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CEQA - I’ve written for CityWatch before about Skid Row and about Los Angeles’ urban forestry policies. These two issues, however unrelated they might seem, are relevant to me given my years of living Downtown and co‑founding Industrial District Green, a volunteer‑led organization that has planted over 400 trees in Skid Row and the Arts District. I have had a front row seat to witness how profoundly unequal both cultural and environmental resources are distributed in the City. This dual vantage point is what recently led me to file a Title VI Civil Rights complaint against the City of Los Angeles.
During the COVID lockdown, I stumbled across a City Planning Recommendation Report for a massive new three‑tower development proposed for the middle of Skid Row by the Weingart organization. Buried in the document was the recommendation of a 33% reduction in required open space and a 50% reduction in required trees. For Skid Row, one of the least‑canopied neighborhoods in the entire State (I know this from grants my organization has received), with some of the highest surface temperatures in Los Angeles, this was not a small technical adjustment. It was a direct hit to a community already living with extreme environmental burdens.
I started asking questions about these proposed reductions, but no one could explain how or why Planning would recommend them for a place that needs more shade and open space, not less. Eventually, as the lockdown lifted, I set the issue aside.
Then the second Weingart tower opened. The absence of trees and greenspace around this enormous new building caused me to take a second crack at trying to understand what happened. A few months ago, I requested the full administrative record for all three towers, including the CEQA files, and began reading through hundreds of pages.
What I uncovered was far more troubling than anything I could have imagined. The timing of the project very much makes it a José Huizar easter egg.
The City used a Sustainable Communities Environmental Assessment (SCEA) for the Weingart project, a CEQA shortcut designed to speed up housing production. In theory, SCEAs are supposed to streamline paperwork, not erase environmental realities.
But in Skid Row, the SCEA became a tool for omission.
A SCEA does not require a full Environmental Impact Report (EIR), a full cumulative‑impact analysis or a standalone environmental justice chapter. But CEQA still requires agencies to evaluate reasonably foreseeable impacts and to avoid misleading omissions.
That didn’t happen here.
Instead, the City:
- deleted references to the Downtown Community Plan (DTLA 2040)
- removed a school‑impact appendix (and family housing initially promoted)
- ignored Skid Row’s extreme open‑space deficit
- avoided analyzing cumulative impacts from the second tower
- treated Skid Row differently than South Park (another neighborhood I analyzed)
- used a weaker CEQA pathway in the neighborhood with the highest environmental burdens
This isn’t streamlining. This is procedural discrimination. Skid Row Is the Most Environmentally Burdened Neighborhood in Downtown and Arguably the State.
Skid Row has:
- the lowest tree canopy
- the least park access
- the highest heat vulnerability
- a predominantly Black population
Yet the City chose the CEQA pathway that requires the least analysis. Why does Skid Row get the shortcut? Why does Skid Row get the omissions? Why does Skid Row get the cumulative harm? These are not rhetorical questions. They are civil rights questions.
What I Found Was Serious Enough to File a Title VI Complaint
After reviewing hundreds of pages of CEQA documents, internal drafts, and related materials, it became clear that the City’s approach to environmental review in Skid Row wasn’t just sloppy - it was structurally unequal. The omissions weren’t random. They formed a pattern: avoiding analysis, avoiding obligations, avoiding cumulative impacts, and avoiding environmental justice.
Title VI prohibits discrimination by any agency or program that receives federal funds, and the multiple City departments involved in approving this project do. When a federally funded agency repeatedly uses the weakest environmental review in the neighborhood with the highest environmental burdens, and when those omissions disproportionately affect a predominantly Black and low‑income community, that’s not just bad planning. That’s a civil‑rights problem.
This Isn’t About Stopping Development - It’s About Equal Protection
Skid Row residents deserve the same level of environmental review as residents in South Park or the Arts District. CEQA is supposed to make impacts visible, not bury them. It’s supposed to prevent exactly this kind of procedural erasure.
The City Must Cure This Pattern
Under Title VI, once a federally funded agency is made aware of a discriminatory pattern, it has an obligation to correct it. That is why my complaint focuses on one core requirement: the City must cure the unequal environmental review it applies in Skid Row. That means applying the same level of analysis, the same scrutiny, and the same cumulative‑impact evaluation that other Downtown neighborhoods receive. This isn’t just a planning issue or a CEQA issue, it’s a civil‑rights obligation. The question is whether the City applies its own laws consistently, or whether Skid Row continues to be treated as an exception.
The Problem: CEQA Streamlining in Skid Row Isn’t Neutral
If Los Angeles wants to build in Skid Row, and it will, then it must stop using CEQA streamlining as a way to avoid acknowledging the neighborhood’s environmental reality. Skid Row deserves more than shortcuts. It deserves justice.
(Katherine McNenny works in Los Angeles' garment industry as a Patternmaker and lives Downtown. She is co-founder of Industrial District Green, an organization that has planted over 400 trees in the area. Her focus is on issues that affect the Skid Row neighborhood and how to improve City urban forestry policy.)
