SR-6-O (4)
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APR 2 2 1986
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M/lv - 6 1986
C/ED:CPD:DKW:klc:lJw
COUNCIL MEETING: 4/22/86
Santa MonIca, CalifornIa
TO: Mayor and CIty Councll
FROM: CIty Staff
SUBJECT: RecommendatIon to Set a PublIC Hear Ing on f1ay 13 to
ConsIder the Land Use Plan of the Local Coastal Program
INTRODUCTION
A Local Coastal program (LCP) is requIred by state law. The
draft Land Use Plan (LUP) of the CIty'S LCP was forwarded to the
CouncIl and PlannIng CommIssion on September 18, 1985. The
PlannIng CommISSIon conducted a PublIC HearIng on the matter and
forwarded ItS comments, together WIth a recommendatIon that the
LUP be adopted, to the CIty CouncIl.
In antICIpation of receIpt
of Coastal CommIssIon staff comments on the LUP, a CIty CounCIl
hearIng on the matter was postponed. Coastal staff comments were
receIved on January 31, 1986. The CIty staff recommendatIons for
LUP rev ISlons reflect a var Iety of concerns expressed by the
Coastal CommISSIon staff.
ThIS staff report recommends that the CIty CouncIl set thIS
matter for PublIC HearIng on May 13, 1986.
In the InterIm,
Interested persons can reVIew the revIsed draft LUP.
BACKGROUND
State law reqUIres each coastal JurIsdIctIon to prepare a Local
Coastal
Program (Lep)
that addresses
reqUIrements of the State,_a
APR 2 2 19&6
Atz, Ii> ')-E
MAY . 6 1986
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Coastal Act. LCP's prepared by local Jur1sd1ct1ons are subJect
to reView and certlflcatlon by the CalifornIa Coastal Commlsslon.
Once the LCP is certif led, respons 1bll1 ty for ImplementatIon of
State Coastal Act proVIsIons reverts to the local government. A
local government may submIt ltS entlre Local Coastal Program at
one tIme or 1n two separate components: the Land Use plan (LUP),
showIng the permItted uses and settIng out polICIes for carrY1ng
out the goals of the Coastal Act; and the ImplementIng
Ord1nances, wh1ch 1mplement the po11c1es specified 1n the Land
Use Plan. Under 1981 leg 1slatIon, a local gove rnment can take
Over Issuance of coastal permIts once the Land Use Plan portion
of the Local Coastal Program has been approved by the Coastal
Comm1ss1on. Sectlon 15265 of the State CEQA GUldellnes exempt
preparatIon of an LUP from the prov1s1ons of the Cal1forn1a
Envlronmental Quallty Act.
Santa MonIca has chosen the optIon of subm1ttlng 1tS Local
Coastal Program 1n two stages. The fIrst component IS
preparatIon of the Land Use Plan. The LUP IS conslstent WIth the
CIty'S General Plan, prImarlly the Land Use Element and addresses
the reqUlrements of the CallfornIa Coastal Act. The ImplementIng
Ordlnances wlll follow Coastal CommISSlon reV1ew and approval of
the Land Use Plan. The Clty staff Intends to Implement the LUP
pr lffiar 11y through the reVlsed Zonl.ng Code, although development
of some speCl.al l.mplementatl.on programs may also be necessary.
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PLANNING PROCESS
The or 19 lnal ver Slon of the Coastal Land Use Plan (LUP) was
approved by the CIty Councll on January 14, 1981, after
conductlng extensl ve local wor kshops, publlC hear Ings and
draftIng of POlICY language. The process included partIcIpatIon
of a Local Coastal Program advIsory commIttee, comprIsed of
member S of the pUblIC, PlannIng ComIDlSS Ion and CIty staff. In
February, 1981, the RegIonal CommIsSIon staff reJected the LUP
submI ttal as being incomplete pr Imar Ily because the LUP dId not
Include a Land Use Map. On Aprll 12, 1981, the Santa MonIca CIty
CounCIl rescInded the prevIously submItted LUP so that the
HOUSIng and VIsual QualIty Components could be revIsed to reflect
changes in local opInIon on polICIes formulated In each of these
components.
Subsequently, the CIty began to re-examIne CItY-WIde plannIng and
development Issues, resul tlng in the eventual adoptlon of new
HOUSIng, Land Use, and CIrculatIon Elements of the General Plan.
Because thIS broad plannIng effort would affect the Coastal Zone
as well as all other areas of the CIty, substantIal work on the
LUP was not begun untll overall land use and development
standards were determIned through the CIty-wIde plannIng process.
In 1982, as thIS comprehenSIve CItY-WIde plannIng process was
underway, the Cl ty retaIned a consul tant to prepare a revised
draft LUP. In January, 1983, a revIsed prelimInary draft LUP was
submItted to the Coastal staff for reVIew. Coastal staff dId not
respond WIth comments untIl September, 1983, when reVISIons to
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the January 1983 prelImInary draft were suggested. At thIS same
tIme, IntenSIve work on the CItY-WIde Land Use and CIrculatIon
Elements was reachlng a key stage so further reVISlons to the LUP
were deferred untll after adoptlon of the reVIsed General Plan
Elements.
The 1986 draft LUP Incorporates much of the precedIng plannIng
efforts, such as the 1981 LUP and the development standards
adopted In the Clty'S Land Use Element. ThlS LUP also reflects
current condItIons of and plannlng for the PIer and the ThIrd
Street Mall. The proposed LUP includes standard Coastal Act
pollcles that have been tallored to the CIty'S local
character IStlCS, and development pollcles from the Ci ty' S Land
Use Element.
ORGANIZATION OF THE LAND OSE PLAN
The LUP IS dIVIded Into SIX chapters. Chapter I descrIbes the
background and purpose of the Local Coastal Plan. It prOVIdes a
brIef hIstory of the State's mandate to protect the CalifornIa
coastllne for future generatlons by plannIng for the orderly
development of thIS valuable resource. It also descrIbes Santa
MonIca's role In that plannlng effort.
Chapter II descrIbes In detail the Coastal Zone of Santa MonIca.
For ease of analYSIS and because of the var lety of land uses
WIthIn the Coastal Zone, the Coastal Zone has been dlvlded Into
eIght subareas. ThIS chapter descr ibes cur ren t condl tlons and
the coastal Issues that arIse In each subarea.
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Chapter III d~scusses five maJor pol~cy top~es:
Access
Recreat~on and V~s~tor Serv~ng Fac~lit~es
Env~ronmental Qual~ty
ScenIc and VIsual Resources
Development
The d~ScussIon of each top~c Includes the eXIstIng cond~tIons as
well as some of the opportunItIes, problems, or constraInts that
currently eXIst.
Chapter IV ~s the pIvotal component of the Land Use Plan. It
contaIns the specifIc polICIes organIzed by Issue group, adopted
for the COdstal Zone In Santa MonIca.
Chapter V descrIbes the potentIal Impact of the plan on varIOUS
subareas of the Coastal Zone and Chapter VI ~ntroduced the
~mplementatIon program to be completed once the Land Use Plan IS
adopted and certIfIed. The entIre Land Use Plan IS summarIzed In
a Land Use Map.
ADOPTION PROCESS
The PlannIng CommISSIon's reVIew and comment on the LUP was the
fIrst step In the adoptIon process. The CIty Counc~l must adopt
the LUP, and forward it to the CalIfornIa Coastal CommISSIon for
eer tIfIcat~on. AdoptIon of an LUP by the CIty, WIth eventual
eertI f Ica t~on by the CalIfornIa Coastal CommIss Ion, IS cr 1 tIcal
for several reasons. W~thout a certlf~ed LUP, most types of
development: ~n the CI ty I S Coastal Zone must obtain a Coastal
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permIt In addltlon to any requlred Clty permIts. ThIS Coastal
permIt reqUIrement Imposes sIgnIfIcant tIme delays on development
proJects, as well as creatIng duplIcatIve reVIew procedures.
CertIflcatlon of Santa Monlca's LUP WIll allow the CIty to Issue
development permIts In the Coastal Zone WhICh currently must be
Issued by the Coastal CommISSIon.
In addItIon to private developers, the CIty Itself IS also
subJect to Coastal permIt reqUIrements. One major MunIcIpal
proJect WhICh IS SIgnIfIcantly affected by the lack of a
certlfled LUP IS PIer RestoratIon. The CalIfornIa Coastal
Conse rvancy approved S 1,000,000 In ass Istance to the CIty for
development of the pier Carousel Park. However, by the terms of
agreemen t WIth the Conservancy, the CIty cannot draw down on
$850,000 of these funds untIl an LUP IS certIfIed. ThIS
sltuatIon creates a contInuIng negatIve balance In the PIer Fund,
and effectIvely results In SIgnIfIcant opportunity costs for
Santa MonIca, SInce the CIty must utIlIze Its own funds for the
proJect.
PLANNING COMMISSION REVIEW
The CommIssIon I S reVIew of the LUP focused on Chapter IV WhICh
contaIns POlICY statements, and on the proposed par kIng
standards. The PlannIng CommISSIon's comments on the POllCY
sectIon are set forth In ExhIbIt B of thIS staff report. Staff
concurs WIth most of the POlICY recommendatIons, as reflected In
the recommended reVISlons shown In ExhIbIt A. AddItIonal reVIew
by the PlannIng CommISSIon does not appear necessary at thIS
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tlme, Slnce most of the LUP reV1Slons are technlcal 1n nature and
are conslstent Wlth eXlstlng Clty POllCY.
COASTAL COMMISSION STAFF COMMENTS
On September 17, 1985 a copy of the draft LUP was sent to the
Ca11fornla Coastal Comm1sslon staff for reV1ew. The Coastal
CommISSIon staff responded 'tnth comments (ExhIbIt C) on January
31, 1986. One of the comments was that more detalled LUP maps
be prov1ded. CIty staff recommends that the CouncIl authorlze
staff to prepare such maps.
The Coastal staff also ralsed a number of other concerns. The
Coastal staff stated an assumptlon that a number of Clty
documents ment10ned 1n the LUP, such as the Pier Development
GU1del1nes and the Houslng Element, were proposed for
1ncorporat10n lnto the LUP. ThlS was not the intent of Clty
staff, so whenever posslble, references to these documents have
been deleted In the revlsed LUP so that the Coastal staff1s
reVlew wlll focus on the LUP, rather than on other Clty p1ann1ng
documents.
The Coastal staff was also concerned about the Inclusion of
par klng standards in the LUP, Sl.nce such standards are usually
establl shed through lmplemenc.l.ng zonlng ordlnances. Therefore,
the parklng standards have been deleted 1n recognIt1on of the
Coastal staff I s concern, and also because the pendlng C1ty-wlde
draft Zonlng Ordinance contains proposed parkIng standards.
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The Coastal staff also stated a concern regardIng access to the
beach north of Santa Monica PIer. However, Cl ty staff belIeve
that g~ven ex~stlng geographical, c~rculatlon, and ownership
realItIes, the beach access provIded by the eXIstIng beach
par kIng lots, pedestr Ian overpasses, and Pac If lC Coast HIghway,
whIle not Ideal, IS adequate. CIty staff agree wIth Coastal
staff that one SIte where publIC access may be Improved In this
area IS at the Sand and Sea Club SIte. The CIty IS In the
process of explorIng alternatIve uses for thIS SIte WhIch would
Improve publIC access.
The Coastal staff also suggested that Santa Monica commI t to a
coastal-area shuttle system to improve coastal access. CIty
staff belIeves that InvestIgatIon of a shuttle system IS
appropr 1a te, but absolute commItment to such a system In the
absence of exper lence as to its effectlveness and cost is not
advIsable. Therefore, the proposed LUP Includes polICIes WhICh
call for ImplementatIon of a shuttle system If feaSIble.
The Coastal staff also indIcated a concern with resldent1.al use
and development In the north beach area west of PaCIfIC Coast
HIghway, the Oceanfront area between P1.CO and Colorado west of
Ocean Avenue, and on Ocean Avenue north of CalIfornIa Avenue.
rhe Coastal staff suggested that these areas would be best
planned for viSItor-servIng uses. However, the CIty staff does
not belleve that removal of reSIdentIal uses In these areas would
be desl r able, practlcal or appropr late. SImilar ly, the Coastal
staff lndIcated a concern WIth the eXlstlng MaIn Street
development standards whlch Ilffi1t some VlS1.tor-servlng uses such
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as restaurants and bars. The Coastal staff stated a concern that
MaIn Street mIght become developed prImarIly wIth banks, offIces
and other general commercIal uses. However, It IS belIeved that
eXIstIng restrIctIons on certaIn uses are approprIate, and
further that banks, offIces and general commercIal uses provide
important goods and serVIces necessary to the commun!ty, and that
gIven the character of Maln Street, 1t IS unlIkely that
VISItor-servIng uses would be dIsplaced.
Another concern of the Coastal staff was addl tIonal residentIal
development 1n the reSIdentIal areas of the CIty'S Coastal Zone,
such as Ocean Park and the area north of WilShIre and west of 4th
Street. WhIle the CIty staff shares the concern WIth the denSIty
of reSIdentIal development, 1 t IS belIeved that ex lstIng
development restrIctions satisfactorIly address thIS matter. The
Land Use Element recently reduced allowable denSIty on R2, R3 and
R4 zoned land. The Land Use Element EIR found that substantIal
numbers of additIonal reSIdentIal unIts would not create
SIgnifIcant Impacts on the Infrastructure, CIrculatIon, or publIC
serVIce systems of the CIty. Further, the CIty'S Rent Control
law effectIvely lImIts l"ecycllng of many propertIes to hIgher
denSIty.
After the CounCIl adopts the LUP, It IS antICIpated that any
dIfferIng VIeWpOInts between the CIty and the Coastal CommlSSlon
WIll be dIscussed extensIvely and ultImately resolved In a manner
satisfactory to both partIes.
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RECOMMENDED REVISIONS TO LUP
In response to comments and suggestlons of the PlannIng
CommISSIon, Coastal CommissIon staff, members of the publIC and
Cl ty staff, a number of changes to the LUP are recommended for
Councll approval. These changes are set forth In Exhib~t A.
Most of the changes are technical In nature. Generally, the
reVISIons fall Into one of several categorIes:
o ClarIfIcation and updatIng of background InformatIon.
o Reduction In the level of detaIl In background InformatIon on
varIous tOPICS, such as the marine envIronmental settIng and
the PIer, to create a more conCIse and focused document.
o ClarIfIcation of POlICY intentions.
o ReViSions to polICies to reflect concerns of the Planning
CommISSIon, Coastal CommISSIon staff, members of the publIC
and CIty staff.
o ElImInatIon of a number of policies which are already set
forth in the city's Land Use and ClrculatIon Elements.
o
Deletlon of the
CIty-wIde parkIng
further modif1.ed
Ordlnance.
proposed
standards
LUP parkIng standards,
SInce
currently exist and WIll be
through the
adoptIon of a rev Ised ZonIng
A varIety
productlon
of
of
edItIng
fInIshed
changes such
graphICS WIll
as page renumberIng and
occur followIng CouncIl
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actIon and prIor to transmIttal of the adopted LUP to the Coastal
CommISSIon.
BUDGET/FISCAL IMPACT
Approval of thIS report WIll result In no flnanclal or budgetary
lmpact.
RECOMMENDATION
I t IS respectfully recommended that the CIty Counc 11 set thIS
matter for PublIC Hearlng for May 13, 1986.
ExhIbIt A: ReVIsed LUP
B: PlannIng Commlsslon Comments
C: Coastal CommISSIon 1/31/86 Letter
Prepared by: D. Kenyon Webster, SenIor Planner
CIty Plannlng DlVlSlon
CommunIty and EconomlC Development Department
ccdlcp
4/l5/86
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STATE OF CALIFORNIA-THE RESOURCES AGENCY
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Exh~b~t C
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GEORGE OEUKMEJIAN Go~mor
_ CALIFORNIA COASTAL COMMISSION
SOUTH COAST AREA
243 WEST BROADWAY SUlTE 380
LONG BEA.CH, CA 90802
{213j 590-5071
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January 3l, 1986
Ann Siracusa
Director of Planning
City of Santa Monica
1685 Main Street
Santa Monica, CA 90401
Dear Ms. Siracusa.
This letter provides the City with our comments on the revised
draft Santa Monica Land Use Plan (LUP) dated September 1985. We
welcome the opportunity to comment on the LUP text and policies so
that revisions can be considered before final action is taken on the
draft LUP by the City Council. Our comment letter includes a
summary of major Coastal Act concerns related to the five individual
LUP components, and a pollcy-by-policy analysis of proposed LUP
policies. These LUP comments represent the views of the Coastal
Commission staff involved in reviewing the Santa Monica Local
Coastal Program (LCP), and do not necessarily reflect the views of
the Coastal Commissioners.
The format of our comments is a general analysis of the overall
organization and content, followed by comments on the background and
issues sections (Chapters II and III). a policy-by-policy analysis
of Chapter IV. comments on the Land Use Policy Map. and finally
comments on Chapter V. Impacts.
The revised draft of the LUP is better organized and easier to
follow than the 1983 and earlier drafts. However we would like to
see the referenced background documents before we conclude our
formal review of the LUP draft document. The Pier Restoration and
Development Guidelines. the Scenic Corridor, Housing. and Land Use
Elements of the General Plan, the Sand and Sea ClUb use criteria and
all other City planninq documents proposed for incoproration should
be part of this document, either attached or specifically noted in
the LUP. Chapters I and II contaln minor typos however, creating
discrepancies between the aap aAd fiqure numbers and the references
to them in the text, as well as the number of subareas stated in
paragrapgh 2 on page 8 and the number of subareas listed.
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The pu~pose fo~ the inclusion of Chapte~ VI: tapIementation is
unclear. The proloque of the document states that this chapter
introduces the implementation proq~am to be completed once the Land
Use Plan is adopted and certified. While we appreciate a preview of
these standards. since they are not a pa~t of the LUP submittal. we
will reserve detail comment on them until the draft submittal of the
implementation program. However. a general comment is that they are
substandard and vague in some cases.
Chapter II: Santa Monica's Coastal Zone
Subarea 1: Santa Monica State Beach. A map Showing the
location of the beach pUblic parking lots and their capacity would
better illust~ate the pUblic facilities available in the area.
Subarea lA contains fairly detailed analysis of auto. pedestrian.
transit and bicycle ascess to the north beach area. This
information more appropriately belongs in Chapter III under Access.
This section also mentions the criteria for the future use of the
Sand and Sea Club. If that criteria is to be adopted by ~eference
into the LUP. we need to ~eview the document.
suba~ea 2 The paragraph on pedestrian access to the Pier
should also more appropriately be included in the access chapter.
As stated earlier. the pier Restoration and Development Guidelines
should also be submitted for our review.
Subarea 3 The last paragraph of this section concerning
parking should also be moved to the Access chapter in the
appropriate access mode section.
Subarea 5 The information contained in the last paragraph
of this s~~~ion also should be qenerally located in the Access
chapter, The last sentence of this paragraph needs clarification.
The Parking Assessment District is located in the downtown subarea.
The only downtown area not within the District is the approximately
one block area from the south side of Broadway to the Santa Monica
Freeway and the half block area from the north side of WilShire to
just notrh of Wilshire. Because most of the area is within the
District there is no requirement that development provide support
parking. Therefore. office buildlngs in the downtown area generally
do not provide their own parking. The provision of support parking
for office development in the downtown area is an exception rather
than the rule. Only very large office developments within the
District have been required to provide their own parking.
Subarea e A map of the preferential parking district
would help in better understanding the parking situation and
on-street capacity. The Main Street Master Plan document should
also be SUbmitted for staff review so that a land use analysis can
be made.
Subarea 9. Is the City contemplating any measures aimed at
preserving the character and scale of the South Beach Tract
communlty? The status of the Ocean Park Redevelopmnet Project
should be updated. ~e II has also been built~d constuction has
begun on the public on-site park and the parking lot, parks and road
improvements as well as the Phase III condominiums at Ocean Park
Blvd. and Neilson Way.
Chapter III: Coastal Zone conditions and Issues
Access We disagree with the last sentence of the first
paragraph on page 30 that states that there remains ample publicly
owned parcels and parking lots that provide convenient and adequate
access to the sand. This statement is contrary to earlier
statements that access to the north beach is difficult largely
becau~e of limited public parking facilities. interspersed among
private residential development. which fill up quiCklY. It is
further stated that the only safe vertical pedestrian access to the
north beach is by way of the five bridges over the Coast Highway
which are impractical for the very young, and the elderly since the
use of the bridges necessitate climbing the stairs of the steep
Palisades bluffs.
Parking counts for the 16 beach parking lots contained in the
1983 draft LUP indicates that in 1981. the average percent usage of
the south lots was between 66 and 76\ on summer weekdays and between
III and 166\ on weekends. Similarily usage of the north lots was
even higher at 80 to 102\ during summer weekdays and 110 to 172\ on
the weekends.
The LUP states that there should not be a significant increase
in land area devoted to ~3rking uses but that existing beach lots
may be reconfigured to pr,vide more parking spaces. It is unclear
as to whether this statement applies only to the lots located
adjacent to the beach or other lots within the coastal zone which
can be considered as beach lots. specifically Main Street lots.
This statement can also be construed to preclude the construction of
badly needed parking area for the Main Street visitor-serving
commercial area. Also the intent of this statement should be
clarified. i.e. if it 1S for scenic and visual resource concerns for
parking areas located between the first pUblic road and the
shoreline. We cannot support this statement without further
clarification as well as an alternative plan to enhance access to
the most heavily used beaches in the entire Los Angeles County area.
Without additional parklng areas. there must be a commitment to an
effective beach shuttle program among other access alternatives.
Page 33 contains a statement that there are 4.700 parking spaces
in eight pUblic parking structures in the downtown area providing 3
hour free parking. as well as 276 additional spaces in public lots.
while on page 21 it states that there are six structures provlding
much less pUblic parking capacity. The December 1984 Technical
Background Report of the Third Street Mall Specific Plan states that
there are six publicly-owned parking structures in the downtown area
providing 2.749 spaces. This discrepancy shcu]a be rectified in
order to obtain a clear picture of the pUblic parking availability
which can be used to provide additional beach parking
While we WhOleheartedly endorse the implementation of a shuttle
system to the beach and other coastal recreation areas of the CIty,
we would discourage4lte beach lot as a shuttle4llrking lot. We
would prefer that the beach lots be reserved for those wishing to
visit the shoreline as a primary destination and that the peripheral
lots be used as shuttle parking for those wishing to visit the other
recreational and shoppping coastal areas as well overflow beach
parking. What are the parking arrangements for the existing shuttle
system?
Recreation and Visitor-servinq Facilities
Santa Monica Pier and Breakwater Pages 44-49 contain too
aucb detail on pier restoration activities. studies and
alternatives. It would be sufficient to include only the chosen
alternative and the basis for that choice.
Scenic and Visual Resources. This section identifies four
categories of viewshed. Is it the City'S intention to use these
categories in formulating scenic and visual resource protection
standards? The relationship of these categor~es to protection
policies is unclear.
We will need to review both the Scenic Corridor and Land Use
Elements of the General Plan to adequately comment on this section.
In conclusion, we hope our comments will be of help to you and
City planning staff as you consider further revisions to the current
LUP draft document. We look forward to meeting and working with you
in your new position as planning director. Commission staff would
be happy to meet with you and your staff to discuss the concerns
detailed in this comment letter and attached policy analysis as well
as any other LUP issues you would like to discuss. Thank you again
for giving us the opportunity to provied advance comments on the LUP
prior to local adoption of the document.
Sincerely.
VI ; 'if I J J
{,,{j,,~..K- LA/CCO""'-r
l/ Robert Joseph
[--Coastal Program Manager
cc: Kenyon Webster
Ruth Galanter
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SPECIFIC COMMENTS ON LUP POLICIES
To preface our remarks on each component's policies. we'd like to
stress to th@ C~ty staff that a Land Us@ Plan should cons~st of
policies which provide spec~f~c and concise development standards
and criter~a Many of the polic~es are vagu~ as they do not give
clear direction Our primary concern in the City's LUP is the lack
of specificity in dealing with standards and direction. Th~
vagueness of some of the poliCies could potentially lead to a
situatlon where land us~ d~cisions might b~ made bas~d on discretion
instead of clear directives of the land use policies. The LUP must
be specific and cl~ar in its pOliCY language so that future coastal
development will be conslstent wlth the Coastal Act We would like
to pOint out that our alternatlu~ policy language is only on~
suggested method of revislon. There may be other ways to address
our concern over the suggested language
Qeneral POllCY Section
POI1C~ 3. Th1S pOliCy is clearly and correctly stated here
However, on the preViOUS page, the second paragraph says, IInothlng
ln thiS plan shall reduce or remove requirements from other plans"
Sometlmes a conflIct may result in a policy from another plan beIng
laId aSIde Therefore, the second paragraph on page 74 must reflect
the statement In POliCY number 3. The thlrd paragraph dealIng w1th
hOUSIng also creates confUSIon In this respect Page 74 contains a
statement that the hous1ng pollcles of the General Plan WIll apply
ln the Coastal Zone As thIS statement could be construed to make
these polICies part of the LUP, we need to reVIew them They should
be submItted along WIth this LUP document and can be adopted as part
of lt by reference
Pollcy 4 Thls pol~cy doesn't go far enough to speCify the methods
by WhiCh thIS POlICY Will be carrIed out
POlICY~. ThiS policy must clearly IndIcate that there cannot be
interference with establIshed use after an accessway has b~en
dedIcated but not yet opened
POlICY 7 ThIS polley should also include access from Barnard Way
and Appian Way to Include access from the fIrst publIC road for the
entire length of the coastline POllCY 7 must also reflect POlICY
4 POlICY 7 says that access shall be prOVIded It should say
"maXimum access 1n accordance WIth policy 4 shall be prOVIded
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yoliCY 11 Is maXImum access for these groups to be Implemented in
new development or IS this a separate proJect for implementatIon 1n
Phase III of the LCp?
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Policy 12: This policy is inadequate The Coastal Act requires
that access be maximized and "prov~dedll in new development projects
except under very spec~f~c c~rcumstances "Assisting" ~s not
enough. Also, "remodeling" and "ins~gnificant additions" are not
spec~f~c enough terms. There should be critiera w~th regard to the
circumstances under wh1ch m1tigatlon may be substituted for access
If there are long stretches of beach with no access, even with
mitigation, certa1n areas will not carry their fair share, as people
would have to walk long dlstances, It is unclear as to how a beach
shuttle or tram w11l enhance and maximize lateral public access. A
more appropriate mitigation for lateral access enhancement for new
development with beach frontage would be to part1cipate 1n the
extension of the bikepath in the north beach area Other poss~ble
mitigation for actual vertical access is partic~pation ~n the
provl5ion of shuttle turn-outs or stops or benches. In general, It
may be argued that shuttles can serve as ad~quate parking
substltutes but actual vert~cal accessways are also necessary to get
the pub12C onto the sand.
pollcy 13 Again "insignlflcant additions II must be def~ned
What lS the rationale for seeking vertical accessways every SOD feet
~n thlS stretch of the beach? How far apart are current vertlcal
accessways? What 15 the distance between vert1cal accessways In the
north beach area and the rest of the south beach? Would th~
prOV1S1on of vertlcal accessways every 500 feet only 1n th1S stretch
maXlmlZ@ acc@ss as the Coastal Act requ~res?
E.Ol1CY 1~ What 1S meant by lIopen equally"? Perhaps a morE>
appropr1at@ use of these facl11tles 1S a publIC use or commerc~al,
retall or some other VIs1tor-serving use as opposed to a prlvate
club WIth open membershlp A change in the land use deslgnatlon or
zonIng should be cons1dered.
~qllCY 16 What 15 the reference to th1S l~mlt? These k~nd of
trafflc control measures could create beach access problems If
thes@ types of measures are attempted, they should be carried out
conslstent w1th the publIC access polICIes of the Coastal Act
POllCY 1~ Th~s POllCY should also seek to lmprove automoblle
access to the north beach area also
?ollcy 18 The slgnlng program should also lnclude shuttle
informatlon, Includlng the route, frequency, cost, the locatlon of
remote lots, etc
Polley 19 ThIS POllCY creates the potential for traffIC Jams
thereby reduclng access An effectlve Slgnlng program (pOllCY 18)
should ald In reduc1ng res1dent1al trafflc If a ne1ghborhood
assoclatlon 1S Implemented, then a prlmary concern and goal of the
assoclation shall be assurance that the publlC access r1ghts a~d
methods are preserved and enhanced
POIlCY 20 Does thls lnclude new residentlal development also?
ConSlstent with the Coastal Act access pol~cies, Reglonal
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Interpretive GUIdelines were adopted by the Commission WhICh also
contaln general information on support parking In conJuction with
development and access to these faCIlIties To avoid adv~rse
Impacts on traffic and existing on-street parking, new development
should aVOId addltlonal curb cuts and take access from alleys or
secondary streets. Any attempts to control access pOInts of new
devplopment must also bp consistent with the adopted GuidelInes and
the publlC access policies of the Coastal Act
policy 21. "SignifIcant publIC benefIt" must be defIned and
criterIa for l.ts determinatl.on. lINearby" must also be quall.fied
The ratio of replacement parking must be specified as well as l~mIts
set on the proximIty of the replacement parking.
POIICY 22, IISignifIcant increase" is vague. Do~s thlS policy
encompass the entire coastal zone or Just the parkIng lots adjacent
to the beach? Does this POllCY apply only to land used soley or
primarIly for parking or does It also Include parking to support new
development? All new development must provlde adequate support
parklng The substItutIon of new parkIng land for eXIstIng parking
land could create problems If the new land is not in close proximlty
to the development lt is to serve. If the intent of thlS POllCY 15
to protect scenlC coastal views from expanses of asphalt, then
parking areas located between the first public road and the
shoreline should be treated separately than those located
elsewhere However intens1fication of existlng parklng faclllt~es
wlth the us~ of parking structures wlll also lmpact scenIC and
vlsual resources This policy may result in a llmltation on new
deuelopment If new parkIng land IS precluded.
POllCY 23_ WIll pedestrIan, cyclist, and skater access through
publIC parking lots be maintaIned and enhanced at the expense of
parklng spaces If parking spaces are removed WIll they be replaced
in accordance WIth POlICY 21 or IS thIS an exceptIon to policy 21?
POlICY 24 We would have to reVIew Artlcle XX of the CIty Charter
before commentIng on this POllCY. The parklng standards and other
requlrements for the Tenant Ownershlp RIghts converSlon projects
must be consistent WIth the prOVIsions of the Coastal Act.
POlICY 25 Although this IS a key POllCY it 1S written In
non-commIttal language It IS also lackIng in the speCIfICS as to
how thIS POllCY (If at all) wlll be carrled out. Many of the other
pollcles of the LUP are contIngent upon the Implementation and
malntenace of an effectIve and viable shuttle system WIthIn the
Santa MonIca Coastal Zon~ as an alternative to additIonal parkIng
and the better ut~lization of ex~sting park1ng areas other than the
lots adJacent to the beach The City must be commltted to the
implementatIon and maIntenance of a VIable shuttle system We have
actIv~ly endorsed a shuttle system for nearly ten years
POllCY 27 Are these to be munICIpal bus or shuttle bus shelters?
CoordInatIon WIth the munIcipal bus llnes would be necessary to
establIsh new bus stops If It IS not approprIate for a d~velopment
to provlde a bus shelter or other fIxed faCIlity, payment Into an
In-lelU fee could be reqUIred to help fund the shuttle system
Crlterla, howeuer must be establIshed
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Policy 29~ This polley is not written in an objectlve manner with
verifiable standards. As we commented in the analysls of polley 25.
the implem~ntatlon and maint~nance of a viable shuttle system should
be a polciy of thIS land Use Plan, therefore, delete the words "if
feasibl~" "In general" should be str~nghtened and the crIter1a for
participation In the program establIshed to glve developers guidance
Policy 30; Is thIS policy intended to apply to transit programs for
new employees? This POl1CY should be expanded to read that
alternat1v~ transportation programs will be required for new
developments where on-site parking is deficient to meet the
proJectts parking demand.
~91icy 31. D~l~te the words "If feasibl~". The availabIlity of
remote parking facilities is crucial to the effective operation of a
shuttle system
Policy 32 How 15 the extension to be accompo1sh~d? Is the blKepath
to be placed solely on publIC land? What about privacy buffers
betwe~n private and publIC property? If the path is on prIvate
land, how WIll it be built without being a condItIon of new
development proJects?
POlICY 34 BIke racks should not interfer~ WIth automobll~
c1rculatIon patterns either
PoliCY 35 Crlteria should be included to indIcate the number of
bicycle racks to be prouided In new development Will bicycle racks
reduce the number of requIred parklng spaces in new development?
Policy 37
"Should" should be replaced by tlshallll,
folICY 40 ArtIcle 3 of the Coastal Act addresses recreat10nal use
of coastal areas. SectIon 30221 states that oceanfront land
sUltalbe for recreatIonal use shall be protected for recreatIonal
use and development unless present and forseeable future demand for
publlC or commerClal recreatlonal actiulties that could be
accommodated on the property IS already adequately provided for In
the area ThIS Coastal Act policy should be reflected In the LUP
policy As It IS written, thIS POlICY deals only With encouragment
of facllitles AdditIonally. the north beach area has been excluded
from thIS policy ThIS stretch of beach should also be Included 1n
this poliCy ConSistent WIth SectIon 30212 5 of the Coastal Act, we
encourage a more even distr1bution of beach users both north and
south of the PIer
Policy 41 RecreatIonal boatIng WIll presumably occur from the
western end of the PIer Recreat10nal boatIng Includ1ng moorIng and
dry dock spac~ should not confl1ct WIth the eX1st1ng low-cost
recreatIonal fishIng use at th1s location
Policy 42 The best use of leas~d publIC land would be to revert 1t
back to publIC use upon exp1ratlon of a lease In order to provlde
maXlmum publIC access and use
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POlICY 43 AlternatIve wording of the last sentence of thlS POlICY
is. "Pler. and will enhance public uses and not be permltted to
Interfere with the public areas.
Polley 4~ From what points shall VIews of the park be protected?
PalIsades Park should be preserved for publIC passive recreational
uses and only development consistent with thIS use should be
permItted The Ocean Avenue development standards should b~
referenced here,
Po1ciy 46 This policy could b~ construed to allow just about any
kind of development Allowable development must be much more
narrowly defIned Is "publIC facillty development" llmited to
publlc works type of facilitles or does thlS also include other
facll1ties for publlC use?
POllCY 49 Section 30213 of the Coastal Act requlr~s that lower cost
visltor and recreational facllitles be protected Mltlgatlon must
be comparable to the loss In-lIeu payments must be used to
mitIgate the reduction In lower cost lodgIng facilitIes or other
programs to Increase public use of the coast,
Policy 50 ThIS POlICY could b~ possible mitIgatIon for POlICY 49.
The word "promotell should be clarIfIed as to where these facllltles
would be located. how funded, etc
Polely;1 ThIS POlICY is more appropriate as a part of pol~cy 47
(unless they are to be located other than in the Oceanfront area),
POlICY 53 This POlICY speaks to the protectIon of envlronm~ntal1~
senSItive habItat areas. The LUP does not define any areas as
ESHAs It also does not proulde any defInItions of what constItutes
envrIonmentally sensItlve habItat The lUP could Include Section
30107 ~ which would serue as an adequate defj~ tion
polic~ 56 The additIon of any other species ldentlfled as
threatened or endangered Will prevent the need for subsequent
amendments to this POllCY
POll C Y 60 II Large offi c e addl tlon11 mus t be furthe r defl ned
WIthout reVIew of the proJect mitigatIon program adopted In the
General Plan, it IS dlfflcult to Judge thiS POllCY
The Environmental Quality POllCY sectIon of the LUP does not include
any policles which speCifically address the eXisting deteriorated
breakwater Without speCifIC language which assures the stabIlity
of the Clty.S shorellne. (1 e commitment to rebUIld the damaged
breakwater). the Commission cannot fInd the placement of the
bikepath or any new development along the shorelIne to be conSIstent
wlth SectIon 30253 of the Coastal Act
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Sc~nlc and VIsual Resources PolicIes
Policy 61 The scenIC coastal areas to be protected should be
specifIed scenIC areas or locations
POlICY 62 Does this policy preclude the relocation of Pier parkIng
to the adJacent north beach parkIng lots as stated on page 32 of the
lUP? Would It mean eventual removal of existIng beach parkIng? The
phrase. "without additional concrete areas at these facIlities",
appears to conflict WIth policy 22 that says eXIsting parkIng
facilitIes may be intenslfled. The implementation and maintenance
of an effectIve shuttle system 15 the key to remote parking
facilitles and the enhancement of shorelIne access WIthout
addItIonal parking facilitIes AddItIonal parking areas do not
necessarily result in advers~ scenic and VIsual impact Effectlve
landscapIng such as that approved in the Ocean Park Beach
Improvement Plan for the 2,500 space south beach parking lot can be
utlJlzed at other beach parking lots.
~olicy 67 ThIS POlICY should either establIsh the allowable
bUIldIng envelope or other spec~fic criterla, Will thls be
explaln~d In Phase III?
POlICY 69 The word Itencourgell should be substi tuted wi th a more
enforceable term
POlIC~ 70 ThIS POlICY should speCIfy WhICh streets are to have
pedestrlan-orlentatlon WIth no setbacks
~OlICY 71 _ The reVIsed Land Use Element of the General Plan states
that a maJor urban deSIgn POlICY would be to VIsually extend
PalIsades Park along Ocean Auenue to Crescent Bay Park and reqUIre a
low bUIldIng facade at the Ocean Avenue and Promenade facades Has
thIS concept been abandoned? In order to VIsually enhance thIS
area. des ig na ted as a S cenl C corrldor on page- 70 of thl s LU p. the
setback and landscaping requirement should be establIshed by strong
POlICY language replaCIng IIshouldll with "shall" and deleting 1I1f
feaslbleu
Although page 70, paragraph 3 of the LUP IdentIfIes several streets
as scenIC corrIdors, the ScenIC and VIsual Resources PolICIes do not
contaIn any polICIes for the enhancement of these areas The
speCIal urban deSIgn features or landscapIng in order to maintaIn or
Improve the scenIC qualItIes of these streets must be made Into
pollCles
New Development
POlICY 73 The thIrd sectIon of thIS polley should contain more
speCIfIC language WIth the follOWIng alternatIve wordIng, lIprovIdlng
adequate on-slt@ parklng faCllltles or partlclpate In a program to
proulde new parkIng facllltles or provldlng substltute means of
serVIng the development with publlC transportatIon" This IS also a
key access POlICY and should be cross-referenced in the Access
POlICY Sectlon
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~ollcy 75 This policy could prouide a better definitlon of
"coatal-dependent and/or coastal related" deuelopement For
example, S~ctions 30101 and 30101.3 provide deflnltions of both
types of development. To be consistent w~th the definition
contaIned in the Coastal Act. the words, "at all" should follow the
word "functlonl'
POlICY 77 The "approued transportatIon control measures" should be
defIned (or examples of such measures and the words, "include but
are not lImited to" added)
Policy 18 As stated earlier in our comments, the parking standards
listed in appendix A are generally less stringent than those of the
Commission adopted off-street gUIdelines and accepted statewId~
ratios as well as beIng too vague in some cases. We feel much work
is needed to bring the standards up to CommISS1on ratios. It may be
best to delete the Appendlx from the LUP at thlS tIme If It 15 too
lengthy a task to re-do
Policy 79 We do not agree with this POllCY If It 1S Intended to
reduce the resldential parking requlrement since residentIal
development has one of the hlghest demands for parking However If
the Intent is to encourage residential uses in mixed use commercial
and office developm~nts and the units are located above the ground
floor (with higher priorIty visltor-serving recreatlonal and
commerlclal uses on the ground floor) and are otherwise consistent
with Coastal Act poliCies, we can support thIS palelY.
PoliCy 80 This policy npeds further clarification. The clause.
"requirIng on-site parking and/or an in-lieu parking fee for
development that slgnlf~cantly Increases the park1ng demand 1n the
area, can be construed to mean a uar1.ety of thIngs Does "the areal!
encompass the entIre Assessment District or would a development
located near a parkIng structure wlth a lesser parkIng demand not be
reqUIred to prOVIde parking or pay the In-lieu fee? Types and Slzes
of developments (lncludlng addItIons) should be speCIfIed WhICh
would be requIred to provide Its own parklng or payment Into the
In-lIeu fee. no matter where It 1.S located wlthln the DIstrIct
Also thiS POlICY needs a follow through so that the CIty can 1.mpose
reqUIrements based on fIndIngs of the study OtherwIse. even if It
finds In-lI~u or on-slte parkIng necessary. the baSIS for actIon
WIll not eXIst
PQllCY 82 Sectlon 30222 of the Coastal Act states that reSIdentIal
use IS a low prIor1ty use of prluate oceanfront land sUltable for
U1sltor-serving commerc1al recreat10nal faCll1tles deslgned to
enhance publIC Dpportunltles for coastal recreatlon The Land Use
and ZonIng Map on page 28 indlcates that the exising resldential
uses along the north beach are low denSIty Rl uses. ThlS POllCY
states that thIS stretch of the beach shall accommodate hIgh denslty
multiple famIly residentIal use We strongly dlsagree WIth a zone
change and policles to lnt@nsify thlS non-prlorlty use on the
state's most popular beach where access IS already I1mIted by
Inadequate parkIng and uertlca1 accessways Instead of intensifYIng
..
'~rivate residential ~~ in thIS area, it should4lt a long range
policy goal of the lUP to phase out thls use for hlgh priorlt~ uses
in accordance with Section 30222 of the Coastal Act, whenever the
opportunity arises. Possible funding for this could be the funds
collected in Polley 12.
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POllCV 83
given.
The Deauville property should be defIned or its locatlon
POllCY 84 LikeWIse. the retentIon of residentIal uses on the beach
should not be encouraged 1n the south beach area What is the
percentage of current residential use? Visitor-serving commerclal
or re~reatlonal uses are more approprIate land uses here
also.
POllCY 88 In our prevlous comment letter, we asked that the ilSanta
Monica Pier Restorat1on and Development GUldelineslI and any
subsequent amendments be lncluded as appendices to the lUP
Pollcy 9Q Uses that serve the public could include Just about any
development language should be added that allows only such
development WhICh preserves V1ews of the shorelIne and the park as a
scenIC, Vlew oriented, passive recreatIonal facilIty.
POllCY 91 This POllCY needs to be more specifIC as to the proposed
ratio, mIX, and standards (vlsitor-servlng uses required on the
ground floor) Wlll new res~dentlal uses be allowed?
Pol~cy 94 The word ,lIand ratioll should follow the word "m1XIl 1n the
next to last sentence of thlS pol1cy The last sentence should be
modlfled thusly, 1I0ffIce dev€>lopment to the extent that adequate
on-site parking can be provlded, may be permitted above the ground
floor
Po)icy 95 Add llstreet lE'vel uses shall be restrlcted to
vls1tor-servlng usesll.
POllCY 97 and 98 These two policies are somewhat contradictory to
one another Polley 97 states that vIewlng platforms shall be
encouraged abovE' the thlrd floor whl1e POllCY 98 says that bu]ldJng
heights shall not exceed three storlE'S except in one block whlch 15
currently developed If conslstency wlth Sectlon 30251 of the
Coastal Act is deslrable, then Ilshall be encouraged" should be
changed to IIshall be requlrE'd". ThlS would be conSIstent Wlth
CommlsSlon actlon on permit no 69-76 where we requlred vlewlng
corr1dors WhICh have turned out to be successfull Wlthout know1ng
the height and density of hotel development 1n other areas of the
Clty. 1S 15 dlfflcult to judgE' the 1mpaet of thlS polley as to
whether it wlll be compatIble wlth the forthcoming urban design
criteria of th1S deSIgnated scenlC corrldor
Policy 99 Is the area bounded by Callfor~1a Avenue, Ocean Avenue,
Montana Avenue and Fourth Street currently bUllt out to the R4
denSIty of ltS current zonlng? Or wlll development at thlS zon1ng
create a s~9nlfcant 1nCreaSE' 1n the areals denslty through th~
recyclIng of single famIly resldences to four story multIple fam~ly
structures? Access to the PalIsades Park and the north b~ach could
be adversely lmpacted by a slgnIflcant Increase In the use of
coastal access routes by resldentlal trafflc and parklng demand as
well as potentially overburdenlng
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coastal recreatlonal resources. If thls area is mixed density then
efforts should be taken to preserve the lower density uses Further
background data is needed to support th~s policy.
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Downtown Core
Although the LUP pol~cy section divldes the downtown area into a
IIcoren and a "framen, these area boundaries are not def~ned In thlS
or any preUlOUS sect1on. For the purpose of these comments, we are
assumlng that the Downtown Core is the area containing the Parking
Assessment Dlstrlct and the Downtown Frame is the surroundIng area
outslde the Dlstrict.
Because the Frame is not wlthin the Olstrict, new development must
be required to provlde adequate on-site parking to avold adverse
impact on acceSs to coastal recreational areas located one block
west We are not sure that a maJor entertainment or cultural use
would be economlcally feaslble for the Frame area given the on-slte
parklng requirement and the hlgh land costs in thIS area. Perhaps
the Downtown Core containlng the Parking Assessment Dlstrlct would
be a better locatlon for a major entertalnment or cultural use since
the use would not have to provlde lts own parking If its peak
parking demand was at nIght.
BUIldings that exceed four storles should be required to provIde
publ1C balconies, t~rraces or rooftop v19wlng platforms where views
of the coast would be posslble
POIlCY 103 may be overly restrlctlve 1n that it would exclude such
uses as halrdressers and other "downtowntl uses that may be deslrable-
since they usually require an appolntment
C1UlC Center
POllCY 110 Th15 15 the only Identlfled outlYlng parklng area
avaIlable for use ln a coastal 2one-wlde shuttle system There must
be more remote paklng areas and thlS POllCY should be
cross-referenced to the shuttle policy (Policy 29).
Oceanfront
Polley 112 The last sentence should rE'ad, II Some office use shall
also be perm1tted above the ground floor"
polley 113 The followlng should be added to the end of the POllCY,
II usable open space, WIth low Ocean Avenue and Promenade facades
conSIstent wlth the Ocean Avenue Scenlc CorrIdor deslgn standards
PpllC,y 114 Substltute "encouraged" WIth IIrequlred"
Pollcy 116 ThlS policy appears to be somewhat contrad1ctory to
polley 40 WhICh states that public recreational faCllitles shall
have prIorlty In the area and thlS policy WhlCh conserves the
eXlstIng mlX of res1dentlal use
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'~hat ~s the eXlstln~ratio and mlX of resldentlal use to
visitor-serving uses? Would this POllCY reqUJre that resldential
uses not be recycled to publlC recreational uses in order to achlev~
this goal? Ground floor visitor-serving uses should be allowed
below r~sidential uses. Also Slnee most of the City's lower cost
overnight lodging faCllities in the coastal zone are locatied 1n
this area, there should be languag~ to protect these facilitles
consistent wlth Sectlon 30213 of the Coastal Act. There should also
be a statement added to th1S policy requir1ng that the Ocean Avenue
and Promenade facades. setbacks and landscaplng be consistent wlth
the Ocean Av@nue Scenic Corr1dor standards
policy 119 ~Encourage" should be substltuted with ~requlre"
Ma1n Street
P9l1CY 121 ThlS policy should further qual1fy ~variety of uses~.
Because the Ma1n Street area, particularly south of Ocean Park
Boulevard, is d1rectly llnked to the beach by a major pedestr1an
vertical accessway. the uses on thlS commerc1al strip should be
primarily vls1tor-servlng commerc1al and recreatlonal uses to
enhance public opportunitles for coastal recreatlon consistent wlth
Sectlon 30222 of the Coastal Act. We would not want to se~ thlS
area developed primarily WIth banks, offlces and other general
commerclal uses These non-priority uses should be llmited and
located above the ground level and a balance of land uses to
accommodate both visitor-servlng and nelghborhood commerclal
serVlces sought WhIle we understand your concern With wanting to
limlt or control lIquor stores, bars and large restaurants glven the
ImmedIately adjacent reSIdentIal areas and the existing crltical
parklng deflclencles. however non-prlorlty land uses must not
predomlnate this important coastal area eIther. A VIable shuttle
system, llnked wlth remote parkIng lots. will greatly allev1ate the
parkIng problems 1n the area and can be set up to allow developers
of more d~slrable commer1cal uses to pay lnto an in-Ileu fee program
to fund the shuttle system as opposed to having to provlde on-SIte
parklng ThlS arrangement wll1 also allow the pedestrlan
orlentatlon of Main street to be preserved and enhanced, A possIble
mechanism to limlt the underslrable commercIal uses would be to
requ1re that they provide theIr own support parkIng on-SIte.
Ocean Park Redevelopment ProJect
Polley 126 How WIll the Clty encourage the retent10n of the mIX of
slngle fam1ly and very low dens1ty development ln the area? The
majority of the land ~n thlS area is zoned for medlum and hlgh
denslty residential use Wl1l the area be downzoned? Th~ Clty'S
practlce 1n thlS area has been however to increase the denSIty in
the area even beyond the current medlum and hIgh zonlng by
conslstenly allowlng incluslonary unlts for affordable houslng In
multi-famIly hous1ng projects Wlth the contlnued incluslon of
un1ts over and above the current high denslty zoning, the ultimate
bUlld out of thlS area can have a severe adverse lmpact on coastal
access by ouerburdenlng the already heavlly used coastal access
routes, publlC on-street parklng as well as coastal
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,i recreational areas~ new residents, The comJltsion has found 1n
num~rous permlt decisions that affordable housing per se has no less
parking demand than market rate housing Only housing speciflcally
defined for low income elderly res~dents have been found to create a
lesser demand for parking only if there is not an eXlstlng need for
more public parking in the project area and adequate public translt
15 available nearby
Although the City currently has a rent control ordinance in effect
which is limlting the recycllng of underdeveloped lots, this
ordlnance may not always be in effect. The lUP should includ an
assessment of revised total build-out figures for areas proposed for
inclusionary affordable residential development (including in the
north side res~dential area), and an evaluatlon of the impacts
caused by thls hlgher density on avallable coastal resources made
Polley 127 "Serv1ee commerclalll uses should be defined,
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LAND VSE POLICY MAP
We have serious problems with the land Use Policy Map ~n terms of its
land use categor~es and the designations of some of the areas wlth~n
the coastal zone. In general, this land Use Pol~cy Map appears to
be inconslstent wlth the lUP pollcles contalned 1n the precedlng
chapter The terms llsted below the map are not defIned nor were
they def1ned or allowable uses under these categories stated
anywhere in the LUP text
This map designates the entire stretch of land seaward of Paclflc
Coast H~ghway between the north City boundary and Cal~forn~a Avenue
either hIgh densIty or single famIly resIdentIal uses Is It the
CIty'S Intentlon to replace the eXIsting public beach parking lots
wlth residential use and develop this area resldentlally? We
strongly oppose thIS land use deslgnation (see our comments on
P01IC~ 82).
The land use desIgnatlon of Pallsades Park, the neighborhood parks
of the 0cean Park area and the entlre state beach have the same
llParksll land use dE'signatlon SInce the intendE'd development and
allowable uses wlthln these facllities all dlffer. they should have
either dlfferent land use deslgnatlons or these dlfferences
explalned.
Chapter II of the LUP dlvIdes the Santa Monlca Coastal Zone into
n~ne subareas, one beIng the Oceanfront subarea located between the
CiVIC Center and the ocean, from Colorado Avenue on the north to
PICO Blvd on the south However the Land Use POlICY Map
deslgnates the area west of Pallsades Beach Road from Callfornla
Avenue to Colorado Avenue, as well as a portion of the area south or
PlCO Blvd as llOceanfront SpecIal DistrIct". Also the PIer has thlS
deslgnatlon What are the development standards of thls D~strlct?
Do they encompass all of the varied uses and regualtlons proposed
throughout the pOllcies for these areas? Because the polICIes for
these areas propose development standards that dlffer In terms of
land uses, heIghts, deslgn and publIC facllltles, It would be less
confusIng not to glue all of these areas the same land use
deslgnatlon
Although there are roughly ~ooo parklng spaces In parkIng lots along
the beach, they are not shown on th1S POlICY Map, Are publIC
parklng lots allowable uses under the Parks, Oceanfront Speclal
Dlstrlct and resldentlal land use categorles deslgnated for these
areas where the lots currently eXIst Would the proposed land use
deslgnatlons allow add~tlonal parklng areas?
POlICY 109 states that the CIVIC Center area shall prlmarIly contaln
government faCIlltles but other uses includlng publIC parklng,
cultural and publlC recreatIonal faCllltles and Vlsltor-servlng uses
such as hotels and commercIal recreatIonal uses WIll be allowed
W:l.l1 the "InstItut'lOn" land use designation allow thesE' uses,
espeCIally publlc parkIng faCllltles Slnce thIS area was deslgnated
as a remote parklng lot for the shuttle system
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The "Seru1ce and Speciality Commercial" land use designation should
be defined as well as the corresponding dens1ties of the res1dential
land use deslgnatlons.
CHAPTER 5 IMPACTS
We disagree wlth the stated potentlal 1mpacts of the Ocean Park
Resident~al Area, specifically the statement that recycling to
higher allowable densities will remain low due to the City's Rent
Control ordinance Although removal permits for s1ngle famIly
residences and multI-family projects with three or fewer units are
baslcally automatic, permits for the removal of larger projects ar~
also allowed through a hearing process, Owners of multi-family
proJects wishIng to demolIsh structures and rebuild the same number
of unIts or to a higher allowable density (often with extra
1nc]usIonary unIts), will also not face much diffIculty in gettlng
Rent Control Board approval We feel further analysIs of the
cummulative impacts of the present zoning and the practIce of
routInely allowlng Incluslonary unIts should be studIed and efforts
made to reduce the density of thIS area (also see comments on Policy
126).