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SR-6-O (4) : .~ e e ,L\wiD 6:;-0 APR 2 2 1986 '1-E 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 - 1 - -, r" e e 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. - 2 - " ". - It 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 - 3 - '. ", III e 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. - 4 - ~ ~. -- - 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 - 5 - .. II -- 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 - 6 - 'f ., - - 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. - 7 - ... e e 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 - 8 - ~ l, e e 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. - 9 - '. e e 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 - 10 - - e 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 - 11 - STATE OF CALIFORNIA-THE RESOURCES AGENCY - FEB I i- t, !~ e Exh~b~t C I. GEORGE OEUKMEJIAN Go~mor _ CALIFORNIA COASTAL COMMISSION SOUTH COAST AREA 243 WEST BROADWAY SUlTE 380 LONG BEA.CH, CA 90802 {213j 590-5071 Ei'~-{_.. r;:-~, .~r-f~' ~/ 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. ~ e e 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 . e 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 11 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? e e 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 .' _ e 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 >' . e 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 .' e e 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 ,i e e 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 " ~ e , . ~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. 1 . 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 .>oS ,f _ e 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. . . 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 ~ f ... '\- . e '~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 , . .. . ,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, .. ' ~t , .. ,{ . e 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 .. .... c ~ J . e 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).