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17 Sw. U. L. Rev. 1 (1987-1988)
AB 283 - A Zoning Consistency Odyssey

handle is hein.journals/swulr17 and id is 11 raw text is: AB 283 - A ZONING CONSISTENCY
Anthony Saul Alperin*
In 1978, the California Legislature enacted AB 283,1 thus initiating
Los Angeles' zoning consistency odyssey. That odyssey has resulted in
several major lawsuits and the expenditure of vast amounts of time, effort
and financial resources toward the goal of bringing the City's zoning and
general plan into consistency. The purpose of this article is to trace this
odyssey with particular emphasis on the legal issues which have sur-
rounded it. Although the legislation involved and the litigation which
has interpreted it have peculiar significance for the City of Los Angeles,
the legal principles discussed in this article should be of interest to any-
one concerned about land use planning, either from a legal or a policy
Each city in California, including charter cities, is required to adopt
a comprehensive, long term general plan for the physical development
of the . . . city ... 2 The general plan is intended to serve as an
effective guide for orderly growth and development of the city.' Until
the enactment of AB 283, state law4 required only general law cities to
. bring zoning into consistency with their general plans. All charter cities
were exempt from this requirement. However, with the enactment of AB
283, Los Angeles became the only charter city in California to bear this
* Mr. Alperin is an Assistant City Attorney for Los Angeles. He received an A.B. from the
University of California at Berkeley (1968) and a J.D. from the University of California at Los
Angeles (1971). The views expressed in this article are his own and do not necessarily represent the
views of the Los Angeles City Attorney.
1. AB 283 was the bill introduced in the California Legislature resulting in the enactment of
subd. (d) of CAL. Gov'T CODE § 65860 (West 1983). The new law, which became effective in 1979,
is popularly and generally referred to by its bill number.
2. CAL. GOV'T CODE §§ 65300, 65302 and 65700 (West 1983 & Supp. 1986).
3. Id. § 65400 (West 1983).
4. Id. § 65860 (West 1983).

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