera in starting new businesses), university-based Small Business
Development Center, Malaysian Agricultural Research and Development Institute (to encourage
participation in the food manufacturing industry), SMIDEC; 3. Human resource development,
technical and vocational programs: Human Resources Development Council (employee training cost
subsidies), Industrial Technical Assistance Fund (consultancy services, development grants, product
or process upgrade grants, export market activity reimbursements, Center for Instructor and Advanced
Skill Training, Industrial Training Institutes, Forest Research Institute of Malaysia, the Standards and
Industrial Research Institute of Malaysia (helps with product certification, listing, quality system
registration, laboratory accreditation), Malaysian Technology Development Corporation (MTDC)
(helps commercialize research), Malaysian Institute of Microelectronics System (links Malaysian
firms with international technology networks—with a focus on semiconductor technology), Malaysian
Science and Technology Information Center (technology information clearinghouse providing
education and information services), Malaysian External Trade Development Corporation (assistance
for exporters), Youth Training Centers, Vocational Schools, Polytechnics, and higher education
programs; 4. Locational and infrastructural facilities: The Malaysian Industrial Estate Limited
(MIEL)—a federal agency that sells and leases factories—by 1997 it had constructed 31 factory
projects nationwide; The Council of Trust for Indigenous People rents out infrastructure facilities at
subsidized rates to Bumiputera entrepreneurs; Technology Park Malaysia—located on 150 acres
within Kuala Lumpur and serves as a business incubator for information technology, biotechnology,
environmental technology and other business sectors; Free Trade Zones (FTZ) provide relief from
customs duty for exporting businesses; Licensed Manufacturing Warehouses (LMW) are government
owned and designed to disperse export-related industries to non-FTZ areas (in less-developed
regions); and 5. Fiscal incentives: Pioneer status (tax relief for the first 2-8 years of operation);
Investment Tax Allowance and Reinvestment Allowance (businesses may be reimbursed for up to 100
percent of investments in improvement and expansion); Export Credit Refinancing (provides
exporters with short-term credit); Abatement of Adjusted Income (for exporters); Double Deduction
of Export Credit Insurance (encourages new markets); Double Deduction for Promotion of Exports;
potential deductions for research and development, training, industrial buildings, operations, plant and
machinery; Double taxation agreements with other nations so that businesses are only taxed once;
relief from excise duties; and Labor Utilization Relief (businesses are allowed tax exemptions based
on the number of their full-time employees) (59-144)

192
how support programs necessarily involve addressing social capital aspects—such as
employee training and minority inclusion.
Even given the extensive array of assistance programs available to small
manufacturers, Abdullah found that the majority of firms do not take advantage of
them. He concluded that the incentives were not realistic in their time frames, that
the funding available was not sufficient in most cases, that the “boundaries of
responsibility, priorities and targets” were not clearly defined, and they were not
relevant to domestic firms. (183) He suggests that because the Malaysian
government’s incentives primarily target export-oriented firms, they are not
reinforcing the stabilizing linkages that other SMEs foster in the domestic
economy—thereby fueling a weakening of the domestic industrial structure. (See
e.g., Abdullah and Beal 2003)
In addition to SMIDEC and the other organizations described thus far,
another prominent source of support for SMEs is the FMM (Federation of Malaysian
Manufacturers), a member-based organization established in 1968, and “the largest
private sector economic organisation in Malaysia representing over 2,000
manufacturing and industrial service companies of varying sizes” which runs an
SME Resource Center and has offices in each state. (FMM 2003)
An interview with a manager of the Selangor State Branch of the FMM
revealed that most of the factories in Kuala Lumpur had been relocated to the
“outskirts of the city” and that there are only about 150 “old factories” left in the
city, while there are about 10,000 factories of various sizes in the state of Selangor.

193
(Ek 2003) Major issues of concern to manufacturing firms in Kuala Lumpur are that
industrial land is very expensive, there is a difficulty in recruiting workers to work in
the factories, and it is a challenge for firms to keep operating costs down and still
remain globally competitive. (Ibid.)
32

Ritual Process: Brownfields and the Environmental Policy Context

The Ministry of Science, Technology, and the Environment (MOSTE) is the
national government agency empowered to enforce environmental laws in Malaysia.
Within the Ministry, the DOE conducts activities concerning implementation of
environmental laws and coordinates its activities with the state-level offices.
The National Environmental Quality Act of 1974 is the backbone of
Malaysian environmental law, but there are numerous other pieces of legislation
concerning different aspects of environmental governance, which were judged
“fairly comprehensive” in a 1999 United Nations Economic and Social Commission
for Asia and the Pacific (UNESCAP) report concerning how to integrate
environmental considerations into economic decision-making. The UNESCAP study
evaluated the institutional mechanisms of environmental policy in Kuala Lumpur
and concluded that there is a necessity to better coordinate the functions of the
federal, state, and city government in regard to the environment. For example,
Malaysia has an Environmental Impact Assessment (EIA) process that is required for

32
Concerning institutional networking, the Malaysian Industrial Development Authority and
SMIDEC were cited in the business surveys as the government entities most involved with
manufacturing firms. As far as other groups that SMEs network within, the Small to Medium Sized
Industry Association (SMI Association) was cited along with “many other smaller industry

194
new developments (similar to the EIR/EIS process described in the Los Angeles
case), but is only enforceable by the DOE.
EIAs are prescribed for project development under the Environmental
Quality Order of 1987: “Incorporating environmental dimensions in project planning
and implementation by determining the implication of proposed projects and the
costs of necessary environmental mitigation measures. (MIDA 2003) EIAs are
required for certain industries based on their daily production capacities and
therefore the burden of compliance varies widely by sector. The DOE provides a list
of consultants that are able to provide EIA services; environmental consulting is a
rapidly growing industry in Malaysia. According to one consultant whose company
conducted the environmental investigations for the Kuala Lumpur Central Station
project and who was one of the lead participants in the Malaysia-Idaho Brownfields
partnership, there is “no set standard for site assessment or soil and groundwater
pollution” in Malaysia, but companies are still undertaking assessments of
contaminated sites using a variety of different methods, such as the ASTM E1527,
and the Dutch and British standards. (Balamurugan 2002) The EIA process, as well
as the certification of consultants and implementation of standards, are consistent
with the institutional context of brownfields in the Los Angeles/U.S. case.
The Malaysia-Idaho Partnership was the first high-level focus on brownfields
in Malaysia. Unlike the evolution of brownfield policy in the U.S., which had been
motivated by citizen concern at Love Canal, the partnership had been initiated by

associations”. (Ibid.) The SMI Association focuses its attention on export-oriented manufacturing
firms with a mission to increase their visibility on the Internet.

195
IEM (a professional organization) in order to develop a technical expertise in
remediation technology—specifically concerning the redevelopment of mine-scarred
lands (See Figure 6.). This technical expertise-sharing was the basis for the selection
of Idaho as the U.S. state to be partnered with Malaysia because it is home to
INEEL, which employed some of the world’s leading soil remediation technology
experts. Additionally, the state of Idaho was appropriate because of its own history
of mining and resultant contamination. (Bard 2002)

Source: Perak: Glorious Mining History, by V.P. Sujata,
http://202.184.114.102/state/perak/perakintro.asp
Copyright 1995-2006: Star Publications (Malaysia) Bhd (Co No 10894-D)·
Managed by I.Star , About AllMalaysia

Figure 6: Tin Mine in the State of Perak, Malaysia

196
In Malaysia, past tin mining has been blamed for contaminating the food
supply; a 2002 study found that “foodstuff from a legendary tin mining
area…revealed high levels of potentially toxic elements (PTEs) that could cause
cancer.” (Reuters News Service, 2002)
The brownfield partnership has also involved collaboration with universities,
environmental technology companies and the Idaho Department of Commerce. Two
reciprocal visits took place in 2002 and the partnership is expected to result in a
brownfields policy guidance paper drafted by INEEL
33
for Malaysia as well as
establishment of the Asia-Pacific Institute for Brownfields Restoration and Research.
(Marshall 2001, 4) The ultimate goal of the partnership is to

focus on Malaysia’s brownfield environmental issues while providing
a framework for addressing multiple environmental problems; transfer
environmental science and engineering experience to Malaysia,
including system training on brownfield evaluation software for site
assessment, regulatory compliance, enforcement and institutional
controls, information management, development of manuals and
professional papers for establishing environmental quality cleanup
standards. (Ibid., 3)

Part of Malaysia’s motivation for involvement in the partnership was concern
for health and human safety because of the prevalence illegal dumping sites. (Bard
2002) This problem arises from a lack of capacity for and coordination of
enforcement activities on the part of the relevant government agencies. (UNESCAP
1999) For instance, the federal DOE jointly monitors toxic and hazardous waste with
City Hall, but only the DOE can bring “offenders to prosecution”. (Ibid., I-F, 1)

197
There is also a DOE office for the Federal Territory of Kuala Lumpur (that acts as its
State level agency), which monitors industrial pollution under certain mandates. At
present, the environmental functions of City Hall are rather fragmented across
departments. Although its solid and toxic waste management functions have recently
been privatized, enforcement responsibility still falls to the City Hall and DOE and
the problem persists. (Ibid.) Figures 7 and 8 below illustrate how people and animals
are often exposed to hazards at dump sites and this implies that there may far-
ranging impacts of this (e.g., vis-à-vis the food supply in the case of cattle grazing).

33
INEEL has since been reorganized and is now (in 2006) divided into two organizations, the Idaho
National Lab (housing the Applied Geosciences Division that studies mine remediation) and the Idaho
Cleanup Project (which focuses on cleanup of past sites including nuclear energy facilities).

Source: PCB Symposium 2002, http://www.tabemono.info/chosa/chikyukan/2003/5/5_3/e_1.html
Copyright 2003: The Japan Offspring Fund All Rights Reserved.
Supported by the Japan Fund for Global Environment
Figure 7: Malaysian Waste Dump Site: Example of PCB Pollution Problem

198

These practices—of human activity and cattle grazing as well as illegal
dumping—on the waste sites indicate that there is likely not much widespread
understanding of the dangers present or enforcement of regulations pertaining to
restricting such behaviors, which contribute to the creation of brownfield problems.
PCBs Situation in Malaysia by Hatijah Hashim, Research Officer,
Consumers Association of Penang
Source: PCB Symposium 2002,
http://tabemono.info/chosa/chikyukan/2003/2003/malaysia/e_1.html
Copyright 2003: The Japan Offspring Fund All Rights Reserved.
Figure 8: Examples of Dangerous Practices at Waste Dump Sites

199
Kuala Lumpur City Hall exists as the primary municipality and local
authority in the Federal Territory of Kuala Lumpur. City Hall’s Master Planning
Department adopted a principal planning policy—the Kuala Lumpur Structure Plan
or KLSP—in 1984, which guides its overall development planning program for the
city. (Ibid., I-C) The KLSP contains a policy intended to divert and redistribute
office space and businesses to four satellite cities (Ibid.) and periodically enforces a
policy that limits “the construction of new office buildings to not more than 10
storeys in order to discourage further employment generation and to prevent any
further increase in the number of commuters into the city.” (Ibid., I-E) City Hall has
targeted polluting industries in particular, such as “the small industrial
establishments [that] tend to proliferate around established industries and in densely
populated areas” and “the large and polluting industries” for relocation and
encourages their replacement with “non-basic industries such as vehicle workshops,
repair services and food manufacturing plants which serve the city”. (I-F)
As O’Rourke (2002, 2004) has documented in Vietnam, the role of the public
in environmental monitoring has been increasing in Malaysia also and an example of
this is a campaign to have the public report cases of open burning and illegal
dumping (See Figures 9 and 10 on the following page.). However, instead of an
antagonistic relationship between government and communities, this likely
demonstrates the government’s recognition that it must rely on—and therefore
trust—the vigilance of the public in order to identify environmental problems.

200

Figure 9: Examples of a Reliance on Civic Vigilance in Reporting Contamination
Source: 2003 Malaysian Department of the Environment (DOE)

201
The general public, volunteer groups and the mass media are also being
encouraged to either volunteer to undertake monitoring activities or to telephone City
Hall to report incidences of any factories that release smoke during episodic haze
situations in Kuala Lumpur. (III-A, 4) Other evidence of a need for environmental
monitoring and enforcement capacity is an undated message displayed prominently
on the DOE website next to its description of the environmental impact assessment
process:
Source: 2003 Malaysian Department of the Environment (DOE)
Figure 10: Example Public Notice Describing Punishment for Fire-Related Crimes
(including illegal dumping of hazardous waste)

202
YOUR SERVICES ARE NEEDED! REGISTER QUICKLY WITH
THE DEPARTMENT OF ENVIRONMENT AS AN EXPERT IN
REVIEWING DETAILED ENVIRONMENTAL IMPACT
ASSESSMENT REPORTS (DEIA). WE NEED YOUR SERVICES
EITHER AS AN EXPERT OR ACADEMICIAN IN ANY FIELD
PERTAINING TO ENVIRONMENTAL MANAGEMENT.
REGISTRATION IS FREE. (DOE 2003)

Malaysia may be more active than other developing countries in addressing
environmental problems
34
and in sharing the responsibility for their solutions with
the public because it has been experiencing severe air pollution from forest fires in
neighboring Indonesia for a number of years (See Figure 11 below.):

34
Indeed, in a recent Yale University study identifying an overall environmental performance index
(EPI) measure, Malaysia was the only developing country ranked in the top ten—at number 9—
whereas the United States was ranked 28th. (Esty et al. 2006) The EPI focuses on two broad
environmental protection objectives: reducing environmental stresses on human health and promoting
ecosystem vitality and sound natural resource management; these are evaluated using sixteen
indicators in six policy categories: Environmental Health, Air Quality, Water Resources, Productive
Natural Resources, Biodiversity and Habitat, and Sustainable Energy.
Source: Reuters, Copyright: MSNBC 2005
Hazardous haze shrouds Kuala Lumpur: Port, schools closed as government
encourages residents to wear masks, Associated Press, August 11, 2005.
Figure 11: Malaysian Students Wear Masks at a School in Kuala Lumpur

203
Figure 11 shows students wearing masks in school when a state of emergency
was declared in August 2005 because the air quality reached such a hazardous level.
Forest fires are set in Indonesia in land clearing activities and there has been an
ongoing debate about responsibility-sharing since some Malaysian firms are thought
to participate in these activities in Indonesia.
Water pollution is also considered a serious problem in Malaysia where
“Residential sewage accounts for nearly 80 percent of BOD [biological oxygen
demand]-related water pollution, followed by agriculture and industry…[whereby]
concentrated industrial wastewater and agricultural run-off of fertilizer and
chemicals into surface water affect levels of dissolved oxygen in water…resulting in
destruction of aquatic life and the natural ecology of the rivers.” (REACH 2005)
Because “Forest harvesting and agricultural and urban development have resulted in
the pollution of most river systems, affected ecological dynamics and disrupted
natural food chains, industry has been identified as a primary culprit in water
contamination, “In 1991, 40.5% of the 2,292 industries in Malaysia, identified as
major sources of water pollutants, were food and beverage industries. 14.1% were
rubber producing and 11.8% were chemical producing industries…The heavily
industrialized Peninsular states that are most affected by these pollution sources are
Selangor, Johor, Penang and Perak…Further clearing of forested land, tin mining
and effluent discharges from industries, tin mining, logging, use of weedicides,
insecticides, latex processing plants and manufacturing industries are polluting
surface water sources.” (Ibid.)

204
Targeting industry as culprits in environmental contamination is similar to
the Los Angeles brownfield case; however, efforts to engage the public in active
monitoring of changing environmental conditions—such as in the prevention of
brownfield creation—is quite different. Another difference is the positive externality
of the export-driven industrial development in Malaysia, which has raised the level
of awareness of SMEs regarding environmental quality standards outside of the
country. To remain internationally competitive, Malaysian firms are adopting the
International Standards Organization (ISO) protocols (Balamurugan 2002; Ek 2002)
and, in this way, benefiting their local communities via better environmental
practices and increasing their own knowledge base and awareness of what to expect
from future directions in domestic environmental policy. ISO compliance has proven
to be “an effective instrument for gaining cooperation from the local industries and
factories in adhering to environmental regulations, in the form of ISO 9000 and ISO
14000” (UNESCAP 1999, I-F 2) and this may give Malaysia an innovative edge in
dealing with brownfields without having to experience the evolutionary blight that
has plagued cities, like Los Angeles, in the U.S.

Research Results
Results from the Kuala Lumpur/Selangor small business survey were difficult
to obtain, however enough information was available to inform the present enquiry.
Supplemental information on the SME sector was derived from the FMM’s 2002
membership database. These are discussed next.

205
Data Pool
Of 80 firms personally contacted to participate in the survey by a Malaysian
staff person at the FMM in Selangor, only nine completed the survey, which yields a
response rate of 11 percent. Although this is not a representative sample of the total
pool of Malaysian SMEs, the in-depth nature of the survey provides some important
anecdotal insight into the perspective of small manufacturing firms and their
understanding of brownfields in their communities.
As was to be expected by the previous discussion of the distribution of SME
firms in Malaysia, the majority of respondents (seven) are from outside the Federal
Territory of Kuala Lumpur in the State of Selangor, which has the largest
concentration of SMEs nationwide (35 percent). The other survey responses (two)
are from inside Kuala Lumpur itself.
All of the respondents are manufacturing firms and the range of their
products include chemicals, optical discs, laboratory equipment, laminated gypsum
boards, ceiling tiles, forged precision pins for electrical and electronics industries,
polyurethane systems, elevators and parts, paper cutting knives, woodworking tools,
and tea anti-oxidant.
Also as to be expected, all but two firms produce for export markets, with
current markets including Australia, Brunei, Canada, China, France, Indonesia,
Japan, Kuwait, Papua New Guinea, the Philippines, Saudi Arabia, Singapore,
Taiwan, Thailand, United Arab Emirates, the United Kingdom, and the US. Some
future export destinations of the respondents are Brunei, Cambodia, Iran, Laos,

206
Myanmar, and Vietnam. (Of the approximately 1,490 SMEs in the FMM
membership database, 962 (or 65 percent) currently produce for export markets and
524 (or 55 percent) of those firms plan to expand their export activities to other
countries while 23 (or 4 percent) of those that are not producing for export markets
plan to do so in the future.)
All of the survey respondent businesses are headquartered in Malaysia except
one whose parent company is in Helsinki, Finland. One is Japanese-owned. Also of
note is that four respondents are ISO 9002 certified and one is ISO 9001 certified,
demonstrating their propensity to adhere to these international quality standards (Of
the entire FMM membership pool, 527 firms (or 35 percent) have obtained at least
one ISO certification, often more than one.). Thus, the Malaysian sample appears to
be much more internationally integrated than the Los Angeles sample. They also
seem to be engaged in extensive interregional trade, which is reflected in the
characteristics for the entire FMM membership. (See Table 24 below and on the
following page.)
Table 24: Malaysia SME Export Market Countries (with 80 or
more SME relationships)

Export Market Number of Companies
Singapore 717
Indonesia 362
Hong Kong 358
Thailand 358
Australia 354
Japan 335
U.S.A. 314
Philippines 295
China 258
United Kingdom 258
Taiwan 247

207

Table 24 (Continued): Malaysia SME Export Market Countries (with
80 or more SME relationships)

Export Market Number of Companies
Brunei 201
Vietnam 183
Germany 157
New Zealand 155
Sri Lanka 139
South Korea 137
India 135
United Arab Emirates 115
France 103
Mauritius 96
Canada 95
Netherlands 93
Italy 87
Saudi Arabia 87
Bangladesh 83
Source: Federation of Malaysian Manufacturers Membership Database 2002

The age of businesses in the Malaysian sample is also much lower than those
in the Los Angeles sample: an average of 12.8 years with 3 businesses five or fewer
years old and no businesses older than 23 years. For the entire FMM membership
database, it is evident that small businesses are the majority (See Table 25 on the
following page.). Of the approximately 1,480 companies that listed their year of
incorporation, the average age of business is 17.48 years, ranging from one business
that is less than one year old to the oldest business, at 73 years, distributed as
follows:

208

Table 25: Age (in years) of FMM Member Businesses

Years in Business Number of Companies
5 or fewer 115
6-10 280
11-20 589
21-30 341
31-40 104
41-50 41
51-60 4
61-70 2
71-80 3
Source: Federation of Malaysian Manufacturers Membership Database 2002

All of the businesses consider themselves small except three, but they still
meet the “employee size” requirement of a small business at 66, 100-120, and 80
full-time employees respectively. For the entire FMM SME database, a significant
majority of firms are considered small by the employee number criterion. The
average for this group was 121.32 employees, distributed as follows:
Table 26: Size (by number of employees) of FMM Member
Businesses

Number of Employees Number of Companies
10 or fewer 44
11-20 79
21-30 95
31-40 78
41-50 84
51-60 66
61-70 63
71-80 45
81-90 56
91-100 50
101-110 37
111-120 37
121-130 33
131-140 24
141-150 44
151-160 17
161-170 13
171-180 16
181-190 6
191-200 32

209

This shows that the large majority of businesses fall within the smaller range
of the continuum with between 11 and 50 employees. Two of the respondent
businesses are family operations and four consider themselves minority businesses.
Only one of the businesses is individually-owned and the rest are either a partnership
or group of more than two owners.
Three owners live at the business, one lives less than a 15-minute drive away,
two are a 16-30 minute drive away, 2 are up to an hour away, and one is more than
on hour away. One lives in Japan. On average the owners spend 3.8 days at the
business during the week; however, this ranged from 0 for two respondents to 6 for
two others. The small sample size restricts any reliable extrapolations from these
data.

Table 26 (Continued): Size (by number of employees) of FMM
Member Businesses

Number of Employees Number of Companies
201-220 28
221-240 20
241-260 27
261-280 16
281-300 26
301-320 10
321-340 9
341-360 14
361-380 8
381-400 13
401-420 7
421-440 5
441-460 8
461-480 3
481-500 14
500 or more 144
Source: Federation of Malaysian Manufacturers Membership Database 2002

210
Community Connectedness
Five companies own the land on which they operate, and the other four are
renters. Regarding location choice, the Malaysian firms also cited land price/rent as
the most important factor (8 response occurrences versus 6 for transportation access,
and others were 4 or fewer). Two listed other important factors as being “familiar”
with the area and that the area be “industrial.”
Regarding influential factors in selecting their present location, the most
popular answer for important was land price (9) and transportation access (9),
followed by facilities (6) and access to labor pool (6). Eight of the nine respondent
businesses operate on land of less than one hectare (one hectare equals 2.47acres) in
size and one operates on a property of 3 to 5 hectares (7.4-12.3 acres). Notably, all of
them operate on industrial estates.
The following data tables are presented for informational purposes only—
with comparisons to the Los Angeles case; however, the small sample size of
Malaysian firms and the broad distribution of their answers does not allow for
reliable generalization. Of note, however, is the majority of answers that indicate the
Malaysian firms do not believe that they are located within disadvantaged
neighborhoods (See Table 27 below.). This may be due to the fact that they each
operate in a relatively new industrial estate, possibly in greenfield areas.

211
Table 27: Community Perceptions of Respondent Businesses in Malaysia
SA AS BA
AGREE
DIS;
AGREE
BD DS SD Total
My business is located in a
disadvantaged neighborhood.
0 0 0 0 9 1 2 6 9
Crime is a problem in the
neighborhood where my
business is located.
0 2 1 3 6 0 4 2 9
Vacant properties are a
problem in the neighborhood
where my business is
located.
0 2 1 3 6 0 2 4 9
Abandoned properties are a
problem in the neighborhood
where my business is
located.
1 2 2 5 4 0 1 3 9
I know by name many of the
residents in the
neighborhood where my
business is located.
0 2 1 3 6 1 2 3 9
I know by name many of the
other people who operate
businesses in the
neighborhood where my
business is located.
0 2 1 3 6 2 2 2 9
I would like to keep my
business in the same
neighborhood for the next
five years.
4 4 0 8 1 0 0 1 9
I would like to keep my
business in the same
neighborhood for the next
ten years.
1 6 0 7 2 0 1 1 9
I would like to keep my
business in the same
neighborhood for the next
twenty years.
0 2 2 4 5 1 1 3 9
Conditions are improving in
the neighborhood where my
business is located.
0 2 3 5 3 1 1 1 8
Conditions are deteriorating
in the neighborhood where
my business is located.
0 0 2 2 7 2 2 3 9
*Note: SA=Strongly Agree; AS=Agree Somewhat; BA=Barely Agree; BD=Barely Disagree; DS=Disagree
Somewhat; SD=Strongly Disagree; Total=the number of respondents who answered the question

212
Contamination Practices and Perceptions
All respondents said that they had never had a problem with land
contamination and do not monitor soil conditions on a regular basis. Three
respondents said that they had investigated the soil conditions at the time of
purchase, but all of the others said they never had undertaken an investigation. There
appears to be very little agreement on the perceptions of contamination within the
vicinity of the respondent businesses:
Table 28: Perceptions of Contamination by Respondent Businesses in Malaysia
SA AS BA
AGREE
DIS-
AGREE
BD DS SD Total
Contaminated properties are
a problem in the
neighborhood where my
business is located.
0 4 0 4 5 0 1 4 9
There are abandoned, vacant,
or contaminated properties
located within a half-mile of
my business.
0 3 1 4 5 0 1 4 9
There are abandoned, vacant,
or contaminated properties
within one block of my
business.
1 2 0 3 6 1 1 4 9
*Note: SA=Strongly Agree; AS=Agree Somewhat; BA=Barely Agree; BD=Barely Disagree; DS=Disagree
Somewhat; SD=Strongly Disagree; Total=the number of respondents who answered the question

As in Los Angeles, there appears to be no consensus concerning what are the
indicators of a brownfield site. The most popular responses were that signs would be
posted at the property (4) or there would be trash/debris at the site (4). The next most
popular answer was “I don’t know (2), followed by “other” (1). What is interesting is
that no companies selected fencing or vacancy as indicators of brownfield sites. This

213
is compelling because, in the U.S., fencing usually results when either a landowner
fears liability and wants to keep people away from his/her potentially contaminated
property or when a governmental organization has taken over responsibility for a
brownfield site. In Malaysia, because of the absence of enforceable regulatory
liability, fencing might not be a prevalent practice. Also, without such compliance
requirements, properties would likely be transacted without a period of liability-
generated dormancy or vacancy and, therefore, fencing might not be a realistic
symbol of a brownfield problem in certain cultural contexts.
Malaysian firms do seem to be somewhat extensively networked with other
businesses in their neighborhoods—three stated that they interact with five or more
other businesses, four with one or more and only two with none. This is consistent
with their operation within industrial estates, which are often designed to foster such
interrelationships.

Legal Liability Perceptions
Answers to three of the land use questions were unanimous in agreement
(See Regulatory and Liability Perceptions table below.). One implies that Malaysian
SMEs find the land use regulations that apply to them to be reasonable. Given that
they are relatively young businesses that operate within an estate planned for
industrial land uses, this may be expected. For the other two questions with
unanimous agreement, given recent changes in solid waste disposal policies and land
development policy in accordance with the EIA process, it is also expected that they

214
would concur with the statement that land use regulations, including cleanup
liability, would significantly influence their relocation decisions and perceptions
regarding liability.
Table 29: Regulatory and Liability Perceptions of Respondent
Malaysian Businesses
SA AS BA
AGREE
DIS-
AGREE
BD DS SD Total
I am knowledgeable
about the land use
regulations that apply to
my neighborhood.
3 2 1 6 2 1 1 0 8
Other businesses in the
neighborhood where my
business is located are
well-informed about land
use regulations.
3 0 2 5 3 2 1 0 8
The land use regulations
that apply to my business
are reasonable.
3 3 2 8 0 0 0 0 8
If I decided to move my
business to another
location, land use
regulations, including
cleanup liability would
significantly influence
my decision.
3 3 2 8 0 0 0 0 8
I am concerned about the
liability that applies to
businesses regarding land
cleanup in the
neighborhood where my
business is located.
3 3 2 8 0 0 0 0 8
The costs of complying
with land use regulations
that apply to my business
are too high.
2 0 2 4 4 2 1 1 8
I am concerned that land
use regulations contribute
to business failures in the
neighborhood where my
business is located.
1 2 1 4 4 1 1 3 8

215

Notably, none of the firms said that they would be willing to relocate to a
brownfield—meaning that Malaysian firms may have the same reservations that
American ones do regarding reuse. Comments concerned the need to know about
health hazards, and the idea that employees might not feel comfortable, that
employees’ health might be threatened and that there is a “fear of contamination”
because it might be “unseen despite clean up.” Five firms said “no” and four said
they did not know if they would relocate to a remediated brownfield.
Table 29 (Continued): Regulatory and Liability Perceptions of Respondent
Malaysian Businesses
SA AS BA
AGREE
DIS-
AGREE
BD DS SD Total
Land use regulations
affect the
competitiveness of my
business locally.
1 3 1 5 4 0 1 3 9
Land use regulations
affect the
competitiveness of my
business nationally.
1 3 1 5 4 0 1 3 9
Land use regulations
affect the
competitiveness of my
business internationally.
1 3 1 5 4 0 1 3 9
Small businesses like my
business get a lot of help
to clean up land that may
become contaminated
during their operations.
0 0 2 2 7 1 2 4 9
*Note: SA=Strongly Agree; AS=Agree Somewhat; BA=Barely Agree; BD=Barely Disagree;
DS=Disagree Somewhat; SD=Strongly Disagree; Total=the number of respondents who answered the
question
216
The most popular answer for action on a contaminated site in the
neighborhood was that the government would discover it during inspection (6
indications) followed by the report of a property owner to the government (4) or that
it would be reported to the government by “someone in the neighborhood” (4). One
“other” answer was suggested that “the government would fine the company and
suspend the manufacturing license.”
The lead actor in brownfield cleanup was identified as the government (6)
and the next most popular answer was the community (3). The other listed categories
received 2 or fewer responses. One suggested “other” answer was “property
owner/tenant who caused the contamination on the property.”
Both of these result sets indicate that Malaysian firms also expect the
government to be a main driver in brownfield cleanup, as do the responses to the
question concerning the “point of contact” on a site’s contamination status: the
government (6), consultants (5), and all other categories received two or fewer
responses. Open answers included “self inspection,” “ask around the neighbourhood”
and “Do not know as there is no agency at the moment that keeps a record of
contaminated land/properties.” The government was also listed as the main contact
for assistance if a business discovered contamination (7), followed by consultants
(5), real estate developers (4), and “other”: “Municipal Council of the district where
my business is located,” “last owner,” and “Previous owner if there was cover up of
the condition.”
217
Malaysian firms indicated that brownfields can be quickly remediated and
returned to use: less than six months (6), don’t know (3), 1 to 2 years (2), and 3 to 5
years (1). Unlike the Los Angeles firms, the Malaysian firms were fairly certain that
a brownfield would be returned to productive use in less than a year. Although not
statistically significant, these responses could reflect that the Los Angeles firms’
experience with long-dormant brownfields in their neighborhoods.

Cultural Context
Two firms had operated businesses in other countries: China, where the
respondent claimed that land use regulations were “about the same” and the
Netherlands where they were said to be “more strict.” The second company said land
use policies had influenced its decision to locate overseas and commented that
regulations everywhere are getting stricter due to greater “awareness of the
population.” Concerning business networking, Malaysian firms also mentioned
manufacturing associations most frequently. This is likely due to the fact that all nine
respondents are members of the Federation of Malaysian Manufacturers and were
contacted by the FMM regarding this study; however, according to the earlier
discussion, such industry groups are influential support networks to SMEs in
Malaysia. The manufacturing association was also listed as the primary source of
land use information (6) along with the newspaper (5); all other categories received
two or fewer responses. This pattern indicates that the news media is possibly very
influential in sharing policy messages concerning brownfields. When asked to
218
discuss the most important environmental issue concerning the operation of their
businesses, the firms mentioned recycling, water and land pollution, and disposal of
hazardous chemicals.
The survey exercise, though limited in its wider applicability, was helpful in
that it provides a snapshot view of the pre-brownfields era in Malaysia. As the
proposed plans and policies discussed earlier are more comprehensively
implemented, it will be interesting to see what institutional forms they assume in
support of their powerful SME sector and, given their internationally-focused
industrial structure, if they are able to innovate differently than the brownfield policy
process of U.S. localities.

Imposition of Foreign Values
This qualitative summary of the brownfield process in Malaysia compared to
the case of brownfields in Los Angeles illustrates how the concept’s uncritical
replication in diverse settings may be harmful when it assumes and imposes
foreign/external values regarding land use, stewardship, and remediation roles and
responsibilities. Fundamentally, the brownfield problem is understood differently
because it was constructed in one culture—the industrially-advanced Western
nations—and then transmitted to another—developing countries of the global South.
Even though globalization has meant that many policies and programs are shared
among countries and that instrumental definitions may be appropriate for standard-
setting and for forming the basis of multilateral agreements, the case of brownfields
219
is unique because (1) it imposes a valuation of a place-based problem (a site,
property, parcel, tract, land)—one that cannot be divorced from the locality in which
it exists—and (2) it imposes value judgments about the people affecting land use
outcomes (culprits and clients).
Moreover, even if one of these conditions is considered objectively—such as
when a property or parcel is subjected to a technical standard of soil contamination
or if everywhere the property owner is considered the undisputed culprit—something
expressive is lost in the nexus between how a place is understood over time and who
identifies with it. Thus, to presume that the U.S. brownfield policy process is
relevant to the Malaysian context is dangerous if it does not also allow for a broad-
based social evolution in its new, transplanted context. Berger & Luckmann (1962)
provide an important contextual framework for understanding this nexus between
humans and their cultural environment, which implies a powerful message about
how they then relate to their environment over time:
…the developing human being not only interrelates with a particular
natural environment, but with a specific cultural and social order,
which is mediated to him by the significant others who have charge of
him. Not only is the survival of the human infant dependent upon
certain social arrangements, the direction of his organismic
development is socially determined. From the moment of birth, man’s
organismic development, and indeed a large part of his biological
being as such, are subjected to continuing socially determined
interference. (46)

Social mediation, then, is critical to the emergence of institutions—such as
brownfield policy—either becoming meaningful to a society or at risk of getting lost
in irrelevance…
220
…transmission of the meaning of an institution is based on the social
recognition of that institution as a ‘permanent’ solution to a ‘permanent’
problem of the given collectivity. Therefore, potential actors of
institutionalized actions must be systematically acquainted with these
meanings. This necessitates some form of ‘educational’ process. The
institutional meanings must be impressed powerfully and unforgettably upon
the consciousness of the individual. (65 italics in original)

As implied, to sediment the relevance of institutions across generations,
tradition and ritual are then collectively developed. In the case of brownfields—they
are not necessarily understood pejoratively in one culture—as “bad” or “taboo”—as
they are sedimented in the collective consciousness of another. However, when the
instrumental meaning gets transmitted as given, then the pejorative connotations are
then dictated as fact—brownfields are expected to look the same and are bad
everywhere.

Institutionalizing the Exclusion of Local Expression
Another danger of exporting the U.S. brownfield institution and its
concomitant taboo is that because it requires a top-down implementation process (in
this case driven by the IEM and DOE through business associations and land
development agencies), it dictates roles and responsibilities of other local groups and
individuals—thereby setting in motion a pathology that removes or marginalizes
decision-making power from the grassroots level.
To dictate a brownfield policy process—or ritual process of identifying
societal pollution and then how to purify it—then becomes dangerous if it asks a
society to adopt or even fake a cognitive understanding of a problem it has not yet
221
encountered; e.g., according to Douglas (1966/2002), “…ritual focuses attention by
framing; it enlivens the memory and links the present with the relevant past. In all
this, it aids perception. Or rather, it changes perception because it changes the
selective principles.” (79) In this way, a caution emerges which indicates that to live
through the experiences which inspire a ritual make it more relevant and meaningful
as a social process.
In the case of Malaysia, individual citizens are currently encouraged to play a
role in monitoring and reporting the harmful environmental practices they observe in
their communities. Although no research to date has focused on the effectiveness of
this process, it provides evidence of an important layer of decision-making in the
emergence of brownfield policy because, if empowered, citizens are likely the best
candidates to identify, characterize, and prevent brownfield creation in process. This
layer is largely absent in the Los Angeles case, where the brownfield process does
not include, but instead discourages a systematic, institutionalized or ritualized
process of citizen involvement. While the reliance of the Malaysian government on
citizens to report brownfield-type pollution in progress likely derives from necessity
as the regulatory infrastructure matures to respond to the problem, it provides an
opportunity to capture a critical perspective that would serve to improve the
effectiveness of brownfield redevelopment in the future—since local-level buy-in is
critical to the long-term success of redeveloped properties.

222
Splintering of a Key Stakeholder Group
Both Los Angeles and Kuala Lumpur are large metropolises facing a shortage
of available industrial land and both have experienced a sprawl-like flight of more
affluent residents to the urban fringe areas. This has left behind degraded land and
has taxed the capacities of governments in both cities to deal with the necessary
property investigation and enforcement requirements to curb the related
environmental pollution and the threat to public health. Industrial tenants are key
stakeholders to this process in both cities and they may be seen as culprits in each as
governments have sought to clean urban brownfields resulting from illegal dumping
and other—such as hazardous waste contamination—from small businesses. In the
case of Kuala Lumpur, the term brownfield is less well-known, but the problem is
associated with the illegal dumping of waste by existing industries.
However, the everyday reality of small businesses in Los Angeles is quite
different than that of their counterparts in Malaysia. In regard to brownfields, Los
Angeles businesses clearly feel like culprits yet Malaysian businesses have not been
involved in the process to any great extent at all—as either culprits or clients. This
means that there could be room for them to be engaged earlier—at the brownfield
prevention stage. This also means that it would be dangerous to automatically treat
them like clients (as per U.S. experience and policy prescriptions) prior to first
exploring ways that they might be active and engaged civic stewards. This implies a
likely power differential whereby small businesses can become protagonists and
223
work together with communities to stem the evolution of blight. Douglas describes
such a community power struggle thus,
...to continue with the inventory of spiritual powers, there is another
classification according to the social position of those endangering
and those endangered. Some powers are exerted on behalf of the
social structure; they protect society from malefactors against whom
their danger is directed. Their use must be approved by all good men.
Other powers are supposed to be a danger to society and their use is
disapproved; those who use them are malefactors, their victims are
innocent and all good men would try to hound them down—these are
witches and sorcerers. This is the old distinction between white and
black magic. (123)

What is implied here is that the culprits and clients within a culture are
socially-constructed and to assume that they play the same role in different cultures
is, again, dangerous.
The strategy of the government in Kuala Lumpur to relocate small
manufacturing firms to greenfield industrial estates outside of the city is quite
different than the Los Angeles case. Malaysia still has the luxury of available land on
the urban fringe and an entrenched export-oriented industrial structure that makes it
easier to offer small firms modern amenities nearby. Although the full ramifications
of such broad-scale industrial relocation policy is not yet known, given the
importance of firms’ present and potential social contributions to local communities,
this process is likely damaging to the existing urban social fabric in Kuala Lumpur
that loses firms to the urban fringe or satellite cities and industrial estates.
The Malaysia case also highlights an important difference between the
export-oriented and domestic small firms in Malaysia and how they do not have
224
access to the same networks of support, which, according to Abdullah (1999), is
threatening to damage important linkages that domestic firms provide to local
communities. While export-oriented firms have access to innovative environmental
technology and are adhering to advanced international environmental standards, they
are not necessarily providing benefits to the local communities when they are
operating in distant satellite industrial parks. Thus, there may be a mismatch between
the firms with the best environmental stewardship practices and the ability of those
same firms to share knowledge with their local neighborhoods.
What remains to be seen is how the brownfield message will become further
diffused throughout Malaysian society—whether an adopted foreign instrumental
meaning—one laden with taboo and ready-made culprits—will be embraced,
whether a new instrumental process will be developed or whether expressive
meaning emerges. Since there is a widespread recognition that “Not many countries
in Asia have…comprehensive legislation to control and abate pollution in relation to
soil or groundwater” (IEM 2006) and this is language used to encourage
participation at the Brownfield Asia conference (scheduled to take place in Kuala
Lumpur in September 2006) there is likely room for a more expressive, culturally-
based meaning that can stress prevention and better inform the creation of future land
use law. Next, Chapter Six will discuss how local knowledge and culture may be
made endogenous to the brownfield policy process as it is exported across
countries—avoiding an indiscriminate transmission of a taboo-based pathology.
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Chapter 6:
Summary and Directions for Future Research

A distinct language has emerged around contaminated lands that we now call
“brownfields” which has in turn generated an industry of experts, identifiable
culprits and clients, and a regularized way of dealing with polluted lands. Moreover,
as a process of highly-bureaucratized ritual purification, brownfields in the U.S. may
be seen as contemporary pollution symbols linked to risk, threat, and liability. In this
way, they function as Douglas’ (1966/2002) idea of taboo.
The perpetuation of the idea of brownfield as taboo can be seen as arising
from a distinct cultural background tied to a history of deindustrialization in
economically-advanced nations in the Western hemisphere. Understanding
brownfields as socially-constructed provides a lens for interpreting brownfields as
not only constituent to, but also consequences of a complex interplay of societal
beliefs and values. The emergence and persistence of brownfields, then, may be seen
as a collective understanding of a class of problems—from small, abandoned corner
gas stations to large tracts of former mining lands—that together have become a
generically-masked as a single problem or taboo through the label “brownfield.”
This is reinforced through repetitive use in diverse places, demonstrating Douglas’
idea of taboo since, “Taboos depend on a form of community-wide complicity.” (xii)
Understanding brownfields as reliant upon community-wide complicity begs
the question of how the community understands them and upholds their
continuance—particularly whether there is a uniform understanding of the problem
226
by all members of a community or if certain individuals and groups may perceive
them quite differently. There can be a variety of responses to this query, many of
which will necessarily be tied to the country-specific or region-specific context in
which they originate. Although my findings emphasize the contextual nature of these
differences, I have been interested in seeking out systematic explanations that can
transcend the limitations of context.
Mary Douglas’ dichotomy of two distinct meanings of pollution: the
instrumental and the expressive, provides a helpful way of being simultaneously
systematic and appreciative of context. My contribution in the dissertation has been
to use this dichotomy to illuminate the problem of brownfields as a case where the
instrumental meaning of pollution has outstripped its expressive meaning. I have
traced the instrumental meaning of pollution to the technical or legal understanding
of the problem and how it is implemented through laws and ritual. Conversely, the
expressive meaning of pollution involves local beliefs and the faith that people have
in the laws and rituals that govern them.
Evidence for the tension between instrumental and expressive, notably the
dominance of the instrumental and the marginalization of the expressive, has come
from at least three distinct sources. First, we find that this has happened in the
literature surrounding brownfields, where although a vibrant technical literature
about cleanup is available and is growing, there is little written about the social
context within which brownfields get identified and acquire salience. Indeed, the
227
recognition of social construction should be ubiquitous; however, in the case of the
brownfield literature it is virtually non-existent.
Second, I have shown in my work on Los Angeles that the professional
analog of the dichotomy can be seen in the highly-ritualized, bureaucratic process of
cleanup that leaves little room for local business groups and for the citizenry to
participate in defining the problem and developing solutions. This ends up isolating
small firms from their communities and concomitantly drains responsibility for
pollution management from them.
Third, through a reconnaissance of the early Malaysian effort to develop a
brownfield policy, I have shown that despite a culture where businesses participate in
all aspects of community life, the new emphasis on brownfields and the reproduction
of Western practices, such as technical and legislated approaches, threatens to
relocate businesses to new satellite cities, and exacerbate the challenges to
community building and city planning.
On the one hand these are two quite different contexts, contributing to the
need for a context-based analysis. On the other, these outcomes are also systematic
in that they are reflective of the way in which one perspective (the instrumental)
overtakes another (the expressive) whether this happens over time in the case of Los
Angeles or because of emulation of Western practices, in case of Kuala Lumpur.
Together, the cases serve to demonstrate that the understanding of the
concept “brownfield” is clearly a societal process, involving the interplay of a variety
of actors—agents—and agencies in each city’s history. This is consistent with Hall’s
228
(1997) description of social construction as ideas that are “produced—constructed—
rather than simply ‘found’” and, in this way, the representation of the label
“brownfield” may be seen as an expression of culture, “conceptualized as a primary
or ‘constitutive’ process” (3-4) of what is considered pollution in one place versus
the other.
Within the constitutive brownfield process I have also found another
systematic relation, which I have described as a tension between “culprit” and
“client.” Technical or instrumental meaning turns pathological when those who
are—or should be—clients of brownfield policy are alienated by being seen as
“culprits.” Again, different individuals and groups assume different roles as the
context changes. For instance, while each case—Los Angeles and Kuala
Lumpur/Selangor—possesses a significant small manufacturing business sector,
these play very different roles in the brownfield equation. In the former they are
made to feel like culprits, but in the latter they have not yet engaged in the dialogue
on brownfields. Both small business survey populations proved difficult to engage
for a variety of reasons—but primarily because of the time constraints imposed on
them in their regular business operations and, in the case of Malaysian firms, because
of an expressed unfamiliarity with the topic at hand. Thus, while brownfields are
directly relevant to firms in the Los Angeles region, they are currently less relevant
to firms in Kuala Lumpur and Selangor. But, again, while we recognize that the
actual formulation of the brownfield problem will be different in both settings, the
culprits and clients exist in both.
229
Policy Directions
It may be possible to make some preliminary policy-oriented suggestions; for
instance, the institutional analysis suggests that there is a strong multi-level
governmental infrastructure in place to implement brownfields work in Los Angeles,
but that system has not yet incorporated existing small business owners, who are
largely unaware of the brownfield phenomenon and process. Because of the interest
of policymakers in Los Angeles in redeveloping small, industrial urban
brownfields—such as through the Industrial Development Policy Initiative—it is
critical that the small firm perspective be better articulated and supported.
Preliminary evidence here has shown that even long-standing firms do not see the
government as a source of support to them in environmental management.
Detailed comments provided by respondent firms in Los Angeles revealed
that there is definitely a “culprit” sentiment present. Firms indicated that they are
overwhelmed by the environmental compliance requirements placed upon them
regarding air emissions, water quality, and solid waste disposal and have a fear of
liability regarding brownfields. Notably, firms did not indicate a willingness to
relocate to a former brownfield because of these reservations and this is important
given that future local policies to attract businesses to such properties will have to
address this reluctance. Traditional governmental incentives do not appear to have
much of an effect on small firms’ land use behavior in Los Angeles, but land prices
and infrastructure amenities certainly do.
230
Although the pool of respondents in Los Angeles exhibited a much longer
history in their neighborhoods than their counterparts in Malaysia, their connection
to the neighborhood seemed to be somewhat tenuous—they do not personally know
many of the people in the business neighborhood, they hire most workers from
outside of the neighborhood and they do not network with many nearby businesses.
There was also a strong tendency to characterize the business neighborhoods in Los
Angeles as disadvantaged, but most businesses still believe that the future prospects
for their neighborhoods are promising.
In a sense this suggests that existing firms must be brought into the
brownfields dialogue—as much as the future firms that will be recruited to take over
brownfield sites—because they will be the neighbors of the new businesses, they
have historic knowledge of the neighborhoods, they are or will become aware of
environmental problems in the neighborhoods and, as early findings here show, they
will remain in place. If changes are not made to the way that existing firms are
engaged regarding environmental compliance, they likely will not change their
stewardship behavior—they will not report possible contamination problems, they
will not seek solutions to them, and they will not become involved in solving wider
neighborhood property problems.
There is certainly a complex array of social forces and government policies
that have enabled this to happen in each case, but given present circumstances, it
appears that a compelling way to make firms better clients in community
231
revitalization is to incentivize and reward what is missing—their social connections
and commitments to their neighborhoods. Specifically, this might happen by:
• Setting up a public notification system whereby individuals and firms
could learn about brownfields and be encouraged to report
contamination on their properties or on others without fear of stigma
or liability;
• Establishing neighborhood-level improvement funds through
Business Improvement Districts (BIDs) or other assessment
mechanisms that could be invested to grow and then be applied to
contamination problems as they arise;
• Creating frequent neighborhood-level land condition evaluations to
coincide with other regularized information collection processes—
such as voter registration, Neighborhood Watch programs,
Community Plan updates or Census data gathering—to provide an
opportunity for local citizens to monitor and record changes in land
use over time in order to identify vulnerable properties that could
develop into brownfield problems;
• Streamlining bureaucratic processes so that brownfield properties can
be more quickly turned over to individual public or private
developers, such as the “One Stop Shop”
1
practices that are emerging
in cases of local government performance improvements; and

1
Examples of this approach exist at the local level in Emeryville, California and at the state level via
the Connecticut Brownfields Redevelopment Authority, established recently—in early August 2006.
232
• Expanding the meaning of brownfield to include more diverse
pollution ideas that are not necessarily linked to statutory definitions
of contamination, underutilization, or blight, but instead have been
identified as priorities by localities themselves.

Together, these changes could foster brownfield prevention through a more
collaborative process that results when social capital is strong and long-term
commitment to the neighborhood by both residents and businesses is mutually-
understood. In Los Angeles the challenge is to engage entrenched firms that have
experienced a legacy of governmental antagonism—their perspective is critical to
designing brownfield incentive programs that will really work. In Malaysia the
challenge is to engage the powerful internationally-focused industrial network
infrastructure with the domestic brownfields agenda, so that their information and
technological advantages are better shared by domestic firms and local communities.
A number of compelling future research directions emerge. For instance,
researchers might want to ask just why people choose to abandon properties? Why is
land left vacant and idle? Who are brownfield property owners? When and why does
a brownfield property attract outside interest (i.e., what are the triggers and are they
the same everywhere)? Why are people so unfamiliar with the land use practices of
their neighbors? Are there systematic winners in brownfield policy implementation
(If so, who are they, how does this happen, and what are the impacts?)?
This dissertation also suggests that governments worldwide would be wise to
learn from the U.S. experience and avoid implementing brownfield policies that
233
alienate local stakeholders, such as small businesses, in embracing an instrumental
meaning of the problem at the expense of the expressive. Since the U.S. exhibits a
more entrenched instrumentally-focused approach to brownfields, it is less promising
to implement a more expressive approach retroactively. However, developing
countries may have an advantage in being able to design their brownfield
redevelopment policies to embrace the expressive—and systematically incorporate
important local knowledge—because they would not have to compete with long-
standing cynicism resulting from an experience with ineffective past practices. Thus,
a number of future research directions could be pursued in finding out how
developing countries might “leapfrog” the complex regulatory process of more
industrially-advanced nations and instead innovate beyond them by instituting less
formal practices that would obviate the need for distant government involvement in
local land use decisions. A counterintuitive approach might be to seek out
developing countries with rapidly urbanizing areas and ask, “Why aren’t you talking
about brownfields?”

234
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257
Appendix A:
Survey Questionnaire Instrument for Small Businesses in Los Angeles

Note: This is a plain text version; the full color version is only available in
Dreamweaver software format and was made available on the
Internet at: http://www-scf.usc.edu/~carolarm/Armstrong_LA_Survey_mod.html.
In order to access the survey, respondents first acknowledged their understanding of
university policy via a cover page that was approved by the University of Southern
California Institutional Research Board, UPIRB #03-02-050.

Survey Questionnaire for
BUSINESS OWNERS AND MANAGERS
Project Title: Small Businesses and Land Use in Los Angeles
This survey questionnaire is to be completed by the individual who is either the
owner, principal manager, or other executive of the business. Please submit your completed
questionnaire by clicking the "Submit" button at the bottom of this page. All
questions/comments about the survey should be addressed to Ms. Carol Armstrong at
carolarm@usc.edu. Your participation is MOST GRATEFULLY appreciated—thank you
very much!
--------------------------------------------------------------------------------
PERSONAL INFORMATION
Please select your preferred title. Mr. Ms. Mrs. Dr.
Your Name (First, Middle, Last)
Business Name
*Street Address 1 (Number, Street, Street Type)
*Street Address 2 (Unit or Suite): City, State/Province, Postal Code
*Telephone Number, *FAX Number, *E-mail Address, *Website Address
BUSINESS INFORMATION
What is your primary type of business?
Manufacturing Services Retail Other:
What do you primarily produce/sell?
What are your business codes (if known)?
Standard Industrial Classification (SIC) Code
North American Industry Classification System (NAICS) Code
How long has your business been at its present location? Less than one year 1-5 years 6-10
years 11-15 years 16-20 years More than 20 years Other:
In what year was your business founded?
Where is your company headquartered? (City, State/Province, Country)
Is your business a small business? YES NO
How many employees does your business have? Full-Time Employees Part-Time

OWNER INFORMATION
In case of multiple owners, please describe the managing partner or if there is no managing
partner, please indicate the owner that lives closest to the business site.

Are you the business owner? YES NO
Is your business a family business? YES NO
Is your business a franchise? YES NO
258
Do you consider your business a minority business? YES NO
Describe the business owner: Individual Ownership Partnership Group (More than 2
owners) Other:

Approximately how far away from the business does the owner live?
Owner lives at business Within walking distance Less than 15 minute vehicle commuting
distance 16-30 minute vehicle commuting distance 31-60 minute vehicle commuting
distance More than one hour in vehicle commuting distance
Other:

Approximately how many miles from the business does the owner live?
Less than one mile 1-2 miles 3-5 miles 6-8 miles 9-10 miles 11-15 miles 16-20 miles 21-25
miles 26-30 miles More than 30 miles Other:

Approximately how many days a week does the owner work at the business?
0 1 2 3 4 5 6 7

SITE INFORMATION
Do the owners of your business own the land on which it operates?
YES NO If "NO", do you rent? YES NO
Do you have a long-term lease? YES NO
Is your business located in a business or industrial park complex? YES NO

What influenced your decision to locate your business where it is now?
(Please check all that apply and include any other factors in "Other".)
Land price/rent
Access to market/customers
Transportation access
Governmental incentives
Access to labor pool/workers
Facilities or amenities, such as buildings and equipment)
Other:

How important are different location factors?
(Please indicate how important these factors were to you and include any other factors in
"Other".)
Land price/rent Important Not Important
Access to market/customers Important Not Important
Transportation access Important Not Important
Governmental incentives Important Not Important
Access to labor pool/workers Important Not Important
Facilities or amenities, such as buildings and equipment) Important Not Important
Other (Please type here.): Important Not Important

Approximately how large is the land parcel your business occupies?
Less than one acre 1-2 acres 3-5 acres 6-8 acres 9-10 acres 11-20 acres 21-40 acres 41-60
acres 61-100 acres More than 100 acres

259
Has your business ever had any problems with land contamination?
YES NO DON'T KNOW
If "YES", please describe here:

Does your business monitor land/soil conditions on a regular basis?
YES NO DON'T KNOW
If "YES", please describe how and how often here:

When was the last time you assessed the land/soil conditions at your business site?
At time of purchase During new construction Never Other:
What signs indicate to you that a property is contaminated or polluted?
(Please check all that apply.)
It is vacant
There is trash/debris on it
There is a fence around it
Signs posted at the property
I don't know
Other If "Other", please describe here:

NEIGHBORHOOD INFORMATION
Please indicate whether or not you agree with the following statements by clicking in the
circle that corresponds with your opinion of each statement. Answer choices listed are:
Strongly Disagree, Disagree Somewhat, Barely Disagree, Barely Agree, Agree Somewhat,
Strongly Agree

My business is located in a disadvantaged neighborhood.
Crime is a problem in the neighborhood where my business is located.
Vacant properties are a problem in the neighborhood where my business is located.
Abandoned properties are a problem in the neighborhood where my business is located.
Contaminated properties are a problem in the neighborhood where my business is located.
There are abandoned, vacant, or contaminated properties located within a half-mile of my
business.
There are abandoned, vacant, or contaminated properties within one block of my business.
I know by name many of the residents in the neighborhood where my business is located.
I know by name many of the other people who operate businesses in the neighborhood
where my business is located.
I would like to keep my business in the same neighborhood for the next five years.
I would like to keep my business in the same neighborhood for the next ten years.
I would like to keep my business in the same neighborhood for the next twenty years.
Conditions are improving in the neighborhood where my business is located.
Conditions are deteriorating in the neighborhood where my business is located.

Approximately what percentage (%) of your employees live within ONE mile of your
business? 1-5 % 6-10% 11-15% 16-20% 21-30% 31-40% 41-50% 51-60% 61-70% 71-80%
81-90% 91-100%

Approximately what percentage (%) of your employees live within FIVE miles of your
business? 1-5 % 6-10% 11-15% 16-20% 21-30% 31-40% 41-50% 51-60% 61-70% 71-80%
81-90% 91-100%
260
With approximately how many businesses in your neighborhood do you have regular
business relationships? 0 1 2 3 4 5 More than 5
In addition to my business activities, I interact with the neighborhood where my business is
located by___________________________.
(At right, please indicate all that apply.)
Participating in neighborhood groups
Sponsoring or donating to neighborhood groups or causes
Advertising neighborhood events
Hosting local events/activities
Training local residents
Other
If "Other", please describe here:

LAND USE INFORMATION
The following questions refer to land use regulations as including zoning and other use
restrictions, as well as maintenance requirements, including reporting of contamination and
cleanup responsibility. Answer choices listed are: Strongly Disagree, Disagree Somewhat,
Barely Disagree, Barely Agree, Agree Somewhat, Strongly Agree

I am knowledgeable about the land use regulations that apply to my neighborhood.
Other businesses in the neighborhood where my business is located are well-informed about
land use regulations.
The land use regulations that apply to my business are reasonable.
If I decided to move my business to another location, land use regulations, including cleanup
liability would significantly influence my decision.
I am concerned about the liability that applies to businesses regarding land cleanup in the
neighborhood where my business is located.
The costs of complying with land use regulations that apply to my business are too high.
I am concerned that land use regulations contribute to business failures in the neighborhood
where my business is located.
Land use regulations affect the competitiveness of my business locally.
Land use regulations affect the competitiveness of my business nationally.
Land use regulations affect the competitiveness of my business internationally.
Small businesses like my business get a lot of help to clean up land that may become
contaminated during their operations.

If I decided to move my business, I would be willing to relocate to a formerly contaminated
property that had been cleaned up. YES NO DON'T KNOW
Please explain your answer here:

If there were a contaminated property in the neighborhood where my business is located,
what would happen?
(Please check all that apply.)
Nothing
The owner would clean it up his/herself
It would be reported to the government by the property owner
It would be reported to the government by someone in the neighborhood
The government would discover it during inspection
It would be cleaned up by the government
261
It would be discovered prior to resale and the owner would clean it up
It would be discovered prior to resale and the new owner would clean it up
It would be discovered after resale and the new owner would clean it up
The government would provide help to the old owner in cleaning up the property
The government would provide help to the new owner in cleaning up the property
Other If "Other", please describe here:

If there were a contaminated property in the neighborhood where my business is located,
who would take the lead in making sure it was cleaned up?
(Please check all that apply.)
The business
The community
The government
Real estate developer
Consultants
Insurance company
Other If "Other", please describe here:

If you wanted to find out if a property was contaminated in your neighborhood, who would
you contact?
(Please check all that apply.)
The owner of the property
A community organization
The government
Real estate agent
Real estate developer
Consultants
Insurance company
Other If "Other", please describe here:

If you purchased a new property in your neighborhood and found that it was contaminated,
who would you contact to clean it up?
(Please check all that apply.)
The government
Real estate agent
Real estate developer
Consultants
No one
Other If "Other", please describe here:

Approximately how long do you think it takes for a contaminated property to be cleaned up
and reused in the neighborhood where your business operates? Less than six months 7
months-1 year 1-2 years 3-5 years 6-10 years 11-15 years More than 15 years
Other (Please explain.):

OPERATIONS INFORMATION
Have you ever owned, operated, or managed a similar business in another country? YES
NO
If "YES", which country/ies?:
262
If you responded “YES” to the question directly above, please answer questions A, B, C, and
D here. If you responded “NO”, please skip them.
A. Were/are the land use policies in the other country/ies as strict as they are in the US?
(Please type country names and then choose the most appropriate answer at right.)
Country 1: Please choose: More strict land cleanup policies Less strict land cleanup policies
About the same
Country 2: Please choose: More strict land cleanup policies Less strict land cleanup policies
About the same
Country 3: Please choose: More strict land cleanup policies Less strict land cleanup policies
About the same
Country 4: Please choose: More strict land cleanup policies Less strict land cleanup policies
About the same

B. Do you think that the land use policies in the different countries strongly influenced your
decisions to do business in the foreign locations?
YES NO

C. Do you think that the land use policies in the different countries have become more
similar or less similar to the policies in California over time?
MORE SIMILAR LESS SIMILAR
Please explain your answer:

D. Have the land use policies in the other countries changed significantly over time?
YES NO If "YES", how have they changed?
MORE SIMILAR LESS SIMILAR
Please explain your answer:

In which (if any) business network groups do you participate?
(Please check all that apply.)
Chamber of commerce
Manufacturing association
Lobbying group
Community group
Government group
Technology group
University research group
Other:

Where do you receive most of your information about land use regulations and issues?
(Please check all that apply.)
Chamber of commerce
Manufacturing association
Lobbying group
Television
Internet
Newspaper
Radio
Community group
Federal Government
263
State government
Local government
Technology group
International sources
University research group
Trade publications (journals, etc.)
Other:
What do you consider the most important environmentally-related issue that affects the
operation of your business?
Please briefly describe here:
Please use this space to communicate any additional comments:
THANK YOU VERY MUCH FOR TAKING THE TIME TO PARTICIPATE IN THIS
STUDY.
--------------------------------------------------------------------------------
This survey questionnaire is intended for academic purposes only and is in accordance with
the appropriate university research policies (USC UPIRB #03-02-050).
*The items with an asterisk were eventually taken off the survey since the information was
already available in the directory from which the companies were chosen and doing this put
less of a typing input burden on the respondents.

264
Appendix B:
Results of the Content Analysis of City of Los Angeles Land Use Plans

Table A1: Conservation Element of the General Plan

Expressed Pollution Ideas Expressed Cleanup Processes
Sec. 14, “Hazardous Materials”: The city has a primary regulatory, informational and
catalytic role in hazardous materials management, cleanup and brownfields site
revitalization. (46)

Uses out-dated definition of brownfield: “as abandoned, inactive or underutilized
industrial and commercial properties where expansion or redevelopment is
complicated by real or perceived environmental contamination” (44) This is from
Section 101 of the Comprehensive Environmental Response, Compensation, and
Liability Act of 1980 (42 U.S.C. 9601).
Seek external funding: The [U.S.] EPA provides funds for site
assessment and revitalization of sites that are contaminated with
hazardous materials. (44)
Technical Assistance: The goal of the city program is to assist
property owners in resolving contamination related problems
(e.g., legal, financial, bureaucratic) so that contaminated
properties cleaned up and redeveloped, thereby providing a
catalyst for community revitalization. (44-45)

Table A2: 35 Community Land Use Plans

No. Plan Area Expressed Pollution Ideas Expressed Cleanup Processes Brownfield Sites
Brownfield
Language
1 Arleta - Pacoima
Industrial hazardous waste
contamination and costs of
cleanup Improvement of
economic and physical
condition of community
Restrictive zoning, industrial parks,
Cooperative joint public and private fix-up,
cleanup and maintenance projects on selected
neighborhood blocks
Private sponsorship of cleanup and
beautification programs...along railroad
rights-of-way, to improve the general
environment
Study for the Pacoima Business
District to determine what are
possible approaches to
redevelopment of the
deteriorating portion of Van
Nuys Boulevard between Laurel
Canyon and Borden Avenue.
Contaminated,
cleanup
2
Bel Air-Beverly
Crest
Regarding idle lands, as a
general policy, public lands on
which present uses are
discontinued should be turned
into or left in open space.
Private development and maintenance of
mini-parks on property provided for public
use and as an interim use of vacant private
lands, with permission of the owner.
Sponsoring clean-up and beautification
programs.
Property Improvement Tax Relief—Revision
of laws to provide incentives to property
owners making improvements to their
properties.
Tax Delinquent Properties—Provision for
City acquisition of tax delinquent properties
for open space and recreational use.
None Idle lands,
vacant private
lands,
cleanup, tax
delinquency

265

Table A2 (Continued): 35 Community Land Use Plans
No. Plan Area Expressed Pollution Ideas Expressed Cleanup Processes Brownfield Sites
Brownfield
Language
3 Boyle Heights
Redevelopment of industrial
and commercial land
Residential structure
deterioration
Substandard parcels that do
not facilitate assemblage
and redevelopment
Physical decay of housing is
a complex problem. (The
root causes are various, and
consequently there are no
simple solutions.)
Industrial sector
characterized by smaller
parcels, piecemeal
development and
substandard streets,
restricting the potential for
site expansions to increase
storage or production space,
or the rehabilitation and
reuse of structures. There is
an absence of vacant land.
CRA study focused on industrial and
commercial land only: examination of
development trends, land costs,
transportation facilities, employment,
demand for retail, future property values
and blight.
Removal of underutilized or substandard
structures.
Study feasibility of providing efficient,
labor-intensive industrial parks in existing
industrial areas containing vacant land,
abandoned railroad rights-of-way and
marginal industrial uses.
Intensification, rehabilitation, reuse and
multiple-use of facilities and sites should
be utilized.
Developing and maintaining mini-parks
on property provided for public use and as
an interim use of vacant private lands,
with permission of the owner.
Sponsoring clean-up beautification
programs to improve the general
environment.
Property Improvement Tax Relief
Tax Delinquent Properties—acquisition
of tax delinquent properties for open
space and recreational uses.
Sears site: Due to the size
and potential build-out of
the site, any re-use or
redevelopment of this site
will have significant
community wide impacts
as well as immediate
impacts on the
surrounding uses and
neighborhood. This site
should be redeveloped
along with vast parcel of
commercial land north of
Olympic Boulevard.

CRA,
redevelopment,
blight,
underutilized,
substandard
structures,
rehabilitation,
reuse, cleanup,
tax delinquency
4
Brentwood-
Pacific Palisades
Commercial: Visual and
physical pollution from
auto-related commercial
activities “Police
Protection”: Security
concerns, contaminated
parcels
Objective 2-2, Allow for the development
of automobile-related uses in specific
commercial designations along major
arterials
Require screening of open storage and
auto repair uses, and prohibit storage of
automobile parts and other noxious
commercial related products in front of
commercial development exposed to the
street.
Recreation and Park Facility: Pursue
resources to clean up land that could be
None Contamination,
physical
pollution,
cleanup, housing
(structural)
rehabilitation

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Table A2 (Continued): 35 Community Land Use Plans
No. Plan Area Expressed Pollution Ideas Expressed Cleanup Processes Brownfield Sites
Brownfield
Language
used for public recreation safely.
Housing: Maintain and preserve character
and integrity of existing neighborhoods
and encourage participation in self-help
preventive maintenance to promote
neighborhood conservation, beautification
and rehabilitation.
5
Canoga Park-
Winnetka-
Woodland Hills-
West Hills
Blighting impact of vacant
and obsolete commercial
development on adjacent
residential neighborhoods
Oversupply and poor
appearance of strip mall
development and obsolete
commercial space on major
thoroughfares
The viability of older
industrial districts is
challenged by changing site
and location requirements
of modern industrial uses
Contraction of industrial
sectors important to the
west valley, such as
aerospace, has led to a loss
of local manufacturing jobs
and the need to find new
industrial uses
Poor maintenance, unsightly
appearance and dilapidated
condition of structures.
Proliferation of low-end
uses such as auto repair
establishments.
The appearance, physical
layout, and proliferation of
strip mall development are
major issues...poor or
obsolete design and
inadequate maintenance
characterize a significant
share of existing
Support efforts of active homeowners
groups working to promote identification,
preservation and rehabilitation of local
neighborhoods.
Use land policies to support ongoing
affordable home-ownership and
rehabilitation programs in older single-
family neighborhoods.
Encourage recycling of unused industrial
sites by uses linked to expanding sectors
of the region’s economy.
Increasing presence of desirable (“clean”)
industrial uses, thus generating less
harmful pollutants and lower noise levels.
BIDs, Urban Design Guidelines
Conserve and strengthen viable
commercial development and encourage
recycling of obsolete commercial
development.
CRA Redevelopment Project Area.
Within these areas, obsolete commercial
space may be recycled through use of
redevelopment powers.
Policies 2-2.2: Require screening of open
storage and auto repair uses, and prohibit
storage of automobile parts and other
noxious commercial related products in
front of commercial development,
exposed to the street.
Pursue resources to clean up land that
could be used for public recreation safely.
Maintain and preserve the character and
integrity of existing neighborhoods and
encourage participation in self-help
preventive maintenance to promote
“Major Development
Opportunity Sites, Canoga
Park Industrial Corridor”:
This corridor is in a period
of transition and
opportunities for recycling
exist. Policies and
programs to promote
clean industrial uses such
as light assembly,
research, and
subcontracting specialties
related to the motion
picture industry should be
promoted.

Blight, vacant,
obsolete uses,
recycling, clean
reuse, unsightly,
dilapidated
structures, CRA
redevelopment,
deterioration,
rehabilitation,
revitalization,
harmful
pollutants from
industrial use

267
Table A2 (Continued): 35 Community Land Use Plans
No. Plan Area Expressed Pollution Ideas Expressed Cleanup Processes Brownfield Sites
Brownfield
Language
commercial development.
Industrial restructuring in
recent years has led to a
deterioration of older
industrial space along
Canoga Boulevard, and
pressures to reuse modern
facilities for retail and other
non-industrial uses.
neighborhood conservation,
beautification, and rehabilitation.
6 Central City
Objective 10-2: To maintain
and reuse one of the largest
and most distinguished sets
of underused historic
buildings in the United
States. Perceived lack of
safety and cleanliness in
commercial areas
High vacancy rates in older
office buildings.
Aging industrial facilities
that are inadequate to meet
the technological and space
requirements of new and
emerging industries.
Aging infrastructure
Lingering impacts of
regional economic
restructuring resulting in
loss of existing industry and
the lack of new industries.
The need to preserve and
rehabilitate historic areas
with sensitivity to their
architectural integrity.
Decaying historic core with
high vacancy rate in
obsolete office buildings on
Spring Street or Broadway.
Although land use planning
in itself cannot accomplish
the task of economic
development, it can play a
Contains multiple CRA project areas
Adaptive Reuse Ordinance to facilitate
the conversion of vacant and underused
commercial and industrial buildings to
house and live/work space.
Completion of the Alameda Corridor
Transportation Project ensuring
convenient high-speed direct rail
connections to the Ports of Los Angeles
and Long Beach.
Indirect benefits resulting from the
proposed $3 billion investment in the
downtown area.
An effective economic development
plan—with components directly related to
marketing, advocacy, the physical and
economic revitalization of
neighborhoods, and jobs creation which
are the primary functions of such groups
as the Convention and Visitors Bureau,
the CRA, and other downtown groups and
associations such as the BIDs
Encourage the rehabilitation and adaptive
reuse of historic buildings for housing,
artist lofts and live-work units.
Monitor the supply of low-income
housing stock to guard against loss of
units through demolition, conversion, and
deterioration
Utilize all available funds to rehabilitate
and/or construct low income housing or
subsidize rents
Policies 2-1.2: To maintain a safe, clean,
3-1.3: Encourage the
refurbishment of the old
produce terminal for more
efficient wholesale
activities and office uses.

Vacant,
underused,
rehabilitation,
CRA
redevelopment,
reuse, obsolete,
revitalization,
deterioration,
restore, graffiti,
litter, crime,
outdated, aging
industrial
facilities and
infrastructure,
blight,
underutilization

268
Table A2 (Continued): 35 Community Land Use Plans
No. Plan Area Expressed Pollution Ideas Expressed Cleanup Processes Brownfield Sites
Brownfield
Language
role in setting public
policies and programs that
create a positive physical
environment.
Figueroa Corridor...area
lacks consumer awareness,
and there is a perception of
a lack of security and crime
in the area
Industrial: ...small and
medium-sized individual
businesses offer continued
economic vitality and job
growth opportunities despite
an often blighted and
uninviting work
environment, aging
infrastructure, insufficient
parking as well as strong
regional and international
competition.
Downtown has a significant
stock of historic buildings
and places. Deterioration of
these resources affects the
economic vitality, the social
well being and the physical
appearance of all of
Downtown. The ability to
renovate, restore and reuse
these buildings can be
accomplished with
increased private- and
public-sector commitment
to creating regulatory and
financial incentives for
investment.
The arts have been a strong
economic force and an
integral component in
downtown’s revitalization
and will greatly influence
attractive, and lively environment
Program—Create and coordinate an
Adopt-a-Sidewalk program for adjacent
businesses and property owners that
encourages the planting and maintenance
of trees, shrubs, and flowers
Policies 2-2.2: Develop a plan and
otherwise facilitate the development of
night-time entertainment uses, such as
night clubs, bars, comedy clubs, dance
clubs, restaurants and theaters in the
vacant portions of the historic buildings
on Broadway and in the Broadway
National Register Historic District which
will rehabilitate the structures, revitalize
the district and foster a 24-hour
downtown.
Policies 3-1.1: Update existing, outdated
industrial facilities
Objective 5-2: Incorporate whenever
possible guidelines contained in the City’s
Crime Prevention Through Environmental
Design “Design Out Crime” Guidelines
and 9-2.5—Coordinate among law
enforcement, public agencies and social
service providers to establish homeless
services and programs that harmonize the
provision of such services with the safety,
cleanliness and quality-of-life concerns of
the growing downtown residential
community, visitor and tourism industry
and myriad commercial and
manufacturing businesses.
Create a Historic Building Advocacy
office to revitalize Downtown’s history
districts and other historic structures at
and above street level.
Establish a fund for small business loans
to allow industries to update their plants
and equipment.
Support the temporary use of long-term
underutilized land for parks and

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Table A2 (Continued): 35 Community Land Use Plans
No. Plan Area Expressed Pollution Ideas Expressed Cleanup Processes Brownfield Sites
Brownfield
Language
the overall image of LA to
the world in years to come.
community gardens.
Convention Center/Arena: Establish on-
going, community-based programs to
address issues of graffiti, litter, crime and
beautification.
Grand Avenue Cultural Corridor”:
Establish a BID or local organization that
will maintain streets and sidewalks for
benefit of both property owners and
visitors.
7
Central City
North
CRA Chinatown Project
area was created in 1980 to
address the need for
affordable housing for the
area’s senior citizens and to
develop public parking to
assist the ailing retail
businesses.
South Industrial, The
Alameda Corridor
terminates in this area and
will serve to connect the
Ports of Los Angeles and
Long Beach with downtown
Los Angeles.
Issues, Commercial:
Continued decline of the
Chinatown commercial
community due to
businesses relocating to
other areas of Southern
California.
Issues, Industrial: Outdated
warehouse and industrial
facilities that can no longer
accommodate modern
technology.
Major Opportunity Sites,
Issues: Costs to remove
existing hazardous wastes
and make the site suitable
for human habitation.
Opportunities, Commercial: The CRA’s
establishment of the Chinatown
Redevelopment Project Area which
provides low interest loans and grants to
businesses in the community.
Opportunities, Industrial: The
establishment of the Alameda East
Redevelopment Area by the CRA in order
to address the blighted conditions of some
of the industrial areas.
Land Use, Residential, Objective 1-1:
Program, 1-1.3, The Residential
Rehabilitation Loan Program, the
Homeowner’s Encouragement Loan
Program (HELP)—provides rehabilitation
loans to owners of small residential
buildings to correct code violations—and
the Neighborhood Preservation Program
(provides financial resources to
rehabilitate single and multi-family
homes (including rental housing).
North Industrial, This area
is the site of the large
Cornfield/Bullring site
formerly a Southern
Pacific Railroad yard.
Special Boundaries,
Cornfield/Bullring Site:
Designated as a major
opportunity site. Due to
the size of the property
and its location adjacent to
Downtown Los Angeles
and Union Station, the
development of this
property could have a
significant impact on land
development within the
broader Central City
community.
Special Boundaries,
Alameda District Specific
Plan: Approximately 70
acres in size and consists
of two components: the
52-acre Union Station
property and the 18-acre
United States Postal
Service Terminal Annex
property.
Hazardous
wastes, outdated
facilities, blighted
conditions,
rehabilitation,
deterioration

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Table A2 (Continued): 35 Community Land Use Plans
No. Plan Area Expressed Pollution Ideas Expressed Cleanup Processes Brownfield Sites
Brownfield
Language
Land Use, Residential:
Deteriorated housing stock
8
Chatsworth -
Porter Ranch
To address noise and air
quality impacts and the
potential for a diminished
quality of life experienced
by residents and others as a
result of future build-out
permitted under the 1974
District Plan.
Conditions of approval shall
prohibit smoke stacks, metal
plating, toxic and noxious
industrial uses, and any new
retail commercial uses
within these zone
classifications.

The Plan encourages the rehabilitation
and/or rebuilding of deteriorated single-
family areas for the same use. Single-
family housing should be made available
to all persons regardless of social,
economic, and ethnic backgrounds.
Jobs/Housing Relationship: An equal
relationship between jobs and housing
should be encouraged through
revitalization of the Devonshire/Topanga
Corridor, implementation of the Porter
Ranch Specific Plan, implementation of
floor area ratio limitations, and minor
modification to exceed the industrial floor
area ratio limitations.
Private participation should:
Sponsoring clean-up and beautification
programs to improve the general
environment
Developing or remodeling shopping
facilities and multiple-residential uses
incorporating an appropriate theme such
as Spanish Colonial
None Rehabilitation
and deterioration
of housing,
revitalization of
commercial/indus
trial areas,
cleanup and
beautification,
remodeling of
existing shopping
facilities
9
Encino -
Tarzana
Residential: Undeveloped or
underdeveloped land
Industrial: Attract desirable
(“clean”) industrial uses,
thus generating less harmful
pollutants and lower noise
levels.
Availability of sites planned
for job producing uses that
improve the economic and
physical condition of the
area.
Industrial: GOAL 3 Provide
land of sufficient size for
expansion of low intensity
non-toxic producing
Residential: The Homeowner’s
Encouragement Loan Program (HELP),
administered by the City’s Housing
Preservation and Production Department,
provides rehabilitation loans to owners of
small residential buildings (one to four
units) to correct code violation.
The Residential Rehabilitation Loan
Program, administered by the Community
Redevelopment Agency (CRA), makes
funds available for the rehabilitation of
lower-income multifamily rental housing.
The program is partially funded by the
U.S. Department of Housing and Urban
Development (HUD) and requires
matching funds from a private lender with
None Underdeveloped,
harmful, toxic
pollutants from
industry,
environmental
impacts, noxious
commercial
products, land
cleanup, illegal
activity

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Table A2 (Continued): 35 Community Land Use Plans
No. Plan Area Expressed Pollution Ideas Expressed Cleanup Processes Brownfield Sites
Brownfield
Language
industrial uses which create
employment opportunities
and have minimal adverse
impacts on adjacent
residential uses.
Objective 3-1 To provide
for existing and future
industrial uses which
contribute job opportunities
for residents and which
minimize environmental
and visual impacts to the
community.
Objective 3-2 To assure
mitigation of potential
negative impacts generated
by industrial uses when they
are located in proximity to
residential neighborhoods,
the Plan proposes design
guidelines for new
industrial uses when so
located.

CRA as a last resort.
Commercial Policy 2-2.2 Require
screening of open storage and auto repair
uses, and prohibit storage of automobile
parts and other noxious commercial
related products in front of commercial
development, exposed to the street.
Restrict new industrial uses located
adjacent to a residential neighborhood to
uses first permitted in the CM zone.
Recreation and Parks: Coordinate with the
Department of Recreation and Parks and
the Police Department to insure adequate
police patrols and “defensible space”,
where feasible, in the design of recreation
and park facilities.
Promote the supervision of park activities
and enforcement of codes restricting
illegal activity.
Pursue resources to clean up land that
could be used for public recreation safely.
10
Granada Hills -
Knollwood
The Plan encourages the
rehabilitation and/or
rebuilding of deteriorated
single family areas for the
same use.
Private Participation: The establishment
of a community-wide revitalization and
beautification committee. This committee
would inventory and identify areas that
are in need of cleanup, repair and
improvement, and would investigate
means available to remedy these areas.
None Deteriorated
structures,
rehabilitation,
revitalization,
cleanup
11 Harbor Gateway
Mentions specific sites: The
Martin Marietta
Technologies Inc.,
International Metals, and
Ascot Raceway.
Residential: Need to
preserve and rehabilitate
single-family housing in
established neighborhoods.
Commercial: Improve the
Possibility for redevelopment of large
sites which may provide locations for
community facilities in the future.
Industrial: Oil wells should be landscaped
and maintained in an attractive condition,
especially where adjacent to residential
uses.
Wherever possible, industrial uses should
be concentrated in industrial parks.
To maintain existing housing and upgrade
None, but mentions other
specific sites (Martin
Marietta, International
Metals, and Ascot
Raceway)
The International Metals
Division (ILM) property
is a vacant 67 acre heavy
industrial site, on the
southeast corner of 190th
Large vacant,
former industrial
sites,
redevelopment,
rehabilitate
housing,
hazardous waste
contamination in
industrial areas,
commercial

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Table A2 (Continued): 35 Community Land Use Plans
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Brownfield
Language
function, design and
economic vitality of the
commercial corridors.
Unsightliness of new
construction due to the lack
of landscaping, and
architectural character.
Existing commercial areas
need revitalization.
Encourage inclusion of
environmentally sensitive
industrial uses within the
industrial areas.
For industrially planned
areas, cost to mitigate any
hazardous waste
contamination.
Redevelopment of large
industrial zoned sites.
Availability of large sites
for reuse or development
which are planned for job
producing uses that improve
the economic and physical
condition of the area.
deteriorating homes, the following actions
should be taken by responsible agencies
Federal rehabilitation programs such as
mortgage insurance and interest subsidies.
Private Participation: Citizen groups are
encouraged to undertake private actions
for Community improvement, such as
sponsoring clean-up and beautification
programs.

Street and Western
Avenue. The site was
formerly operated as a
titanium and aluminum
production facility but
ceased operation in
August 1992. The owner
of the site is proposing to
build a large retail phased
development in the future.
The former Ascot
Raceway site located on
the southeast corner of
182
nd
Street and Vermont
Avenue consists of 325
acres of vacant land
designated for heavy
industry, and is currently
not in use. To date, no
plans have been made to
redevelop the site.
revitalization,
active oil wells
12 Hollywood
Deteriorated single-family
housing
Recreation sites and
facilities should be
upgraded through site
improvements,
rehabilitation and reuse of
sound structures, and
replacement of obsolete
structures, as funds become
available.
Participation is desired in
the CRA Project Area by as
many residential and
commercial owners and
tenants as possible.
Certain uses are considered
Hollywood Redevelopment Plan
(Pursuant to the purposes of the
California Community Redevelopment
Law):
By protecting and promoting sound
development and redevelopment of
blighted areas and the general welfare of
the citizens of the City by remedying such
injurious conditions through the
employment of appropriate means.
Housing Incentives, “CRA Board may
authorize new housing to be developed
with more units per acre than otherwise
permitted…”
Private sponsorship of clean-up and
beautification programs
“Encourage the involvement and
None Rehabilitation of
deteriorated
residential
structures,
redevelopment,
obsolete
structures, blight,
improper
utilization, reuse,
cleanup and
beautification
programs,
revitalization,
noxious industrial
use, prohibited
uses (automotive
yards and small

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Brownfield
Language
harmful and are, therefore,
prohibited:
Automotive Yards. Any
automobile dismantling
yard or automotive repair
use, as defined in Section
12.03 of the Code, in
addition to any auto-related
uses involving automobile
hoists, which are not
conducted completely
within an enclosed building.
Small Assembly
Workshops.
No “extremely hazardous
substances” as listed in
Section 335 (Appendix A)
of Title 40 of the Code of
Federal Regulations shall be
used, sold or stored on the
site; and no “hazardous
materials,” as listed in
Article 9, Title 22 of the
California Health and
Safety Code, shall be
utilized on the site except
those associated with
normal household use.

participation of residents, business
persons, property owners, and community
organizations in the redevelopment of the
community.”
Promoting rehabilitation and restoration
guidelines and integrate public safety
concerns into planning efforts
Recognize, promote and support the
retention, restoration and appropriate
reuse of existing buildings, groupings of
buildings and other physical features
especially those having significant
historic and/or architectural value
If an owner-participant fails or refuses to
rehabilitate or develop his real property
pursuant to this Plan and a Participation
Agreement as defined herein, the real
property or any interest therein may be
acquired by the Agency and sold or leased
for rehabilitation or development in
accordance with this Plan.
Industrial uses” shall be of a low noise
and non-noxious nature, conform with the
goals and objectives of the Plan and
promote community revitalization.”
No new use or structure which by reason
of appearance, traffic, smoke, noise, odor,
or similar factors that would be
incompatible with the surrounding areas
or structures shall be permitted in the
Project Area
assembly shops
using hazardous
materials)
13
Mission Hills-
Panorama City-
North Hills
Residential: Deterioration of
the streetscape.
Lack of maintenance of
existing housing stock,
particularly rented multiple
family projects.
Industrial: Intrusion of
commercial uses within the
industrial base, and in
particular the industrial
properties south of the
Commercial: CRA assistance using
earthquake recovery funds allocated to the
community.
Continuing Public Utility, State, and
Local government incentive programs
which offer tax credits (Revitalization
Zone), technical assistance
Community Development Department),
employee hiring credits (Los Angeles
Revitalization Zone), and capital
generating assistance.
The General Motors
former assembly plant site
is to be redeveloped with
industrial uses and
commercial uses.
The General Motors (GM)
site located in the 8000
Block of Van Nuys
Boulevard is the most
significant opportunity
site in the Plan area. GM
Hazardous waste
contamination,
deterioration,
revitalization,
reuse,
Revitalization
Zone, physical
and aesthetic
upgrading,
negative impacts
from industrial

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Brownfield
Language
Panorama Regional Center
and north of the Southern
Pacific Railroad tracks.
Cost of mitigating any
hazardous waste
contamination.
Major Opportunity Sites:
Several areas are identified
as major opportunity sites,
including the former
General Motors assembly
plant site on Van Nuys
Boulevard (a City
brownfield site).
Development of Major Sites
of Opportunity: Panorama
Regional Center.
Development of shopping
areas to serve the
neighborhoods.
Ensure appropriate
transitions between
commercial (mixed use) and
adjoining uses, especially
residential. Some of these
properties currently have
commercial structures that
are 40 years old on them
and many appear to have
maximized their functional
usefulness due to age,
narrow lot widths, and lack
of continuity.
Earthquake Damage and
Preparedness: The
Community Redevelopment
Agency of the City of Los
Angeles (CRA), as directed
by the City Council in July
1994, established an
Earthquake Disaster
Assistance Program
Programs:
The City’s Neighborhood Preservation
Program
The City’s Homeowner’s Encouragement
Loan Program (HELP)
The City’s (federally-supported)
Residential Rehabilitation Loan Program
Commercial: Redevelopment of existing
commercial corridors and areas, and
conversion of existing structures to more
appropriate uses should result in the
physical and aesthetic upgrading of these
areas.
Objective 3-3 To assure mitigation of
potential negative impacts generated by
industrial uses when they are located in
proximity to residential neighborhoods,
the Plan proposes design guidelines for
new industrial uses when so located.
Industrial/Residential Interface
Areas, (Design Guidelines section)
Program: Restrict new industrial uses
located adjacent to a residential
neighborhood to uses first permitted in
the CM zone.
Recreation and Parks: 5-1.2 Protect
significant environmental resources from
environmental hazards.
Implementation of State and Federal
environmental laws and regulations such
as The California Environmental Quality
Act (CEQA), the National Environmental
Protection Act (NEPA), the Clean Air
Quality Act, and the Clean Water Quality
Act. Implementation of SCAG's and
SCAQMD's Regional Air Quality
Management Plan, and SCAG's Growth
Management Plan.
Encourage and assist economic
revitalization and reuse of older industrial
properties for industrial uses through
City, State, and Federal programs.
will retain about 27 acres
of the 100-acre site and
continue to operate its
vehicle testing facility.
Sixty-eight acres are to be
sold for development and
five acres will be reserved
for use as a Public
Facility. The 100 million
dollar development of
300,000 square feet of
commercial space and
500,000 square feet of
industrial space should
create more than 2,000
jobs within 5 years of its
completion. Cleared for
future development with a
combination of
commercial and industrial
uses.
The site previously owned
by GM on Van Nuys
Boulevard will continue to
have industrial uses and
will focus on newer
technologies such as
entertainment industry,
information system,
medical, and the
expanding garment
industry. Approximately
34 acres of that site is to
be retained for the new
industrial uses.
Industrial land use is a
valuable commodity that
must be maintained due to
the economic benefits and
the employment
opportunities generated.
use

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redevelopment plan. The
five-year Plan provides
disaster and recovery
assistance in helping the
community to rehabilitate
from the effects of the
January 1994 earthquake.
The Plan facilitates the
redevelopment of
properties; develops and
implements job
revitalization through job
creation, retention, and
training; and encourages
business attraction,
retention, and expansion.
The Plan requires that these
redevelopment activities be
consistent with the existing
community plan but does
not modify or broaden in
any way existing City
development and land use
controls.
Plan policy provides for the
development of single or
aggregated parcels for
mixed-use commercial and
residential development.
These structures would
normally incorporate retail
office, and/or parking on
lower floors and residential
units on upper floors. The
intent is to provide housing
in close proximity to jobs,
to reduce vehicular trips,
congestion, and air
pollution, to assure adequate
sites for housing, and to
stimulate pedestrian
oriented areas to enhance
Assist in the aggregation of smaller, older
sites to facilitate revitalization or reuse,
where appropriate.
Employment: Encourage and assist
economic revitalization and the reuse of
older industrial properties for industrial
uses through City, State and Federal
programs.

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the quality of life in the Plan
area.
14
North
Hollywood-
Valley Village
The main focus of the
redevelopment area is to
assist in the rebuilding of
structures damaged in the
January 17, 1994
earthquake. Additionally the
Los Angeles City Planning
Commission has approved
an expansion of the Laurel
Plaza Regional Shopping
Center.
Commercial: Improve the
function, design and
economic vitality of the
commercial corridors.
Unsightliness of newer
construction due to the lack
of landscaping, architectural
character and scale.
Industrial: To encourage the
inclusion of
environmentally sensitive
industrial uses within the
industrial areas.
Intrusion of commercial
uses within the industrial
base, and in particular those
properties fronting along the
Sherman Way industrial
corridor from Coldwater
Canyon to Clybourn
Avenue.
Cost to mitigate any
hazardous waste
contamination.
For industrially planned
areas, costs to remove
existing hazardous wastes.
The need to preserve and
rehabilitate historic areas
A building setback line along the railroad
rights-of-way should be initiated to aid in
the beautification of the community by
eliminating billboards and other unsightly
structures therein.
Private Participation: Citizen groups,
including the North Hollywood Chamber
of Commerce, are encouraged to
undertake private action in concert with
the CRA in its project area for community
improvements, such as:
Initiation by property owners and
merchants of programs to rehabilitate
commercial improvements
Sponsoring industrial and commercial
promotional programs to market new
sites.
Establishment of a development
corporation to channel private
development, interest and resources
towards the implementation of the
North Hollywood Center.
Plan the few remaining sites for major
development for needed job producing
uses that improve the economic and
physical condition of the community.
Designating land for industrial
development that can be used without
detriment to adjacent uses of other types
and imposing restrictions on the types of
and intensities of industrial uses necessary
to this purpose.
Expand manufacturing uses that generate
employment for the local work force.
Attract desirable ("clean") industrial uses,
thus generating less harmful pollutants
and lower noise levels.
...the plan proposes industrial uses in
areas where they will not adversely affect
surrounding development.
None Hazardous waste
contamination,
underutilization,
residential
rehabilitation,
underutilized
strip commercial
development

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with a sensitivity to the
character of the established
neighborhood.
Improving the function,
design and economic
vitality of the commercial
corridors.
…redesigning underutilized
strip commercial zoning to
more appropriate uses; and
improving the appearance
of commercial buildings
along the major arteries.
To improve the visual
environment of the
community and, in
particular, to strengthen and
enhance its image and
identity. To discourage the
distasteful array of signs
and billboards located along
the major arteries of the
community.
15
Northeast Los
Angeles
Freeway development has
contributed to degradation
of industrial and
commercial areas and has
divided former
neighborhoods and
communities
Early commercial buildings
need to be re-used for
revitalization (Preservation
and rehabilitation of older
structures)
El Sereno: Vacant industrial
sites and multiple
deleterious effects of the at-
grade railroad crossing
Need to revitalize existing
commercial strips and
conserve major open space
An Economic Development Element
focused on the revitalization and
redevelopment of commercial and
industrial areas
The development of locally-based, small
enterprises within the community, should
be encouraged as a vital part of the
strategy to revitalize neighborhoods
(training of local residents)
Coordination of public and private
resources engaged in economic
development activities.
Streamlining of regulations and, where
appropriate, the removal of regulatory
barriers/obstacles to economic
development programs.
Creation of appropriate incentive
programs designed to encourage business
development.
The former site of the
Franciscan Pottery Works.
Cypress Park is the site of
the largest railroad yard in
the City, the largely-
abandoned Taylor Yard,
and is the site of the
former Lawry’s California
Center, which was a major
regional destination for
dining and an
international destination
for tourist shopping.
In recent years, the area
has lost many of its major
employers but has
received considerable
interest by investors
because of the
Reuse,
revitalization,
rehabilitation of
structures, vacant
industrial sites,
soil
contamination,
underground
tanks, abandoned
and underutilized
sites,
deterioration,
obsolete
structures,
clouded titles,
illegal uses, toxic
contamination

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resources on steep hillsides
with limited access.
Unsightliness of and lack of
amenities and public access
to areas adjacent to the Los
Angeles River, Arroyo
Seco, and other flood
control channels.
Destruction and
deterioration of community
resources, including scenic
views and viewsheds, open
space, open space corridors,
and historic structures.
Deterioration of housing
stock
Improving the function,
design, and economic
vitality of commercial areas
Sign clutter
Fragmented land ownership
patterns or access problems
that limit use of industrially-
zoned land.
Cost of abating soil
contamination or
underground tanks prior to
expansion or redevelopment
of industrial sites.
Revitalizing commercial
and industrial development
sites with needed job
producing uses that improve
the economic and physical
condition
Commercial land need to be
revitalized in the face of the
challenges of competition
from neighboring cities,
changing demographics,
recent construction of a
haphazard plethora of mini-
Specific Plan along Colorado Boulevard
Highland Park
Residential: Clustering projects on
undeveloped or underdeveloped land.
Commercial: Support for efforts to
preserve and rehabilitate commercial
historic structures. Develop and
implement regulations and incentives to
reduce visual blight including open
storage and sign clutter adjacent to
residential neighborhoods and in
neighborhood-serving commercial areas.
Identifying areas with soil contamination
and underground storage tank problems
and promoting abatement programs.
Neighborhood Recovery Program
The City Planning Department should
continue to assist the City Housing
Department to identify vacant or
underutilized City owned properties that
have potential for development for
affordable housing. Redevelopment of
existing commercial strips and areas, and
conversion of existing structures to more
appropriate uses should result in the
physical and aesthetic upgrading of these
areas.
2-1.1 Consolidate commercial areas
through appropriate planning and zoning
actions to strengthen the economic base
and expand market opportunities.
Inventories should be developed and
maintained of uses located in areas
targeted for revitalization programs, such
as BIDs and the Local Area
Neighborhood Initiative Program, as well
as in areas regulated by CDOs, HPOZs,
PODs, or Specific plans.
3-3.1 Protect large rail yards and other
large industrially-planned parcels located
in predominantly industrial areas from
development by other uses that do not
opportunities for
redevelopment of the
Lawry’s site and the
Taylor Yard, which has
been largely abandoned
for railroad usage.

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malls along commercial
strips, and a proliferation of
large shopping centers and
malls in and near the Area.
Commercial areas are in
need of revitalization as
evidenced by high vacancy
rates and high turnover
among commercial tenants.
The principal reason for this
condition is the increasing
competition from shopping
malls and redeveloped
commercial areas in
neighboring cities.
Industrial: Northeast Los
Angeles has a long history
of industrial development
because of its central
location and proximity to
major transportation
facilities. Functional
obsolescence is common as
evidenced by the number of
abandoned, and
underutilized industrial
properties, with the largest
concentration near the Los
Angeles River and a
secondary concentration
along the rail line that
generally follows Main
Street and Valley
Boulevard. Redevelopment
of these areas is problematic
because of antiquated
structures, poorly
configured or fragmented
land holdings, inadequate
infrastructure, and toxic
contaminations. Some of the
sites, notably the Taylor
support the industrial and economic base
of the city and the community.
Open Space: A master plan should be
prepared for the Taylor Yard area to
include protection for public open
space/recreational activity areas near the
Los Angeles River and linkages to the
Arroyo Seco.
Police Protection: Promote the
establishment of Police facilities which
provide police protection at a
neighborhood level.
16-1.1 Establish a clearing house for
community resources to identify agencies
and organizations engaged in economic
development. (III-35)
Program: Utilize the outreach programs in
the Planning Department and Council
Offices in compiling and reviewing such
a resource list.
16-1.2 Strengthen contacts and
cooperation between public and private
sector organizations engaged in economic
development activities within the
community.
Program: Determine an appropriate
agency or organization to initiate a
regular schedule of meetings and
networking activities between public and
private interests in targeted
neighborhoods and communities.
16-1.3 Encourage the improvement of
infrastructure facilities to meet existing
community needs and assist in the
revitalization of blighted areas.
Program: Continue implementation of the
City’s Capital Improvement Program.
16-2.1 Identify and amend or remove
local ordinances that are duplicative
and/or do not offer protection to the
community from hazards and nuisances
while impeding appropriate economic

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Yard, offer enormous
potential for redevelopment.
To protect and enhance
historic and architectural
resources in commercial
areas in a manner that will
encourage revitalization and
investment in these areas.
Lincoln Heights and
Montecito Heights:
...characterized by
incompatibilities among
land uses and some major
pockets of deterioration.
These present major
challenges to policy-makers
to direct resources in a
manner that promotes
revitalization and yet
preserves the historic
resources that give the area
so much of its
distinctive character.
The North Broadway
commercial corridor has
suffered from high vacancy
rates and rapid turnover.
The large area centered on
the County-US Medical
Center and US Health
Science Campus is in the
midst of redevelopment
owing to the impending
replacement of County
Hospital and other obsolete
or seismically unsafe
structures.
An active artist-in-residence
community principally
housed in the historic
Eastside Brewery complex
offers an unparalleled
development.
Program: Continue implementation of a
regular review of local ordinances and
their effectiveness in protecting health,
safety, and welfare.
Code Enforcement: Promote more
effective enforcement of all applicable
government codes regulating the built
environment and environmental quality.
Assist enforcement agencies in increasing
community awareness of existing and
proposed building, housing, and zoning
regulations.
Encourage greater inter-agency
cooperation in developing zone code
amendments and other zoning tools to
better define roles and responsibilities for
review and enforcement.
Encourage cooperation in updating and
disseminating zoning maps and databases
in a timely manner among regulatory
agencies to ensure that regulations are
applied more consistently.
Provide inter-departmental training
opportunities on an on-going basis to
respond to changing enforcement issues.
Parks and Open Space: Coordinate among
the Recreation and Parks Department, the
Police
Department, the City Attorney’s Office,
and other relevant agencies to ensure
maximum involvement of local youth in
park upkeep and program development.
Pursue resources to reclaim vacant land
that could be used for public recreation
safely.
Schools: Consider large vacant or
underutilized properties as a first
alternative to accommodate the demand
for new schools, prior to the displacement
of existing uses.
Support and encourage community-based

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Language
opportunity in Northeast
Los Angeles for
development of a
Commercial and Artcraft
District.
Residential development on
the steep hillsides: These
areas are also burdened by
obsolete subdivisions and
clouded titles.
crime prevention efforts (such as
Neighborhood Watch), through regular
interaction and coordination with existing
community-based policing, foot and
bicycle patrols, watch programs,
assistance in the formation of new
neighborhood watch groups, and regular
communication with neighborhoods and
civic organizations.
Identify underutilized or abandoned
industrial properties that can be more
appropriately re-used or revitalized for
non-industrial purposes through adaptive
re-use or other measures.
Assist in the aggregation of smaller, older
sites to facilitate revitalization or re-use,
where appropriate. Design Guidelines:
Building materials shall be employed to
provide relief to bland untreated portions
of exterior building facades and minimize
opportunities for graffiti.
16 Northridge
Deterioration of the
streetscape.
Lack of adequate design
standards and code
enforcement along
commercial corridors.
Unsightliness of new
construction due to the lack
of landscaping, architectural
character and scale.
Improving the function,
design and economic
vitality of the commercial
corridors.
Planning the remaining
commercial and industrial
opportunity sites for needed
job producing uses that
improve the economic and
physical condition of the
Northridge area.
Industrial: Ensure that there is sufficient
land for a variety of industrial uses with
maximum employment opportunities for
the community’s workforce which are
safe for the environment and which have
minimal adverse impacts on adjacent
uses.
Open Space: Protect significant
environmental resources from
environmental hazards.
Industrial: Encourage and assist economic
revitalization and reuse of older industrial
properties for industrial uses through
City, State, and Federal programs.
Assist in the aggregation of smaller, older
sites to facilitate revitalization or reuse,
where appropriate.
Consider factors such as neighborhood
character and identity, compatibility of
land uses, impacts on livability, impacts
on services and public facilities, and
Deterioration of
streetscape,
vacancy,
abandoned
business areas,
revitalization,
structural
rehabilitation,
underdeveloped,
reuse of historic
structures, lack of
code
enforcement,
abandoned earth-
quake damaged
structures

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Residential: In a few areas,
vacant land has been left
undeveloped or
underdeveloped, creating
opportunity areas that
require sensitive
consideration so that their
development becomes an
asset to the community.
Other areas have
experienced a slow decline
and offer opportunities to
rehabilitate the housing
stock
Mixed-use structures would
provide housing in close
proximity to jobs and
shopping, to reduce
vehicular trips, to reduce
congestion and air pollution,
to assure adequate sites for
housing, and to stimulate
pedestrian-oriented areas to
enhance the quality of life
in the Plan area.
To enhance the appearance
of commercial districts.
Employment: Encourage
and assist economic
revitalization and the reuse
of older industrial properties
for industrial uses through
City, State and Federal
programs.
Earthquake damage: The
1994 Northridge earthquake
devastated portions of the
Northridge area. (The
magnitude 6.8 (Richter
Scale) earthquake caused
extensive and widespread
property damage to
impacts on traffic levels, and
environmental impacts when changes in
residential densities are proposed.
Program: HELP, provides rehabilitation
loans to owners of small residential
buildings (one to four units) to correct
code violations and assist handicapped
homeowners.
Require that any development minimize
grading to reduce the effects on any
environmentally sensitive areas.
Compliance with the CEQA.
There is also a need to focus attention on
rehabilitation and rejuvenation of
abandoned business areas, and restoration
of formerly vibrant commercial uses.
Fast food restaurants and mini-malls
should be discouraged.
A BID should be strongly considered for
the purpose of improving and upgrading
Reseda Boulevard generally between
Roscoe Boulevard and Lassen Street. The
BID should take advantage of the
proximity to Cal State Northridge and
coordinate the efforts of business and
property owners. Improvements resulting
from a successful BID may include
landscaping, signage, street sweeping,
additional parking, security patrols, new
building facades, sidewalk cafes and
pedestrian activity, and undergrounding
of utilities.
Improve the visual appearance of
commercial districts through better
control of signage, including billboard
proliferation.
Program: Increased enforcement of the
Citywide sign ordinance.
Program: Implement conformance with
Design Guidelines of the Plan.
3-2.1 Industrially planned parcels located
in predominantly industrial areas should

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residences, businesses,
nonprofit organizations,
public facilities, and
infrastructure including
freeways, water lines,
power lines, and natural gas
lines.) Recovery and
rebuilding efforts are taking
place following the
Northridge earthquake and
will continue over the next
several years. The City’s
Building and Safety
Department regulates the
demolition of buildings
damaged by the earthquake
that have been abandoned
by property owners, and
determined to be a public
nuisance.
The Plan facilitates the
redevelopment of
properties; develops and
implements job
revitalization through job
creation, retention, and
training; and encourages
business attraction,
retention, and expansion.
The Plan requires that these
redevelopment activities be
consistent with the existing
community plan but does
not modify or broaden in
any way existing City
development and land use
controls.
be protected from development by other
uses which do not support the industrial
economic base of the City and the
community.
Program: The Community Plan and City's
Planning and Zoning Code
The City should utilize land use, zoning,
and financial incentives to preserve the
economic viability of Northridge's
existing industries.
The Parthenia industrial corridor between
Tampa and Lindley is particularly
unsightly and in need of visual upgrading.
3-1.3 Adequate mitigation should be
achieved through design treatments and
compliance with environmental protection
standards, for industrial uses where they
adjoin residential neighborhoods and
commercial uses.
Program: Utilize City historic properties
restoration programs which provide
funding for renovating and/or reusing
historic structures.
Support and encourage community-based
crime prevention efforts such as
Neighborhood Watch Programs.
Assist private owners of historic
properties/resources to maintain and/or
enhance their properties in a manner that
will conserve the integrity of such
resources in the best possible condition.
New lighting systems will be designed to
minimize glare and “light trespass”.
17
Palms-Mar
Vista-Del Rey
Need to promote
rehabilitation of residential
areas
Unsightly strip commercial
with poor visual identity,
Fluid from dumping grounds for dredged
spoils or its rehabilitative processes shall
not degrade or pollute fresh water
marshes, streams or other natural
processes downstream in the Ballona
Residential
rehabilitation,
revitalization,
adaptive reuse,
harmful

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lack of parking and
convenient access and
oriented to pass-through
traffic rather than
neighborhood and
pedestrian-oriented.
Unsightliness of new
construction such as mini-
malls due to the lack of
landscaping, architectural
character and parking.
Physical improvement of
commercial buildings by
incorporating appropriate
design criteria and
landscaping which promote
a healthy retail
environment.
Industrial: Protection of
residents from possible
detrimental effects of
industrial activities.
Coastal: ...where feasible, to
restore and enhance visual
quality in visually degraded
areas.
Marine and Land
Resources: Los Angeles
County Flood Control
District and/or Los Angeles
City Engineer should
approve a feasible design to
reduce harmful pollutants
from storm drain waters
prior to these waters
entering the marina.
Stormwater runoff into
channels
Wetland habitat disturbance
Obstruction of distinctive
visual resources (e.g.,
bluffs, wetlands)
Wetlands.
Noise and dust form development shall be
managed in such a manner so as not to
disturb the natural processes.
Industrial practices: Wherever feasible,
modern energy conservation methods
should be studied and employed.
Encourage economic revitalization and
reuse of older industrial properties for
industrial uses through available City,
State and Federal incentive programs.
Assist in the aggregation of smaller, older
sites to facilitate revitalization or reuse,
where appropriate.
Assembly of small parcels to create
industrial parks is encouraged.
Creation of Habitat Management Area
near Ballona Wetlands
Commercial: Public Utility, State and
Local government incentive programs
which
offer tax credits (Revitalization Zone),
technical assistance for BIDs
Neighborhood shopping centers and
mixed use developments which would
encourage walking and reduce traffic
congestion and air pollution.
Make funds available through the
neighborhood Preservation Program
administered by the City’s Housing
Department and the Housing Authority to
rehabilitate housing.
Program: Provide loans to owners of
small residential buildings (one to four
units) to correct code violations through
the HELP program.
Assist businesses in obtaining technical
assistance for BID and other programs
from the Community Development
Department (CDD)
Industrial: Designate and preserve lands
for the continuation of existing industry
pollutants (in
stormwater
runoff), vacant
land

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Adverse impacts of urban
development on
environmentally sensitive
habitat resources
No billboards or off-
premise commercial signs
will be permitted.
and development of new industrial parks,
research and development uses, light
manufacturing and similar uses which
provide employment opportunities.
8-2.1 Support and encourage community
based crime prevention efforts (such as
Neighborhood Watch) through regular
interaction and coordination with existing
community based policing, foot and
bicycle patrols, watch programs and
regular communication with
neighborhood and civic organizations.
Encourage the preservation, maintenance,
enhancement and reuse of existing
historic buildings and the restoration of
original facades.
To encourage private owners of historic
properties/resources to conserve the
integrity of such resources.
Future development must be based on
thorough site specific geologic and soils
studies including specific geotechnical
studies related to mitigation of
liquefaction and lateral spreading.
Encourage continuing efforts by County,
State and Federal agencies to acquire
vacant land for publicly owned open
space.
Provide for the supervision of park
activities and promote enforcement of
codes restricting illegal activities.
Pursue resources to clean up and activate
land that can be used for public
recreation.
New lighting systems will be designed to
minimize glare and “light trespass”.
18
Reseda -West
Van Nuys
Residential: Deterioration of
the streetscape.
Lack of maintenance of
existing housing stock, both
single and multiple family
dwellings.
Coordinate with Chamber of Commerce
and Los Angeles City Clerk’s office to
encourage the establishment of BIDs to
revitalize commercial areas by promoting
streetscape improvements, maintenance
and security. The area which could
Mentions City Brownfield
site: Industrial Office Park
(55 Acre) The
revitalization of a 55 acre
industrial sector will
convert the vacant site
Hazardous waste
contamination,
commercial
revitalization,
land cleanup,
harmful

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Cost to mitigate any
hazardous waste
contamination at old
industrial sites.
Commercial: The
commercial land use
policies reflect the need to
locate new commercial uses
in the community to
facilitate convenient
shopping and easy access to
professional services.
Redevelopment of existing
commercial corridors and
areas, and conversion of
existing structures to more
appropriate uses should
result in the physical and
aesthetic upgrading of these
areas.
Planning the remaining
commercial and industrial
development opportunity
sites for needed job
producing uses that
improves the economic and
physical condition
In spite of its usefulness as a
buffer mechanism to
maintain the identity of
single family residential
areas, the term “multiple
family” often conjures up
images of densely populated
areas with high crime
activity. In reality, only a
few Specific areas have
been identified by the
community residents where
crime rates are perceived to
be related to land use
densities.
potentially benefit from BIDs is the
Reseda CBD.
Program: Implementation of the Van
Nuys Airport Master Plan regarding noise
mitigation measures.
Mixed use commercial and residential
development. These structures would
normally incorporate retail office, and/or
parking on lower floors and residential
units on upper floors. The intent is to
provide housing in close proximity to
jobs, to reduce vehicular trips, congestion,
and air pollution, to assure adequate sites
for housing, and to stimulate pedestrian
oriented areas to enhance the quality of
life in the Plan area.
Objective 3-1 To provide for existing and
future industrial uses which contribute job
opportunities for residents and which
minimize environmental and visual
impacts to the community.
Policies 3-1.1 Designate lands for the
continuation of existing industry and
development of new industrial parks,
research and development uses, light
manufacturing, and similar uses which
provide employment opportunities.
3-1.2 Adequate compatibility should be
achieved through design treatments,
compliance with environmental protection
standards and health and safety
requirements for industrial uses where
they adjoin residential neighborhoods and
commercial uses.
Policies 3-3.1 Encourage new industrial
uses adjacent to residential neighborhoods
to the extent feasible.
Program: New development of industrial
uses located adjacent to residential
neighborhoods shall comply with the
Industrial/Residential design guidelines
Program: Restrict new industrial uses
into a business park, the
Marquardt Industrial
Office Park, immediately
west of the airport. The
$24.5 million project
contains approximately
700,000 square feet of
industrial buildings, to be
constructed over the next
three years. The business
park is projected to
generate 500 to 1,000
employees.
pollutants

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1-1.5 Protect quality of the
residential environment
west of the Van Nuys
Airport through attention to
noise and traffic.
Industrial impacts on the
environment and on
neighboring uses
Pursue resources to clean up
and activate land that could
be used for
public recreation.
Crime
located adjacent to a residential
neighborhood to uses first permitted in
the CM zone.
8-2.1 Support and encourage community-
based crime prevention efforts (such as
Neighborhood Watch), through regular
interaction and coordination with existing
community-based policing, foot and
bicycle patrols, watch programs, and
regular communication with
neighborhood and civic organizations.
Continue Public Utility, State, and Local
government incentive programs which
offer tax credits (Revitalization Zone),
technical assistance (Community
Development Department), employee
hiring credits (Los Angeles Revitalization
Zone), and capital generating assistance.
Designation of the CBD as a CRA project
area, utilizing earthquake recovery funds
allocated to the
community for commercial facade and
signage improvement.
Los Angeles Neighborhood Initiative
(LANI) project area, BID, POD, Specific
Plan
Industrial: Encourage and maintain
industrial/manufacturing uses which
generate employment for the local work
force.
Availability of sites planned for job
producing uses that improve the economic
and physical condition of the area.
Encourage continued use of Van Nuys
Airport as a hub of general aviation
activities in the Southern California area,
in conjunction with the surrounding
neighbors’ environmental concerns, such
as related noise and traffic.
Attract desirable (“clean”) industrial uses,
thus generating less harmful pollutants
and lower noise levels.

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Availability of “incubator” type business
that allow small business owners to
relocate to larger sites as business
improves.
City’s Housing Preservation and
Production Department provides
rehabilitation loans to owners of small
buildings
(one to four units) to correct code
violations.
Program: The Residential Rehabilitation
Loan Program administered by the CRA
makes funds available for the
rehabilitation of low income multi-family
rental housing. The program is partially
funded by the U.S. Department of
Housing and Urban Development (HUD)
and requires matching funds from a
private lender
Coordinate with representatives of the
Police Department to institute “Crime
Prevention Through Environmental
Design (CPTED) strategies
Maintain and preserve the character and
integrity of existing neighborhoods and
encourage participation in self-help
preventive maintenance to promote
neighborhood conservation,
beautification, and rehabilitation.
Industrial: Encourage and assist economic
revitalization and reuse of older industrial
properties for industrial uses through
City, State, and Federal programs.
Assist in the aggregation of smaller, older
sites to facilitate revitalization or reuse,
where appropriate.
Commercial: Encourage the establishment
of BIDS to revitalize and improve
commercial areas.
Coordinate with the Los Angeles City
Clerk’s office and the Chamber of
Commerce to disseminate BID guidelines

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to the business community.
Employment: Encourage businesses to
participate in job training programs for
local residents.
Develop employment opportunities for a
wide range of jobs, skills, and wages.
Encourage and assist economic
revitalization and the reuse of older
industrial properties for industrial uses
through City, State and Federal programs.
Design Guidelines: In order to mitigate
potential negative impacts generated by
industrial uses when they are located
adjacent to residentially zoned or
developed neighborhoods, new
development of industrial uses shall
incorporate specific interface area
guidelines
19
San Pedro Industrial pollution from
petroleum and marine
supply uses
Coastal pollution, including
potential spillage from
offshore oil drilling
activities
Need to improve the visual
environment of multiple
family dwellings through
the development of
appropriate design criteria
and landscaping.
Lack of maintenance of
older existing housing stock
particularly rental multiple
family dwellings.
Poor appearance and
maintenance of the Rancho
San Pedro Public Housing
facilities.
Poor physical condition of
older commercial areas and
proliferation of unsightly
San Pedro Local Coastal Program
Specific Plan
CRA Beacon Street Project: provides a
revitalized core of downtown San Pedro
and the Regional Commercial Center with
a hotel, office building, housing, theaters
and improved infrastructure.
CRA Pacific Avenue Corridor: main goal
is to improve the economic vitality and
appearance of the Downtown San
Pedro area including the Pacific Avenue
Corridor, would include significant
sections of the Community Commercial
and Regional Commercial Centers and
Mixed Use Boulevards in the Community
Plan Area. Community Development
Department (CDD) Harbor Enterprise
Zone (includes hiring tax credits, sales
and
use tax credits, business expense
deductions, net interest deduction for
lenders, and provisions to allow net
operating loss carryover)
Homeowner programs including loans for
Open Space includes
Friendship Park (a
brownfield site). To the
north are the Navy Fuel
Depot and Harbor Park (a
brownfield site) which are
proposed to be preserved
in their present open state.
The Osgood/Farley
Battery site, Lookout
Point site, and the Korean
Bell site shall be
designated as public view
sites and any development
which obstructs views
from these sites shall be
prohibited.
Program: That the existing
Pennzoil/GATX terminal
complex, GATX annex,
and Union Oil deepwater
marine terminal be
relocated to Terminal
Island or its proposed
Blight,
revitalization,
redevelopment,
hazardous
chemical
compounds

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facades.
Need for developing an
integrated relationship with
the Port of Los Angeles to
improve the vitality of
downtown San Pedro,
World Cruise facilities, and
Ports O’ Call.
Air pollution
Coastal view obstruction
Port railroad and traffic-
related pollution
Large non-conforming uses
that may be detrimental to
adjacent uses
To improve the physical
design, condition and
security of all public
housing units.
1-8.1 To rehabilitate and
modernize public housing
projects to conform
with all applicable health
and safety codes.
Decline of the downtown
area (economic and
physical)
Deterioration of historic
sites and structures
19-3.1 Facilities used for
the storage, processing, or
distribution of potentially
hazardous petroleum or
chemical compounds,
located in the Cabrillo
Beach, East and West
Channels or West Bank
portions of the main
Channel should be phased
out and relocated at
Terminal Island or its
proposed southerly
maintenance and purchase.
Potential for residential and mixed use
projects along transit and commercial
corridors.
CRA is studying Downtown San Pedro
and Pacific Avenue for the establishment
of Redevelopment Project Area
Industrial land use is a valuable
commodity that must be maintained due
to the economic benefits and the
employment opportunities generated.
Uses in these areas include those related
to the petroleum and marine industries,
and smaller firms such as plumbing and
heating companies.
Objective 3-1 To provide for existing and
future industrial uses which contribute job
opportunities for residents and which
minimize environmental and visual
impacts to the community.
Policies
3-1.1 Designate lands for the continuation
of existing industry and development of
new industrial parks, research and
development uses, light manufacturing,
and similar uses which provide
employment opportunities.
3-1.2 Define and separate new and/or
expanded industrial uses from other uses
by freeways, flood control channels,
highways and other physical barriers.
3-1.3 Require a transition of industrial
uses, from intensive uses to less intensive
uses, in those areas in proximity to
residential neighborhoods.
Objective 3-3 To improve the aesthetic
quality and design of industrial areas,
eliminate blight and detrimental visual
impact on residential areas, and establish
a stable environment for quality industrial
development.
5-1.2 Protect significant environmental
southerly extension.
Program: AB283 Zoning
Ordinance No. 165,406
addresses the uses
permitted in the Port and
implements this policy.

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extension, with no further
expansion of existing
facilities or the development
of new facilities permitted.

resources from environmental hazards.
Program: Implementation of State and
Federal environmental laws and
regulations such as CEQA, NEPA, the
Clean Air Quality Act, and the Clean
Water Quality Act.
Program: Implementation of SCAG's and
SCAQMD's Regional Air Quality
Management Plan, and SCAG's Growth
Management Plan.
Program: Implement the State mandated
Congestion Management Program
designed to reduce traffic congestion and
to improve air quality.
Program: Offshore oil drilling be strictly
controlled in the immediate area off San
Pedro so as to safeguard against oil
spillage, prevent interference with
shipping lanes, preserve the scenic value
of the coastline, and protect ecologically
important areas and designated wildlife
refuges.
Program: Any new storm drain system
shall not discharge in any way that could
cause the erosion of coastal bluffs. Any
new storm drain system shall minimize
impacts on tide pools and any other
Encourage the retention of passive and
visual open space which provides a
balance to the urban development of the
community.
Although not a part of the Port’s Plan
area, the San Pedro Plan makes the
following recommendations for
consideration by the Harbor Commission,
State Coastal Commission, and other
decision making bodies having
jurisdiction over the Port.
Goal 19: Coordinate the development of
the Port of Los Angeles with surrounding
communities to improve the efficiency
and operational capabilities of the port to

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better serve the economic needs of Los
Angeles and the region, while minimizing
adverse environmental impacts to
neighboring communities from Port-
related activities.
19-2.1 The underutilized railroad lines in
the West Channel/Cabrillo Beach and
West Bank areas of the Port should be
phased out upon relocation of the dry and
liquid bulk transfer and storage facilities.
Program: Various State and Federal laws,
including CEQA and NEPA provide for
inter-agency review of plans for new
projects adjacent to other communities.
19-2.3 The port should commit resources
toward providing public amenities
(commercial, recreational and service
oriented) that will benefit the San Pedro
community, consistent with the State
Tidelands Grant, the California Coastal
Act of 1976 and the City Charter.
Objective 19-3 To seek the relocation of
potentially hazardous and/or incompatible
land uses away from the adjacent
commercial and residential areas of San
Pedro.
Policies
Commercial: Promote the Harbor
Enterprise Zone’s incentives for new
businesses
Explore the establishment of a BID for
the visual improvement of the commercial
corridors.
Industrial: There are few large, vacant
parcels in the community. Most changes
are likely to occur from modification or
adaptive reuse of buildings. The majority
of new development is expected to be
small scale, unless parcels are assembled
and existing structures demolished.
Residential: The Neighborhood
Preservation Program, HELP, and

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Residential Rehabilitation Loan Programs
Eliminate incompatible and non-
conforming uses from existing residential
neighborhoods, to preserve the residential
character of these neighborhoods and
protect residents from adverse
environmental impacts caused by such
uses.
1-6.1 The enlargement of nonconforming
incompatible commercial and industrial
uses within areas designated on the Plan
map for residential land shall be
prohibited, and action shall be taken
toward their removal on a scheduled basis
in conformance with section 12.23 of the
Municipal Code.
1-6.2 Compatible non-conforming uses
that are a recognized part of a
neighborhood (e.g., “Mom and Pop”
neighborhood stores), should be allowed
to continue in accordance with applicable
provisions of the Municipal Code.
Program: The provisions of Section 12.23
of the Municipal Code allow a Zoning
Administrator to authorized the continued
maintenance of such uses, if they were
legally established and are reasonably
compatible and not detrimental to
adjacent properties and the public
welfare.
Redevelopment through adaptive reuse
and mixed use
Redevelopment of existing commercial
corridors
An Advisory Committee has been
appointed by Council District Fifteen to
guide the redevelopment planning.
Revitalize and strengthen the Downtown
San Pedro Commercial area as the
historic commercial center of the
community, to provide shopping, civic,
social, and recreational activities.

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Program: The Plan designates portions of
Downtown San Pedro as Regional Center,
Community Center, and Mixed Use
Boulevard.
Program: The plan recommends the
establishment of an economic
development and revitalization program
for downtown San Pedro, utilizing
provisions of a BID and/or CRA Project
Plan which incorporates but not be
limited
to the following objectives and criteria: a.
Reverse the economic and physical
decline and deterioration of downtown;
Establish an effective marketing
management program; Encourage new
developments which can serve as strategic
anchors to attract other new uses and
induce the upgrading of existing
structures; Encourage the use of private
and public resources designed to stimulate
commercial rehabilitation and new
development.
Program: Support legislation and
administrative actions which adequately
allows the City to encourage business
development such as taxable bonds, bond
pools, historic preservation bonds,
seismic rehabilitation bonds and use of
bond financing by local economic
development corporations.
Program: Support for legislation and
administrative actions which allow the
City to continue to support small business
development, including but not limited to,
small business revolving loan funds and
commercial corridor rehabilitation
program, such as those established in the
City’s Commercial Area Revitalization
Effort (CARE) Program.
Assist private owners of existing and
future historic resources to maintain

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and/or enhance their properties in a
manner that will preserve the integrity of
such resources in the best possible
condition.
Program: Adherence to the City's historic
properties preservation ordinances and
Cultural Heritage Board requirements for
preservation and design. Implementation
of design standards.
Program: Utilize City historic properties
restoration programs which provide
funding for renovating and/or reusing
historic structures. Develop HPOZ
Coordinate with the Department of
Recreation and Parks and the Police
Department to ensure adequate police
patrols and the utilization of "defensible
space", in the design of recreation and
park facilities.
Promote the supervision of park activities
and enforcement of codes restricting
illegal activity.
Support and encourage community-based
crime prevention efforts (such as
Neighborhood Watch) through
coordination with existing community
based policing, foot and bicycle patrols,
watch programs, and regular
communication with neighborhoods and
civic organizations.
Industrial: Assist in the aggregation of
smaller, older sites to facilitate
revitalization or reuse, where appropriate.
Encourage and assist economic
revitalization and the reuse of older
industrial properties for industrial uses
through City, State and Federal programs.
Pedestrian-Oriented Height and Building
Design
In Mixed Use Districts, Neighborhood
Districts and Community Centers the
mass, proportion and scale of all new

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buildings and remodels shall be at a
pedestrian scale. The design of all
proposed projects shall be articulated
to provide variation and visual interest,
and enhance the streetscape by providing
continuity and avoiding opportunities for
graffiti.
20
Sherman Oaks-
Studio City-
Toluca Lake-
Cahuenga Pass
Residential: Compatibility
between residential and
industrial uses
Commercial: Unsightliness
of new construction due to
the lack of landscaping,
architectural character and
scale
Industrial: To provide
adequate protection for
residentially zoned
properties adjacent to
industrial uses.
Major Development
Opportunity Sites:
Properties Along the South
Side of the Los Angeles
River
Issues: Potential for
additional policing
problems.
Planning the remaining
commercial and industrial
development opportunity
sites for needed job
producing uses that
improves the economic and
physical condition of the
Plan Area.
Commercial, Objective 2-4:
To enhance the appearance
of commercial districts
Objective 3-1 To provide
for existing and future
industrial uses which
Residential: Active homeowners groups
promoting identification and preservation
and rehabilitation of historic resources
Commercial: Support for efforts to
preserve and rehabilitate commercial and
residential historic structures when
located on commercial sites.
Industrial: Attract desirable (clean)
industrial uses, thus generating less
harmful pollutants and lower noise levels.
Providing appropriate administrative
review for major expansions of existing
industrial sites when located near
residential uses.
Availability of sites planned for job
producing uses that improve the economic
and physical condition of the area.
Re: CBS Studio Center (The largest
industrial piece of property in the plan
area.
Programs: …community and
neighborhood revitalization programs for
residential projects shall provide for Plan
consistency
The City’s HELP and federally-supported
Residential Rehabilitation Loan Programs
Commercial: Policy 2-2.1 Prohibit the
development of new automobile-related
uses in pedestrian oriented districts
(POD’s).
Policy 2-2.2 Require screening of open
storage and auto repair uses, and prohibit
storage of automobile parts and other
noxious commercial related products in
front of commercial development,
Land cleanup,
structural
rehabilitation,
clean industrial
uses desired,
buffering from
noxious industrial
uses

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contribute job opportunities
for residents and which
minimize environmental
and visual impacts to the
community.
Open space is important due
to its role in both physical
and environmental
protection.
Housing, 2. Maintain and
preserve the character and
integrity of existing
neighborhoods and
encourage participation in
self-help preventive
maintenance to promote
neighborhood conservation,
beautification and
rehabilitation.

exposed to the street.
Industrial: Goal 3: Provide sufficient land
for expansion of low intensity non-toxic
producing industrial uses which create
employment opportunities and have
minimal adverse impacts on adjacent
residential uses.
Policy 5-1.3 Require development in
major opportunity sites to provide public
open space.
Coordination Opportunities for Public
Agencies, Recreation and Parks Facilities:
Coordinate with the Department of
Recreation and Parks and the Police
Department to insure adequate police
patrols and ‘defensible space,’ where
feasible, in the design of recreation and
park facilities.
Promote the supervision of park activities
and enforcement of codes restricting
illegal activity.
Pursue resources to clean up land that
could be used for public recreation safely.
Police Protection: Support and encourage
community-based crime prevention
efforts such as Neighborhood Watch
…establish a set of design guidelines that
will serve to improve the environment
both aesthetically and physically
21
Silver Lake-
Echo Park-
Elysian Valley
Interface impacts of
industrial and residential
areas: “…the residential
neighborhoods are impacted
by noise and environmental
pollutants generated by
existing industry. Often
because of the compactness
of the area and the
narrowness of the lots, there
is no buffer between the
uses.” (I-5)
“Deterioration of housing
Commercial: Encourages, where
appropriate, intensification, re-use and
more efficient use of obsolete or
underused commercial space ad
encourages mixed-use development with
mixed-use incentives along designated
corridors.
Objective 2-1: Conserve and strengthen
viable commercial development and
encourage the reuse of obsolete
commercial development.
Objective 3-1 Provide sufficient land for
expansion of low intensity industrial uses.
Public and Institutional
Land Use: Recreation and
Parks Facilities: “…the
State in 2001 funded parks
on former industrial lands
along the river including
the Cornfield property just
outside the…[Community
Plan Area]…to the
southeast and Taylor
Yards just across the river
in the Northeast
Community Plan Area.
Obsolete,
underused,
abandoned,
blight, vacancy

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stock and architecturally
significant or historic
structures due to neglect or
inappropriate remodeling,
particularly in Echo Park.”
(I-6)
“Unsafe and overcrowded
conditions”
“Assembly of lots to build
large developments that are
incompatible with size,
scale and design of
neighborhoods and which
threaten existing affordable
housing.” (I-6)
Commercial: The aesthetic
quality of the Plan area’s
shopping centers and
commercial corridors.
Improve the physical
appearance of older
industrial areas.
The quality and vitality of
commercial areas.
Security and maintenance of
small secluded pocket parks
and other new park/open
space facilities developed
throughout the Plan area
and along the Los Angeles
River.
Abandoned or underutilized
industrial structures or
properties
Policy 3-1.1 Designate lands for the
continuation of existing industrial uses
and development of high technology,
light manufacturing and other clean
industrial uses which provide
employment opportunities.
Program: Rezone specified industrially
designated land
Program: New industrial development is
required to institute measures that contain
dust, odors, noise, waste and other
environmental pollutants produced by
manufacturing processes and to provide a
landscape or other buffer between
industrial and residential properties.
Urban Design guidelines and a permanent
Qualified Condition [Q] attached to
industrial zoning will implement this
policy.
3-2.2 Encourage development of a
Neighborhood Center
Program: Establish a Special Study Area
Objective 3-3: Retain industrial plan
designations to maintain the industrial
employment base of the City.
Policy 3-3.1: Promote continuation of
appropriate existing industry and attract
development of compatible industrial
development.
Program: The Plan protects existing
viable industrial areas by retaining
industrial land use designations and
promoting development of light
manufacturing, research and
development, high technology industries
and artcraft manufacturing. The [Q]CM
zone will permit clean industrial uses and
encourage joint live/work uses. Policy 3-
4.1 Encourage new industrial uses
adjacent to residential neighborhoods to
mitigate their impact on the residential
neighborhoods, to the extent feasible.

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Program: Encourage compliance with and
inspection by responsible agencies to
ensure health and safety standards. New
development of manufacturing uses
adjacent to residential neighborhoods
shall comply with the
industrial/residential design guidelines
Program: Explore economic development
tools and initiatives and marketing
strategies that aim to encourage the
location of high technology, research and
development uses, light manufacturing,
artisan and similar uses that are
compatible with nearby residential uses
and have minimal impact on the
environment.
Use industrial lands for parks
Policy 4-1.1 Preserve the existing
recreational facilities and park space.
Program: Inventorying and identifying of
staircases and dedicated but undeveloped
streets to…provide or enhance linkages in
greenways and trail systems (add to re
and park facilities)
Program: Encourage City departments to
reuse and/or convert unused or underused
publicly owned land and facilities for
recreation and open space facilities,
whenever feasible.
Program: Encourage the reuse of obsolete
or underused publicly owned properties
for open space and recreational uses.
Open Space: Open space provides the
community with important physical
benefits and environmental protection.
Coordination Opportunities for Public
Agencies
Code Enforcement: Promote more
effective enforcement of all applicable
government codes regulating the built
environment and environmental quality.
R & P & OS: Coordinate with the Dept.

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of R & P and the Police Department to
insure adequate police patrols and
“defensible space”, where feasible, in the
design of recreation and parks facilities.
Promote the supervision of park activities
and enforcement of codes restricting
illegal activity.
Encourage the City Department of
Recreation and Parks to coordinate with
community groups, nonprofit
organizations and public land trusts which
increasingly take an active role in the
identification, clean up, acquisition of
parks and open space and the
implementation of various recreation and
open space facilities.
Housing: Maintain and preserve the
character and integrity of existing
neighborhoods and encourage
participation in self-help preventive
maintenance to promote neighborhood
conservation, beautification and
rehabilitations.
Industrial: Encourage economic
revitalization and reuse of older industrial
properties for light manufacturing
industrial uses, especially for high
technology, research and development
and entertainment-related industrial
manufacturing, through available City,
State and Federal incentive programs.
Assist in the aggregation of smaller, older
sites into business park style areas, to
facilitate revitalization or reuse, where
appropriate.
“…encourage the principles of
sustainable development”
Support efforts of active neighborhood
groups to preserve and rehabilitate local
neighborhoods and strengthen
neighborhood character and identity.
Use land use policies to support ongoing

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affordable homeownership and
rehabilitation programs in single and
multiple family neighborhoods.
Commercial: Establish guidelines for
reuse of vacant and underused structures
and infill of underused and vacant parcels
of land along the plan area’s commercial
corridors, emphasizing innovative, mixed-
use projects.
Develop regulations and incentives to
reduce visual blight including open
storage and sign clutter adjacent to
residential neighborhoods and in
neighborhood-serving commercial areas.
Industrial: Allow joint live/work uses as a
means to preserve industrial lands in
Elysian Valley to meet evolving needs of
modern manufacturers and
reconceptualize traditional industrial uses.
Permit mixed-use development and
neighborhood-serving commercial uses to
better support and provide amenities for
residents.
Develop guidelines for the reuse of
unused industrial sites and linking
redevelopment to uses in expanding
sectors of the region’s economy.
Increase presence of desirable (“clean”)
industrial uses to minimize negative
impacts and potential future
incompatibilities with adjacent uses.
Program for Policy 1-1.2: Promote the
rehabilitation of existing housing stock
over demolition.
Promote use among Plan area residents of
the LAHD’s single family housing
rehabilitation loan program, the
Handyworker program and home
ownership assistance programs to
encourage maintenance, repair,
rehabilitation and home ownership among
eligible low- and moderate-income

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homeowners and residents in the area.
Seek TNI funds, a grant program initiated
by the Mayor’s Office and administered
by the various City departments…to
support housing rehab, home ownership,
public improvements and economic
development.
The Plan encourages commercial projects
that constitute more efficient use or reuse
of obsolete or underused commercial
structures or commercially designated
land. Direct public resources, especially
those that leverage private investment
such as TNI funds, to stimulate
commercial rehab and econ devel in
designated Neighborhood Districts,
Community Centers and Mixed Use
Boulevards, e.g. Community Design
Overlay Districts (CDOs)
Policy 2-3.3 Require screening of open
storage and auto repair uses, and prohibit
storage of automobile parts and other
noxious commercial-related products in
front of commercial developments
exposed to the street.
Program: Discourage decision-makers
from granting conditional use permits for
wireless telecommunications facilities
and, as appropriate, to require screening,
co-location and removal of obsolete
structures. (III-24)
Policy 2-4.1 Ensure that commercial infill
projects achieve harmony with the best of
existing development.
Program: Rezone to “…prohibit
automobile and recycling uses and drive-
through windows; and regulate the design
of fast food establishments” (III-26) “…to
prohibit any new automobile uses to
ameliorate a prevailing overconcentration
of automobile-related uses in close
proximity to residential uses.” (III-26)

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Police Protection: Support and encourage
community-based crime prevention
efforts…
Industrial: Require design elements that
discourage graffiti.
22
South (Central)
Los Angeles
Older strip, industrial
parcels present problems
related to location close to
existing residential
development, the cost of
cleaning up toxic soil
conditions, the lack of a
labor pool with appropriate
skills, community
perception and the flight of
business from the area. In
addition, the number of
agencies involved in
regulations over new
industrial development
creates barriers to the
redevelopment of these
older sites. The larger
industrially planned parcels
within the Plan area, such as
the
Slauson/Gage/Western
Industrial area have some
potential for redevelopment
or a change in planned land
use. However, because
many industrial facilities
use or have used toxic
materials, industrial sites
especially the larger sites
often need extensive
remediation before they can
be used for other purposes,
including new industrial
uses.
Infill development on
vacant parcels and
After the disturbances of April/May 1992,
the local organizations from within the
Community were empowered to create
neighborhood plans and to establish
implementing organizations to see that
these plans were put into effect.
During the period immediately following
the 1992 April/May civil disturbances, the
City Planning Department and several
Community groups and organizations
became involved in a series of meetings
with the Community to identify and
accumulate data on the major issues
affecting the Community. These groups
and organizations divided themselves into
neighborhood clusters, created by
grouping neighborhoods together to
establish cluster boundaries.
Active homeowners’ groups, promoting
identification, preservation and
rehabilitation of residential resources.
Block Clubs and local community
organizations involved in rehabilitation
and new housing strategies, appropriate to
the Community and its Neighborhoods.
Potential for the establishment of
Community Design Overlay Zones.
Exploration and expansion of economic
development opportunities are crucial
elements in the revitalization and growth
of the Community. Designing a
comprehensive set of programs to
empower local communities to capitalize
on the opportunities available for
economic development should be the
goal of both public and private agencies.
Issues: A lack of training in, knowledge
The Vermont/Manchester
Area and Vermont
Corridor contains vacant
and underutilized parcels,
is part of a major
transportation corridor and
contains significant
community resources that
should be mobilized in the
redevelopment of the area.
Toxic soil
contamination,
revitalization,
reuse,
remediation,
vacant,
underdeveloped
and underutilized
parcels

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redevelopment of
underdeveloped parcels has
created some impact in
some neighborhoods. Such
new development has
affected the existing street
system and infrastructure. In
other areas, vacant land has
been left undeveloped and
vacant buildings left
unused, creating
opportunity areas that
require sensitive
consideration so that their
development adds value to
the community.
Absentee ownership and
deteriorating housing stock.
Absentee ownership with
little or no commitment to
neighborhood values.
Rehabilitation of existing
housing stock first before
focusing on building new
housing.
No new concentrations of
low income housing,
resulting in further “Ghetto-
ising” the Community. (I-5)
Generate major
improvements in the
function, design and
economic vitality of the
commercial corridors.
Perceptions of the
Community that are
inaccurate and held by both
residents and potential
investors. Low levels of
investment in the
Community.
Lack of variety in the goods
of and experience in the business world.
Inadequate access to legitimate funding
sources. The need to generate and take
advantage of economic development
opportunities in the area.
Centralized source of available resources
in the Community.
Pent up purchasing power within the
Community.
The strengthening or establishment of
chambers of commerce and/or merchant
associations of both tenants and owners.
Create BIDs
Better use of existing commercially zoned
vacant and underdeveloped parcels.
Active pursuit of joint development and
other revitalization programs, including
the leveraging of any capital improvement
projects and locally developed business
improvement programs to retrain
employees.
Establish design guidelines for all
commercial areas.
Utilization of all incentive programs at
local, State and Federal levels. (I-6)
Existing under-utilized and vacant
industrial parcels capable of the
development of new and improved
industrial plant.
Potential for the development of new
industrial parks, e.g., Western/Gage.
Opportunities for the development of
public/private joint development.
Formation of urban opportunity areas to
provide development options in industrial
areas.
Mixed use development to provide
housing in close proximity to jobs, to
reduce vehicular trips, to reduce
congestion, and air pollution, to assure
adequate sites for housing, and to
stimulate Pedestrian Oriented Areas to

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and services offered to the
Community.
Limited use of the local
labor force by existing large
employers.
Unsightliness of some new
and existing construction
due to the lack of
landscaping, architectural
character and scale.
The existing industrial base
is in poor condition.
A lack of screening and
buffering between industrial
and other uses and scale e.g.
in the area along railroad
tracks certain areas.
An old industrial base that
requires upgrading and an
accommodation of new
industrial technology.
Graffiti.
Crime and too much
density.
Infill development and
recycling or rehabilitation
of existing older structures
offer opportunities for
enhancing neighborhood
character and providing
more housing.
Deterioration of historic
sites, structures, and other
resources.
enhance the quality of life in the Plan
area.
Ensure the viability of existing
neighborhood stores (i.e, mom-and-pop)
which support the needs of local residents
and are compatible with the
neighborhood.
Require screening of open storage and
auto uses, and prohibit storage of
automobile parts and other noxious
commercial related products in front of
commercial development, exposed to the
street.
Objective 2-3 To attract uses which
strengthen the economic base and expand
market opportunities for existing and new
businesses.
Objective 3-1 To provide for existing and
future industrial uses which contribute job
opportunities for residents and which
minimize environmental and visual
impacts to the community.
Plan the few remaining sites for major
development for needed job producing
uses that improve the economic and
physical condition of the community.
There is a lack of resources to nurture
cultural expression within the community;
e.g. programs at local parks, churches and
community centers.
The establishment of cultural districts
allowing for the expression of unified
cultural themes.
The support for and the creation of new
locally-based development corporations
offer opportunities for economic
empowerment by the community.
The establishment of public/private
partnerships to stimulate economic
development. (I-11)
Residential: The Plan recommends
utilizing the Department of Building and

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Safety’s PCIS System to monitor
development and encourages the use of
the environmental assessment process to
relate development to the environment. It
also designates land for residential
densities and commercial and industrial
intensities in the
locations most suited to those levels of
development.
Commercial: Redevelopment of existing
commercial strips and areas, and
conversion of existing structures to more
appropriate uses should result in the
physical and aesthetic upgrading of these
areas.
The Figueroa Corridor: a number of
vacant parcels, also, that offer additional
opportunities for development that can
impact the community. The development
of a comprehensive plan to address design
issues particularly related to auto-related
uses, the encouragement of alternate uses
for motels and liquor stores can provide a
significant boost towards the
revitalization of the Corridor.
Based upon National Association of City
Managers and Police Department
standards, the deployment ratio of police
officers to population is a little more
than half what it should be. There is
therefore a deficiency in the number of
police officers per 1,000 persons within
the Community Plan area.
Encourage private owners of historic
properties/resources to conserve the
integrity of such resources.
Encourage appropriate adaptive reuse of
historic resources.
Encourage vocational schools to locate in
commercial or industrial areas where
training opportunities are enhanced by the
surrounding uses. However, siting of

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schools in areas planned for industrial
uses should be evaluated in light of their
proximity to any hazardous use.
Support and encourage community-based
crime prevention efforts (such as
Neighborhood Watch), through regular
interaction and coordination with existing
community-based policing, foot and
bicycle patrols, watch programs,
assistance in the formation of new
neighborhood watch groups, and regular
communication with neighborhoods and
civic organizations.
Encourage economic revitalization and
reuse of older industrial properties for
industrial uses and assist through City,
State, and Federal programs.
Assist in the aggregation of smaller, older
sites to facilitate revitalization or reuse,
where appropriate.
23
Southeast Los
Angeles
During the period
immediately following the
1992 April/May civil
disturbances, the City
Planning Department and
several Community groups
and organizations became
involved in a series of
meetings with the
Community to identify and
accumulate data on the
major issues affecting the
Community.
These groups and
organizations divided
themselves into
neighborhood
clusters, created by
grouping neighborhoods
together to establish cluster
boundaries. Community
meetings were held within
Active homeowners’ groups, promoting
identification, preservation and
rehabilitation of residential resources.
Block Clubs and local community
organizations involved in rehabilitation
and new housing strategies, appropriate to
the Community and its Neighborhoods.
Clusters of historic structures could form
a district providing numerous examples
for new projects to complement existing
structures.
Infill development and recycling or
rehabilitation of existing older structures
offer opportunities for enhancing
neighborhood character and providing
more housing.
Establishment of Community Design
Overlay Zones.
Economic Development Issues: A lack of
training in, knowledge of and experience
in the business world.
Inadequate access to legitimate funding
Several areas have been
identified as major
opportunity sites: the
northern Industrial Ring,
the Alameda Corridor, the
Slauson Industrial area
and the Watts/Lanzit area.
The designation has been
applied to areas which
will potentially generate
significant community
wide impacts. The
following characteristics
were considered in
identifying these
properties as major
opportunity sites:
The need for community
empowerment regarding
future development.
The need for a variety of
jobs and job training for
Toxic soil
contamination,
revitalization,
reuse,
remediation,
vacant,
underdeveloped
and underutilized
parcels

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each cluster. These
meetings were followed by
a series of collaborations
between the City
Planning Staff and the
cluster leaders. Each Cluster
then prepared a
Neighborhood Plan which
contained issues, planning,
social and others, and also
established a set of goals,
objectives and programs
intended as a
manual for change within
the Community. During this
period, the Planning
Department also embarked
on a series of community
meetings to gather data for
the revision of the Citywide
General Plan and the
development of the
Framework document.
Planning Staff utilized
relevant information from
these meetings and
Neighborhood Plans of the
Clusters to develop a
preliminary set of Planning
issues and opportunities in
order to prepare a draft of a
Preliminary Plan.
Industrial: The geographic
location of the Southeast
Community and its
proximity to the historic
urban core of the City has
resulted in a development
pattern of industrial parcels
that are large in size and
often have antiquated
facilities and supporting
sources.
The need to generate and take advantage
of economic development opportunities
in the area.
Centralized source of available resources
in the Community.
Large, contiguous parcels, e.g., in older
industrial areas, have the potential to
create significant development.
There are several locations within the
Community where the development of a
particular cultural or historic theme offers
opportunity for the development of
related businesses.
The support for and the creation of new
locally-based development
corporations offer opportunities for
economic empowerment by the
community.
The establishment of public/private
partnerships to stimulate economic
development.
Opportunities through all of the above to
generate new job opportunities. Planning
the remaining commercial and industrial
development opportunity sites for needed
job producing uses that improves the
economic and physical condition of the
Southeast Community Plan Area.
Historic preservation by prevention: The
Plan empowers communities to identify
potential areas which are recommended to
be considered for Historic Preservation
Overlay Zones.
Mixed-Use: Plan policy provides for the
development of single or aggregated
parcels for mixed use commercial and
residential development. These structures
would, normally, incorporate retail,
office, and/or parking on lower floors and
residential units on the upper floors. The
intent is to provide housing in close
community residents.
Ancillary development
reflective of community
needs.
The need for a master plan
along the Corridor to
prevent incongruent,
incremental development.
The identification of
nodes along the Corridor
with appropriate
development strategies.
(III-14)
The Cultural Crescent
The Watts Cultural
Crescent presents a unique
opportunity to expand on
the cultural/arts theme and
develop a center with the
Watts Towers as its
centerpiece. The
Community Plan
encourages the
development of a specific
set of guidelines to
promote the cultural and
arts-related activities and
opportunities for the
region. (III-15)

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infrastructure. These older
industrial facilities present
problems related to location
close to existing residential
development, the cost of
cleaning up toxic soil
conditions, the lack of a
labor pool with appropriate
skills, community
perception and the flight of
business from the area. In
addition, the number of
agencies involved in
regulations over new
industrial development
creates barriers to the
redevelopment of these
older sites. The larger
industrially planned parcels,
such as the Alameda
Corridor, the Slauson
Industrial area have
considerable potential for
redevelopment or a change
in planned land use.
However, because many
industrial facilities use or
have used toxic materials,
industrial sites especially
the larger sites often need
extensive remediation
before they can be used for
other purposes, including
new industrial uses.
Need to preserve and restore
established single family
neighborhoods.
Absentee ownership and
deteriorating housing stock.
Rehabilitation of existing
housing stock first before
focusing on building
proximity to jobs, to reduce vehicular
trips, to reduce congestion, and air
pollution, to assure adequate sites for
housing, and to stimulate Pedestrian
Oriented Districts to enhance the quality
of life in the Plan area. While the Plan
does not mandate mixed-use projects, it
encourages them in certain commercially
designated areas, such as in Pedestrian
Oriented Districts, and in transit oriented
districts.
Protect commercially planned/zoned areas
from encroachment by residential only
development.
Permit the development of new
automobile-related uses in some
commercial and industrial areas.
Program: The Plan retains areas where
new automobile-related uses are
permitted, primarily along the General
Commercial and Industrial plan
designations.
2-2.4 Require screening of open storage
and auto uses, and prohibit storage of
automobile parts and other noxious
commercial related
products in front of commercial
development, exposed to the street.
Industrial uses provide needed
employment opportunities and economic
benefits to the community and should be
encouraged when impacts to surrounding
land uses can be mitigated.
To provide for existing and future
industrial uses which contribute job
opportunities for residents and which
minimize environmental and visual
impacts to the community. 3-1.1
Designate lands for the continuation of
existing industry and development of new
industrial parks, research and
development uses, light manufacturing,

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new housing.
No new concentrations of
low income housing,
resulting in further
“Ghetto-ising” the
Community. (I-5)
Undeveloped or
underdeveloped land
New development which
does not complement
neighboring structures.
Graffiti.
Crime and too much
density.
Overcrowding of units in
both single-family and
multi-family areas.
Residential: Infill
development on vacant
parcels and redevelopment
of underdeveloped parcels
has created some impact in
some neighborhoods. Such
new development has
affected the existing street
system and infrastructure. In
other areas, vacant land has
been left undeveloped and
vacant buildings left
unused, creating
opportunity areas that
require sensitive
consideration so that their
development adds value to
the community.
Fire Vulnerability: Many
structures in the Southeast
Community Plan Area lack
fire protection systems,
being turn-of-the century
structures, thus, increasing
the potential for property
and similar uses which provide
employment opportunities.
To retain industrial plan designations to
maintain the industrial employment base
for community residents and to increase it
whenever possible.
Historic Resources: 18-2.1 Encourage the
preservation, maintenance, enhancement
and adaptive reuse of existing buildings in
commercial areas through the restoration
of original facades and the design of new
construction which complements old in a
harmonious fashion, enhancing the
historic pattern.
Support the Watts Cultural Crescent and
areas like the Central Avenue Corridor as
cultural resource centers and encourage
their revitalization through reinvestment
in the area.
The strengthening or establishment of
chambers of commerce and/or merchant
associations of both tenants and owners.
Opportunities for the creation of BIDs.
Better use of existing commercially zoned
vacant and underdeveloped parcels.
Active pursuit of joint development and
other revitalization programs, including
the leveraging of any capital improvement
projects and locally
developed business improvement
programs to retrain employees.
Existing under-utilized and vacant
industrial parcels capable of the
development of new and improved
industrial plants.
Potential for the development of new
industrial parks, e.g., south of Slauson at
Western and Avalon.
Opportunities for the development of
public/private joint development.
Formation of urban opportunity areas to
provide development options in industrial

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damage and personal injury
due to fire.
Perceptions of the
Community that are
inaccurate and held by both
residents and potential
investors.
Low levels of investment in
the Community.
Lack of variety in the goods
and services offered to the
Community.
Limited use of the local
labor force by existing large
employers.
Lack of continuity of
complementary uses and
cohesiveness along
commercial frontages
Unsightliness of some new
and existing construction
due to the lack of
landscaping, architectural
character and scale.
Inadequate transition
between commercial and
residential uses.
The flight of quality
commercial enterprises and
of consumer dollars from
the area.
Pent up purchasing power
within the Community.
The existing industrial base
is in poor condition.
A significant out-migration
of and divestment in
manufacturing plants in
recent years.
Absentee ownership with
little or no commitment to
neighborhood values.
areas.
Establish appropriate transition uses
between industrial and adjoining uses,
especially residential.
Identify and utilize all incentive programs
at the local, State and Federal levels.
Opportunities for the adaptive use of
historic buildings.
Formation of urban opportunity areas to
provide development options in industrial
areas.
The use of currently available historic
residences for low and moderate income
ownership.
The circulation system of roads and rail
accommodates the movement of people,
goods and services throughout the
Community Plan area. An expanded
public transit system aimed at providing
both capacity and new developmental
opportunity is important to reduce
congestion, transportation costs, improve
air quality to better serve all segments of
the Community.
The expression of significant cultural
themes needs to be encouraged within the
community.
There is a lack of resources to nurture
cultural expression within the community;
e.g. programs at local, parks, churches
and community centers.
The establishment of cultural districts
allowing for the expression of unified
cultural themes.
Design standards and guidelines
established to guide new and infill
development.
Consider the suitability of the geology in
any proposal for development within the
Plan area.
Program: Continue the application of the
environmental assessment process and the

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Commercial land use in the
Southeast Community Plan
area is in a state
of transition. The traditional
retail centers of Central
Avenue, Watts and
Vernon have undergone a
transition due to
demographic changes, the
flight of some businesses
from the area, “dollar
flight” from the area,
competition from
neighboring cities and the
proliferation of “mini”
shopping malls.
implementation of Subdivision Map Act
on individual project applications to
determine the cumulative impact on the
Community’s resources.

New and rehabilitated office space can be
established in the commercial “centers”
and areas designated for mixed use,
proposed transit oriented districts and
Pedestrian Oriented Districts.
Redevelopment of existing commercial
strips and areas, and conversion of
existing structures to more appropriate
uses should result in the physical and
aesthetic upgrading of these areas.
Commercial: Ensure the viability of
existing neighborhood stores (i.e, mom-
and-pop) which support the needs of local
residents and are compatible with the
neighborhood.
Program: The Plan redesignates to a
Neighborhood District land use category,
some properties which were previously
zoned and planned highway commercial
and which included the type of uses
identified in this policy. Stores, which are
a recognized part of the neighborhood,
and nonconforming, should be given
favorable
consideration by a decision maker when a
review to continue the use is required.
Gasoline Stations and Other Auto-Related
Uses:
Allow for the development of automobile-
related uses in appropriate commercial
designations along major arterials.
2-2.1 Permit the continuation of gasoline
stations and supporting service facilities
along major streets and highways in
which they are currently located and
require a decision maker to insure that
expansions and modifications of existing

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facilities be designed to improve
landscaping and achieve a higher quality
architectural character.
2-2.2 Prohibit the development of new
automobile-related uses in Pedestrian
Oriented Districts (POD’s).
There is a deficiency in the number of
police officers per 1,000 persons within
the Community Plan area.
Promote the establishment of Police
facilities which provide police protection
at a neighborhood level.
Encourage private developments to
contribute to providing protection
services to the residents of the
community.
Provide for the supervision of park
activities and promote enforcement of
codes restricting illegal activity.
Pursue resources to clean up land that
could be used for public recreation safely.
Encourage vocational schools to locate in
commercial or industrial areas where
training opportunities are enhanced by the
surrounding uses. However, siting of
schools in areas planned for industrial
uses should be evaluated in light of their
proximity to any hazardous use.
Support and encourage community-based
crime prevention efforts (such as
Neighborhood Watch)...
Encourage economic revitalization and
reuse of older industrial properties for
industrial uses and assist through City,
State, and Federal programs.
Assist in the aggregation of smaller, older
sites to facilitate revitalization or reuse,
where appropriate.
24
Sun Valley-East
La Tuna Canyon
The community
incorporates the highest
concentration of mineral
processing facilities in Los
Reuse of exhausted sand and gravel
extraction sites.
Potential future reuse of sand and gravel
pits to provide for residential,
Program: Consideration
should be given to the
future potential use of the
Department of Water and
Reuse of former
mining sites

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Angeles, with rock and
gravel mining operations as
well as cement and concrete
processing. (I-1)
The Sun Valley area has
developed into the
Northeast Valley’s
industrial base. The new
community was promoted
as an area with a fuel pipe,
natural gas line, electricity,
aqueduct, water and
switching facilities. Among
the first products
manufactured were water
heaters, metal windows, and
sand and gravel as the major
industry. (I-2)
Need for adequate buffering
of residential neighborhoods
near the Burbank-Glendale-
Pasadena Airport.
Need for housing, jobs and
services in mutual
proximity.
Undeveloped or
underdeveloped land
allowing opportunities for
clustered development.
Need to preserve industrial
land.
Need to buffer heavy
industrial uses to minimize
adverse influence on
adjacent land.
Need to minimize adverse
impact of sand and gravel
extraction activities
upon residential and
commercial areas.
Work with the Burbank-
Glendale-Pasadena Airport
commercial, industrial and recreational
needs of the community.
Improving the function, design and
economic vitality of the commercial
corridors.
Planning the remaining commercial and
industrial development opportunity sites
for needed job producing uses that
improves the economic and physical
condition of the community. (II-3)
Existing economic program activity
within Sun Valley-La Tuna Canyon
includes the Northeast Valley Enterprise
Zone and a federal empowerment zone.
The City has also adopted a Preliminary
Plan for the proposed Northeast San
Fernando Valley Project Redevelopment
Plan and is developing an economic
development strategy for the Hansen Dam
area.
Surface mining operations are regulated
by the State under the Surface Mining and
Reclamation Act of 1975. The Act
requires surface mining operators to
obtain a permit from, and submit a
reclamation plan to the City.
The reclamation plan is to include
information on the anticipated quantity
and type of minerals for which the surface
mining operation is to be conducted; the
proposed dates for the initiation and
termination of surface mining operation;
the maximum anticipated depth of the
surface mining operation; and a
description of the proposed use or
potential use of the mined lands after
reclamation. A reclamation plan is
required of all operations conducted after
January 1, 1976. The Act also requires
surface mining operators to provide
financial assurances to ensure that
reclamation is performed in accordance
Power Valley Steam Plant
site as a sand and gravel
extraction site.
There is a series of large
industrial districts along
the railroad line that
parallels San Fernando
Road. A large industrial
district also stretches
along Sherman Way, on
the southern boundary of
the Community Plan Area.
Existing mining
operations include
CalMat’s Sheldon Site
(Sheldon Street and
Glenoaks Boulevard) and
Boulevard Site (Branford
Street between San
Fernando Road and Laurel
Canyon Boulevard). It is
anticipated that existing
mining operations will be
exhausted by the year
2008. Exhausted mining
operations include
CalMat’s
Trout/Schweitzer Pond
and Peoria Street Site, Los
Angeles By-Products
Company’s Strathern
Street Site and the Bradley
Landfill. Both the Peoria
Street Site and the
Strathern Street Site are
being filled with inert
landfill material. It is
projected that the Bradley
Landfill will be filled by
the year 2003. Once filled,
the site will be converted
into a state-of-the-art

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Authority and the FAA to
mitigate airport-related
noise, traffic, pollution, and
other negative
environmental impacts.
Earthquake-damaged
structures
with the approved reclamation plan.
The City’s Conservation Plan, an element
of the General Plan of the City of Los
Angeles, also provides guidelines for sand
and gravel extraction. The Conservation
Plan provides objectives, policies,
standards and criteria, and programs for
the controlled extraction of these
resources. Reclamation of sand and gravel
extraction sites for recreation or open
space uses is also proposed in the
Conservation Plan.
Future industrial development which
would be more compatible with the
existing airport oriented land uses and
less noise sensitive to airport activity,
should be considered adjacent to the
Burbank-Glendale-Pasadena Airport.
Public and private development must be
fully coordinated, in order to avoid
expensive duplication and to assure a
balance among needs, services and costs.
Work with the Recreation and Parks
Department in setting aside portions of
reclaimed sand and gravel mining sites
for open space or recreational uses (see
Policy 3-1.4).
Protect significant environmental
resources from environmental hazards.
Implementation of State and Federal
environmental laws
and regulations such as The California
Environmental Quality Act (CEQA), the
National Environmental Protection Act
(NEPA), the General Plan Air Quality
Element, and the Clean Water Quality
Act.
Program: Implementation of SCAG's and
SCAQMD's Regional Air Quality
Management Plan, and SCAG's Growth
Management Plan. Views/Scenic
Resources: Protect Scenic Corridors by
recycling center - the “Sun
Valley Recycling Park of
Los Angeles”.

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establishing development controls in
harmony with each corridor’s individual
scenic character.
Prohibition and/or control of signs and
billboards
Objective 14-1 Reduce impact of airport-
related uses upon noise-sensitive land
uses.
Participate in a sound insulation program
for noise-affected residences and schools
as funded by the Burbank-Glendale-
Pasadena Airport Authority.
Program: Implement F.A.R. Part 150
Noise Compatibility Study mitigation
measures.
Coordinate with the Department of
Recreation and Parks and the Police
Department to ensure adequate police
patrols and the utilization of "defensible
space", where feasible, in the design of
recreation and park
facilities.
Promote the supervision of park activities
and enforcement of codes restricting
illegal activity.
Support local policing activities, such as
Neighborhood Watch.
Encourage and assist economic
revitalization and reuse of older industrial
properties for industrial uses through
City, State, and Federal programs.
Assist in the aggregation of smaller, older
sites to facilitate revitalization or reuse,
where appropriate.
Improve storm drains on streets
susceptible to flooding through the City’s
Five Year Capital Improvement Program.
Employment: Encourage businesses to
participate in job training programs for
local residents.
Natural Disasters: The 1971 Sylmar-San
Fernando and the 1994

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Northridge earthquakes, floods, and fires
have and will continue to impact the
community. City government, other
governmental agencies, the private sector,
disaster relief agencies, and the citizens of
the community should be encouraged to
work together to minimize the impacts of
a disaster in terms of land development
practices, providing essential services,
preventing transportation and
communication blockages and to ensure
that recovery will proceed as
expeditiously as possible.
Earthquake Preparedness: The 1994
Northridge earthquake damaged portions
of the Sun Valley-La Tuna Canyon area.
The magnitude 6.8 (Richter Scale)
earthquake caused extensive and
widespread property damage to
residences, businesses, nonprofit
organizations, public facilities, and
infrastructure including freeways, water
lines, power lines, and natural gas lines.
Recovery and rebuilding efforts have
already begun following the Northridge
earthquake and will continue over the
next several years.
The CRA as directed by the City Council
in July 1994, established an Earthquake
Disaster Assistance Program
redevelopment plan. The five-year Plan
provides disaster and recovery assistance
in helping the community to rehabilitate
from the effects of the January 1994
Northridge earthquake. The Project
facilitates the redevelopment of
properties; develops and implements job
revitalization job creation, retention, and
training; and encourages business
attraction, retention, and expansion.
Promote neighborhood preservation in
existing residential neighborhoods.

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Program: The NPP and HELP
Require that grading be minimized to
reduce the effects on environmentally
sensitive areas.
Program: Compliance with CEQA
requires that local and state governmental
agencies consider and disclose potential
environmental effects of a project before
rendering a decision, and provide
methods to mitigate those impacts.
To promote and protect the existing rural,
single-family equestrian oriented
neighborhoods in RA zoned areas and
“K” Supplemental Use Districts. To avoid
precedent-setting actions including zone
variance, conditional use, or subdivision
that might endanger the preservation of
horsekeeping uses.
Commercial: To enhance the appearance
of commercial districts.
Require that older commercial business
areas be designed and developed to
achieve a high level of quality, distinctive
character, and compatibility with existing
uses.
Program: A CDO
Industrial: Objective 3-1 To provide for
the retention of existing industrial uses
and promote future industrial
development which contributes to job
opportunities and minimizes
environmental and visual impacts.
3-1.1 The City should utilize land use,
zoning, and financial incentives to
preserve the economic viability of the
Plan’s existing industries.
Program: The Community Plan provides
for the retention of existing industrial
development.
Program: A portion of Sun Valley-La
Tuna Canyon is included within the
federal empowerment zone. Businesses

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within the zone are eligible for a $3,000
per employee tax credit.
Program: The City has prepared a
Preliminary Plan for the proposed
Northeast San Fernando Valley Project
Redevelopment Plan.
Adequate mitigation should be achieved
through design treatments and compliance
with environmental protection standards,
for industrial uses where they adjoin
residential neighborhoods and
commercial uses.
Program: Urban design guidelines
3-1.4 The utilization of sand and gravel
areas shall be conducted in such a way as
to conserve sand and gravel resources for
future availability and use, minimize the
impact of extractive activities upon
residential
and commercial areas, and provide for the
reclamation and reuse of exhausted pits.
Program: All sand and gravel mining pits
shall be buffered from adjoining uses with
appropriate fencing and screening such as
landscaping or block walls.
Program: Where located near to
residential areas, consideration should be
given to setting aside portions of
reclaimed sites for open space or
recreational uses.
Program: The City has established the
survey area boundaries for the proposed
Northeast San Fernando Valley Project
Redevelopment Plan. Located within the
boundaries are the sand and gravel areas.
Assist private owners of existing and
future historic resources to maintain
and/or enhance their properties in a
manner that will preserve the integrity of
such resources in the best possible
condition.
Protect and encourage reuse of the area’s

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historic resources.
Program: Adherence to the City's historic
properties preservation ordinances and
Cultural Heritage Board requirements for
preservation and design.
Program: Implementation of urban design
standards and utilize City historic
properties restoration programs which
provide funding for renovating and/or
reusing historic structures.
Work with the City of Burbank and the
Burbank-Glendale-Pasadena Airport
Authority, the FAA, and other City
Departments in continuing to mitigate
airport-related environmental impacts on
adjacent land uses.
25
Sunland-
Tujunga-
Lakeview
Terrace-Shadow
Hills-La Tuna
Canyon
Need for regulation of
hillside development.
Undeveloped or
underdeveloped land
allowing opportunities for
clustered development.
Unsightliness of new
construction due to the lack
of landscaping,
architectural character and
scale.
New hillside buildings
blocking views or
presenting an unsightly
view
from below.
Commercial rehabilitation
needed
Deterioration of housing
stock
Earthquake-damaged
structures and service
systems
Antiquated infrastructure:
need to upgrade the
wastewater collection
Opportunities: Citizen awareness and
active participation in community affairs.
Upgrade commercial areas on Foothill
Boulevard and Commerce Avenue
through the Foothill Boulevard Specific
Plan.
Create an arts-oriented neighborhood on
Commerce Avenue featuring antique
shops, cafes, artist studios and live/work
space.
Industrial: Objective 3-1 To provide for
the retention of existing industrial uses
and promote future industrial
development which contributes to job
opportunities and minimizes
environmental and visual impacts.
The City should utilize land use, zoning,
and financial incentives to preserve the
economic viability of the Plan’s existing
industries.
Adequate mitigation should be achieved
through design treatments and compliance
with environmental protection standards,
for industrial uses where they adjoin
residential neighborhoods and
commercial uses.
The former Lopez Canyon
Landfill site is now known
as Lopez Canyon
Restoration
Project. The Plan
designates the former
Lopez Canyon Landfill
Site as Open Space.
The State of California
requirements for closing a
landfill site involve
preparation of a
postclosure maintenance
plan. This plan mandates
that the site be maintained
and monitored for not less
than thirty (30) years after
the last shipment of waste
to the site. The plan
requires the detection and
monitoring of methane
gas and its migration
underground during this
time. In addition, a 30-
year restoration project,
entailing slope
Revitalization
and reuse of older
industrial sites,
underdeveloped/u
nderutilized
parcels

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system to mitigate existing
deficiencies (want to
develop procedures to
eliminate septic tanks in
existing residential
neighborhoods)
Want to prohibit signs and
billboards
Lack of sufficient security:
The Community Plan area is
grossly underpoliced and its
geographic isolation further
intensifies the problem.
Officers who patrol the
community are based at the
Foothill station located
some distance away. There
is a need for a substation in
the community available to
officers on a 24-hour basis
where administrative tasks
could be performed without
driving back to Foothill
headquarters.
To encourage private owners of historic
properties/resources to conserve the
integrity of such resources.
16-2.1 Assist private owners of existing
and future historic resources to maintain
and/or enhance their properties in a
manner that will preserve the integrity of
such resources in the best possible
condition.
Recreation, Parks, and Open Space:
Coordinate with the Department of
Recreation and Parks and the Police
Department to insure adequate police
patrols and "defensible space", where
feasible, in the design of recreation and
park facilities.
Promote the supervision of park activities
and enforcement of codes restricting
illegal activity.
Support and encourage community-based
crime prevention efforts such as
Neighborhood Watch...
Industrial: Encourage and assist economic
revitalization and reuse of older industrial
properties for industrial uses through
City, State, and Federal programs.
Assist in the aggregation of smaller, older
sites to facilitate revitalization or reuse,
where appropriate.
Natural Disasters: Natural disasters such
as the 1971 Sylmar-San Fernando and the
1994 Northridge earthquakes, floods, and
fires have and will continue to impact the
Sunland-Tujunga-Lake View Terrace-
Shadow Hills-East La Tuna Canyon
community. City government, other
governmental agencies, the private sector,
disaster relief agencies, and the citizens of
the community should be encouraged to
work together to minimize the impacts of
a disaster in terms of land development
practices, providing essential services,
stabilization and
landscaping, is proposed
for the site. Closed
organic waste landfill sites
in the County of Los
Angeles have not been
reused for residential
purposes. The Plan
proposes that the site be
designated a future
recreational area.

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preventing transportation and
communication blockages and to ensure
that recovery will proceed as
expeditiously as possible.
Earthquake Recovery: The 1994
Northridge earthquake damaged portions
of the Plan area. earthquake caused
extensive and widespread property
damage to residences, businesses,
nonprofit organizations, public facilities,
and infrastructure including freeways,
water lines, power lines, and natural gas
lines. Recovery and rebuilding efforts
have already begun following the
Northridge earthquake and will continue
over the next several years.
CRA Plan facilitates the redevelopment of
properties; develops and implements job
revitalization job creation, retention, and
training; and encourages business
attraction, retention, and expansion.
The City should promote neighborhood
preservation in existing residential
neighborhoods.
Program: The NPP and HELP initiatives
Open space locations in the community
include the Tujunga Wash, Angeles
National Forest, the Verdugo Mountains,
and the former
Lopez Canyon Landfill site now known
as Lopez Canyon Restoration Project.
The Plan also recognizes the
Conservation Plan identification of the
Tujunga Wash as a rock and gravel
resource area. The objective of the
classification and designation process
required by the Surface Mining and
Reclamation Act of 1975 is to assist local
government in preserving for the future
essential mineral resources that otherwise
might be unavailable when needed. The
State Mining and Geology Board has

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classified the Tujunga Wash area as a
“Mineral Resource Zone - 2" which
indicates significant mineral deposits are
present. The natural resource preserve
designation used in this plan is consistent
with the objective of the Surface Mining
and Reclamation Act in that it is intended
to preclude development that would
prevent future mining. The need to mine
in the wash is not anticipated during the
life of this plan and it is the intent of the
plan to prohibit such mining through the
year 2025.
Open Space: Protect significant
environmental resources from
environmental hazards.
Program: Implementation of State and
Federal environmental laws and
regulations such as The California
Environmental Quality Act
(CEQA), the National Environmental
Protection Act (NEPA), the Clean Air
Quality Act, and the Clean Water Quality
Act. Program: Implementation of SCAG's
and SCAQMD's Regional Air Quality
Management Plan, and SCAG's Growth
Management Plan.
Program: A minimum 100-foot buffer
zone should be designated from the top of
channel bank for all riparian habitats.
Program: Projects that affect wetlands or
natural waterways should comply with
requirements of the California
Department of Fish and Game and U.S.
Army Corps of Engineers.
26
Sylmar Some of the industrial
buildings along San
Fernando Road have
potential for revitalization
or a change in planned land
use. However, because
many industrial facilities
The Neighborhood Preservation Program,
the HELP initiative, the Residential
Rehabilitation Loan Program,
Maintain and preserve the character of
existing neighborhoods and encourage
participation in self-help preventive
maintenance to promote neighborhood
None Vacant and
underutilized
sites,
revitalization,
reuse

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use or have used toxic
materials, industrial sites
may need toxic waste
"clean-up" to OSHA or
Environmental Protection
Agency standards before
they can be used for other
purposes such as retail,
office, residential,
educational or even new
industrial. Vacant and
underutilized industrial sites
that abut residential
development offer a
significant challenge for
reuse.
Some of the parcels in the
industrial zones have vacant
buildings on them and an
additional 122 acres of
undeveloped industrial
zoned land exists in the
recently approved Sunset
Farms Industrial Park
Project located Vacant or
undeveloped land comprises
18.27% of the land area or
1,442 acres of the
community.
Need for regulation of
hillside development.
Deterioration of the
streetscape.
Improve the function,
design, and economic
vitality of the community's
commercial corridors and
commercial areas.
Lack of adequate design
standards and code
enforcement along
commercial corridors.
conservation, beautification and
rehabilitation.
Encourage the identification and
documentation of the area’s historic
resources.
A 129-acre industrial park has already
been planned for the Sunset Farms
property located in the northwest edge of
the community. When fully developed,
jobs lost through the current phase of
manufacturing firm restructuring and less
than optimum use of industrial parcels in
Sylmar should be more than compensated
by the Sunset Farms Industrial Park.
To provide for the retention of existing
industrial uses and promote future
industrial development will which
contribute to job opportunities and which
minimize environmental and visual
impacts.
3-1.1 The City should utilize land use,
zoning, and financial incentives to
preserve the economic viability of
Sylmar's existing industries.
Adequate mitigation should be achieved
through design treatments, compliance
with environmental protection standards,
and health and safety standards for
industrial uses where they adjoin
residential neighborhoods and
commercial uses.
Economic revitalization and reuse of
older industrial properties for industrial
uses should be encouraged and may be
assisted through City, County, State and
Federal programs.
Program: It is recommended that an
industrial area enhancement or
revitalization study should be considered
by the CRA, CDD, and the Mayor's
Office of Business and Economic
Development

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Natural disasters: Agencies, the private
sector, disaster relief agencies, and the
citizens of Sylmar should be encouraged
to work together to minimize the impacts
of a disaster in terms of land development
practices, providing essential service,
preventing transportation and
communication blockages and to ensure
that recovery will proceed as
expeditiously as possible.
Earthquake preparedness: Two moderate
sized earthquakes in the past 25 years
have devastated portions of the Sylmar
area. CRA Earthquake Disaster
Assistance Program redevelopment plan.
The five-year Plan
provides disaster and recovery assistance
in helping the community of Sylmar to
rehabilitate from the effects of the
January 1994 Northridge earthquake. The
Plan facilitates the redevelopment of
properties; develops and implements
job revitalization through job creation,
retention, and training; and encourages
business attraction, retention, and
expansion.
Establishment of a community resource
center operated by both the public sector
and the private sector which would
provide information and act as a
clearinghouse for employment
opportunities, job training programs, re-
training programs, and part-
time/temporary jobs for persons in-
between jobs, seeking new careers,
involved in life-style changes, and retired.
Commercial decline: Older commercial
areas in periods of transition due to
competition from neighboring cities and
the advent of newer shopping malls and
"big box" discount centers like the
HomeDepot/Sam’s Club in the City of

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San Fernando. Commercial strips along
major arterials have also faced increased
competition from shopping malls as well
as “dollar flight” from Sylmar. The
commercial land use pattern in the
community is mainly strip commercial
along major arterials, with nodes of
varying sizes at specific intersections.
To maintain the viability and vitality of
the existing Sylmar Central CBD as a
community focal point. The Common
Bond Fund (CBF) provides taxable
financing for commercial and industrial
projects. The Bonds, issued by the Los
Angeles City Industrial Development
Authority, are sold to private investors.
The program can provide up to
$10,000,000for business development at
rates significantly below conventional
financing.
Program: The Small Business Fund (SBF)
is CDD's largest, direct loan program and
administered by CDD's Industrial and
Commercial Development Division
(ICD).Through it, ICD offers secondary
or "gap" financing for commercial and
industrial projects. Program: Job Training
Partnership Act (JTPA): Provides Federal
funding from the Department of Labor for
job training assistance for unemployed,
displaced, and underemployed workers.
JTPA programs are administered by the
Private Industry Council (PIC).
To enhance the appearance of commercial
districts.
To maintain and increase the commercial
employment base for community
residents whenever possible.Policies2-5.1
Businesses should be encouraged to
participate in job training programs for
local residents. Program: Entrepreneurial
Training Program: This program is aimed

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at providing training, technical assistance
and access to financing for new and
emerging businesses. This program is
administered by the Community
Development Department (CDD), by the
Valley Economic Development
Corporation (under contract with
CDD),and by the North Los Angeles
County Small Business Development
Center (SBDC) operated by the Valley
Economic Development Corporation.
Program: Job Training Partner-ship Act
(JTPA): Provides Federal funding from
the Department of Labor for job training
assistance for unemployed, displaced, and
under-employed workers.
Mini-parks shall be designed to prevent
potential negative impacts on adjacent
residents, and provide high visibility to
prevent criminal activity.
Protect significant environmental
resources from environmental hazards.
Preserve existing stable single-family
neighborhoods.
This is important in the Sylmar Plan area
which contains structures and historic
sites which may be threatened with
demolition or removal as development in
the community continues.
Provide for the supervision of park
activities and promote enforcement of
codes restricting illegal activity.
Coordinate between the Department of
Recreation and Parks and the Police
Department to insure adequate police
patrols and the utilization of "defensible
space" in the design of recreation and
park facilities.
Pursue resources to clean up land that
could be used for public recreation safely.
Maintain and preserve the character and
integrity of existing neighborhoods and

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encourage participation in self-help
preventive maintenance to promote
neighborhood conservation,
beautification, and rehabilitation.
Economic revitalization and reuse of
older industrial properties for industrial
uses should be encouraged and may be
assisted through City, State, and Federal
programs. Assist in the aggregation of
smaller, older sites to facilitate
revitalizationor reuse, where appropriate.
Graffiti: 1. Minimize places for graffiti by
planting shrubs or surface clinging vines
in front of solid fences and walls
(excluding building walls) facing
publicrights-of-way.2. Minimize places
for graffiti by utilizing fences made of
wrought iron or wood picket rather than
solid walls, unless other-wise required.3.
Paint solid walls or fence surfaces
accessible to public view with a washable
"Graffiti-Proof paint or other protective
materials.
27
Van Nuys-North
Sherman Oaks
The Van Nuys Airport, just
outside the western
boundary of the Van Nuys-
North Sherman Oaks plan,
is a large economic
generator in the community,
designated as the busiest
general aviation airport in
the country. It services 850
aircraft on a 725-acre site.
(I-2)
Undeveloped or
underdeveloped land may
allow opportunities for
clustered development.
Deterioration of streetscape.
Unsightliness of new
construction due to the lack
of landscaping, architectural
Attract desirable ("clean") industrial uses,
thus generating less harmful pollutants
and lower noise levels.
Availability of “incubator” type
businesses that allow small business
owners to relocate to larger sites as
business improves.
The City’s Community Department has
initiated the Commercial Area
Revitalization Effort (CARE) program for
the civic center area. The program was
designed to provide low interest loans to
small businesses for facade improvement
and to provide more appropriate signage.
A significant program co-sponsored by
the Los Angeles City Planning
Department and the Urban Design
Advisory Coalition produced the
document, “Vision Van Nuys” which
The Former Stroh
Brewery Site: This 47 acre
site is located at 7521
Woodman Avenue just
south of Southern Pacific
Railroad tracks between
Hazeltine and Woodman.
The property is zoned M2-
1 and is ideal for locating
industrial-type jobs in an
area which lost over 2,000
jobs since the closure of
the plant in 1992. The site
is presently occupied by
three lessees (Mayflower
Vanlines, Copart
Company, LA Cellular)
with one of the leasers
seeking a ten year
Hazardous waste
problems at old
industrial sites,
reuse,
revitalization of
civic core

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character and scale.
Industrial: Potential for
hazardous waste problems
at old sites.
Commercial decline, e.g.,
there is a definite consensus
within the Van Nuys-North
Sherman Oaks community
to revitalize the San
Fernando Valley
Government Center (Van
Nuys Civic Center).
Crime in multiple-family
neighborhood areas: In spite
of its usefulness as a buffer
mechanism to maintain the
identity of single family
residential areas, the term
“multiple family” often
conjures up images of
densely populated areas
with high crime activity. In
reality, only a few specific
areas have been identified
by the community residents
where crime rates are
perceived to be related to
land use densities. A
footnote has been added to
the Plan to restrict density
in those specific areas to the
lowest density permitted by
the zone. (III-2)
developed recommendations directed at
stimulating the Van Nuys Corridor.
The most recent effort currently underway
to revitalize the Civic Center involves the
“San Fernando Valley Civic Center -
Revitalization Concept Plan” which
focuses on city-owned properties with the
intent of consolidating City services in
one location to create a “full-service” City
Hall while becoming more financially
efficient.
Commercial: To revitalize and reverse
decline of commercial areas through the
establishment of BIDs for signage,
streetscape and other area improvements.
2-3.1 Encourage the establishment of
BIDS
Program: Coordinate with the Chamber of
Commerce and the Los Angeles City
Clerk’s office to disseminate guidelines
on establishing BIDS to the business
community. Industrial land uses are
instrumental in forging a foundation of
employment and economic development.
Efforts must be made to preserve the
fragile industrial base in the Valley.
To provide for existing and future
industrial uses which contribute job
opportunities for residents and which
minimize environmental and visual
impacts to the community.
3-1.1 Designate lands for the continuation
of existing industry and development of
new industrial parks, research and
development uses, light manufacturing,
and similar uses which provide
employment opportunities.
Program: The Plan identifies lands which
have industrial
designations to accommodate the variety
of uses noted above and through plan
amendments and recommend
extension on their lease.
The property owner,
however, is seeking a
buyer. (I-8)

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corresponding zone changes implements
this policy.
3-1.2 Adequate compatibility should be
achieved through design treatments,
compliance with environmental protection
standards and health and safety
requirements for industrial uses where
they adjoin residential neighborhoods and
commercial uses.
To retain industrial plan designations to
maintain the industrial employment base
in the community.
To assure mitigation of potential negative
impacts generated by industrial uses when
they are located in proximity to
residential neighborhoods, the Plan
proposes design guidelines for new
industrial uses when so located.
3-3.1 Encourage new industrial uses
adjacent to residential neighborhoods to
mitigate their impact on the residential
neighborhoods to the extent feasible.
Program: Urban design guidelines,
restrictive zoning
Natural Disasters/Earthquake
Preparedness: Natural disasters such as
the 1971 Sylmar-San Fernando and the
1994 Northridge earthquakes, floods, and
fires have and will continue to impact the
Van Nuys-North Sherman Oaks
community. City government, other
governmental agencies, the private sector,
disaster relief agencies, and the citizens of
Van Nuys-North Sherman Oaks should be
encouraged to work together to minimize
the impacts of a disaster in terms of land
development practices, providing
essential services, preventing
transportation and
communication blockages and to ensure
that recovery will proceed as
expeditiously as possible.

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The 1994 Northridge earthquake
devastated portions of the area, causing
extensive and widespread property
damage to residences, businesses,
nonprofit organizations, public facilities,
and infrastructure including freeways,
water lines, power lines and natural gas
lines. Recovery and rebuilding efforts
have already begun following the
Northridge earthquake and will continue
over the next several years. (CRA Project)
It should be noted that there is a concerted
effort from the business community to
establish a more "professional" and
"business-like"environment in the Van
Nuys area. Grass roots organizations such
as Business Watch aspire to beautify Van
Nuys and attract additional businesses
into the area to develop a stronger
economic base. Their
accomplishments include trash and
graffiti removal along Van Nuys and
Sepulveda Boulevards and a landscaped
median on Sepulveda.
An extension of the “grass roots” efforts
to revitalize commercial areas may
benefit from the establishment of BIDs.
A Community Design Overly district
(CDO) is designated for the older
commercial business district along Van
Nuys Boulevard between the south side of
Oxnard Street to Wyandotte Street.
Recreation and Parks: Small parks shall
be designed to prevent potential negative
impacts on adjacent residents, and
provide high visibility to prevent criminal
activity.
Protect significant environmental
resources from environmental hazards.
Promote the implementation of Crime
Prevention Through Environmental
Design (CPTED) strategies including

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natural access control, natural
surveillance and territorial reinforcement.
Historic resources: Objective 17-2,
Encourage the preservation, maintenance,
enhancement and reuse of existing
historically significant buildings and the
restoration of original facades.
Program: Continue identification of
appropriate City designated historic and
cultural monuments and preservation of
those existing.
To encourage private owners of historic
properties/resources to conserve the
integrity of such resources.
17-2.1 Assist private owners of existing
and future historic resources to maintain
and/or enhance their properties in a
manner that will preserve the integrity of
such resources in the best possible
condition.
Program: Adherence to the City's historic
properties preservation ordinances and
Cultural Heritage Board requirements for
preservation and design. Implementation
of design standards.
Program: Utilize City historic properties
restoration programs which provide
funding for renovating and/or reusing
historic structures.
Coordinate with the Department of
Recreation and Parks and the Police
Department to insure adequate police
patrols and the utilization of “defensible
space”, where feasible, in the design of
recreation and park facilities.
Provide for the supervision of park
activities and promote enforcement of
codes restricting illegal activity.
Pursue resources to clean up land that
could be used for public recreation.
Schools: Encourage vocational schools to
locate in commercial or industrial areas

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where training opportunities are enhanced
by the surrounding uses. However, siting
of schools in areas planned for industrial
uses should be evaluated in light of their
proximity to any hazardous use.
Support community policing, e.g.,
Neighborhood Watch
Link revitalization to historic
preservation: Incorporate the preservation
and enhancement of historical sites
located in the Van Nuys Civic Center into
any plans for revitalization of the area.
Maintain and preserve character and
integrity of existing neighborhoods and
encourage participation in self-help
preventive maintenance to promote
neighborhood conservation, beautification
and rehabilitation.
Improve the coordination of public
services to support neighborhood
conservation activities.
Industrial/Commercial: Encourage
economic revitalization and reuse of
older industrial properties for industrial
uses and assist through the City, State and
Federal programs.
Assist in the aggregation of smaller, older
sites to facilitate revitalization or reuse,
where appropriate.
Encourage businesses to participate in job
training programs for local residents.
Encourage and assist economic
revitalization and the reuse of older
industrial properties for industrial uses
through City, State and Federal programs.
28
Venice The majority of the Plan
Area (approximately 85
percent), that extends from
the Pacific Ocean to Lincoln
Boulevard, lies within the
California Coastal Zone and
is thus subject to the
Recreation and Parks: Protection of
existing natural and recreational
resources, including Venice Beach,
Ballona Lagoon, and Grand and Venice
Canals.
Restoration of the Venice Canals and
improvement of the lagoon and canals
None Revitalization,
reuse

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provisions of the Coastal
Act of 1976. (I-1)
The Venice Community
Plan is consistent with the
Venice Local Coastal
Program, complements it
and integrates its policies
and implementation
programs as they apply to
the Venice Coastal Zone in
compliance with the
provisions and requirements
of the California Coastal
Act of 1976. (II-2)
Residential: Need to
improve the visual
environment of multiple-
family dwellings through
the development of
appropriate design criteria
and landscaping.
Need to promote
rehabilitation of residential
areas and improve quality of
housing in some parts of the
plan area.
Proliferation of illegal
additions of dwelling units
to areas zoned for single
family use.
Private residential
encroachments into the
public rights-of-way.
Illegal conversion of
residential uses to
commercial uses.
Commercial: Unsightly strip
commercial development
Proliferation of out-of-scale
signs including billboards,
roof and wall signs and
sandwich board signs on
banks and bridges would preserve this
unique community resource.
Commercial: Most of the commercial
areas within the Community Center are
proposed for an Artcraft District where
the on-site sale and production of artwork
and other goods can be integrated with
artist housing.
Ensure the viability of existing
neighborhood stores and businesses
which support the needs of local residents
and are compatible with the
neighborhood.
Program: The Community Development
Department offers technical assistance for
BIDs and other economic revitalization
programs. In a business improvement
district, property owners or merchants
collectively contribute to a fund that pays
for improvements such as street cleaning,
landscaping, security, marketing
campaigns and holiday decorations. The
formation of a district requires the support
of the majority of the merchants or
property owners within its boundaries.
2-1.4 Encourage neighborhood “mom &
pop” stores throughout the community at
appropriate locations.
Program: Authorization by means of
commercial zoning with conditions
imposed to protect adjacent residential
uses, or by zone variances.
Amendment of the Commercial Artcraft
District to better meet the needs of the
community and eliminate undesirable
uses.
To enhance the appearance of commercial
districts. Industrial: Objective 3-1 To
provide for existing and future industrial
uses which maintain a viable industrial
base and afford job opportunities for
residents with minimal environmental and

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sidewalks.
Unsightliness of new
construction such as mini-
malls due to the lack
of landscaping, architectural
character and parking.
Inadequate transition
between commercial and
residential uses.
Industrial: Need to protect
residential areas from
possible detrimental effects
of industrial activities.
Inadequate buffering and
landscaping in industrial
areas.
Unsightly and generally
outdated infrastructure such
as above ground
utility poles and lines
Historic resource
degradation (including
Venice Canals)
Natural resource
degradation (coastal
beaches and water bodies)
No billboards or off-
premise commercial signs
will be permitted.
visual impacts to the community.
3-1.1 Designate and preserve lands for the
continuation of existing industrial uses
including multi-media, entertainment,
tourism and other coastal-related
industrial uses such as boat building,
servicing, and production of related
marine supplies and goods, which provide
employment opportunities.
3-1.2 Ensure compatibility between
industrial and other adjoining land uses
through design treatments, and
compliance with environmental protection
standards and health and safety
requirements.
To assure mitigation of potential negative
impacts generated by industrial uses when
they are located in proximity to
residential neighborhoods and to improve
the aesthetic quality of industrial uses.
3-2.1 Encourage new industrial uses
adjacent to residential neighborhoods to
mitigate their impact on the residential
neighborhoods to the extent feasible.
Canals: Protect significant environmental
resources from environmental hazards.
Program: Implement the protection
measures for significant environmental
resources identified in the Venice Coastal
Zone Land
Use Plan.
5-1.4 Protect and maintain unique open
space areas, including the Venice Canals,
Grand Canal, Ballona Lagoon and
beaches.
Program: Implement the Grand Canal
Rehabilitation Project recommendations
to improve water quality, aquatic habitat
and pedestrian access.
Program: The Venice Coastal Zone
Specific Plan contains a provision that
limits recreational boating use of the

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Venice Canals to non-commercial
shallow-bottom and non-motorized boats.
Program: Maintain and enhance the
canals and lagoon public walkways.
Marine and Land Resources Policy: Los
Angeles County Flood Control District
and/or Los Angeles City Engineer should
approve a feasible design to reduce
harmful pollutants from storm drain
waters prior to these waters entering the
Marina.
The environmentally sensitive habitat
areas in the Venice Coastal Zone include
the Ballona Lagoon and Grand Canal
south of Washington Boulevard; the
Venice Canals north of Washington
Boulevard; habitat buffer areas on the east
and west banks of Ballona Lagoon; and
the California Least Tern nesting areas on
the southern part of Venice Beach. The
existing and potential sensitive values in
these areas shall be protected, enhanced,
and where feasible, restored.
The Venice Canals, along with adjacent
Ballona Lagoon, support some of the last
remaining pockets of coastal wetland
habitat in Los Angeles County. The
Venice Canals are part of the Ballona
Lagoon sea water system and are
connected with Ballona Lagoon via Grand
Canal. For sixty years the Canal
waterways had been subject to bank
erosion, runoff and stagnant water
conditions. The Venice Canals
Rehabilitation project was completed in
1993 to rectify these conditions. The
majority of the bird utilization of the
Venice Canals is by domestic birds such
as ducks and geese. Yet, occasionally
individual California Least Terns are
observed in the canal area. (III-35)
The protection of estuaries and wetlands

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and the restoration and protection of the
Venice Canals.
Program: The canal area north of
Washington Boulevard shall continue to
be maintained as a unique coastal
environmental and social resource, as
provided by the Venice Canals
Rehabilitation Plan.
Program: Uses permitted in or adjacent to
the canals shall be implemented in a
manner to protect the biological
productivity of marine resources and
maintain healthy populations of marine
organisms.
Program: To protect the marine habitat, a
one and one-half to two foot- wide safety
landscape buffer strip shall continue to be
provided and maintained between the
canal banks and sidewalks.
Landscaping in the buffer strip shall
consist of native coastal strand marshland
or wetland vegetation as specified in the
Canals Rehabilitation Project. (III-36)
Where feasible, as defined by Section
30108 of the Coastal Act, any resources
found in the portions of the Local Coastal
Program study areas planned for
development should be collected and
maintained at the
interpretive center planned at the wetland
preserve, or at the Los Angeles County
Natural History Museum.
To ensure proper surface and site
recordation, the State Historic
Preservation Office shall be notified,
along with City Planning Director, if any
resource is discovered during any phase
of development construction.
Industrial: Encourage economic
revitalization and reuse of older industrial
properties for industrial uses through
available City, State and Federal incentive

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programs.
Assist in the aggregation of smaller, older
sites to facilitate revitalization or reuse,
where appropriate.
Public Utilities and Services: Encourage
mitigation measure to reduce solid waste
generation including trash separation,
recycling, source reduction, and
compacting and composting.
Commercial: Assist interested businesses
in using existing City programs offering
technical assistance in establishing BIDs
where appropriate.
Encourage businesses to participate in
job-training programs available through
the Community Development Department
and other agencies.
Develop employment opportunities for a
wide range of jobs, skills and wages.
In order to mitigate potential negative
impacts generated by manufacturing uses
when they are located adjacent to
residentially zoned neighborhood, new
development of industrial uses should
incorporate certain design guidelines:
Promote beach-oriented and visitor-
serving commercial activities and other
coastal-dependent uses.
Major Opportunity Sites: Except for the
Metropolitan Transportation Authority
(MTA) bus maintenance yard located at
Main Street and Sunset Avenue, there is a
lack of large and vacant parcels in the
community with significant development
potential. Many changes are likely to
occur from modification or adaptive reuse
of buildings. The majority of new
development is expected to be small scale
since existing regulations prohibit land
assembly of more than two parcels,
particularly in the Coastal Zone. (I-6)
Preserving and enhancing the low-density

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character of residential areas to maintain
the variety of the residents’ lifestyles.
Preserving and promoting existing uses,
particularly small businesses and artisan
which characterize Venice various
neighborhoods.
Promote the preservation of existing
single-family and multi-family
neighborhoods.
Program: NPP and HELP initiatives
Program: Encourage the use of federal
rehabilitation programs, such as mortgage
insurance and interest subsidies.
Promote the development of senior
housing on City-owned vacant land
Provide rent subsidies for rehabilitating
old hotels and apartment buildings
through the Los Angeles Housing
Authority.
Implement the Replacement of
Affordable Housing Unit
provisions of the Venice Coastal Zone
Specific Plan for projects involving the
demolition or conversions of affordable
housing in the Coastal Zone.
Policing: Support and encourage
community-based crime prevention
efforts such as Neighborhood Watch
Ensure that landscaping around buildings
does not impede visibility.
Program: Discretionary land use
approvals should apply “Design-Out
Crime Guidelines” and other standards in
consultation with the Police Department.
Encourage the preservation, maintenance,
enhancement and reuse of existing
historic buildings and the restoration of
original facades.
17-2.1 Identify and document the
community’s historic resources.
Assist private owners of historic resources
to maintain and enhance their properties

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and preserve their architectural integrity.
Program: Adherence to the City’s Historic
Preservation Ordinances and Cultural
Heritage Commission requirements for
preservation and implementation of
design standards.
Program: Promote education and interest
in cultural, historical and architectural
resources, and encourage Building Code
flexibility to preserve these structures.
Program: Utilize City historic properties
restoration programs which provide
funding for renovating and/or reusing
historic structures.
Permitted development shall be sited and
designed to
protect views to the ocean and scenic
coastal areas, to minimize the alternation
of natural land forms, to be visually
compatible with the character of
surrounding areas, where feasible, to
restore and enhance visual quality in
visually degraded areas.
Open space buffer areas between new
development, identified wetlands and
support areas will be established.
Protect existing views of the wetlands
from the surrounding public streets and
open space areas.
Landscaping and plant materials should
be used to screen and soften visually
obtrusive elements.
Hazards: floods, earthquakes,
liquefaction, and seismic sea waves
Direct the Commander of the Emergency
Control Centers to consider the potential
threat of tsunamis in the preparation of
disaster response plans for low-lying
harbor and coastal areas.
Instruct the Commander of the
Emergency Control Center to investigate
the feasibility of establishing a tsunami

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alert procedure.
Provide for the supervision of park and
beaches activities and promote
enforcement of codes restricting illegal
activities.
Coordinate with the Dept. of Recreation
and Parks and the Police Department to
ensure adequate police patrons and the
utilization of “defensible space” in the
design of recreation and park facilities.
Pursue resources to clean up and activate
land that can be used for public
recreation.
The Venice Beach is a major feature of
the Community. It should be protected
from erosion, development and deposit
waste; be provided with appropriate
recreational facilities; be made
conveniently accessible to both local
residents and beach visitors from other
areas; and be fully
integrated with development of the
Community.
Coordinate with the Dept. of Public
Works the restoration of the Venice
Canals and Lagoon, and improvement and
maintenance of public
right-of-way.
29
West Adams-
Baldwin Hills-
Leimert
Because many industrial
facilities use or have used
toxic materials, industrial
sites especially the larger
sites often need extensive
toxic remediation before
they can be used for other
purposes, including new
industrial uses. More
importantly, industrially
planned sites that abut
residential development
offer a significant challenge
for redevelopment due to
Development and use of programs linking
schools with established cultural and
artistic interests
Establishment of cultural districts
allowing for the expression of unified
cultural themes
Design standards and guidelines
established to guide new and infill
development
Clusters of historic structures to form a
district providing examples for new
projects to complement existing
structures.
Infill development and recycling or
The Santa Barbara Plaza
is centrally located in the
Plan Area—it is just under
20 acres in size and is
developed around its
perimeter, generally with
one and two story
buildings offering retail,
office and service uses.
The central portion of the
site is occupied by a large,
open, shared parking lot.
The property is critical to
the Community due to its
Toxic
remediation,
revitalization,
reuse,
redevelopment,
vacant,
underutilized

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concern for any potential
incompatibility between the
two land uses.
An old industrial base that
requires upgrading and an
accommodation of new
industrial technology.
Strip commercial
development suffered from
loss of revenue and
deterioration. Some of these
properties were
subsequently converted to
light manufacturing uses.
Commercial and industrial
decline
Deterioration of housing
stock, including historic
sites and structures
Mini-malls dominated
corner locations and made
the strip
commercial development
along major thoroughfares
less viable.
Physical constraints, narrow
or shallow lot depths,
absentee landlords and
competition from large
outdoor malls further
contributed to the decline of
strip commercial
development. The result
was an increasing vacancy
rate, boarded up storefronts
and abandoned buildings.
The need to preserve and
enhance historic residences.
The unattractiveness of
some new development
within the Community.
Displacement of existing
rehabilitation of older structures
Require screening of open storage and
auto uses, and prohibit storage of
automobile parts and other noxious
commercial related products in front of
commercial development, exposed to the
street.
Identify and address the
overconcentration of uses which have
resulted in the encouragement of activities
detrimental to the health and welfare of
the people of the community.
1-3.1 Oppose any overconcentration of
new auto-related uses in any localized
area of the community.
Program: The Crenshaw Corridor
Specific Plan
Program: Require a decision-maker to
adopt a finding which utilizes
overconcentration as a criteria in any
decision relating to such uses.
1-3.2 Encourage the active targeting for
possible revocation all hotel and motel
sites involved with repeated prostitution
and drug sales.
Program: Continue application of the
revocation process and improve
enforcement of targeted sites.
1-3.4 Encourage the greater use of the
City's revocation process to close down
serious public nuisance alcohol outlets in
the community.
Provide for existing and future industrial
uses which contribute job opportunities
for residents and which minimize
environmental and visual impacts to the
community.
1-1.1 Designate lands for the continuation
of existing industry and development of
new industrial parks, research and
development uses, light manufacturing,
and similar uses which provide
large size, potential to
generate significant
development and its close
proximity to the Baldwin
Hills-Crenshaw Plaza.
The Redevelopment Plan
for the site is under
consideration by property
owners, Community
residents and the CRA.
The following are some of
the issues which should be
addressed by any future
development of the site:
the need for community
empowerment regarding
future development, the
need for a variety of jobs
and job training for
community residents.

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residents by gentrification
or demolition.
Compatibility between
residential and other uses.
Residential-rich, jobs-poor
area.
There is a lack of resources
to nurture cultural
expression within the
Community.
Inconsistent architectural
development which does
not address neighborhood or
Community themes.
Inconsistent and
incompatible urban design
treatments.
Of considerable concern is
that new or remodeled
development in historic
neighborhoods be sensitive
to the existing character of
these neighborhoods.
Overconcentration of auto-
dependent commercial uses
Hotel and motel sites
involved with repeated
prostitution and drug sales
Proliferation of nuisance
alcohol outlets
Absentee ownership with
little or no commitment to
neighborhood values. (I-8)
employment opportunities.
Pursue resources to clean up land that
could safely be used for public recreation.
Encourage vocational schools to locate in
commercial or industrial areas where
training opportunities are enhanced by the
surrounding uses. However, siting of
schools in areas planned for industrial
uses should be evaluated in light of their
proximity to any hazardous use.
Support and encourage community-based
crime prevention efforts (such as
Neighborhood Watch.
Industrial: Encourage economic
revitalization and reuse of older industrial
properties for industrial uses and assist
this process through City, State and
Federal programs.
Assist in the aggregation of smaller, older
sites to facilitate
revitalization or reuse, where appropriate.
Economic Development: Traditional
economic development strategies have
emphasized the introduction of large
plants, commercial or industrial, to serve
as a catalyst
to generate a variety of spinoff enterprises
to revitalize communities. Within South
Los Angeles, the environment is less
conducive to the creation of such plants.
There are few large, vacant parcels to
accommodate such plants. Large areas of
redundant or underutilized industrial
property require assemblage of parcels
under different ownerships.
The development of locally-based, small
enterprises within the community should
be encouraged as a vital part of the
strategy to revitalize neighborhoods. The
significant issues that would affect the
achievement of these goals are:
A lack of training in, knowledge of and

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experience in the business world;
Inadequate access to legitimate funding
sources; The need to generate and take
advantage of economic development
opportunities in the area; Centralized
source of available resources in the
Community; A poor physical
environment and unsightly commercial
areas; Disinvestment in the area on the
part of public and private institutions.
Coordination of public and private
resources engaged in economic
development activities.
Streamlining of regulations and where
appropriate, the removal of regulatory
barriers/obstacles to economic
development programs.
Business incentive programs
Implement Revitalization
/Redevelopment programs, a CDO and
urban design guidelines
2-1.1 Establish a clearinghouse of
community resources to identify agencies
and organizations engaged in economic
development.
2-1.2 Strengthen contacts and cooperation
between public and private sector
organizations engaged in economic
development activities within the
community.
Program: Determine an appropriate
agency to organize a regular schedule of
meetings and networking activities
between public and private
2-1.3 Encourage the improvement of
infrastructure facilities in areas requiring
the revitalization of economic activities.
Program: Continue implementation of the
City’s Capital
Improvement Program and the
Circulation TIMP
2-1.4 Support and encourage the

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expansion of existing programs operated
by all agencies that are designed to assist
in the formation and growth of viable
small businesses in the community.
Program: Continue programs such as low-
interest loan programs, management
assistance, business retention programs,
and the establishment of incubation
centers.
Develop with appropriate agencies, a
comprehensive package of incentives in
order to stimulate economic growth.
Program: Continue expansion and
implementation of City, State, and
Federal incentive programs.
2-1.6 Support appropriate State and
Federal enterprise and revitalization
zones.
Program: Continue cooperation with the
CRA, CDD, and Housing Department, in
the determination of boundaries for such
zones and the development programs to
achieve the goals and policies identified
in the zones.
Objective 2-2 To streamline, and where
appropriate, revise regulations that create
barriers to economic development.
Identify and amend or remove local
ordinances that are duplicative and/or do
not offer safeguards to the community
while impeding appropriate economic
development.
Program: Continue implementation of a
regular review of local ordinances and
their effectiveness.
2-2.2 Encourage legislative advocacy
which generates proposals appropriate for
the community and the City of Los
Angeles.
Program: Continue to provide analysis
and data for legislative programs that
address land use and economic

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development issues affecting the
community.
3-1.2 Target job training programs toward
groups and geographic areas most
impacted by long-term structural
employment.
The design of all proposed projects shall
be articulated to provide variation and
visual interest, and enhance the
streetscape by providing continuity and
avoiding opportunities for graffiti.
The strengthening or establishment of
chambers of commerce and/or merchant
associations of both tenants and owners.
Opportunities for the creation of BIDs.
Better use of existing commercially zoned
vacant and underdeveloped parcels
Historic resource inventory
Adaptive reuse of historic structures
The establishment of public/private
partnerships to stimulate economic
development
Redevelopment of existing commercial
strips and areas, and conversion of
existing structures to more appropriate
uses should result in the physical and
aesthetic upgrading of these areas.
Ensure the viability of existing
neighborhood stores (i.e. “mom and pop”)
which support the needs of local residents
and are compatible with the
neighborhood.
Identify appropriate
revitalization/redevelopment areas
30
West Los
Angeles
Blighting influence of
industrial uses
Unsightly strip commercial
development with poor
visual identity, lack of
parking and convenient
access and oriented to
automobile traffic rather
Provide for a funding mechanism that
would buy out existing billboards along
Santa Monica Boulevard (and throughout
the community) and, prohibit future
billboards by special ordinance.
To retain existing industrial uses and
promote future development which
contributes to job opportunities and
Blight,
abandoned
property,
underutilized

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than neighborhood
pedestrian use.
Proliferation of out-of-scale
signs including billboards,
wall signs, and flashing
signs.
Unsightliness of some new
construction due to a lack of
landscaping, and
unimaginative architectural
quality. Development of
standards and Plan policies
to visually improve
industrial areas.
The abandoned railroad
right-of-way located south
of Exposition Boulevard
should be considered for a
busway and/or bikeway
corridor.
Deteriorated housing stock
Deteriorated historic sites
and structures
minimizes environmental impacts.
3-1.1 Designate and preserve lands for the
continuation of existing industry and
development of new industrial parks,
research and development uses, light
manufacturing and similar uses.
3-1.2 Ensure compliance with
environmental protection standards and
health and safety requirements.
Objective 3-2 To improve the aesthetic
quality and design of industrial areas,
eliminate blight and detrimental visual
impact and mitigate negative impacts
generated by industrial uses on nearby
residential neighborhoods.
A Community Design Overlay or Specific
Plan to address the blighting visual
appearance along Sepulveda Boulevard
should be considered.
Encourage the preservation, maintenance,
enhancement and reuse of existing
historic buildings and the restoration of
original facades.
Program: Adherence to the City’s historic
properties preservation ordinances and
City’s Cultural Heritage Commission
requirements for preservation and
implementation of design standards.
Program: Seek City Historic-Cultural
Monument designation for appropriate
sites, including those of Native
Americans. The Plan map identifies Serra
Springs located at University High School
as a Cultural/Historical resource. To
encourage private owners of historic
properties to conserve the integrity of
such resources.
17-3.1 Assist private owners of historic
resources to maintain and enhance their
properties in a manner that will preserve
the integrity of such resources.
Provide for the supervision of park

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activities and promote enforcement of
codes restricting illegal activities.
Coordinate with the Department of
Recreation and Parks and the Police
Department to ensure adequate police
patrols and the utilization of "defensible
space" in the design of recreation and
park facilities.
Pursue resources to clean up land that can
be used for public recreation.
Encourage economic revitalization and
reuse of older industrial properties for
industrial uses through available City,
State and Federal incentive programs.
Assist in the aggregation of smaller, older
sites to facilitate revitalization or reuse,
where appropriate.
Interface areas:
In order to mitigate potential negative
impacts generated by manufacturing uses
when they are located adjacent to
residentially zoned neighborhoods, new
development of industrial uses should
incorporate specific design guidelines.
Promote neighborhood preservation in all
residential neighborhoods.
Make funds available through the
Neighborhood Preservation Program
administered by the City’s Housing
Department to rehabilitate single-family
homes and multi-family housing.
Program: Provide loans to owners of
small residential buildings (one to four
units) to correct code violations through
HELP
Mixed-use development: The intent of
mixed use development is to provide
housing in proximity to jobs and services,
to reduce vehicular trips, congestion and
air pollution, to provide for rental
housing, and to stimulate pedestrian-
oriented areas.

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Ensure the viability of existing
neighborhood stores and businesses
which support the needs of local residents
and are compatible with the
neighborhood.
Program: Assist businesses in obtaining
technical assistance for BID and other
programs from the City of Los Angeles.
To provide facilities for specialized
recreational needs by utilizing existing
public lands such as flood control
channels, utility easements, Department
of Water and Power property, or
underutilized railroad rights-of-way.
Policies4-2.1 Unused or underutilized
public lands should be considered for
open space and recreational purposes.
Program: Implement bicycle and walking
trails along the abandoned Exposition
Boulevard railroad right-of-way and
Santa Monica Boulevard, as land and
funding become available; and if
compatible with use as a transportation
corridor.
Conversion and upgrading of
underutilized publicly-owned property.
Program: Improvement of the abandoned
railroad right-of-way along Exposition
Boulevard with landscaping, benches,
picnic sites, walkways, or other low-
intensity recreational uses.
Unused or underutilized public lands
should be considered for open space and
recreational purposes.
Program: Neighborhood parks or gardens
should be considered along the abandoned
Exposition Boulevard railroad right-of-
way.
Industrial: Attractive buffers should be
created along street frontages of industrial
sites, and to serve such purposes as
security, sound attenuation, the separation

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of functional areas, and the screening of
unsightly nuisances: Requiring
freestanding walls to use articulations,
surface perforations or other elements,
and to include plantings of vines or tall
shrubs or trees along exterior faces, to
relieve long monotonous expanses and
mitigate graffiti.
31
Westchester-
Playa Del Rey
The downtown community
center has many
opportunities for physical
improvement and economic
development/revitalization.
Physical appearance of
industrial areas (many of the
businesses are closely tied
to the aviation industry and
include logistics, aircraft
repair or part fabrication,
food service, and parking
lots for car rental agencies
and long-term airport
parking use)
Older commercial areas
need general maintenance of
their exteriors including
regular cleaning, and
landscaping care. Unsightly
strip commercial
development with poor
visual identity…oriented to
automobile traffic rather
than neighborhood
pedestrian use.
Air pollution
Airport-related pollution
Blight: To improve the
aesthetic quality and design
of industrial areas, eliminate
blight and detrimental
visual impact on residential
areas, and establish a stable
Industrial: Land use compatibility should
be achieved by including environmental
protection standards and health and safety
requirements in the design and operation
of industrial facilities, including
mitigation measures for the handling,
storage or transfer of dry bulk
commodities for the purposes of reducing
the potential of explosion or fire, and
reducing the emission of dust or other
particulate matter to insignificant levels.
Strict compliance with all applicable air
quality standards Small-scale, on-site
treatment and disposal of industrial
hazardous wastes and mobile hazardous
waste treatment services as effective
alternatives to centralized treatment and
disposal facilities and the inherent
transportation risks associated with the
latter.
When a facility is proposed which will
involve on site treatment and disposal of
industrial hazardous wastes and mobile
hazardous waste treatment services, and
the handling, transfer of storage of
commodities categorized by law as
hazardous, it is the policy to require an
analysis of risk problems which may arise
within the facility itself and which may
affect adjacent facilities or areas be made
and the results used in locating,
designing, constructing and regulating the
operation of the proposed facility.
10-1.1 Protect coastal communities from
None Underutilized,
revitalization

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environment for quality
industrial development.
Ocean pollution (Hyperion
wastewater treatment plant)
Degraded coastal
environment (e.g., soil and
water contamination, bluff
erosion)
Stormwater runoff
Underground gas
storage/migration
potentially adverse impacts arising from
differing or conflicting land uses, giving
special attention to the relationship
between public works/public utility
facilities and sensitive open space or
residential land uses.
The Plan fully supports careful review by
the City of any future expansions or
modifications to the Hyperion plant, with
strong attention to these facilities for
appropriate public education and
appreciation of coastal resources and
habitats should be located on the site and
serve the Community Plan Area
Program: The Hyperion Treatment Plant
conducts education programs and tours.
The Los Angeles Science Education
Center is planned to be constructed for the
facility.
Protect, maintain, and where feasible
enhance and restore the quality of the
Coastal Zone environment and its natural
resources. Assure the orderly and
balanced use and conservation of coastal
ecological amenities, taking into account
the social and economic needs of the
people of the region.
The Westchester-Playa del Rey Local
Coastal Program includes standards for
setbacks and other provisions to buffer
the wetland, lagoon, and other sensitive
areas from development.
18-2.2 Preserve and enhance Ballona
Wetlands by consolidating and restoring
all wetlands and environmentally
sensitive habitats within the Ballona area.
A Ballona Wetlands Habitat Management
Program will be prepared to provide the
following: a comprehensive plan to
improve the quantity, quality, and
distribution of water entering Ballona
Wetlands; a lagoon to perform flood

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control functions while providing habitat
for wild wetland birds; removal of
nonnative plant species, improvements of
tidal flow to the wetlands.
Program: The Local Coastal Program will
also address the restoration of the
wetlands habitat.
The Coastal Bluffs Specific Plan
Development regulations are designed to:
reduce potential adverse effects of
grading in hillside areas, control erosion
and geologic instability, increase ground
water recharge, and reduce water runoff.
Goal 20: Coordinate the development of
Los Angeles International Airport and its
ancillary facilities and circulation system
with surrounding communities to increase
its safety, security and efficient
operational capabilities to serve the
passenger travel and air-cargo demand
throughout Los Angeles and the region,
while minimizing the potential adverse
environmental impacts resulting from
such activities
Objective 20-1 Coordinate the
development of LAX with that of
Westchester-Playa del Rey and other
surrounding communities. Strengthen
coordination between LAWA and the
relevant City departments, other agencies
(MTA), and adjacent communities in the
planning and implementation of all major
LAX projects.
Objective 20-2 Utilize land acquisition,
buffering, transitional uses, and other
effective measures to mitigate noise and
other impacts to Westchester-Playa del
Rey Plan Area. Program: The plan for any
future airport facilities should consider
potential impacts such as noise, exhaust
fumes, etc., on the surrounding
community, and provide for adequate

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buffers, transitional land uses, etc.
Interim-uses: The adopted LAX Interim
Plan provides that all land acquired by
LAX should be put into open space,
recreational and park, and other
community serving uses on a sensitive
and publicly-accepted phasing basis until
it is developed for an actual airport use.
Industrial: Attractive buffers should be
created along street frontages of Limited
Industrial sites, to serve such purposes as
security, sound attenuation, the separation
of functional areas, and the screening of
unsightly nuisances or unpleasant odors.
Improving the function, design and
economic vitality of commercial areas.
(II-3)
Residential: Neighborhood preservation
through revitalization programs (e.g.,
Neighborhood Preservation Program and
HELP
Objective 2-1 Preserve and strengthen
viable commercial development in the
community, and provide additional
opportunities for new commercial
development and services within existing
commercial areas. Enhance the viability
of existing neighborhood stores and
businesses which support the needs of
local residents and are compatible with
the neighborhood.
Program: The Community Development
Department and City Clerk’s Office offer
technical and other assistance to
businesses for the formation of BIDs, and
other programs to assist businesses.
Enhance the land use compatibility, visual
appearance, design and appeal of
commercial development.
Policies
2-3.1 Enhance the visual appearance and
appeal of commercial properties by

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regulating design, signage, landscaping,
and similar issues wherever possible.
1.3 Encourage the development of unused
or underutilized publicly owned property
for open space and recreational purposes.
Underground gas storage: Ensure that the
Gas Company underground storage
facility in the Westchester Bluffs is
maintained and operated in a manner that
is safe, as unobtrusive as possible to the
community, and protective of the coastal
bluffs and wetlands environment.
Program: Numerous Federal and State
regulations govern the operation of
natural gas facilities to ensure safety for
workers, the surrounding community, and
the local environment.
Support and encourage community-based
crime prevention efforts (such as
Neighborhood Watch) through regular
interaction and coordination with existing
policing, foot and bicycle patrols,
community watch programs and regular
communication with neighborhood and
civic organizations. Program: The Plan
supports community-oriented law
enforcement programs, as administered
by the LAPD.
The Plan supports more extensive
coordination by decision-makers,
including the implementation of the City
of Los Angeles CPTED Guidelines.
8-2.3 Ensure that landscaping around
buildings does not impede visibility and
provide hidden places which could foster
criminal activity.
Objective 18-1 Provide a Land Use guide
for the policies contained in the California
Coastal Act of 1976, within the
designated Coastal Zone in Westchester-
Playa del Rey. Continue to provide for the
protection and sustainable development of

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Coastal Communities, Coastal Zone
amenities, and the area’s natural and
constructed resources. Program: The
Westchester-Playa del Rey Local Coastal
Program will also address the restoration
of the wetlands habitat.
Program: The Local Coastal Program
Land Use Plan should include policies to
protect and preserve Del Rey Lagoon and
the surrounding park as an ecological and
recreational resource.
18-2.4 Preserve and protect the unique
and distinctive landforms of Playa del
Rey Coastal Bluffs, which remain habitat
to birds, small mammals, and native
plants.
Program: The Coastal Bluffs Specific
Plan regulates height, setbacks, lot
coverage, land use, lighting, grading, and
drainage on lots located within the Playa
del Rey bluff area. Development
regulations are designed to: reduce
potential adverse effects of grading in
hillside areas, control erosion and
geologic instability, increase ground
water recharge, and reduce water runoff.
Support and encourage community-based
crime prevention efforts (such as
Neighborhood Watch and Business
Improvement District patrols) through
coordination with existing community-
based policing, foot and bicycle patrols
and watch programs.
Assist private owners of historic resources
to maintain, enhance and conserve their
properties.
Maintain and preserve the character and
integrity of existing neighborhoods and
encourage participation in self-help
preventive maintenance to promote
neighborhood conservation, beautification
and rehabilitation.

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Industrial: Encourage economic
revitalization and reuse of older industrial
properties for light manufacturing
industrial uses, especially for high
technology and entertainment-related
industrial manufacturing centers, through
available City, State and Federal incentive
programs.
Assist in the aggregation of smaller, older
sites into business park style areas, to
facilitate revitalization or reuse, where
appropriate.
32
Westlake Physical decay of housing
stock
Deteriorating historic
buildings “The ability to
restore these buildings is
hampered by a costly and
long regulatory process,
accentuated by the high
degree of absentee owners.
The lack of historic
designation protection and a
well organized constituency
makes protection of the
buildings all the more
difficult.” (I-2)
Central City West is the
only area contains large
tracts of vacant land.
Residential rehabilitation
and public improvements
are part of the CRA’s
efforts in Pico Union. Pico
Union has the largest
concentration of Historic-
Cultural Monuments in
Westlake. These homes
mostly located along
Alvarado Terrace represent
a variety of Victorian era
architectural styles built
Housing rehabilitation: The type and
degree of assistance needed will vary with
the age of the housing and the complexity
of the problem. Until an alternative means
of providing new housing for lower
income families is developed,
conservation and improvement of existing
housing stock is the only feasible
alternative.
Discourage the demolition of affordable
housing and provide housing assistance
payments to private landlords on behalf of
eligible families, senior citizens,
homeless, and disabled/handicapped
through the Housing and Urban
Development (HUD) Section 8 Housing
Assistance Program.
Encourage HUD through the Residential
Rehabilitation Loan Program, to make
funds available for the rehabilitation of
low income multi-family rental housing.
Highway-Oriented commercial uses such
as drive-thru establishments, auto-repair,
and other similar uses should be located
away from pedestrian oriented areas.
A study to determine where one stop,
auto-oriented uses such as auto repair
shops and drive-thru establishments can
be located in order to preserve the
existing pedestrian oriented areas and the
None Contamination
from oil drilling,
vacancy, decay,
reuse,
revitalization,
costs to remove
hazardous wastes

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during the late nineteenth
and early twentieth century.
Civil Disturbance: The
Westlake Recovery Project
Study Area under the
jurisdiction of the CRA was
established at the request of
the City Council to assist in
the redevelopment and
revitalization of the
Westlake Community as a
result of the civil
disturbance which occurred
during the Spring of 1992.
The CRA through the
adoption of the Recovery
Plan must determine ways
to alleviate the impacts of
the disturbance on the
community and alleviate
other pre-existing
conditions requiring
revitalization which may
have contributed to the
unrest. The Recovery Plan
must comply with the
Westlake Community Plan
and the General Plan and
will assist both residential
and commercial
development. Displacement
of residents by
gentrification or demolition
of housing units.
Costs to remove any
hazardous wastes.
All new development or
changes should be planned
for needed jobs producing
uses that improves the
economic and physical
condition of the area.
existing streetscape.
A study to determine the opportunities
and feasibility of public improvements at
neighborhood and community shopping
areas.
The industrial sector is characterized by
smaller parcels, piecemeal development
and substandard streets, restricting the
potential for site expansions to increase
storage or production space. New
industrial development is further
discouraged by the absence of vacant
land. In spite of these disadvantages, the
industrial sector needs to be encouraged
and protected. Attempts should be made
to attract new employment generating
industries.
The City should encourage the use of
public and private resources designed to
stimulate industrial rehabilitation,
intensification, and new development.
The existing industrial areas should be
maintained and improved as a means of
providing revenue to the City and
employment opportunities for its
residents.
A study to determine the feasibility of
providing an efficient and adaptive reuse
of existing industrial areas containing
vacant land or abandoned buildings, and
along freeway rights-of-way and marginal
industrial uses. Public and Institutional
Service Systems:
Whenever possible, concepts of
intensification, rehabilitation, reuse, and
multiple use of facilities
and sites should be utilized.

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Contamination from oil
drilling (The Los Angeles
City Oil Field had over 500
wells by 1897.) The area
became a curious mixture of
residential and industrial
uses. There was no limit to
the number of wells a
property owner could drill,
and derricks competed with
Victorian towers as
elements of the built
environment. (III-11)
Unsightliness of new
construction due to the lack
of landscaping, architectural
character and scale.
Inadequate transition
between commercial and
residential uses.
33
Westwood Unsightly strip commercial
development in some
locations with poor visual
identity
Proliferation of out-of-scale
signs including billboards,
especially along Santa
Monica Boulevard.
Unsightliness of some new
construction due to the lack
of landscaping and
architectural character.
There are no large, vacant
parcels in the Community.
Most changes are likely to
occur from modifications or
adaptive reuse of buildings.
The majority of new
development is expected to
be small-scale, unless
parcels are assembled and
existing buildings
Program: Make funds available to
rehabilitate multi-family housing and to
correct code violations on small
residential buildings through the
Neighborhood Preservation Program and
HELP.
Mixed-Use Boulevard concept for
portions of Santa Monica Boulevard
whereby commercial developments could
be integrated with housing in a typically
vertical pattern. These structures would
normally incorporate retail, office and/or
parking on the lower floor and residential
units on the upper floors. The intent is to
provide housing in proximity to jobs and
services, to reduce vehicular trips,
congestion and air pollution, to provide
for rental housing, and to stimulate
pedestrian-oriented areas.
Encourage the preservation, maintenance
and enhancement of existing historic
structures, features, and sites and the
None None

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demolished.
Impact of shadows caused
by high-rise buildings
within and adjacent to the
Specific Plan area.
Housing stock degradation
Degradation of historic
sites/resources and
structures
restoration of original facades.
Program: Adherence to the City’s Historic
Preservation Ordinance and Cultural
Heritage Commission requirements for
preservation and design standards.
16-2.1 Identify and document the
Community’s historic resources.
To encourage private owners of historic
properties/resources to conserve the
integrity of such resources.
16-3.1 Assist private owners of historic
resources to maintain and enhance their
properties.
Historic Preservation: Assist private
owners of historic resources to maintain
and/or enhance their properties in a
manner that will conserve the integrity of
such resources in the best possible
condition.
Housing: Maintain and preserve the
character and integrity of existing
neighborhoods and encourage
participation in self-help preventive
maintenance to promote neighborhood
conservation, beautification and
rehabilitation.
Improve the coordination of public
services to support neighborhood
conservation activities.
Provide for a funding mechanism that
would buy out existing billboards along
Santa Monica Boulevard and prohibit
future billboards by special ordinances.
In the event the Veterans Administration
property or portion thereof becomes
surplus in the future, large portions of the
property should be retained for open
space and low intensity recreational use,
and the land annexed from Los Angeles
County.
7-2.1 Support and encourage community
based crime prevention efforts (such as

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Neighborhood Watch) through regular
interaction and coordination with
community based policing, foot and
bicycle patrols, watch programs and
regular communication with
neighborhood and civic organizations.
Program: Adherence to the City’s Historic
Preservation Ordinance and Cultural
Heritage Commission requirements for
preservation and design standards.
Program: Promote education and interest
in cultural, historical and architectural
resources, and encourage Building Code
flexibility to preserve these buildings.
Program: Utilize City historic properties
restoration programs which provide
funding for renovating and/or reusing
historic structures.
Provide for the supervision of park
activities and promote enforcement of
codes restricting illegal activities.
Coordinate with the Department of
Recreation and Parks and the Police
Department to ensure adequate police
patrols and the utilization of “defensible
space” in the design of recreation and
park facilities.
Pursue resources to clean up and activate
land that can be used for public
recreation.
Support and encourage community-based
crime prevention efforts (such as
Neighborhood Watch) through
coordination with existing community-
based policing, foot and bicycle patrols,
watch programs, and regular
communication with neighborhoods and
civic organizations.
Signs: The following signs should not be
allowed: Signs that flash, move or have
the appearance of movement; Off-site
commercial signs; Pole signs not on

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corner lots; Pole signs on corner lots,
above an appropriate maximum height;
Projecting signs that exceed an
appropriate size or height above ground
level; Roof signs; Billboards along the
Santa Monica Boulevard median.
Public Utilities and Service Systems:
Encourage mitigation measures to reduce
solid waste generation including trash
separation, recycling, source reduction,
compacting and composting.
Locate solid waste recycling centers in
the Community so long as residential
neighborhoods are not adversely
impacted.
34
Wilmington -
Harbor City
Industrial character largely
defined and influenced by
location adjacent to the Los
Angeles-Long Beach
harbors
Oil extraction and refining
activities also have a
predominant influence on
land use.
Fragmented absentee
ownership of small
industrial parcels, leaving
many scattered land sites
either vacant or
underutilized, and leading to
difficulty in assembling
usable industrial sites.
Lack of proper screening
controls and enforcement of
open storage and salvage
operations and the
substandard maintenance of
various industrial sites and
structures have been largely
responsible for eroding the
area's image and generating
nuisance complaints from
Complement the efforts for revitalization
of downtown Wilmington by promoting a
pedestrian-oriented business district using
banners, murals, street trees, kiosks, street
furniture, street lamps, benches, trash
receptacles and other pedestrian-oriented
amenities, and also landmark buildings
that will give the area a distinctive
feeling.
Promote the development of a marine-
related Community Center
Public utility, state and local government
incentive programs which offer tax credits
(revitalization zone), technical assistance
for BIDs and other capital-generating
assistance programs.
Active support for efforts to preserve and
rehabilitate older structures with special
architectural and/or cultural character.
Encourage the area to continue to develop
as a major industrial and employment
center within the Wilmington community
by attracting new industrial uses that
create jobs in the local economy.
Clean up environmentally-damaged sites
and eliminate crime problems, illegal
dumping, and unauthorized uses that
The Wilmington Industrial
Park is an irregular-
shaped area, bounded
approximately by
Anaheim Street on the
north, Harry Bridges
Boulevard on the south,
Alameda Street on the
east, and Broad Avenue
on the west. It has an ideal
location with excellent
access to the Port of Los
Angeles, the Harbor and
San Diego Freeways, and
the Alameda Corridor.
The industrial park is
designated and zoned for
Light Industry, and is
developed with a number
of industrial uses, as well
as some container and
truck storage facilities.
Some large areas of land
remain vacant and
available for development.

At the Industrial Park: The
Vacant,
revitalization,
residential
rehabilitation,
hazardous waste,
contaminated
soil, illegal
dumping ,
abandoned
railroad rights-of-
way, illegal
dumping and
other criminal
activities,
commercial
revitalization
needed, noxious
environmental
impacts of
container storage,
abandoned oil
wells, fragmented
absentee
ownerships,
environmentally-
damaged sites

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nearby residents.
Commercial: Most of this
land is currently vacant,
used for parking or open
storage, with some general
commercial.
Utilization of industrial
properties for cargo
container storage, which can
create adverse impacts when
containers are stacked to
excessive heights in close
proximity to residential or
other sensitive land uses.
Lack of maintenance of
existing housing stock,
particularly rented multiple-
family projects.
Need to promote residential
rehabilitation
Unsightly strip commercial
areas
Visual and aesthetic
problems
Unsightliness of new
construction, such as
minimalls
Adverse environmental
impacts caused by container
storage to surrounding
properties, particularly near
residential areas.
Cost to clean up some sites,
which include hazardous
waste, contaminated soil, or
abandoned oil wells.
Illegal dumping and other
criminal activities have
occurred in some industrial
areas.
Possible environmental
impacts from a variety of
discourage viable industrial uses from
locating in the area.
Revitalize and strengthen the Wilmington
CBD as the historic commercial center of
the community
Support legislation and administrative
actions which adequately allow the City
to encourage business development, such
as taxable bonds, bond pools, historic
preservation bonds, seismic rehabilitation
bonds, and use of bond financing by local
economic development corporations.
Support legislation and administrative
actions which allow the City to continue
to support small business development,
including but not limited to, small
business revolving loan funds and
commercial corridor rehabilitation
program, such as those established in the
City’s Commercial Area Revitalization
Effort (CARE) Program.
Industrial: Land use compatibility should
be achieved by including environmental
protection standards and health and safety
requirements in the design and operation
of industrial facilities, including the
following measures: Mitigation measures
for the handling, storage or transfer of dry
bulk commodities for the purposes of
reducing the potential of explosion or fire,
and reducing the emission of dust or other
particulate matter to insignificant levels.
Strict compliance with all applicable air
quality standards. These standards include
that all parking areas, driveways and
storage areas be paved to relieve dust.
Measures to abate noise, odors and
chemical discharges in the site design of
industrial facilities.
Small-scale, on-site treatment and
disposal of industrial wastes
3-4.3 All zoning, building, health and
cost of cleaning up some
sites which include
hazardous waste,
contaminated soil, or
abandoned oil wells.
Unauthorized uses are
illegally located on some
sites. Illegal dumping and
other criminal activities
have occurred in some
areas of the park.
Opportunities:
Encourage the area to
continue develop as a
major industrial and
employment center within
the Wilmington
community by attracting
new industrial uses that
create jobs in the local
economy. Clean up
environmentally-damaged
sites, and eliminate crime
problems, illegal
dumping, and
unauthorized uses that
discourage new industrial
tenants from locating in
the park.
Planning the remaining
commercial and industrial
development opportunity
sites for needed job
producing uses that
improve the economic and
physical condition of the
Wilmington-Harbor City
Community Plan Area.
Policies: 3-4.1 Develop
and protect the industrial
integrity and enhance the
long-term stability of the

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Table A2 (Continued): 35 Community Land Use Plans
No. Plan Area Expressed Pollution Ideas Expressed Cleanup Processes Brownfield Sites
Brownfield
Language
industrial uses and DWP
facilities located nearby.
The presence of many
vacant parcels, a number of
which are used for open
storage.
A number of motels are
located nearby along Pacific
Coast Highway, which have
been a source of crime
problems in the past.
Cargo container storage
facilities shall have direct
access from major or
secondary highways or
through industrial areas
with no access to such
facilities through residential
areas. Container storage
facilities shall provide
landscaped buffering, height
limitations and noise and
view mitigation measures
protecting nearby residential
areas, and no container
storage shall be permitted
within 300 feet of any
residential zone. Even
though irrigation in some
areas may not be feasible or
allowed, it is the policy to
encourage landscaping with
xeriscape sensitive plants.
Program: [Q] conditions
prohibit cargo container
storage within 300 feet of
any residential zone in most
areas, and where such
facilities are permitted in
sensitive areas, mitigation
measures such as fences or
walls, landscaped buffers,
safety codes should be strictly enforced
within the Wilmington Industrial Park,
including requiring all owners and tenants
to keep their properties clear at all times
from the illegal accumulation of junk,
trash, abandoned vehicles, weeds and
debris, to maintain a safe environment for
industrial activities and prevent nuisances
for the benefit of all property owners,
employees, and the overall community.
Program: Enforcement of zoning,
building, health and safety codes is the
responsibility of the Departments of
Building and Safety, Fire, Sanitation, and
the County Department of Health.
3-4.4 Cargo container storage should be
limited or prohibited within the Industrial
Park, and if permitted, in no instance
should operators be allowed to stack
containers more than “two-high”.
CRA can restrict or prohibit cargo
container storage through the
Redevelopment Plan for the Wilmington
Industrial Park, with enforcement being
the responsibility of the Department of
Building and Safety.
3-4.5 ...to limit access and provide a more
orderly flow of traffic, improve the visual
environment for traffic entering and
exiting from the Park, increase safety,
reduce illegal dumping and other criminal
activities, and permit the assembly of
larger parcels of land that can be more
effectively developed for industrial
purposes the Plan...
Protect significant environmental
resources from environmental hazards.
(The Plan Map designates areas,
including the U.S. Naval Reservation,
where the Palos Verdes Blue Butterfly
has been found.)
Assist private owners of existing and
Wilmington Industrial
Park in conformance with
the intent and provisions
set forth in this Plan.
Program: The
Redevelopment Plan for
the Wilmington Industrial
Park (Los Angeles Harbor
Industrial Center
Redevelopment Project)
was adopted by the City
Council on July 18, 1974,
with the primary objective
to attract labor-intensive
industries which will
provide new employment
opportunities for the
people of the community,
and to provide continued
recognition and support
for activities bringing
about the implementation
of the Plan. Owners and
tenants of property located
in the Wilmington
Industrial Park are subject
to the requirements of the
Redevelopment Plan, and
the Community
Redevelopment Agency
has responsibility for
administering the Plan.
3-4.2 Create and maintain
an industrial park
environment which will
upgrade the quality of the
community and reflect a
high level of concern for
contemporary
architectural and urban
design principles.
Within Harbor Regional

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Table A2 (Continued): 35 Community Land Use Plans
No. Plan Area Expressed Pollution Ideas Expressed Cleanup Processes Brownfield Sites
Brownfield
Language
and height or stacking
limitations are imposed,
effectuated by zone
changes, with enforcement
being the responsibility of
the Department of Building
and Safety.
3-2.1 Protect areas
designated for Industry and
proposed for the MR
restricted zoning
classifications on the Plan
map from unrelated
commercial and other non-
industrial uses, and upgrade
such areas with high quality
industrial development that
is compatible with adjacent
land use.
To improve the aesthetic
quality and design of
industrial areas, eliminate
blight and detrimental
visual impact on residential
areas, and establish a stable
environment for quality
industrial development.
To develop and improve the
Wilmington Industrial Park
into a vital and thriving
industrial center taking full
advantage of its location
near the Alameda Corridor
and the Port of Los Angeles,
providing a strong
economic and employment
base within the community.
(See “Brownfield Sites”
column.)
future historic resources to maintain
and/or enhance their properties in a
manner that will preserve the integrity of
such resources
Revitalization of the Wilmington Central
Business District should seek to protect
architecturally and historically significant
buildings and provide for their renovation
and reuse.
The Plan seeks to coordinate Port related
land use development and the circulation
system with those of adjoining areas by
providing adequate buffers and
transitional uses between the Wilmington
Community and Port.
Policy 18-1.1 Strengthen governmental
inter-agency coordination in the planning
and implementation of Port projects for
the purpose of facilitating greater
efficiency in Port operations and better
serving the interest of adjacent
communities.
Port land acquisitions and development in
Wilmington should bring about the timely
removal of blighting activities and their
replacement with uses consistent with
Port development objectives and which
enhance the physical, visual and
economic environment of the community.
Support and encourage community-based
crime prevention efforts such as
Neighborhood Watch Programs, regular
interaction and coordination with existing
community based policing, foot and
bicycle patrols, and regular
communication with neighborhood and
civic organizations
Strengthen Department of Building and
Safety efforts by allocating sufficient staff
resources to arrest blight and conserve the
housing stock by monitoring and
investigating zoning and building code
Park, there are important
ecological areas that must
be preserved. Although
urbanization has destroyed
much of the wildlife
habitat within the City,
substantial areas of
various habitat types still
exist within these areas,
including the presence of
unique and endangered
species, and their
continued existence is
essential for wildlife
protection and is a source
of interest, pleasure and
education to many people.
Small parks shall be
designed to prevent
potential negative impacts
on adjacent residents, and
provide high visibility to
prevent criminal activity.
The policy is to not permit
the development of new or
expanded industrial
facilities involved in the
handling, transfer, or
storage of commodities
categorized by law as
hazardous if it is found
that such facilities would
adversely affect the
general welfare or
community development.

365
Table A2 (Continued): 35 Community Land Use Plans
No. Plan Area Expressed Pollution Ideas Expressed Cleanup Processes Brownfield Sites
Brownfield
Language
violations and issuing Orders to Comply
with such codes.
Improve the coordination of public
services to support neighborhood
conservation activities.
Encourage reuse of the existing U.S.
Navy housing areas at the John
Montgomery and Palos Verdes sites, in a
manner that will provide needed housing
in the community without adversely
impacting the surrounding area.
Guidelines for Industrial/Residential
Interface areas: In order to mitigate
potential negative impacts generated by
manufacturing uses when they are located
adjacent to residentially zoned
neighborhoods, new development of
industrial uses shall incorporate certain
design guidelines
Policy 3-5.3 Support the initiation of an
Ordinance to require that all drilling sites
and oil production activities comply with
rules and regulations to be provided
therein, which will (a) govern the
maintenance and landscaping of drilling
sites and other oil production activities;
and (b) provide a program for the
abandonment of drilling sites that no
longer serve a useful function.
3-4.7 Identify areas adjacent to the
Wilmington Industrial Park which are
appropriate to be included within the
purview of redevelopment activity.
Program: The Plan proposes that areas
adjacent to the Wilmington Industrial
Park be studied for inclusion into a new
phase of redevelopment activity.
3-5.2 In residential areas, require that
existing and new oil well sites observe
attractively landscaped and well
maintained front yard setbacks, be
enclosed by fencing along the lot lines

366
Table A2 (Continued): 35 Community Land Use Plans
No. Plan Area Expressed Pollution Ideas Expressed Cleanup Processes Brownfield Sites
Brownfield
Language
(except for the landscaped front yard
portions), and have freshly painted oil
equipment maintained at all times.
Program: Petroleum operators participate
in a required program of beautification
and maintenance of drilling sites, with
priority given to wells in residential areas,
followed by beautification of wells in
commercial and industrial areas.
Expand existing clean-up program for
industrial lands, streets and alleys which
are beset by the illegal accumulation of
junk, trash, abandoned vehicles, weeds or
debris, and devising other appropriate
remedies to discourage the further spread
of such deterioration and blight.
Establish a local government task force to
coordinate code enforcement action in the
blighted area generally easterly of
Alameda Street and northerly of Anaheim
Street, and to study improved land use
potential and circulation needs, including
opening or closing of rights-of-way, to
facilitate improved development.
35 Wilshire
Improved appearance of
strip commercial
developments is needed,
with concise, clear signage,
better visual identity.
Signage is perceived by
residents as visually
blighting.
Industrial: Urban design
policies and standards are
needed to visually improve
converted industrial areas.
Poorly designed or
maintained parks and public
facilities can become focal
points for criminal activity
and create negative impacts
on surrounding
3-1.2 Encourage compliance with
environmental protection standards and
health and safety requirements. Program:
Continue to enforce environmental
protection standards and health and safety
requirements through the appropriate
Federal, State, County, and City agencies.
Conversion of alleyways into
neighborhood open space as outlined
under the City’s Nuisance Alley
Conversion Project.
Additional working tools within the Plan
include Specific plans, BIDs, HPOZs,
community design overlay districts
(CDOs), Streetscape programs,
Streetscape plans, Neighborhood Traffic
Mitigation Plans (NTMP), mixed use
(MU) districts, and community
None Underutilization,
revitalization of
commercial
areas, adverse
environmental
impacts of
industrial uses,
reuse, unsightly
nuisances

367
Table A2 (Continued): 35 Community Land Use Plans
No. Plan Area Expressed Pollution Ideas Expressed Cleanup Processes Brownfield Sites
Brownfield
Language
neighborhoods.
Improving the function,
design and economic
vitality of commercial areas.
Enhance the visual
appearance and appeal of
commercial districts.
redevelopment areas under jurisdiction of
the CRA.
The City’s NPP and HELP initiatives
Coordinate with the City Clerk’s Office to
assist businesses in obtaining technical
and financial assistance for the formation
of BIDs and of other programs from the
City of Los Angeles.
Underutilized public lands should be
considered for open space and
recreational purposes.
Objective 3-1 Retain existing industrial
uses and promote future development,
especially in entertainment and high
technology applications, which contribute
to job opportunities and minimize
environmental impacts.
Study the creation of a CDO to resolve
issues of visual blight along Pico and
Venice Boulevard industrial areas.
Minimize environmental impacts of
industrial uses from other uses by
highways and other physical barriers.
Encourage economic revitalization and
reuse of older industrial properties for
light manufacturing industrial uses,
especially for high technology and
entertainment-related industrial
manufacturing centers, through available
City, State and Federal incentive
programs.
Assist in the aggregation of smaller, older
sites into business park style areas, to
facilitate revitalization or reuse, where
appropriate.
Attractive buffers should be created along
street frontages of Limited Industrial
sites, for security, sound attenuation, the
separation of functional areas, and the
screening of unsightly nuisances or
unpleasant odors.

368
Appendix C:
E-Consultations with Neighborhood Council Representatives

Table A3: Neighborhood Council Responses

No.
of
NCs
1.
Are brownfields a problem in your
neighborhood?
(If yes, please describe the
problem.)
No.
of
NCs
2.
What are the major pollution
problems in your neighborhood (if
any)?
No.
of
NCs
3.
What are the major land use
problems in your neighborhood
(if any)?
No.
of
NCs
4.
How does your NC identify and
communicate about pollution and
land use problems?
3
Specific Sites: A former Nike
missile base which is now a
nature preserve that was
cleaned up by the US Air
Force; a former tank farm
under the jurisdiction of the
Port of LA and an adjacent
site which has been covered
with clean topsoil, but not
thoroughly cleaned. These
sites are under consideration
for development, but are
mostly empty except for
parking and some industrial
activity. One particular case
is the Cornfield near
Chinatown. It is a former
railroad yard that State wants
to develop into a park. They
do not have money now to
clean up and develop into
nice amenities for the
residents yet. People are not
supposed to eat the corns as
the soil is contaminated.
3
Air Pollution: Diesel emissions
(including trucks and ships)
from Port;llight pollution from
Port (AQMD’s MATES II
study shows extremely high
level of cancer risk at Point
Fermin area.)
Air pollution (the 101
Freeway)
Asthma, 405 Freeway Odor:
the Tillman Water
Reclamation plant offers a
quality of life compromise, as
it is mostly responsible for a
musty odor in the early
mornings and late evenings
that is rather unpleasant.
3
Overdevelopment
(overtaxing infrastruture)
4
Committees/Board (1): (e.g.,
Port Committee, Planning &
Land Use Committee, N.
Gaffey Steering Committee
developing vision for land
use in that area, Issues and
Traffic Committee)

369
Table A3: Neighborhood Council Responses (Continued)

No.
of
NCs
1.
Are brownfields a problem in your
neighborhood?
(If yes, please describe the
problem.)
No.
of
NCs
2.
What are the major pollution
problems in your neighborhood (if
any)?
No.
of
NCs
3.
What are the major land use
problems in your neighborhood
(if any)?
No.
of
NCs
4.
How does your NC identify and
communicate about pollution and
land use problems?
3
Not that I am aware of
2
Illegal dumping: Trash
dumped on the side of the
road; Small businesses are
responsible for illegal dumping
into our sewers.
1
Too little viable public
transportation
4
Community newsletter (E-
mail updates, website
updates)

1
Not on a major scale, nothing
to the scale of Belmont
Learning Center, for
example. We are a relatively
densely-built community and
have smaller parcels of land
that historically have been
gas stations or have seen light
industrial use.
1
In the four years our council
has been in business, our
stakeholders have consistently
told us pollution is their
number one concern. It’s also
the toughest problem to tackle,
but we have some very
dedicated people working on
it.
2
Lack of consistent
planning/zoning (e.g.,
Hollywood are being re-
developed for large
commercial and/or
residential uses. This area
also has many “Self
Storage” type operations
which are a waste of usable
space.)
2
Membership in outside
group/task force, etc.
Western Ave Task Force to
address Cal Trans & City
Issues
3
What is a brownfield?
2
Water Pollution: problem at
inner part of Cabrillo Beach;
residential gutter runoff
2
Lack of Open Space/Parks:
Maintaining current open
space, providing more
parks
3
Write letters, letters to editor,
to elected officials (including
e-mail) etc.
1
Not really
2
Traffic: Waterfront
development’s increase in
traffic
1
School overcrowding
3
Meetings, host for public,
interpersonal with officials,
etc.

1
Graffiti
1
Parking for commercial
vehicles on residential
streets
1
On-call consultant assistance

370

Table A3 (Continued): Neighborhood Council Responses

No.
of
NCs
1.
Are brownfields a problem in your
neighborhood?
(If yes, please describe the
problem.)
No.
of
NCs
2.
What are the major pollution
problems in your neighborhood (if
any)?
No.
of
NCs
3.
What are the major land use
problems in your neighborhood
(if any)?
No.
of
NCs
4.
How does your NC identify and
communicate about pollution and
land use problems?

1
Industrial Pollution: to a
moderate extent, pollution for
the light industrial
.manufacturing properties in
the area (i.e. mechanic/auto
body shops, gas stations,
garment shops).
1
the building of mixed use
housing along Ventura
Blvd. between the
405 west to Balboa--
increased density
1
Work with City departments
and agencies (CRA, DOT,
Planning were mentioned)

1
Blight: On an aesthetic level
“if that counts” blight-related
pollution such as litter,
garbage and abandoned bulky
items.
1
Obtaining viable
commercial districts
1
By being stakeholders
ourselves

2
Noise pollution
1
Maintaining historic
structures
3
Work with Council Office

Abstract (if available)

Abstract This dissertation illustrates that the concept of "brownfield" in defining and organizing the discourse on contaminated land is a social construction of Western origin, e.g., in the rapidly-industrialized economies of North America and Western Europe, that serves to focus the understanding of the problem on instrumental (legalistic, technical) meanings at the cost of the expressive (cultural), which systematically removes decision-making authority from local communities. Ultimately, this scenario robs communities of the opportunity to engage in important aspects of social expression in the form of what Mary Douglas (Purity and Danger, 1996/2002) calls "ritual purification" and the creation of "taboo" in ordering societal responses to pollution.

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