SR-9-A (104)
LUTM:SF:PF:cgjlcpl.word.ppd
COUNCIL MEETING: April 9, 1991
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santa Monica, california
APR 1 6 1991
TO: Mayor and city council
FROM: city staff
SUBJECT: Recommendation to Approve Land Use and Implementation
Plan of Local Coastal Program
INTRODUCTION
A Local Coastal Program (LCP) is required by state law.
This
draft LCP incorporates revisions requested by the California
Coastal commission and the Planning Commission and includes
revised standards resulting from the adoption of the 1988 Zoning
Ordinance and Proposition s.
staff recommends that the City Council review the document,
provide staff with comments and approve the document to be
forwarded to the Coastal Commission for review and certification.
BACKGROUND
state law requires each coastal jurisdiction to prepare a Local
Coastal Program (LCP) that addresses requirements of the state
Coastal Act.
LCP's prepared by local jurisdictions are subject
to review and certification by the California Coastal commission.
Once the LCP is certified, responsibility for implementation of
state Coastal Act provisions reverts to the local government. A
local government may submit its entire Local Coastal Program at
one time or in two separate components: the Land Use Plan (LUP),
showing the permitted uses and setting out policies for carrying
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and the Implementing
.9i~ 1991
APR ~ t~1
out the goals of the Coastal Act;
Ordinances, which implement the policies specified in the Land
Use Plan. Under 1981 legislation, a local government can take
over issuance of coastal permits once the Land Use Plan portion
of the Local Coastal Program has been approved by the Coastal
Commission. All 67 coastal cities and counties in the state are
required to prepare Local Coastal Programs (LCPs) to govern
development within each jurisdiction~s coastal zone. This area
generally extends inland about one-half mile. The Coastal Act
sets basic goals and policies, but leaves specifics to local
jurisdictions. As each LCP is certified, local government
assumes the authority to issue coastal development permits if the
development is consistent with the LCP. The Coastal Commission
then assumes a secondary role, conducting appeals of local permit
decisions under limited circumstances, considering proposed
amendments to LCPs, providing technical assistance and advice,
monitoring local permits to assure compliance, and performing
five-year evaluations of LCPs.
Santa Monica originally chose to submit its LCP in two stages.
The first component to be prepared was the Land Use Plan. The
original version of the Coastal Land Use Plan (LUP) was approved
by the City Council on January 14, 1981 after an extensive public
review process. Shortly thereafter, however, the city decided to
re-examine planning and development issues city-wide. As a
result, work was not begun on the LUP until 1982 when a
consul tant was retained to draft a revised LUP based upon the
re-examination of the planning and development issues. A draft
of the revised LUP was presented in early 1983; however, the
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revised Land Use and Circulation Elements of the General Plan
were in process. It was decided to defer any revisions to the
draft LUP until after adoption of the revised General Plan
Elements. This process was completed in mid 1984.
After a public review period in 1985, the Draft Land Use Plan
(LUP) was forwarded to the Planning Commission. The Planning
Commission conducted a public hearing on the matter and forwarded
its comments to the city Council with a recommendation that the
LUP be adopted. In June 1986, the City Council reviewed comments
submitted by Coastal Commission staff, Planning Commission, and
members of the public, and adopted the City's version of the LUP.
In July 1987, the Coastal Commission conducted a public hearing
taking into consideration comments submitted by the City. A
modified version of the LCP was approved by the Coastal
Commission, and since the document was different from the one
approved by the City, it was necessary to have the Planning
Commission and City council review the coastal Commission
modifications. In September 1987, the Planning Commission
conducted a public hearing and recommended that the LUP be
adopted as amended by the Coastal Commission.
In November 1987, the City Council conducted a public hearing
and, after deliberation, the Council took no action on the LUP.
The City's consideration of a new comprehensive Zoning Ordinance
led to changes in major elements of the City's land use policies
and, as a consequence, further consideration of the LUP was
postponed pending adoption of the new zoning ordinance. staff
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was directed to modify the LCP to be consistent with the adopted
Zoning Ordinance. The zoning ordinance was adopted in 1988, and
the preparation of a revised LUP began shortly thereafter,
staff has revised the document, which is now comprised of two
components: the Land Use Plan (LUP), establishing development
standards and setting out policies for carrying out the goals of
the Coastal Act, and the Implementing Ordinances, which implement
the policies specified in the Land Use Plan.
The current draft of the LCP is a policy document based largely
on the 1987 draft LCP that resulted from discussions with the
Coastal Commission. However, there are two key changes. First,
the current LCP reflects policy changes made over the three years
since 1987, including the 1988 Zoning Ordinance, the Ocean Park
Rezoning, and Proposition S. Second, the Implementation Plan is
new and represents the City's effort to obtain certification of a
complete LCP.
A revised draft of the LCP was released to the public in May
1990. Following a seven and one-half week public review period,
several comments were received. These comments and their
responses are included as attachments to the staff report. As
noted throughout, appropriate comments and changes were
incorporated into the LCP. Thus, the LCP reflects not only
direction from the Coastal Commission and Planning Commission but
also from the public and other regulatory agencies as well.
ORGANIZATION OF THE LCP
The LCP is divided into two sections.
First is the LUP, which
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outlines existing conditions, issues, and goals of the Coastal
Zone, as well as the policies needed to achieve the goals of the
Coastal Act. The second section is the Implementation Plan,
which includes Zoning Ordinance revisions and specific Coastal
Zone ordinances to implement the policies of the LUP.
LAND USE PLAN (LUP)
The Land Use Plan is divided into five chapters:
Chapter I outlines the background and purpose of the LCP. It
includes a brief history of coastal protection legislation and
describes Santa Monica's role in that planning effort.
Chapter II describes existing conditions and issues in the
Coastal Zone by dividing it into eight subareas, which largely
correspond to zoning boundaries. Each possesses unique
characteristics that are described in detail.
Chapter III discusses five major policy topics:
o Access
o Recreation and Visitor Serving Facilities
o Scenic and Visual Resources
o New Development
Discussion of each topic includes the existing conditions,
opportunities, problems, or constraints that currently exist.
Chapter IV is the key component of the LUP,
specific policies of the Coastal Zone. These
policy topic and include general policies
as it lists the
are organized by
( 1. e . Access,
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Environmental Quality) as well as policies specific to subareas
within the zone (New Development) .
Chapter V outlines the potential impact of the LUP on each of the
eight subareas.
ANALYSIS OF LAND USE PLAN (LUP)
The current Land Use Plan is the pivotal element of the LCP. It
has been updated to reflect the city's existing policies (Zoning
ordinance, Ocean Park rezoning Proposition S) and potential
future policies,
Civic Center Specific plan, Main Street
ordinance revisions. The LUP is designed to be consistent with
all City regulations.
The LUP also reflects input from the
community, Coastal Commission, and other regulatory agencies.
There are III policies listed in the LUP, all organized under the
five policy topics noted in Chapter III. New policies that are
inconsistent with current standards and require amendments to the
Zoning Ordinance and/or the General Plan are noted. Following is
a highlight of key LUP policies (note:
all policies are not
listed) :
Access
These policies cover access to the Coastal Zone, especially the
beach, as well as circulation within the area.
Policy 8:
This policy requires that new development directly
adjacent to the beach front provide a dedicated access
easement under certain conditions. Such easements do
not have to be available to the public unless a
public or private agency agrees to maintain and be
liable for the accessway.
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Policy 13: This policy recognizes that an assessment fee on new
development may be appropriate to enhance public
access to the beach. This would require a nexus
study to determine a reasonable fee. Until such a
fee is adopted, proj ects that significantly impact
access will be required to mitigate the impact to a
level of insignificance.
POlicy 18: This policy recognizes that the city should
participate in efforts to increase capacity on PCH
through programmatic improvements.
Policy 19: This policy requires that new commercial or mixed-use
development make their commercial parking facilities
available to the general public when the business is
not in operation.
Policy 21.:
This policy recognizes
impact parking supplies
monitored by the city.
tha t TORCA
and that
conversions may
impacts will be
policy 23: This policy prohibits residential parking permit use
in the pUblic beach lots during the day. The
Planning Commission recommended changes to this
Policy as outlined later in this report.
policy 24: This policy reflects the Coastal Commission IS
agreement to allow an intensity of development on the
pier than can be accommodated by the 47l parking
spaces to be replaced on or near the Pier. Any
further intensification of development will require
appropriate mitigations (e.g. more parking, shuttle
program) .
policy 27: This policy directs implementation of a shuttle
system to provide service throughout the Coastal Zone
and specifies project timelines.
policy 32: This policy requires that new commercial and
residential development with ten or more parking
spaces provide for secure storage of bicycles.
Recreation and Visitor Serving Facilities
These policies cover visitor-serving facilities within the
Coastal Zone, including restoration of Santa Monica Pier and
encouragement of visitor-serving uses in the Oceanfront and
DowntoTIln areas.
Policy 38: This policy establishes that visitor-serving
commercial recreational facilities have priority over
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residential or general commercial uses on parcels
zoned RVC. Several parcels have and will be rezoned
from residential to RVC in Subareas 1a and lb.
Policy 45:
This policy discusses the protection and
encouragement of low-cost lodging facilities, and
establishes mitigation procedures for demolition of
such facilities.
Environmental Quality
These
policies
emphasize
environmental
quality
policies,
emphasizing protection of marine habitats and water quality.
Policy 56: This policy describes the City's commitment to
monitoring and improving the quality of storm drain
water.
Scenic and Visual Resources
These policies concentrate on visual resources,
including
protection and improvement of public views of the Ocean.
Policy 59: This policy protects pUblic views to, from and along
the ocean, Pier, and Palisades Park.
New Development
This section describes policies for new development that apply
throughout the Coastal zone, including policies for each of the
eight subareas.
These include standards for scale, bulk, and
design considerations. A new pOlicy is being proposed to address
any growth controls on the rate of future development
Policy 65: This policy specifies general guidelines for new
development to enhance public access to and within
the project. Measures include providing pedestrian
and bicycle circulation and assuring the recreational
needs of residents on-site is provided.
Policy 69: This requires compliance with the Mello Act which may
require the replacement of affordable housing in the
Coastal Zone.
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Policy 74:
Development shall
management plans that
controlling the rate
Zone.
comply with future growth
include but are not limited to
of development in the Coastal
Policies 75 through 114, specify development standards and
permitted uses in each of the eight subareas of the Coastal Zone.
These have been designed to be consistent with the development
standards contained in the existing General Plan,
zoning
Ordinance.
However in some areas new policies may be
inconsistent with the General Plan or Zoning Ordinance.
These
policies are noted.
One area in the coastal Zone where staff proposes to modify the
development standards is the area bounded by Pacific Coast
Highway (PCH) to the west, the Pier to the south, and the City
limits to the north. This area is predominantly zoned Rl and R4.
In response to Coastal Commission staff concerns about preserving
existing Coastal-related uses and limiting development and
intensification of residential uses, staff recommends the area be
zoned a mixture of Rl and RVC.
This will allow retention of
existing single and mUlti-family residential uses, however it
will prevent intensification of residential uses by limiting new
construction to single family uses.
Because of the small lot
sizes that predominate along PCH, this rezoning reflects what can
actually be built in this area. At the same time, it responds to
the
Coastal
commission's
concern
about
residential
intensification of this beachfront subarea.
POlicy 75: This policy requires that new single family
residential uses in the subarea north of Santa Monica
pier (along PCH) provide two visitor parking spaces.
Guest parking requirements for single-family
residential uses elsewhere in the City do not change.
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This policy is more restrictive than the existing
guest parking requirements of the Zoning Ordinance
(no spaces required for single-family residential
uses) .
policy 76: This policy describes the rezoning of residentially
utilized parcels north of Santa Monica Pier along PCH
to Rl. This also identifies special building height
wide, including a 3 story, 35' height limit (40' for
pitched roofs). This is necessary due to small lot
sizes and the high water table, which makes
subterranean parking difficult. This policy allows
greater height than the city-wide Rl height limits.
Parcels 30' or wider shall adhere to standard Rl
development standards.
Policy 77: This policy rezones residentially zoned parcels
utilized with non-residential uses in Subarea la to
RVC. This ensures retention of visitor-serving
commercial uses along the beachfront. These parcels
consist of the four beach clubs (Jonathan Club, Sand
and Sea site, the Beach Club, Salt Air Club) and the
public parking lots and vacant parcels. The policy
requires changes to the Zoning map and General Plan
Land Use map. Currently the designation is R4 High
Density residential. Residential uses would be
prohibited on the ground floor of RVC parcels in this
and all other subareas with RVC zoning.
policy 78: This policy rezones the C2 zoned parcels north of
Santa l10nica pier along PCH (currently state-owned
parking lots) to an RVC designation. This
modification would allow appropriate Coastal-related
uses, and public parking. This policy requires
changes to the zoning and General Plan designations.
Currently the designation is C2 Neighborhood
Commercial.
policy 80: This policy describes the zoning standards for the
area bounded by the Promenade, Vicente Terrace, Pico
Boulevard, and parcels west of Ocean Avenue-fronting
parcels. All parcels with non-residential uses will
be rezoned RVC to ensure retention of visitor-serving
commercial uses.
Parcels with residential uses shall be zoned R3 to
ensure a balanced mix of uses in this subarea.
This policy also addressed the area west of Appian
Way to the Promenade, from Pico to Vicente Terrace,
where RVC standards will be 2 stories, 30', with a
l.O FAR. This is consistent with the standards
combined in the Land Use Element but inconsistent
w"i th the Zoning ordinance standards which permit 3
stories 45 I Z. o. FAR. The Zoning Ordinance is in
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error and will be modified in the Implementation
Ordinance.
Policies 44, 88, 105: These policies prohibit residential units
and offices on the ground floor frontage of Ocean
Avenue between California and pico. This is
inconsistent with zoning standards for the area,
currently zoned RVC and CC. The RVC zone permits
residential units while the CC zone currently allows
non-profit offices and conditionally permits private
offices.
IMPLEMENTATION PLAN
This portion of the LCP is divided into five sections. section I
introduces the Implementation Plan and describes its purpose.
Section II outlines amendments to the Zoning Ordinance necessary
to accommodate all policies of the LUP. section III describes a
development impact fee associated with two policies of the LUP.
Section IV describes the shuttle transi t program to be
implemented by a policy of the LUP. Finally, section V outlines
the parameters of a comprehensive sign program for the Coastal
Zone (and the City).
ANALYSIS OF IMPLEMENTATION PLAN
The Implementation Plan, similar to the LUP, is designed to be
consistent with existing city policies and the zoning ordinance.
Key areas of note are highlighted here by section:
section II--Zoning Amendments
This is the most detailed section of the Implementation Plan,
providing text revisions to the Zoning Ordinance. As the most
recent revision of the Zoning Ordinance provided the impetus for
most of the modifications to the LCP, few changes are needed to
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implement the LCP.
Zoning Ordinance:
Four new subchapters are proposed fer the
o
Coastal Overlay District.
in the Coastal Zone and
Coastal Development Permit.
This overlay covers all properties
triggers the requirement for a
o
Coastal Development Permit. This replaces
application to the Coastal Commission and
administrative and appeal processes.
the permit
outlines the
o Administrative Coastal Permit. This permit would apply to
development projects that require administrative approval.
The procedures are spelled out for such permits.
o Local Coastal Program. Future amendments to the LUP are
inevitable as modifications to the General Plan, Zoning
Ordinance, and ather policies occur. This section outlines
the procedures to prepare, amend, and adopt the LUP.
In addition, miscellaneous amendments to the Zoning Ordinance are
necessary to implement specific policies.
Section III--Impact Fees
Section III summarizes the development impact fee imposed on new
development in the Coastal Zone that removes existing low-cost
motel or hotel units. The city Council adopted such a ordinance
in 1990.
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Section IV--Shuttle Transit Program
This section outlines the development of a pilot shuttle program
that would circulate throughout the Coastal Zone, with stops at
all major destinations.
Section V--Comprehensive sign Program
This section summarizes the Comprehensive Sign
establishes a consistent, unified sign program
Coastal-ralated information clearly and effectively.
Program that
that conveys
CEQA
The California Environmental Quality Act (CEQA) exempts
preparation of Local Coastal Programs from environmental review,
pursuant to Section 21080.9 and 21080.5 and Division 20, Chapter
6 of the Public Resources Code. As per the provisions of both,
this program contains the elements and analyses required for
certification of the Land Use Plan of the LCP. The majority of
the LCP Policies reflect existing City policies contained in the
Zoning Ordinance, Land Use and Circulation Element, Ocean Park
Rezoning, North of Wilshire Rezoning, and Proposition S. with
the exception of Proposition S, each of the documents were
analyzed through a separate EIR that provided information and
evaluated impacts.
PLANNING CO}illISSION REVIEW
The amendments to the draft LCP document proposed by the Planning
Commission, and required as a result of proposition s, are noted
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by the slash out and bold treatments in the text. The passage of
Proposition S has required the insertion of language limiting
hotel, motel and restaurants over 2,000 sq. ft. as contained in
the initiative. with the exception of the following issues, the
changes proposed by the Planning Commission primarily involve
minor re-organization and re-wording of policy statements.
Policy #23 which restricts residential permit parking in the
beach lots between the hours of 9:00 a.m. and dusk was a
significant issue with the Planning Commission. According to the
Policy contained in the LCP, residents wishing to park in the
lots between those hours would be subj ect to the parking fees
charged to beach goers. Recognizing that the majority of
residential uses utilizing the beach parking lots have little or
no off-street parking, the Planning commission recommended two
alternatives:
o Evaluate hot" many residential uses have insufficient
parking and then permit a fixed number of parking
permits for those units. Parking would be available in
the beach lots on a first come first serve basis.
o Restrict residential parking between the hours of 9:00
a.m. to dusk only during the peak summer period, June
through August. Residents could still park in the
lots, however, they would be subject to the same fees
as beach goers during the summer months.
Currently, the City offers all day/night beach parking permits to
residents and selected commercial uses and daytime parking
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permits for beach users. These permits can be used only in beach
pUblic parking lots.
The Coastal Commission has consistently stated that residential
parking by permit in public lots during the day is not
acceptable. Such a program takes up several hundred beachfront
parking spaces that are not available to visitors during peak
daytime periods, therefore hindering Coastal access. without the
adoption of a certified LCP, any improvements to the public beach
lots require Coastal Commission approval. When improvements have
occurred to the beach lots the coastal Commission has imposed, as
a condition of approval, a restriction on residential parking in
the beach lots during the day.
Staff is recommending retaining the Policy currently in the Draft
LCP. Should the City Council reject the proposed policy to limit
residential parking during daytime hours, this may jeopardize
certification of the Plan and the City's ability to implement the
remaining policies. without adoption of the LCP, the Coastal
Commission will retain permit authority, and therefore should the
ci ty wish to make any future changes to the lots, the Coastal
Commission will continue to impose the restriction on residential
parking.
The Planning Commission also recommended modifications related to
the general goals of the LCP. The Goals and Policies as outlined
in the State Coastal Act make reference to maximizing public
access and recreational opportunities in the Coastal Zone. The
Planning Commission obj ected to the term "maximizell and
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substituted the word "provide". Therefore, in Goal 3 and Access
Policy 5 where the language once read "...maximize public access
to and along the coast and maximize public recreational
opportunities...II, the language now reads 1I...provide public
access to and along the coast and provide public recreational
opportunities. . .". These modifications may not be consistent
wi th the intent of the Coastal Act and may be rej ected by the
Coastal Commission.
In relation to pedestrian access, the Planning commission
recommended changes to Policy 34. The Policy originally
identified the public walkways at Hill street, Ashland Avenue,
and Seaview Terrace as coastal access designations. As such,
these walkways were to be identified with appropriate coastal
access signs. As the result of neighborhood opposition, the
Planning commission eliminated the signage requirement for
Seaview Terrace, however, they maintained the language calling it
out as a coastal access route. This Policy as originally
presented, was approved by the Planning Commission, city council,
and Coastal Commission in the 1986 Draft LCP.
OTHER RECO~1ENDED CHANGES
In addition to the changes noted in the Draft LCP, staff is
recommending changes to facilitate the Pier Development,
Presently the development standards for the pier are 2 stories
30' with a 1.0 floor area ratio. As part of the Pier development
proposal a fun zone with a farris wheel and roller coaster are
proposed. Both of these features exceed the 30' height
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limitation on the Pier. Therefore, in order to accomIDodae this,
staff is recommending the follwoing changes to both the Policy
and Implementation section:
policy 84:
Building height shall not exceed 2 stories 30 feet
above the pier deck and the floor area ratio shall
not exceed 1.0. However, amusement rides and public
viewing platforms may exceed the permitted height.
Implementation Section: Add a new paragraph under Miscellaneous
Amendments:
9. Pursuant to Policy No. 84, the following amendment to the
IIproject Design and Development Standards", Section 9040.3 of
the zoning Ordinance is required to be added:
(6) Amusement rides and public viewing platform located on
the Santa Monica pier may exceed the permitted height.
ADOPTION PROCESS
Timely adoption of the LCP by the City and certification by the
Coastal commission are critical for several reasons.
First, preparation and adoption of Santa Monica's LCP is a
long-overdue accomplishment,
one whose process began over
thirteen years ago.
During this time, over 58% of all coastal
jurisdictions have had LCPs certified by the state.
In Los
Angeles County, Santa Monica remains one of only four cities (out
of eleven coastal cities) that have not had at least an LUP
certified.
Years of delay have left Santa Monica behind other
cities in fulfilling its legal obligation and obtaining total
permit authority over its coastal development.
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Second, the California Coastal Conservancy has approved
$1,000,000 in assistance to the City for restoration of the pier
Carousel Park. However, by the terms of the agreement, the City
cannot encumber $850,000 of these funds until an LCP is
certified. This situation creates a continuing negative balance
in the pier fund and effectively results in significant costs for
santa Monica, as the City must utilize its own General fund
monies for the project. The Conservancy has notified the City of
its intention to cancel the grant if the City does not adopt an
LCP by May 1991. similarly, potential Conservancy funds for
other common area improvements on the pier cannot be accessed
until the LCP is certified.
Finally, the City has been awarded grant monies of up to $57,305
from the state for preparation of the Implementation Plan section
of the LCP. This agreement reimbursed the City for work
completed up through September lO, 1990. Potential for future
grants may be contingent upon timely progress in adopting the
LCP.
BUDGET/FISCAL IMPACT
Approval of this document will not result in financial or
budgetary impact other than those noted above regarding grant
monies.
CONCLUSION
In light of the development policies in Santa Monica, which have
changed with the adoption of the Zoning Ordinance, the Land Use
and Circulation Element, Housing Element, and proposition S, the
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LCP reflects existing policies.
Once the LCP is adopted, any
future changes to development standards or policies will result
in amendments to the LCP as well.
The LCP represents a body of information, analysis, and policies
that for the most part, have been reviewed and analyzed since
1987. Since that time, the community, regulatory agencies, the
Planning Commission and the California Coastal commission have
all had input into the formation of the LCP. Accordingly, the
revised document modifies the 1987 version by making it
consistent with new city policies. Ultimately, it is a document
designed to comply with the state's Coastal Act and result in a
certified Local Coastal Program for the City of Santa Monica.
RECOMMENDATION
staff recommends that the city Council:
1. Conduct a public hearing on the proposed Local Coastal
Program.
2. Adopt the attached resolution and forward the document
to the California Coastal Commission for revievl and
certification.
prepared by: Paul Berlant, Director of LUTM
Suzanne FriCk, Planning Manager
Paul Foley, Associate Planner
Attachments: A.
B.
C.
Resolution Approving Draft LCP
March 1991 Draft LCP
November 14, 1990 Planning Commission Staff
Report
Public comments on May 1990 Draft LCP
Responses to Comments on May 1990 Draft LCP
D.
E.
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city Council Meeting:
Santa Monica, California
RESOLUTION NO.
(City Council Series)
A RESOLUTION OF THE CITY COUNCIL
OF THE CITY OF SANTA MONICA
ADOPTING THE LOCAL COASTAL PROGRAM
WHEREAS, in November, 1990, the city staff submitted a
draft Land Use Plan to the planning Commission; and
WHEREAS, on November l4 and 28, December 6 and 19, 1990,
and January 23, 1991, the Planning Commission held public
hearings on the Local Coastal Program and approved it with
certain modifications; and
WHEREAS, on April 9, 1991, the city Council held a public
hearing on the Local Coastal Program and adopted it with certain
modifications,
NOW THEREFORE, THE CITY COUNCIL OF THE CITY OF SANTA MONICA DOES
RESOLVE AS FOLLOWS:
SECTION L
Pursuant to Public Resources Code Section
30510, the City council certifies that the adopted Land Use Plan
of the Local Coastal Program, attached hereto, is intended to be
carried out in a manner in full conformance with applicable law,
and that it contains, in accordance with guidelines established
by the Coastal commission r materials sufficient for a thorough
and complete review.
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SECTION 2.
The City Council does hereby authorize the
transmittal of the approved Local Coastal Program to the
California Coastal commission for its consideration.
SECTION 3. The city Clerk shall certify to the adoption
of this Resolution, and thenceforth and thereafter the same shall
be in full force and effect.
APPROVED AS TO FORM:
i ~;~j~":~4~ "",--~ ;
ROBERT M. MYERS
City Attorney
w/lcpres
04/01/91
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A\T~CH~ENT C
PROGRAM AND POLICY DEVELOPMENT DIVISION
Land Use and Transportation Management Department
MEMORANDUM
DATE: November 14, 1990
TO: The Honorable Planning Commission
FROM: Planning staff
SUBJECT: Review of the Draft Local Coastal Program CLep)
SUMMARY
This staff report supersedes the report distributed for the Plan-
ning Commission meeting. Since the distribution of that report,
staff has reviewed the document in depth with the City Attorney's
office and therefore proposes some additional changes for commis-
sion review. The specific changes are identified on the Errata
Summary attached to this staff report.
Since the release of this report it appears the Save Our Beach
Initiative has passed. The Initiative will require changes to
the LCP; those changes will be incorporated into the document
following Planning Commission review and prior to city council
action.
PROPOSED PROJECT
As required by state law, the city of Santa Monica proposes to
adopt a Local Coastal Program (LCP) to assume authority over
coastal development permits. The LCP includes two components: a
Land Use Plan that lists the policies of the Coastal zone and an
Implementation Plan that puts the policies of the LCP into ef-
fect. The LCP must be adopted by the city council before it can
be forvlarded to the California coastal commission, which is
responsible for certifying LCPs.
CEQA STATUS
The California Environmental Quality Act (CEQA) specifically ex-
empts preparation of Local Coastal Programs from environmental
review, pursuant to sections 2l080.9 and 21080.5. An EIR is
therefore not required for the LCP. In addition, Division 20,
Chapter 6 of the Public Resources Code discusses the elements and
analyses regarding impacts that are required for certification of
the Land Use Plan of the LCP. These issues are discussed in the
Impacts section (Chapter V) .
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BACKGROUND
with the Coastal Zone Conservation Act of 1972, California voters
mandated the state to protect and regulate development of the
state's coastline. An interim california Conservation commission
was established as a regulatory agency governing coastal develop-
ment permits. As such, it became a permitting agency for
development near the shoreline. Its primary task, however, was
to develop a coastal plan for California.
Four years later, the California legislature passed the Califor-
nia Coastal Act of 1976 which, among other things, created a per-
manent Coastal Commission. The goals of the Coastal Act included
maximizing public access to and along the shoreline; avoiding
sprawling development: preserving scenic areas: and encouraging
coastal-dependent industry.
The Coastal Act requires all 67 coastal cities and counties to
prepare Local Coastal Programs (LCPs) to govern development
within each jurisdiction's coastal zone. This area generally
extends inland about one-half mile. The Coastal Act sets basic
goals and policies, but leaves specifics to local jurisdictions.
As each LCP is certified, local government assumes the authority
to issue coastal development permits if the development is con-
sistent with the LCP. ~he Coastal Commission then assumes a sec-
ondary role, conducting appeals of local permit decisions, ap-
proving proposed amendments to LCPs, providing technical assis-
tance and advice, monitoring local permits to assure compliance,
and performing five-year evaluations of LCPs.
By state law, the LCP is required to include two sections: a
Land Use Plan (LUP) that describes the policies of the coastal
zone and an Implementation Plan to implement the pOlicies
specified in the LUP. Local jurisdictions may submit the entire
LCP at one time for adoption or in two separate stages. The city
may issue coastal permits once the LCP is certified by the Coast-
al commission.
RECENT HISTORY OF SANTA MONICA LCP
Work on Santa Monica's LCP began in 1977. The city first issued
a draft LUP to the Coastal Commission in 1981. Subsequent delays
and conflicts resulted in release of a Draft Land Use Plan (LUP)
in 1985.
On October 2l, 1985, the Draft LUP was considered by the Planning
Commission, which conducted a public hearing and forwarded its
comments and a recommendation for approval to the City Council.
An Implementation Plan was to follow after initial certification
of the LUP by the Coastal Commission.
On May 6, 1986, after reviewing comments from Coastal commission
staff and after conducting a public hearing, the city Council
adopted the LUP with specific revisions.
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Subsequently, in July 9, 1987, the Coastal Commission conducted a
public hearing, further modified the document, and adopted Santa
Monica's LUP with changes.
On September l4, 1987, the Planning Commission conducted a public
hearing on the revised LUP and forwarded its amendments to the
City Council with a recommendation for adoption.
On November 10, 1987, the city Council conducted a public hearing
and, after deliberation, took no action on the LUP. At that
time, the city was considering a new Zoning Ordinance that would
modify major elements of the City.s land use policies. As such,
further consideration of the LUP was postponed pending adoption
of the new Zoning Ordinance. Staff was directed to modify the
LUP to be consistent with the new Zoning Ordinance, which was
adopted in 1988. Shortly thereafter, preparation of a revised
LCP, including both an LUP and an Implementation Plan, began.
CURRENT DRAFT LCP
The current draft of the LCP is a policy document based largely
on the 1987 draft LCP that resulted from discussions with the
Coastal Commission. However, there are two key changes. First,
the current LCP reflects policy changes made over the three years
since 1987, including the 1988 Zoning Ordinance and the Ocean
Park Rezoning. Second, the Implementation Plan is new and rep-
resents the City's effort to obtain certification of a complete
LCP.
A draft of the LCP was released to the public on May 25, 1990.
Following a seven and one-half week public review period, several
comments were received. These comments and their responses are
included as attachments to the staff report. As noted through-
out, appropriate comments and changes were incorporated into the
LCP. Thus, the LCP reflects not only direction from the Coastal
Commission, but from the public and other regulatory agencies as
well.
ORGANIZATION OF THE LCP
The LCP is divided into two sections. First is the LUP, which
outlines existing conditions, issues, and goals of the Coastal
Zone, as well as the policies needed to achieve the goals of the
Coastal Act. The second section is the Implementation Plan,
which includes Zoning Ordinance revisions and specific Coastal
Zone ordinances to implement the policies of the LUP.
LAND USE PLAN (LUP)
The Land Use Plan is divided into five chapters:
Chapter I outl ines the background and purpose of the LCP. It
includes a brief history of coastal protection legislation and
describes Santa Monica's role in that planning effort.
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Chapter II describes existing conditions and issues in the Coast-
al Zone by dividing it into eight subareas, which largely cor-
respond to zoning boundaries. Each possesses unique characteris-
tics that are described in detail.
Chapter III discusses five major policy topics:
o Access
o Recreation and Visitor serving Facilities
o Environmental Quality
o scenic and Visual Resources
o New Development
Discussion of each topic includes the existing conditions, oppor-
tunities, problems, or constraints that currently exist.
Chapter IV is the key component of the LUPf as it lists the
specific policies of the Coastal Zone. These are organized by
policy topic and include general policies (i.e. Access, Environ-
mental Quality) as well as policies specific to subareas within
the zone (New Development).
Chapter V outlines the potential impact of the LUP on each of the
eight subareas.
ANALYSIS OF LAND USE PLAN (LUP)
The current Land Use Plan is the pivotal element of the LCP. It
has been updated to reflect the city's existing policies (Zoning
Ordinance, Ocean Park rezoning) and potential future policies
(North of wilshire development controls, civic Center specific
Plan, Main Street Ordinance revisions). The LUP is designed to
be consistent with all City regulations. The LUP also reflects
input from the community, Coastal Commission, and other regula-
tory agencies.
The LUP has been designed to comply with the 1976 Coastal Act and
obtain certification from the California Coastal commission.
Upon certification, the City will have the necessary policy basis
and implementing authority to issue coastal development permits.
There are III pOlicies listed in the LUP, all organized under the
five policy topics noted in Chapter III. New policies that are
inconsistent with current standards and require amendments to the
Zoning Ordinance and/or the General Plan are noted. Following is
a highlight of key LUP policies (note: all policies are not
listed) :
Access
These policies cover access to the Coastal zone, especially the
beach, as well as circulation within the area.
POlicy 7:
This policy requires that new development directly
adjacent to the beachfront provide a dedicated access
easement under certain conditions. Such easements do
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not have to be available to the public unless a
public or private agency agrees to maintain and be
liable for the accessway.
policy 12: This policy recognizes that an assessment fee on new
development may be appropriate to enhance public ac-
cess to the beach. This would require a nexus study
to determine a reasonable fee. Until such a fee is
adopted, projects that significantly impact access
will be required to mitigate the impact to a level of
insignificance.
Policy 17: This policy recognizes that the city should partici-
pate in efforts to increase capacity on PCH through
programmatic improvements.
Policy 18: This policy requires that new commercial or mixed-use
development make their commercial parking facilities
available to the general public when the business is
not in operation.
Policy 20:
This policy recognizes that TORCA
impact parking supplies and that
monitored by the city.
conversions may
impacts will be
Policy 22: This policy prohibits residential parking permit use
in the public beach lots during the day.
Policy 23: This policy reflects the Coastal Commission's agree-
ment to allow an intensity of development on the Pier
that can be accommodated by the 471 parking spaces to
be replaced on or near the Pier. Any further inten-
sification of development will require appropriate
mitigations (e.g. more parking, shuttle program).
Policy 26: This policy directs implementation of a shuttle sys-
tem to provide service throughout the Coastal Zone
and specifies project timelines.
POlicy 31: This policy requires that new commercial and residen-
tial development with ten or more parking spaces pro-
vide for secure storage of bicycles.
Recreation and visitor Serving Facilities
These policies cover visitor-serving facilities within the Coast-
al Zone, inclUding restoration of Santa 1>fonica Pier and en-
couragement of visitor-serving uses in the Oceanfront and Down-
town areas.
POlicy 37: This policy establishes that visitor-serving commer-
cial recreational facilities have priority over
residential or general commercial uses on parcels
zoned RVC. Several parcels have and will be rezoned
from residential to RVC in Subareas la and lb.
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Policy 44:
This policy discusses the protection and encourage-
ment of low-cost lodging facilities, and establishes
mitigation procedures for demolition of such facili-
ties.
Environmental Quality
These policies emphasize environmental quality pOlicies, em-
phasizing protection of marine habitats and water quality.
Policy 55:
This policy describes the city's commitment to
monitoring and improving the quality of storm drain
water.
Scenic and Visual Resources
These policies concentrate on visual resources, including protec-
tion and improvement of public views of the ocean.
Policy 58: This policy protects public views to, from, and along
the ocean, Pier, and Palisades Park.
Ne,', Development
This section describes policies for new development that apply
throughout the Coastal Zone, including policies for each of the
eight subareas. These include standards for scale, bulk, and
design considerations. A new policy is being proposed to address
any growth controls on the rate of future development.
policy 64: This policy specifies general guidelines for new de-
velopment to enhance public access to and within the
proj ect. Measures include providing pedestrian and
bicycle circulation and assuring the recreational
needs of residents on-site is provided.
Policy 68: This requires that low or moderate-income housing
demolished in the Coastal Zone be replaced elsewhere
in the zone.
policy 70: This policy requires that the height of hotels and
detached parking structures be governed by the per-
mitted height limits and not by the number of stories
in the C3C and CM Districts.
Policy 72a: Development shall comply with future growth manage-
ment plans that include but are not limited to con-
trolling the rate of development in the Coastal Zone.
Policies 73 through Ill, specify development standards and per-
mitted uses in each of the eight subareas of the Coastal Zone.
These have been designed to be consistent with the development
standards contained in the existing General Plan, zoning Or-
dinance, and pending revisions. However in some areas new poli-
cies may be inconsistent with the General Plan or zoning Or-
dinance. These policies are noted.
- 6 -
One area in the Coastal Zone where staff proposes to modify the
development standards is the area bounded by Pacific Coast High-
way (PCH) to the west, the Pier to the south, and the City limits
to the north. This area is predominantly zoned Rl and R4. In
response to Coastal Commission staff concerns about preserving
existing Coastal-related uses and limiting development and inten-
sification of residential uses, staff recommends the area be
zoned a mixture of Rl and RVC. This will allow retention of ex-
isting single and mUlti-family residential uses, however it will
prevent intensification of residential uses by limiting new con-
struction to single family uses. Because of the small lot sizes
that predominate along PCH, this rezoning reflects what can actu-
ally be built in this area. At the same time, it responds to the
Coastal Commission's concern about residential intensification of
this beachfront subarea.
pOlicy 73: This policy requires that new single family residen-
tial uses in the subarea north of Santa Monica Pier
(along PCH) provide two visitor parking spaces.
Guest parking requirements for single-family residen-
tial uses elsewhere in the City do not change. This
policy is more restrictive than the existing guest
parking requirements of the Zoning Ordinance (no
spaces required for single-family residential uses).
pOlicy 74: This policy describes the rezoning of residentially-
utilized parcels north of Santa Monica pier along PCH
to Rl. This also identifies special building height
standards for the Rl zone for parcels less than 30'
wide, including a 3 story, 35' height limit (40' for
pitched roofs). This is necessary due to small lot
sizes and the high water table, which makes subter-
ranean parking difficult. This policy allows greater
height than the City-wide Rl height limits.
Parcels 30' or wider shall adhere to standard Rl
development standards.
Policy 75: This policy rezones residentially zoned parcels uti-
lized with non-residential uses in Subarea la to RVC.
This ensures retention of visitor-serving commercial
uses along the beachfront. These parcels consist of
the four beach clubs (Jonathan Club, Sand and Sea
site, the Beach Club, Salt Air Club) and the public
parking lots and vacant parcels. The policy requires
changes to the Zoning map and General plan Land Use
map. Currently the designation is R4 High Density
residential. Residential uses would be prohibited on
the ground floor of RVC parcels in this and all other
subareas with RVC zoning.
policy 76: This policy rezones the C2 zoned parcels north of
Santa Monica Pier along PCH (currently state-owned
parking lots) to an RVC designation. This modifica-
tion would allow appropriate Coastal-related uses,
and pUblic parking. This policy requires changes to
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the zoning and General Plan designations. currently
the designation is C2 Neighborhood Commercial.
policy 77:
This policy describes the zoning standards for the
area bounded by the Promenade, Vicente Terrace, pico
Boulevard/ and parcels west of Ocean Avenue-fronting
parcels. All parcels with non-residential uses will
be rezoned RVC to ensure retention of visitor-serving
commercial uses.
Parcels with residential uses shall be zoned R3 to
ensure a balanced mix of uses in this subarea.
This policy also addressed the area west of Appian
Way to the Promenade, from Pico to vicente Terrace/
where RVC standards will be 2 stories, 30', with a
l.O FAR. This is consistent with the standards com-
bined in the Land Use Element but inconsistent with
the Zoning Ordinance standards which permit 3 stories
45' Z.O. FAR. The Zoning Ordinance is in error and
will be modified.
policies 43, 85, 98: These policies prohibit residential
units and offices on the ground floor frontage of
Ocean Avenue between California and Pica. This is
inconsistent with zoning standards for the area, cur-
rently zoned RVC and CC. The RVC zone permits resi-
dential units while the CC zone currently allows non-
profit offices and conditionally permits private
offices.
IMPLEMENTATION PLAN
This portion of the LCP is divided into five sections. section I
introduces the Implementation Plan and describes its purpose.
section II outlines amendments to the Zoning Ordinance necessary
to accommodate the pOlicies of the LUP. section III describes a
development impact fee associated with two policies of the LUP.
section IV describes the shuttle transit program to be imple-
mented by a policy of the LUP. Finally, Section V outlines the
parameters of a comprehensive sign program for the Coastal Zone
(and the City).
ANALYSIS OF IMPLEMENTATION PLAN
The Implementation Plan, similar to the LUP, is designed to be
consistent with existing city policies and the zoning ordinance.
Key areas of note are highlighted here by section:
section II--zoning Amendments
This is the most detailed section of the Implementation Plan,
providing text revisions to the Zoning Ordinance. As the most
recent revision of the Zoning Ordinance provided the impetus for
most of the modifications to the LCP, few changes are needed to
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implement the LCP. Four new subchapters are proposed for the
Zoning Ordinance:
o Coastal Overlay District. This overlay covers all properties
in the Coastal Zone and triggers the requirement for a
Coastal Development Permit.
o Coastal Development Permit. This replaces the permit appli-
cation to the Coastal Commission and outlines the administra-
tive and appeal processes.
o Administrative Coastal Permit. This permit would apply to
development projects that require administrative approval.
The procedures are spelled out for such permits.
o Local Coastal Program. Future amendments to the LUP are
inevitable as modifications to the General Plan, Zoning
Ordinance, and other pOlicies occur. This section outlines
the procedures to prepare, amend, and adopt the LUP.
In addition, miscellaneous amendments to the Zoning Ordinance are
necessary to implement specific policies are listed.
Section III-Impact Fees
section III summarizes the development impact fee imposed on new
development in the coastal Zone that removes existing low-cost
motel or hotel units. The city Council adopted such a ordinance
earlier this year.
section IV--Shuttle Transit Program
This section outlines the development of a pilot shuttle program
that would circulate throughout the Coastal Zone, with stops at
all major destinations.
Section V--Comprehensive Sign Program
This section summarizes the Comprehensive sign Program that
establishes a consistent, unified sign program that conveys
Coastal-related information clearly and effectively.
ADOPTION PROCESS
Timely adoption of the LCP by the City and certification by the
Coastal commission are critical for several reasons.
First, preparation and adoption of santa Monica's LCP is a long-
overdue accomplishment, one whose process began over thirteen
years ago. During this time, over 58% of all coastal jurisdic-
tions have had LCPs certified by the State. In Los Angeles
County, Santa Monica remains one of only four cities (out of
eleven coastal cities) that have not had at least an LUP
certified. Years of delay have left Santa Monica behind other
cities in fulfilling its legal obligation and obtaining total
permit authority over its coastal development.
- 9 -
Second, the California Coastal conservancy has approved
$1,000,000 in assistance to the City for restoration of the pier
Carousel Park. However, by the terms of the agreement, the City
can not encumber $850,000 of these funds until an LCP is certi-
fied. This situation creates a continuing negative balance in
the pier fund, and effectively results in significant opportunity
costs for Santa Monica, as the city must utilize its own General
Fund monies for the project. The conservancy has notified the
City of its intention to cancel the grant if the city does not
adopt an LCP within the next six months. similarly, potential
Conservancy funds for other common area improvements on the Pier
can not be accessed until the LCP is certified.
Finally, the City has been awarded grant monies of up to $57,305
from the state for preparation of the Implementation Plan section
of the LCP. This agreement reimbursed the city for work complet-
ed up through September 30, 1990. Potential for future grants
may be contingent upon timely progress in adopting the LCP.
CONCLUSION
In light of the development policies in Santa Monica, which have
changed with the adoption of the Zoning Ordinance and Land Use
and Circulation Elements, the LCP reflects existing policies.
Once the LCP is adopted, any future changes to development
standards or policies will result in amendments to the LCP as
well.
The LCP represents a body of information, analysis, and pOlicies
that for the most part, have been reviewed and analyzed since
1987. Since that time, the community, regulatory agencies, and
the California Coastal Commission have all had input into the
formation of the September 1990 Draft LCP. Accordingly, the
revised document modifies the 1987 version by making it
consistent with new city policies. Ultimately, it is a document
designed to comply with the State's Coastal Act and result in a
certified Local Coastal program for the City of Santa Monica.
RECOMMENDATION
Planning Staff respectfully recommends that the Planning Commis-
sion conduct a public hearing and forward the Draft Local Coastal
Program as submitted to the city Council with a recommendation
for approval. Following a Council public hearing and adoption,
the LCP will be sent to the California Coastal Commission for
review and certification.
Prepared by: Paul Berlant, Director, Land Use & Transportation
Management Dept.
Suzanne Frick, Principal Planner
Douglas Kim, Assistant Planner
Attachments: l)
2)
3)
4)
Draft LCP, September 1990
Comments on the May 1990 Draft LCP
Responses to Comments on May 1990 Draft LCP
Errata sheet for Sept. 1990 Draft LCP
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=6 Sea Colony DrIve
Santa MODIca, Calt!. 90405
July 4. 1990
By Federal Express
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City Pla:;~lng DlVlslOr /PPD
1585 Mal[: Street. Rcom 212
Santa Momca, Cahf. 90401
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He CocmeT~s or: Draft LCP
'10 1'18 \fembers of the CIty Plar:mng DIVISIon
In revIe'Nl'":g the C1ty of Sarta );1omca1s Yiay, 1990 Local Coastal Prcgram, I wm co;nr-ec-:
0- bo areas In WhICh the CIty'S LCP IS totally IDcorlSlstent w~th the Coastal Act of 1975.
lD. the t'.'iO areas lIsted 8e10w, the CIty'S LCP POllCI€S ar:d ImplementatIOn plar, althoug:-
2p~ean:::g :easo'1able and valld on ti1el[ face, are dla!T'etncally opposIte of the Act1s ;J:'::--
pose ard statec goals.
1 1. Pubhc PartlcIPatlon
Tr e Pr ocess
F'J::suant to t':e Act, each coastal CIty IS requ~red to formulate a local coastal progralTl hit:)
exter.SlVe :;ubl1c ::artlclDatlOD. On three pno: occaSlOns the CIty of Santa :-10~lca has S'J~-
r';t:ec for cert~flcatlOn to tt:e Sal1forma Coastal Cor:H;JISSIOn a local coastal ;Jrogra::' - :0
1981, 1[;, 1983, and lD 1985. for vanous reasons Dare of these LCP's was ce:tlfIed by the
Co m 'TIlSSlon.
T~e eny s~ates on page 1-2, "In prepar:ng thIS cocur-er.t. Sar.ta ylcr:.lca has prOlllOec. :c:-
extensIve pubhc part~cliJatlOn and for r8Vle'.'" by the mterestec publIc." The CIty the... :lS;:S
" '.ar:ety of p"ograr:-s and plans whICh sU;Jposed1y lcvclved meetings and wor1;:shops, '10'.'.'6Ve[.
""'a~y, If cot all, of t:lese '"'^leetmgs and workshops OCC:.1rrec prior to the CIty's SUbrr.1SSlCr:
cf Its :'C? In 1981, 1983, or 1986. ~1any people who are now Santa ~lomca reSIdents '~ere
:lOt resldents pnor to 1981, 1983. or 1986, mdeed the f1(st reSIdents of Sea Colony III, a
cCIT.;Jlex of greater than 125 UnIts. moved iDto thelf horres after 1986. TJ"le people ~\'~o
are coastal reslderts now may form a very dIfferent g:oup than the people who 'i.\"ere 5a:-.-
ta \{omcE ceesta1 reSidents pnor to 1981, 1983, aDc 1986, and many current coastal reslceTr.s
~ave Jeen afforded :to opportumty for commer.t on thIS LCP. In addltlOfi reSIdents w~o a:-
:endec! meetl~gs and workshops on, for exa:nple. the PIer RestoratlOn Progra~, atter::ded
these ~eetmgs and workshops for a speclflc ;:Jurpose and dId not realIze that they we~e
'lpanIclpatmg'l In the preparatlOn of the CIty'S LCP, I attended meetIngs regarding the
:.1am Street Plan whIch focused on COillIT.Umty OppOSItlOTI to a proposed paz-kmg stZ'....:cture
or. ~<am Street; the Santa MOnIca LCP was never mentIOned at a:lY of the meetmgs I at"'l:e~dec.
A year ago 1 sent a letter to CIty of Santa Y10mca Counell (\>lembers and CIty offlclals re-
garcl::g the proposed structure/sculptures to be placed cn our publIc beach; In the letter
1 requested that the pUbhc be gIven rl'.aXliJ'lUm opportunty to partICIpate In the forrr:t:lat:Q~
of an LCP. I receIved no response to my letter wtlch has apparently been Ignored.
The Result
On :.!ay 24, 1990, I receIVed H] the ..."a11 a nonce that Draft LCP's were avaIlable at City
Hall for purchase and comment.
There has been l!2- opportumty for publIc cOrJ me::t or Iriput m formulatmg and developmg
-2-
thIS LCP. T":s LCP rer:'resents the v~ews of CIty employees and a consultant who was h~[e:j
for tl1e pu:-~ose of pre;:;anng thIS docu-nent. and the pohcles and VIews expressed In It do
not -:.eeessan!y reflect the VIews of t~e residents of Santa ~lomca
Are you :-:m~ gOIng to afford us cny o::Jportui'lty for comIT'ent and mput pnor to the su:-
:-15510" o~ t~;s LCP to t; e CIty Coutell and the Call forma Coastal Com IT'.tSSlO r.?
l5 thIS p[1;,tec ane cou-d dccument t1'>e fmal copy you Will present to the Clt}' CounCIl 2nd
tt',e CalIfor:11a Coastal C07;"'1ISslOn. 0:" WIll you make Changes In It based on public I:lOut
a;>d tave It re-pnnted and re-bour.d prior to Its submISSIon to the CIty CouncIl and Coasta:
Co,", i-1SslOn?
TSl"'en :s trIS LCP scheduled to be conSidered by the CIty CounCIl and the CalIforma Coastal
COT ~:S31cn?
2 ? Xatural Ele,ert Scul;Jture (:JES) Park-AKA Beach Master Art Plan-UArtl1 or the beac:,.
Tr€ Precess
I:: eltrer Decerr.ber. 1989. or Ja:"llary , 1990, the CIty WIthout any pubhclty or notIce to the
;JublIc. erected an exhIbIt In CIty Hall regardIng the ~atural Element Sculptcre (NES) Park,
co:n;;;le:e WIth 8allC'ts askFg for co1"1' -:ients. The exhIbIt conSIsted of an aerIal photograph
0: the eO:lre Santa MODica beach:ront (whIch I could not deCIpher WIthout the help of two
General Serv:ces e~;Jloyees) \'ilth XIS In the locatIOns of the proposed 11art11. such X's be'~g
"to sCale." Se;Jarate p,:ctos contc.Ined a descri~tion of 4 of the pIeces, an adcitlOnal 4 to
be addec (ans c.escnbec) at sorre fL:ture tI~e. Only after I sent a January Ii, 1990 letter
regardI:'g :hIS ext'ltnt to the Out!ook:. whlcr led to a full front page article cn thIS sU'::Jec:
:0 :;:~s ne\'. spa~e:. dId Sa~ta Ylor.lca reSIdents learn of the eXIstence of thIS eXhIJlt' In ;71Y
letter I eTlCOd ages Satta ~<or:.lea reSIdents to ex~ress theIr VIews to Santa :.10mca Citv Ceuc.-
e:! ~1errjers. a'":.c I iear~ed fro'TI one Santa Nomca CIty CounCIl :.1ember that 95% of the
resu:er:ts who respo~ded dId not want thIS "art'. on the beach.
Xo -::e'?t!o1'l T.<.'85 "ace of the XES PaLl{!Beach Master Art Planl'"art1' on the beac~ In the
1983 0: lEeS LCP's. even though the Idea was conceIved m 1982 a:ld even though ar. Illustra-
t:ve ":ooklet was In the CalIforma Coastal CommIssIon flIes; therefore. ~ntIl !-1ay, 1989. when
the co::trove::-sy surf aced regardmg tt Solar Web." Santa i\10mca reSidents were totally unaware
of th:s P~an for "artr' on the beach.
Oil ;:Jage IV-12 of the Access PolICIes. General Access PoliCIes sectlon of the Santa Momca
LC? there 15 the folloTNmg.
1'49. To enhance public recreatIOn opportumtles and the beach
eX;Jenence, the CIty shall develop a Natural Element Sculpture
(:JES) Park along the three-mIle stretch of the Santa Momca
Beach. The art works wlll reflect the natural elements and the
UiVlronment. and proVlde a umque coastal oppor"tunI ty. A total
of ten art works have been deSIgned and WIll be placed so as to
be safe, touchable. cllIT'able, unenclosed, and WIthout mterfer-
eree WIth the Vlew of the ocean and the use of the beach. tI
'"
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On Dage 1\-15 lTI the area er:.tltled Sar:.ta :.1omea Beaer ~orth of the Santa !\-1omca PIer
(Subarea 12), :5 gene:-aI access ;lOhcy nUT~er 74 whc~ mcludes l'...eleIT'ents In the
~atural Ele'-"ent Sc~Ipture Park ..,I'
On page 11/-!6 1[1 t;..,e area ent:tled Scrota )fomca Beach South cf t~e Santa ~fomca PIer
(Subarea ibIs ge'1eral access pollcy [l~mber 76 WhlGt'. lncluces 1I...ele"1"1ents m the
i, atural Eler ent Scc:i~:ure Park ...11
Or page IV-16 ., the area entltlec South Beach (S~::Jarea Ic) IS general access ;Jolley
:--....: m ":ler 7i 'NhlC h 1 ncl'1des 11 elem ents In t~ e i'-J atural Ele;n ent Sculpture Park ... I'
T".e Result
\"..~hy are the te": art works "T18rltlonea Ii' polley num::Jer 49, and the "elements" In tre
1\at1..:ral EleTent Sculpt'Jre Park mentIOned ITI pohcy nU'Tlbers 74. 76, and 77 not descrl~ed
1- GetaIl? Exactly what "eJementsl1 are prcposec for the subareas and where IS each to
t:e ;JlaceC? If a reslder,t \\ as unable to V18W the exhibit lD CIty Hall. how. from the refer-
e:ces :r: ger;eral access po!lcles nu-nbers 49,74,76. and n. can that mdlvldual know what
yoe: are propos:ng? Why IS there no map lD the LC? Illust::-atmg the prop osee locatIO!!.5 fa::-
t:--.1S "art" on the beach?
The CIty 1, thiS LCP professes great concern for cO':1~lYlflg with the maJor pronslOr'S In
the Coastal Act :nandatlng Dubhe access, recreatlOn ard envHonrr,ental qualIty, and scer.~c
an;:: \1sual resoerces, yet a descr:ptlOn of 4 of the proposed works (If they are the sa78
4 wcrL.:s ",'hlC:- ',.;ere IILstrated a"d cescr:bec lr: tl-:e Crty Hall exh~blt) shows that the City
hE.s -ace a rrockery c~ f~e '::)aSlC goals c: the Coastal Act. SectlOn 30210 cf the Act ::-a::-
Gates t':;:;t .. - ax:""" U:7J access ... ar.d recreatlona! opportumtles shall be proVldec for ell t~e
people CGtSIStS:lt Wltt1 ;Jubhc safety r:eeds and the need to ;:rotect pt.:~l1c rIghts, cghts of
;:Jrlvate ;ro:Jerty owners ...... Sectwr.. 302.51 rrandates that the I'scer:.lc and vIsual ::;.ual1tles
of ccastal areas sral! oe cC:islderec and pf:Jtected as a resource of ;n.:!Jhc l:n~}Qrtcnce, Pec-
fT":lttec. develo;:n,ent s'1all be Sited ane deSigned to protect views to ar:d along the ocea:: ane
scemc coastal areas. to i7'.lnlG11Ze the alteration of natural lar;d forrr.s, II ane! that lInew
developlle-:t lD hlghiy scemc areas ... srall be S.Jbordtnate to the character of Its settFlg.lI
':'hrG!.lghout the LCP t':e City stresses that maximum access to the coast WIll be enhanced,
t~at ;Jub!:c recreatlCnal opportumtles w111 be rr.axiffiIzed. and that the art works l' w111 be
pLaced so as to be safe, touchable, chmajle, unenclosed, and Without mterference With the
VIew of the ocean a::c: use of the beach." (page 1V-12. pollcy nlimber 49) The CIty further
states that cor.fllcts of pohcles shall be resolved to favor protection of slgmflcant coas,al
:esources such as land, water, alf, etc. (page IV-4, general 90hcy number 2)
I!1 acdltlc::: to the Scemc a:.d VIsual Resources )'1ap WhlC~ Illustrates that the entIre area
along t1:8 ':Jeach IS a SC8:lIC corrIdor, the City states that "Santa Momca1s :Ta]or scemc
resources are those aSSOCIated wIth the beach aoc ~he bay, the PIer, and the Pahsades
bLffs.1' C;Jage III-25, ;Jaragr-aph 2), anc. I1pubhc Vle'l;S to,. froI"", and along the ocean, the
P:er, and Pahsaces Park shall be protected. II (page IV-13, Scemc and Visual Resources polIcy
:',,-,':"".Der 59)
The i\ES "Elehlents/Art11
a. 2 ".:a115 of water. each 200 feet ~Igr. a:id 30 feet apart, WhlCh seCld a Single strea'7l
of water 700 feet hIgh every 15 mmutes to be placed at the end of the Pier In the
water (art1sts Lc.rry Bell 8:1d Ene Orr)
-
-01-
Even thougc the GIty acknowledges that the western end af the P1er ~s a pO~H;lar spo::t
for flshlllg, I'a;: 1.....portant recreatIon for peo~le With a hmlted mcome,11 (page m-16,
>Jarag:aph P, the iJlacwne::t of th:s "eleme~t" at the end of the PIer will Impede this
coastal-cepence!1t recreatIon 2/'"jd will gIve pnor:ty to a nen-coastal deper.dent ar.d r.oP-
ccastai related ce'.'eloiJr.eI't at the ex:)ense of coastal related and coastal dependent
a c:m ty (flsh:ng). thIs 1S In vIOl atlOn of ti1 e Coastal Ac:. The CIty express es grea l
co-:cer:: for ~he least ter'l (Cahforma bro'lm pel1can. and any other threatened or
enca:;gerec SDeCJeS - page 1V-]2. E:1Vlron'"=1ental Ouahty polIcy nu~ber 54), and the
Cl:y ;Jron"'lses to ;;rotect tnelr hab1tat area and consult wIth the Depart"nent of FISh
a-::d Game ;Jrwr to lr:Stltt.;U-:g lrrprovements \....h1ch \'.'111 imiJact the foragmg area. The
Clty'S Er:'.'lrc':::1ental Resources ar::d Hazards ;vlap shows that the least tern forag~ng
area c07l1pletely surrounds the west end of the PIe~; the Departrr:eot of Fish and Garre
has !Delcated that adcltlonal boatmg H: thIS area could Impact the forag1ng area. surely
a 700 foot steear. of water wodd create such tL:rbulence that the foragmg area of the
le2.st ter!:. ,\ Dule ::e !:.egauvely I-npacted, WhICh ca:: cat.:se cetenoratlOu of the ecologIcal
balance In ehe coastal zo~e. F~::al1y, two 200-foot walls of water and one 700-foot
strea:'""' af \-\'ater ''.'111 obstruct pi.l31rc VIews of the coasthne, VIews fraT. anr road, anc
Vle'ss from t~e beach recreatlon area to and along the coast 1r- vIOlatIon of the Coastal
Act.
n
.....
Doc:glas FIr tl-:1ber wall of teee truf'l.::.s 190 - 200 feet In length. 16 feet hIgh, ane 16
feet wlce (artIst Lloyd Hamrol)
A 190 - 200 feot wall of tree tr~nks 16 feet rlgh and 16 feet wide posltlO"'!.ed betT..,ee:-
publIc par1or:g JOTS, the bIke ;:ath. and the pedestrIan path and the ocea~ cannot possIbly
IT'aX~mlZe and enhal1ce :1:e put:hc r 5 access to the ccast. It Im;Jedes, l1:nlts. and cbstrc;cts
pujl1c acce~s to the beach and coest, WhICh access 15 protectec <lnce: the Coastal Act.
Tne ~elgtt of t':~s "ele...ent" obstn:cts pl,;::,hc v~ews of the ocean.
c.
Crater \'.-:-"lch 15 180 feet 1r. clar-.eter and 12 feet deep (artIst James T:..~rrell)
A crater WhlCh 15 ISO feet lU dIameter and 12 feet deep on the beach located bet"seen
p'..;bhc par'.;l~g lots. or tre bIke path, or tJ.e pecestnan path and the ocear:. tctall~' pre-
'/en:s a::: InCll.'lCUal frow reaChl;1:g the coast and ocean wHhol1t wal'm:g all :he way arot..:r:c
the crater a::d thereby totally obstructs pubhc access to the beach. w~:ch access ~s
s~pposed tc be protected under the Coastal Act. Tl1e City "as stated In general access
pelley [;"J'7:.ber 49 that the art works WIll be unenclosed. thereby enabhng a chIld to fall
lrito a 12-foot crater. How can the overworked and understaffec lifeguarcs mcmtor and
~aticl the ocean 1:1 front of them and the "artl1 behlUd therr.? ThIS elerrent 11l'Jstrates
the CIty'S total lack of concern for pubhc safety. health, and welfare, 1;] \'101atlco of
sectlO:" 30210 of t18 Coastal Act. ThIS element takes away from pUblIc recreatlor.al
L:se a:: enor:TIOUS ar;lOunt of beach (the SIZe of 2 olym;nc-slze svnmmmg poois). In the
LCP the City states on page III-12. 'lChlef among the impressive array of coastal recrea-
tIonal ar,d VISItOr-ServIng faClhtles 15 the nearly three mIles of pUblIc beach. IT WhICh
:5 the "'1'05t heaVlIy used beach In Los Angeles County and qUlte pOSSIbly one of the
rr ost mtensely used ill the State." If Santa Nomea Beach IS so heaVlly used for ~each-
related ~eceeatlonal actIVItIeS, why would you 11mlt beach use and gIve [;monty to th:s
no~-coastai cepencent and nOQ-coastal related developmer::t?
~
-5-
d. Black metal sfHcer-ty?e sculDture whch 1S 72 feet long and 16 feet hIgh entItled "Sola:
V,'eb" (artIst .Nancy Holt)
On Septem~er 14, 1989, the Cal!for~na Coastal CO'11IDISSIOn demed tl1e City permISSW:i to
Install "Solar We8"' on the South Beach Just north of Ver:.lce Beach based on pUb!lc safety,
emlron:-r1eI'taI. 2nc scer;IC and vIsual concerns. A declslOr. of the CalIforma Coastal Com-
ffilSSlOn shoulc be :-espected and upheld, not Ignored.
Ar:cthe:- P."'errber of tre Santa r-"1omca CIty Counell suggested that the voters of Santa MOnIca
should be gIven the rIght to vote on whether we wanted art on the beach. On thIS Issue,
t~]s LCP represents another exarr.ple of a pattern of behaVIor by City employees to exclude
the p:;bl1c frow comment on Issues upon WhIch we have a legal. Coastal Act-mancated nght
to com [;lent and 15 deSIgned to clsenfranchlse the voters of the CIty of Santa ).iomca.
Smcerely,
-~~a7~1,~pC~2~a.~
Sharon JaqUlth
1
2
3
. .
July 12, 1990
"J1TY C:: . .
city of Santa Monica
City Plann~ng Div~sion/PPD
1685 Maln street, Room 212
Santa Monica, CA 90401
___ L
Re: Draft Local Coastal proqram
Ladies and Gentlemen:
The unders~gned ~s writing you with the following comments on
the above-referenced program (the It LCP" ) . I request that C~ ty
staff respond ~n detail to each of the comments raised below prior
to proceeding further with the revision or adoption of the LCP.
l. LCP Policy 2, while correctly stating that, in the event
of a confl~ct between city or coastal Act policles, the policy that
~s more protective of coastal resources shall govern, ~t falls to
acknowledge and pr1.ori t1.ze protect1.on of reS1.dent1.al ne1.ghborhoods,
a goal that is also paramount under well-established C1.ty polic1.es
such as the Land Use and Clrculatlon Element (wh1.ch contains
numerous references to the need to protect the quality of l1.fe l.n
the C1.ty's reS1.dentlal neighborhoods). This policy must be revised
to include as a paramount objectlve the protection of resldential
nelghborhoods from cut-through or overflow beach-destined traff~c.
2. LCP POllCY 3 -contalns the same error. It states that In
the event of confllcts between the LCP and those set forth in the
General Plan or regulations, the LCP shall take precedence. I
belleve that further degradation of the quality of life ln Santa
Monlca I s residential neighborhoods as a result of the rampant
commercial development and beach pressures over the past f~ve years
1S an lnexcusable vlolation of the city's own pollcies, and that
the LCP's apparent favorltlsrn of increased commerclal development
~n the Santa Monica Coastal Zone (the "Zone") represents yet
another attack on reS1.dentlal nelghborhoods that cannot be
sanctioned.
3. LCP POlicy 4 contal.ns yet the same error. It would
encourage postlng of freeway directional signs to encourage
beachgoers to use other resldential neighborhoods to get to and
from the beach areas. I believe that this pol1.cy has already been
lmplemented with diasastrous results; for example, there eXlsts
freeway signage along Ocean Park Boulevard that dlrects beach
trafflc to use streets 1.n Sunset Park two miles away; as a result,
Cloverf~eld Boulevard and 23rd street, two Rl resldential streets,
suffer nearly 25,000 dally auto trlpS, wlth significant
deterioration in the quality of life and property values on those
streets. I also note that such polley is lnconsistent wlth the
nelghborhood protectlon plans that will be adopted for thlS and
other Clty nelghborhoods. For example, a key recommendatlon ~n the
P1CO Nelghborhood Protection Plan is the elimination of such
4
5
signage (the P~co Neighborhood suffers from some of the sp~llover
trafflc from sunset Park). This polley 15 also internally
lnconsistent, as It encourages greater traff~c volumes ln
re~ldential nelghborhoods, which, in turn, reduces public safety
and the quallty of llfe ln those areas.
4. LCP Polley 7(b) and (c) focus on the wrong elements of a
redevelopment; rather than focus on the resldentlal use of that
property, 1 t looks to the effort placed in a remodeling. Put
slrnply, whether a single-fam~ly home is torn down and replaced wlth
a reore intenslve land use 1S the key question, not whether the
remodel is expenSlve. This POllCY has the adverse effect of
penalizing remodels that would potentially constitute a vlsual and
aesthetlc improvement.
5. The public access pcllcies LCP are flawed in that they
refuse to deal with the fundaI'\ental problem that the eXlst~ng
infrastructure must be lrnproved before any further development ln
the Zone can be approved. The LCP fails to acknowledge the stark
real1ty that further commercial development will hinder, not
lmprove such public access. At page II-I, the LCP errs in stat1ng
that "visitors from the entire Los Angeles area have easy access to
Santa Mon1.ca beaches. II Wh1le that may seem to be true from looking
at a map, lt 19nores the harsh reality that Pacific Coast Highway
("PCR") is already lnoperable dur~ng peak hours dur~ng the week and
durlng weekends, particularly durlng the summer. The LCP never
states that various env~ronrnental lmpact reports assess~ng proJects
in the Zone l.ndicate that rn.:.~erCJS intersections thereln are
destlned to fail from" a trafflc flow viewpoint (i.e., operate at
level of serv1ce "Ell or "F"). Many people today cannot (or w1.11
not) util1ze this prec10us resource due to horrid traffiC
condi tions. :t is not at all uncommon for an unfortunate soul
heading southbound on peR on a summer afternoon to take more than
two hours to travel from Malibu to the 405 freeway. Equally
~mportant, the LCP acknowledges that state and other agency
involvement 1.S necessary 1n order to perml t further commerc1al
development, yet does not lndlcate how the City wll1 go about
obta1ning such cooperation or 'Whether such further commerclal
development is consistent with the policles and regulat10ns of such
other agencles.
The LCP also appears to favor increased commercial development
ln the Zone, without acknowledging or dealing wlth the
lnfrastructural deficit we face today (which doesn't even reflect
recently-approved hotel and other Zone commerc1al projects comlng
on-line), and despite paying 11p service to the notlon of public
access. I believe that the cr1.tical questions of 1nfrastructural
capaclty and the coord1nated act10n w1th other governmental
agencies must be dealt with before approvlng any further cornmerc1al
development. I also note that the so-called "v1sitor-servlng
pollciesll are in conflict w1th env1ronmental quallty and scen~c and
visual resources pol1cies, as further commercial development will
undoubtedly wreak substantial, unm1tigable environmenta damage and
also block scenic views (see, e.g., LCP Policy 59, wh~ch states
that public V~ews of the coastl~ne shall be protected. How can
they protected if dense commercial structures are allowed (see,
e.g., LCP Policy 78, author1.zing lIh~gh-denslty res1.dent~al
structures with a...he~ght of four storles (451)7")). Lastly, the
l.nfrastructural quest1.on is s1.IDply not a trafflC issue. It goes
beyond that to lnclude questions regardlng selsmlC stability of
future development, the 1IDpact on the already-seriously endangered
Santa Monlca Bay, and how future development 1S possible in llght
of the serlOUS sewage treatment and freshwater shortages we face
today. The LCP fails to adequately deal with any of these lssues.
For example, the LCP, at page 111-22, states that "the c~ty can
protect the marine habitat only by prohibiting development that
would add pollution or interfere with ex~st~ng blological
cor.ununi tles. . . II The Hyperlon sewage treatment plant is already
operating over capacity; this, coupled wJ.th abuse of the storm
drain system, results in raw sewage being dumped into Santa Monica
Bay. How VillI new development do anything but exacerbate thls
problem? LCP Policy 55 does not help any; all it says is that
n(t]he City shall consult wlth relevant Federal and State
agenc1es. . . and shall lncorporate their recommendations. II ThlS
pol icy 15 5lmply lnadequate; development should be absolutely
prohiblted when there is adverse environmental lropacts on mar~ne
llfe, etc. (most of which ~s, by def~nltlon, unmitigable).
The LCP acknowledges that there eXlsts signlf~cant potential
for selsmlC (bluff) lnstabllity (page III-24). Yet the LCP
contaJns no lnformat1on relatlng to studles done or other work that
would lnform the publlC as to how the LCP proposes to deal wi~h
thls serlOUS lssue. Moreover, whlle LCP Pollcy 52 requlres that
new development asst::-e stabll1 ty and structural lntegrl ty, the
Clty's past performance in thlS regard lS suspect. For exa~ple,
the EIR in respect of the beach hotel proposed for 415 Pac1flc
Coast Highway totally ignores the risk that construction of the
underground garage will, by blocklng underground streams,
contribute slgnificantly to bluff instabillty.
The LCP reflects prioritles that are at serious varlance with
those of the c1tizen5 of Santa Monica. It glves greater prlorlty
to commercial development (a.k.a. IIVlsltor-serving facilltlesn)
than would be apparent from the tens of thousands of s~gnatures
that placed the Save Our Beach and SMILE inltlatives on the
November ballot. The adoption of the LCP should be stayed pendlng
the outcome of these ballot initiatlves, and the LCP must be
revlsed thereafter to reflect thlS expresslon of Cltizen
priorities. In llght of the foregoing, all policies that encourage
or contemplate cornmerclal developnent, e.g., LCP Polley 38 and 44-
46, should be eliminated pendlng further determination of what
level of co~~ercial development is possible or desirable.
Very Truly Yours,
~~cb~_
Eric Chen
.
July 6, 1990
Clty Plannlng Dlvls;on/PPD
1685 Maln Street
Room 212
Santa Monlca, CA 90401
Re: Draft Document - New Llne City of Santa Monlca, New Line Local Coastal
Orogram, New Llne Land Use/lmplementatlon
Dear Slrs:
Pursuant to your Notlce of Avaliabllity. I submit the followlng comments
wlth respect to the referenced LC? These comments are addressed to that
port10n of LC? WhlCh lS between the Paciflc Coast Highway on the east and
the mean high tlde llne on the west, commenclng northerly at the Santa
Monlca Clty llne and endlng southerly at a prolongatlon of the center llne
of Colorado Boulevard as it would intersect with the public beach and the
~ear. h1Sh tlde llne.
Commenclng at sald llne and travellng northward. there lS indicated:
"resldentlai-vlsltor commercnl; thence hlgh density multiple fam1iy
resldentlal. thence neighborhood comrnerclal; thence single famlly
resldence; thence hlgh density multiple famlly residential; thence single
famlly resldentlal; thence hlgh density multiple famlly resldentlal."
1
Westerly of the lndicatlon of "the Promenade" is lnd1cated slngle family
resldentlal. I assume that the land use policy map does not propose to
allow slngle family residential westerly of lithe Promenade."
The property deslgnated as neighborhood commercial north of the first block
of hlgh denslty multiple family resldential is presently ut1l1zed for
parklng and for concession stand buslnesses. If the proposal 1S to allow
ne1ghborhood commercial, there should be a buffer zone between the
commerCial and the s1ngle family residence locatlons on the north end of
the proposed cowmerclal development.
2
I further call to your attentlon the disparity between the high denslty
resldential deslgnat;on and the slngle faml1y resldentlal deslgnation. The
resldentlal des1gnatlon provldes for two-storles and 28 feet maximum whlle
RJ\LEIGH ENTERPRISES
:1444 W OLYMPIC BOL.:lEVARD LOS Al>:GElES C^1.IFOR.."J1A 90064 (2U13U-3600 TELEX 69mB N\lEIGH" c;AX l21J1479-3C86
,
Page 2
the ~lgh denslty resldentlal prov1des for four storles and 45 foot height
il..,lt. Proper planmng calls for a d1fferentlal between hlgh denslty and
51ngle faml1y resldence. If the plan lS adopted 1n lts present form, the
slngle famlly reS1dences at thlS tlme, lr. many 1n5tances, exceed 28 feet 1n
helght and two stones. In the event of substant1al destructlon or
rebulidlng of t"e slngle famlly resldence property, the present property
owners would be severely lmpeded from recreatlng ecual utllizatlon.
3
The lots along Pacific Coast H1ghway are, for the most part, fa1rly narrow
Wl dth, reGU1 r1 ng garages to be under the eX1 5t; ng fad 11 ti es. In mary
lnstances, thlS reaUlres at least a three-story helght l;~lt. Inasmuch as
four stor1es are provlded and 45 feet on contlguous property, I bel1eve the
slngle fa~lly res1dences should be allowed at least a three story
ccnstruct10n he1ght and 35 feet to roof peak. There should be add1t1onal
prov1s1on for arch1tectural protrus1ons above the 35 foot helght lim1t.
I urge you to reVlew the eXlstlng conditions and prov1de ln your land use
Jlan for a mlnl~um development rlgnt equal to that Wh1Ch presently exists
for the single faml1y residences 1n many instances along this strip.
c-~~ ,.2~
Georse I. Rcserthal ~
30arc ~e~ber of the
?al1sades Beach Property Owners ASsoc1atlon
5dg Pac1flc Coast Highway
92~ Pac1f;c Coast Hl~hway
1011 Paclf1c Coast Highway
:';IK.: 1 c
cc: John ~allll, C1ty Manager
Lynne Barrette, Asslstant City Manager
~ayor DenniS Zane
~ayor Pro Tern David Finkel
Councllperson Judy Abdo
Councilperson Ken Genser
Councl1person Bill Jenn1ngs
Council person Herbert Katz
Councllperson Christine Reed
Deborah A. Rosenthal, Secretary
Palisades Beach Property Owners Assocatlon
;'~ark Rosenthal
R.".LEIGH ENTERPRlSES
Z14-a-l w OLYVP'C BOLiLEV\RD LOS A"JGElES C'\.UFOR.\:[A 9C064 \.n31.::2-J600 TELEX 601'718 RALEIGH F....X 1~'JI.l~o__~
.
.
3112 4th Street
Sonto Mom (0
CElllformo
,..July J P, ,1990
Clty Planmng D1vlslon/PPD
1665 MEll!) ~,treet, RCIIJrr1212
Scllte Morur~ ~8 -9Q40 1,,~ \',>"' .
v; I '~ ::-';. _. T .
:~I'r. :: _ I
Pe DrBft LoeB] (oestBi Plan
'90 J~L 1 6 A 7 ! 2
Chupter- III - COA~,T AL ZDNE CONDIT IONS AN[l ISSUES ot the Se"'~ '?
Momcd local COd'3tEll Progrdrn E,tates In lis opemng pan:grdph thM It
"contains e dlscusslOn of the condltWtrS and lssues related to the Coos tal
Zot1e" Further, Chepter III deals wlth "tO~IlC3" 'NhlCh EIre Urnost lmportelnt
to the cont Hilled preservEI t lOn find enhenc€'ment 0 f tl1e CIty's COElst61 Zone"
T~ie pn merry MtOple" preE.ented 1 S
1 "1 Access to the Coested Zone) especlolly to the beech end
c1rculE1tlOn wlthm the arefi U
","/hdt then fono'I',"S 12, hO'rtever-, not EJ DISCUSSIOn of access
condl t 1 orl~. f E1C1 ng tl80ch users, but reU1eT B romp11 E1t Ion of routes and
I-node.:. I,^ifrlch aTe evelietde Far more ottentJOn 1$ glYen to perking thon to
U-,e cC'rldl t 1 en of t-OadWO!-lS ~q-OVl dl rl" access
~ tl
Since acee:::.::, to the beach 1$ onE' of the most important roncerns of
nit C oastell Corrlrm ~,Sl on Elnd thE-fef ore shoul d be onE' of Ult' porElrnount
'd1Scusslons of condltlOn;:," 10 iJny LocEll Coastol Plelfl} 1t E1ppears that HIl~
draft 1::' .;,enous1~ deflClent In !gtlDrll1g the stote of trafflc ond CltTuJatlOt:
1n and tieer Ute Local (oo.:.tal Zone
Recent EnVironmental Impoct Reports find the City-'w'lde. Traff1c
~,tLldy flC!'ie provlded ~.ourTe rMtenol for compilatIon of intersectlons and
screenllnes In and around the Locol (Dostal Zone 'NhiCh e~(penence gndlocf~
conditIons or untlcceptElble congestlOn (LO~, F or- E) Tlll?se 10rotlOfls ore
1dentlfled 111 the aCcompanYlng Table and ore marked on the ottflched mop
Thls lnTOrmetlOn should be Included Hi the Locol COElstoJ Plon tiS 0
beseJ1ne for deterrmmnQ permitte-d further development Furthermore, e
progrorn for lrnplenrentotlOn of Pt-oposed rTIit1gotlOn meflSLlres to eose
trl8se elr-e"Eldf..l eYlstmQ conqest1on pomts should tit? Included m the- Plem
~ - ~
.
GRIDLOCKED (LOS F) AND UNACCEPT ABL Y CONGESTED (LOS E)
INTERSECTIONS '\"IITHIN AND IN THE IMMEDIATE VIC1NITV OF THE
SANTA MONICA LOCAL COASTAL ZONE
,
PCH & Entrflde
PCH & ChautEluqua
PCH & Carl forma Incllne
Ocean & Cell form 0
OCE-on & Co 1 orodo
L1ncoln e... .......'l13hl re
Llncoln & AnzonEl
Lincoln & Santo MOnlcEI
11 ncoln & BroodwElI..l
..
llllco 1 n & Co 1 orodo
Oceon & PCH (Rend)
Oceon (Nell son) &. Pl co
NeIlson & Blcknell
Nell son & OCE'on Park
MElln & Plea
Llncoln & OlympIc
(W6 1-10 off-romp)
LIncoln &. Frontoge Rd
(EB ]-10 on-romp)
LIncoln &. PICO
2nd & Anzono
2nd &. Sonto Momce!
2nd & Co] ore! do
4th & WIlst11re
4th e... Coloredo
l1ncoln &, PeEIt-l
l1ncoln &. Oeeen Pork
L 1Oeo] n & Man ne/Nevy
l1ncoln & Rose
4th & Olymplc (\0-/6 1-10 off-romp)
4th & Frontoge Rd (Guest DUEJrters)
4th eX. PI co
4th & Oeeen Pfwk
7th &. Sem 'v'l cente
CITY-If/IDE TRAFFIC STUDY SCREENUNES IN OR NEAR THE SANTA MONICA
LOCAL C(1A~,TAL ZONE 'w'HICH ARE OPERATING AT LOS E OR F
3C - Eost of LIncoln 51'./d, Colorodo to PICO
4A - ~touth of Montone, PoclflC Coost HlghwfI~
SA - South of BroodwElY, PoclflC Coost HlghwClY
7A - South Cltl..l L1Il11ts, Nellson '.,y04 to Lmcoln Blvd
- -
These thIrty-two lntersectlOns and four sCI-eenllnes, representIng
locatIons of very tllgh congestIOn and/or gndlock blocking access to trle
c.oast, iJre shown on tile C1ttElched mop
2
.
2
3
4
In the sectIon on Hotels end Motels (p 111-17), the Plen stotes thElt
-the C1ty wIll stnve to meilntflln Elffordoble vls1tor ser.....lng foc111t18S In
the (oElstEll Zone" ond thot .Contmued hotel development 1S olso plonned
fo:- the Downtown aree of Ule COErstEll Zone" Affordoble lod~lng 1S em
e::~entlElI element OT -access" to the COElst, yet no cntenon for the
per-cenlege of hotel rooms Wf-'lCf1 should meet tin "EllfordClble" stendard hos
been defIned Sente MOniCO has en RVC zone where hotels ore perm1tted -
1ndeed preferred - uses ''/'/e ellso heve ti requ1rement thet El study of hotel
f(lomS be done whenever the lncreose 1n rooms exceeds 750 over the
eX1 st mg nurnber \'Yhen the Lond Use Plon wers odopted (1984) Such e
"stud~" has been done, but - contrery to any reElsonoble person's
expectEltlOns - 1t d1d not lnclude ony recommelJdotlOns regelfdmg future
hotel fecIlltl83 exponslOn, nor dId 1t set ony cnteno for the percentoge of
ne'N hotel rooms \'\'hlCh st10uld be offordElble There lS ObVlOusly not on
lnexheustlble supply of lend for development of lodgIngs 111 the COflstal
Zone A C06stol Plan should set some gU1delme3 for the types of lodgmg to
be developed end also - even more ObvlOusly - the totel number of nt?w
rooms Wi11ch need to be tru1H Sante Hamre has done thiS kmd of
qUEJt1t1tet1ve plesnmng before -- In Dort1culor wrl8n the Councll set the
total number of nel,"{ theotet- 3eClts Wh1Ch would be perrmtted 1n trle C1t~
Slr-ollet- cnteno should be di?flned fot" use of Ell! SCElfce resources 1n the
Clt~ -- In thiS case, lor- COastollond
In Ch\JDtef I'.,.' - POLICIES (p IV-1), It IS stated that QNoth1ng In tillS
plen removes or reduces reqUIrements contolned 111 the CIty Chorter,
C~enerEll Plon, Ot- Zom ng Ordinance - The st8tement then cant lnues
"Hovtevet", should confl1cts EJr15e between the LUP ilnd other C1ty p18nnmg
documents, the pOlICIes of the LUP shEill teke precedence 'N1thm the
Coastel Zone" ~.ectlOn 431 of the ClrculotlOn Elernent of the Generol Plem
12 \J rF'~''':~~2rnent of the GenerE:ll Plon 'Ntll(h 13 Ignored In the AutomobIle
Access DonlOn of "ACCESS POLICIES" (1',/-7) It) the LUP Does thlS mean
thiJt oil P011CE:S In the LUCE 'Nh1Ch ore 19nored In the LUP Y'nll be 19nored
becoLlse "bemQ I qnored" take:; precedence 'NI 0-11 n the Cooste! 1 Zone end
- - '
thus that 43 1 mey be Ignored In the [oo.::tal Zone';'? Or does 1 t meon thot
011 Genen~l Plfln pollc1es whIch ore not dIrectly contradIcted m the LUP
'N111 prevElllln the Coostol Zone?
\tilth t-espect to P01F:'Y ~ 17 (p 1"1-7), PolICY ~274 of the odopted
Mol1bui SontEl MOnlcl:! MountEllns LUP stEltes the.t development lt1 Mfillbu lS
restncted pendlng completIOn ot EI County-tunded study of PCH Th1S Cl:!p
\"1I11 be In effect unt1l the cElpec1lq of PCH IS Inct-eosed one poss1ble
- '
3
method of lncreoslng COPOClty IS dellned os -constr-uctlOn of on oddltlonol
lone betV\'een Mt'llIDU C1VlC Center ond thE' McClure tunnel to be 8Vol18ble
,
ot leost dunng the peok trovel penod In eoch dIrectIon- ThIS study 13
moving llheod The County IS iJbout to select 0 consultont from omong
three fInalIsts, Ult? funds ore oyollable, end the study WIll reQU1re 4-6
months to completIOn It IS recommended thot Sonto MoOlco estobl1Sh 0
slrllllor development cop on proJects whIch WIll contnbute more thon ]0%
of theIr qener-eted tnps to PCH trElfflc, untIl 0 meemnqful pIon for
, ~
It'rCreoslng PCH CaPOClty IS In pIece
,
5
There EIre two mElJor studIes currently underwfly WhICh vnll be
heevlly Impacted by decI SIons rnode now regerdmg the Coost61 Zone These
ore the reVISIon of the MaIn 5treet PIon ond the eM Zomng cnteno, ond
the preporotJOn of the CJl/le Center SpeCIfIc P1Elfl_ At vonous pleces In thIS
Dr-oft lCP, reference IS mode to polIcIes whIch ore not conslstent wIth
Issues currently belng deboted In both these efforts For eXElmple, Pollc~
#4.4 addresses lond use 010n9 Ocean Ave between Coloredo end PleD, Wh1CFI
IS wIthIn the CIVIC Center PloD oreo, whIle PoliCY #63 C6nS for setbacks
In {he some ereo 5w111orly, Po11cles #94-98 need to be rE"vlewed for
conslstenc~ \'I.'1th the CIVIC Center SpeCIfIc PlEIn, Includln~
~ ~
recomrnendetlons for lend use ond development stElndelrds for edJiJcent
ar80S os 'Nell The t1el1n Street Pollc1e~,} 6103-105, need reV1S1on for
conSIstency wlth H-IE' proposed Plon reVISIOn
Amendments to the zomng ordlllonce c.olled for on p IP-3 (61 & 62)
ore 1n confllct \"/1th some of the Issues currently belng dIscussed w1thln
the (P/IC Center Spec1T1c Plen Ad'.llsory CommIttee ond the Moln Street
Pl an RE''y'13I on Comm1 t tee
5ectwn 91543 (p lP-22) is pUZZlIng If the CI\JIC Centet.SpeclflC
6 Plon Elnd the MElIn Street Plen must comply \"l1th the LUP, the gUIdelInes of
these plons should be Incarparoted mto the LUP, InsteEld of the other Wfl~
around
Re the Shuttle Tronsit Program (p lP-27), It ~hould not be suggested
that s.corce [WIC Center pork1ng shOUld be mode ~VEllloble to shuttle user3
7 untIl the CWIC Center 5peclflc Pion 18 completed so thot the porkmg
CelPOClty /jnd demond fIgures for CIVIC Center users cen be cernsldere,j
~11ncerE' 14
~/~
I
Lourel Roennflu
4
AlTKH.MfNI ~
~ESPONSE TO COMMENTS ON THE DRAFT LCP
SEPTEMBER 26, 1990
Response to Sharon Jaquith
1. The May 1990 Draft LCP IS an update of the previous 1986 version of the LCP
and does not represent a completely new attempt to produce a LCP for the
City. Therefore~ the public input which shaped the previous versions of the
LCP 'IS stilllarge\y reflected in t'ne current version. T'ne development po\icies
In the LCP have been updated to reflect the reductions in the permitted
intensity of development which have occurred since 1986. Other changes have
also been made to reflect current conditIOns in the coastal zone and to describe
eXisting City policies and programs.
The public review process for the updated LCP is just beginning. The Draft
LCP is in no way fixed in content at this point and several more opportunities
for pubHc input are forthcoming. including public hearings by the Planning
Commission and City Council.
2. As the commentor has Indicated, the City is In the process of developing a
program for installing sculptures on the beach. ThiS program has not yet
been approved. To accommodate the possibility that art will be approved for
the beach area, new policies regarding the proposed art program have been
Incorporated into the LCP. If the program is not approved, the policies
should probably be .removed from the LCP.
The Natural Element Sculpture I NES) park is a separate program~ the
specifics of which are not appropriate for inclusion in the LCP. Its
development and eventual approval or denial IS independent of the LCP. It is
only necessary the LCP provide a policy basis to accommodate the NES Park
If It is approved or, alternately, to limit art on the beach if it is denied.
However, the NES program will have to be consistent with all LCP policies.
Response to Laurel Roennau
1. Traffic congestion in many portions of the coastal zone is quite heavy during
summer peak periods and this general condition should be reflected in the
Coastal Land Use Plan. However, the LCP is intended to be a long-range
policy document, not a technical analysis, and therefore detailed descriptions
of existing traffic conditions are not appropriate. An analysis of current
traffic conditions would quickly become outdated and would compromise the
long-range nature of the lCP. I n-depth discussions of circulation needs and
traffic problems are best reserved for documents like the City's Circulation
Element, City-Wide Traffic Study, and individual environmental impact
reports. The LCP does describe the routes and modes available in the Coastal
zone. This is the concept of lIaccess" to coastal resources discussed in the
-1-
l;:llifornia Coastal Act. Access refers to the public's ability to physically
reach and utilize the coast. not the existing conditions or congestion that
ex ist on those access routes.
2. Hotels are a conditionally permitted use in the RVe zone. As such, indivIdual
projects are reviewed and an assessment is made to determine If an over-
concentration exists. Recognizing the need to preserve low-cost lodging In
the Coastal zone, the City has adopted a mitigation fee for the removal of
existing low-costs rooms. Money collected will be devoted to the development
of new low-cost lodging facilities. This mitigation fee recognizes that while
the LCP encourages the prOVision and protection of low-cost lodging facilities,
market conditions may not help to maintain or add to the eXisting stock.
Furthermore, the Coastal Act specifies that no regulatory body shallllrequire
that overnight room rentals be fixed at an amount certam for any privately
owned and operated hotel. . .11 Thus, it is inappropriate for the LCP to require
a certain percentage of lodging to be affordable. However, it can encourage
its provision and mitigate the loss of the current stock by imposing the
mitigation fee.
3. The LCP was purposely written not to be unnecessarily repetitive of
prevailing City policies which are currently in effect for the entire City as
well as the coastal zone. To do so would repeat, or at least reference. of much
of the City's municipal code, General Plan, and other policy documents. Only
policies primary to coastal issues are described in the LCP. General Plan
poliCies which are not contradicted in the LCP will still have effect in the
coastal zone.
4. The commentor's recommendation for the establishment of development
restrictions in the City until the capacity of Pacific Coast Highway can be
improved is noted. It should be pointed out that a moratorium on commercial
development is currently in effect in the City, and a yearly commercial square
footage allotment allocation IS under consideration. In addition, the amount
of future non-residential development along PCH north of the Santa Monica
Pier is minimal due to existing conditions and zoning.
5. The policies dted which pertain to the Civic Center area and Main Street
reflect existing land use and development intensities. The LCP will ultimately
be consistent with the Civic Center Specific Plan and the Main Street Plan.
If the LCP is adopted prior to the completion of these two plans, the LCP may
require revisions. If the policy changes necessitated by these two plans are
significant, they may need to be approved by the Coastal Commission. At this
time, it is not known what future policies will be approved for Main Street and
the Civic Center by the City Council and the Coastal Commission.
6. The guidelines of these plans need not be incorporated into the LUP. What is
necessary is consistency between the plans and the LUP. This can be
achieved by making the plans conform to the policies of the LUP or by
amending the LUP to accommodate the objectives of the plans. Any proposed
amendments to the LUP must be consistent with the goals of the Coastal Act.
7. A shuttle transit system serving the coastal lone has been advocated by the
Coastal Commission, been studied by the City for years, and is required as
-2.
a condition of approval for four coastal hotel developments. Some type of
shuttle system will be initiated. The policy states that the Civic Center may
be utilized. in addition to other public parking facilities. During analysis of
such a shuttle proposal. the feasibility of using the Civic Center parking lot
will be considered.
Response to GeorHe Rosenthal
A "Public lands" designation overlays the R 1 zoning designation west of the
Promenade. This property has never been developable. However, due to the
definition and concept of an overlay zone such as the PL district, there must
be an underlying zoning designation. In thiS case R 1 is the underlying zoning
required for the PL overlay district to exist.
2. The neIghborhood commercial designation in this area was originally applied
to reflect the existing commercial land use pattern, which would thereby avoid
making the existing commercial uses nonconforming. This commercial
designation will be rezoned to RVC I Residential Visitor Commercial}. This is
a "bufferll zone of sorts, In that it allows residential uses as well as
appropriate coastal-related commercial uses.
3. The parcels north of Santa Monica Pier along PCH currently zoned R4 wilt be
rezoned to an R3 designation. This will ensure a more appropriate scale of
development. Height limits will be 3510" for a flat roof and 4-0' 0" for a pitched
roof to correspond with pending R3 development standards.
Response to the Southern California Rapid Transit District (RTD)
1. The RTD's suggestions for implementing the proposed shuttle transit program
are noted. The City concurs and is aware of the procedures noted and will
continue to work closely with and cooperate with other transit providers.
2 The RTD's other suggestions are given consideration when Individual
development plans are reviewed and when public improvements are planned.
Response to Eric Chen
, . Protection of residential neighborhoods within the Coastal zone is an important
issue. However. the LCP has other objectives to consider. Summarized, the
goals of the State Coastal Act are to maintain the environmental quality of the
coast, conserve coastal resources, maximize public coastal access, maximize
recreational and visitor-serving opportunities, and assure priority for
coastal-related development. The City has estabhshed policies for
neighborhood protection in the General Plan and other tocal policy documents.
The LCP in no way usurps or interferes with these established policies.
-3-
Several of the new development policies in the LCP are intended to complement
and support neighborhood preservation objectives.
2. The development policies of the LCP are Intended to be consistent with the
CltylS existing development policies contained in the General Plan. zoning
ordinance and other planning documents. The lCP policies favor commercial
development no more than other city policies; however. the goals of the
Coastal Act do give priority to visitor-serving commerCial uses In the coastal
zone when Commercial development is to be permitted. The LCP does contain
policies to preserve and protect residential uses in the Coastal zone.
3. lCP Policy 4 does not call for signs that would encourage traffic to cut
speCifically through residential neighborhoods to access the beach. It merely
calls for directIOnal signs that indicate appropriate access routes to the beach.
not speCifYing whether these routes are to go through residential
neighborhoods or not. If beachgoers are in fact using residential streets to
access the beach In a way that degrades the flow of traffic or the quality of
life along these streets. this should be the subject of a neighborhood traffic
improvement plan. Disruption to residential neighborhoods should be
mln iml zed.
4-. lCP Policies 7b and 7c in no way call for the penalization of homeowners within
the Coastal Zone who remodel their residences. These policies are there
simply to establish criteria for what is to be considered new development. and
what IS not. In so doing. they utilize the principle found in most municipal
zoning ordinances. wherein nonconforming uses that are altered 50% or less
can still function legally as nonconforming uses. or. in this case. can be
considered a remodel rather than new development. New development must
fully conform to all applicable building and zoning regulations.
5. The commentor is correct in stating that traffic congestion may hinder beach
access for those who drive cars to the beach. The specifics of current traffic
conditions at various intersections in the coastal zone are not described in the
LCP because this information becomes easily outdated. The LCP is intended
to be a long-range policy document and therefore does not dwell on the details
of current conditions.
Once again. the LCP policies favor commercial development no more than other
City policies. However, it is true that visitor-serving commercial uses are
given priority in order to fulfill the goals of the Coastal Act. The City is
aware of the impacts caused by additional commercial development. as such.
the City is currently developing a Growth Management Strategy to address the
issues related to future commercial development.
Traffic. seismicity. marine habitat. and infrastructure problems. as well as
their solutions, are very important considerations. However. the LCP is a
polley document. not a focused environmental assessment. Ca1ifornia state law
does not require a separate environmental analysis in conjunction with an
LCP. However. background information for the LCP is based largely from the
land Use and Circulation Elements. zoning ordinance. and EI Rs for
development projects in the Coastal Zone. These documents were all
accompanied with focused Environmental Impact Reports.
-lJ-
Response to Sharon Gilpin
1. The County of LA is conductIng a traffic study to investigate the possibility
of increasing capacity on PCH. Thus. It may be possible to increase the
capacity. though with great difficulty. Note that increasing capacity does not
mean physically widening PCH (as the bluffs and ocean create physical
constraints), but programmatic changes (such as incorporating a reversible
lane of traffic to accommodate peak hours) .
2. The discussion relating to Pacific Coast Highway in the LCP is deSCriptive and
is not a policy. I n response to the Planning Commission and Coastal
CommiSSIon's Comments, the June 1986lCP draft was changed In regard to the
PCH discussion. The current draft essentially maintains the information
contained In the June 1986 draft.
3. The final LCP document wiU contam photos of the existing coastal lone.
4, LCP HEAR1NG DATES
October 21. 1985
Planning commission approved LCP
w / modifications
City Council adopted LCP wI modifications
May 6, 1986
July 9. 1987
Coastal Commission certifted LCP
w / modifications
September 14, 1987
Planning Commission recommends adoption
November 10. 1987
City Council took no action on LCP
5. At the City Council meeting of November 1987. Council directed staff to modify
the LCP to be consistent with the new Zoning Ordinance. As the ordinance
was adopted in 1988, preparation of a revised LCP began shortly after.
No public hearings. meetings. or planning sessions have yet been held on the
1990 version of the LCP. No new planning process was utilized to develop this
new version of the LCP. The draft was produced by staff by simp\y updating
the previous version of the LCP. This new version contains updated
information on conditions in the coastal lone, reflects current City
development policiesl and contains a description of the mechanisms and
programs required to implement the LUP. The policies on new development
have been updated to match current City policy described in the City.s
General Plan, zoning ordinance, and other planOlng documents. Some new
policies have been added to reflect new City programs and policies which have
evolved since 1987. ln general, no new ground is broken with the policies
contained in the current draft version of the LCP. It is simply a carrying
forward and updating of previous policies and a reflection of existing City
policies and programs.
-5-
.
The public review process is just beginning and more opportunitIes for public
input are forthcoming. including public heanngs by the Planning CommissIon
and City Council. Public comments are welcome at any time before the City
Council makes its final decIsion.
6. The comment period was seven and one-half weeks, which exceeds the Coastal
Commission's required review period. Public comments are accepted all the
way up to the fmal public hearing.
7. Public hearings for development projects like the Pier will be held only after
indIvidual environmental assessments are completed. Hearings for larger
planning projects such as the Civic Center Specific Plan and Main Street
Ordinance reVISions WIll have similar public hearings. and are considered
separately from the LCP. I n addition, the City has been awarded grant
monies from the State that must be utilized within a specific time period.
thereby adding further urgency to concluding the process.
8. Any new lIdevelopment" will occur as urban infill or recycling. This does not
preclude the commitment of new open space lands.
9. It is true that traffic conditions in many areas of the coastal zone are very
poor. It is agreed that traffic congestion affects coastal accessibIlIty and will
be reflected in the descrtption of existing conditions.
Note that as a public policy document. the lCP will remain the policy for
coastal development for years. A discussion of specific traffic conditions that
exist today is not appropriate for a policy document.
The general language about traffic conditions in the Coastal Zone will be
excerpted from the City-Wide Traffic and Mitigation Study and incorporated
into the background section.
10. The beach area has been divided up into three areas because of their distinct
and separate characteristics. As a result, dividing the area into smaller zones
is appropriate to understanding and addressing the unique specifics of the
beach zone.
11. Please see response to comment #'1.
12. The Jonathan Club1s lease has not been specifically addressed in the current
draft as the level of site specific detail appeared inappropriate in the LCP.
which is a policy document. The current description updates the 1985 Draft
LCP wording by deleting details not pertinent to the discussion.
13. Agreed. The revised LCP will delete mention of an aquarium as the intended
use. The Cityls intent for the Deauville site is to have a coastal-related use
that preferably attracts patrons during both the summer and non-summer
seasons.
The proposed aquarium is an example of a visitor-serving, off-season tourism
use that is appropriate for the coastal zone. As noted by the commentor I no
-6-
approvals have been issued for an aquarium and the site may not end up being
used for this purpose.
14. Though the hotel project has been approved, ultimate use of the site will be
decided by voters in the upcoming November election. The September 1990
Draft LCP has been amended accordingly to discuss the current use of the site
and Intended use in the future.
15. ThIs IS only a deSCription of the subarea, not a po\icy statement.
16. Environmental assessment for development projects in the Coastal Zone and
the City do evaluate a project's impacts upon aesthetics, shade, and shadow.
and views. Then studies then propose any necessary mitigation to reduce any
Impacts to a level of insignificance. It should be noted that it is not luxury
hotels per se which cause views to be blocked, but rather it is large buildings
in genera\, especIally those which are not sensitively designed so as to
minimize impacts on view corridors.
17. Agreed. The LCP encourages retention of open space and preservation of
ex isti ng recreational uses, view corridors, and parking.
18. Agreed. The CivIc Center Specific Plan process includes an advisory
commIttee and requisite environmental review to ensure that density. open
space, air quality, and development standards will not be detrimental to the
area.
19. Should any of the proposed initiat'lves pass, appropriate amendments to the
General Plan, Zonin-g Ordinance, and LCP will be made.
20. Comment noted. The LCP contains policies and a low-cost lodging replacement
program to help make coastal lodging available to all income groups.
21, Please see response to comment #16. Preservation of visual resources is
consistent with the goals of the Coastal Act.
22. I n an agreement with the Loews' hotel developer, the City removed metered
parking along Ocean Avenue In front of the hotels in exchange for fees that
would help fund new meters and maintenance of existing meters. Thus, while
some spaces were removed from Ocean Avenue others have been installed
elsewhere in the Coastal zone.
Any hotel removing signage required to note public parking is in violation of
the Development Agreement or development approval that required It. and is
subject to enforcement action. Such action can be initiated by a complaint.
The Parking and Traffic Division has mOnitored the usage of the public
parking lots along the Third Street Promenade. As utilization of the garages
by Promenade patrons or beachgoers increases, conditions will be reassessed
with appropriate modifications made to accommodate the demand.
23. In conjunction with the Growth Management Strategy for the City, the
methodology for calculating traffic impacts wiH be studied. AdditionaHy, the
-7~
policy states that the CIVIC center site may be utilized. Feasibility studies will
be conducted prior to implementation.
24. PrevIous uses on the hotel property sites did not promote Llaccess ways" to the
beach any more than the current hotels, as they were privately developed lots
wIth no IIpublic walkways" to the beach. In fact, both the Loews' and Park
Hyatt hotels were required to improve access to the beach by funding
specIfied pedestrian-oriented improvements.
25. Granting of new alcohol outlets in the City is decided on a case-by-case basis
by the Planning Commission and/or City Council through the Conditional Use
Permit process. These are subsequently reviewed by the ABC.
26. While the preliminary tests show problems with the early warning sensor/alarm
system, the testing of different prototypes continues. The goal is to
eventually have a system that can accurately detect, at the very least,
common hydrocarbons like gasoline fuel.
At the same time. the pilot ozone-treatment system is continuing to function
well. If the program is successful, treatment and reclamation of storm drain
water may be a reality. Thus. the City remains committed to research into
storm dram treatment.
27. The current draft language is more restrictive than the 1985 LCP, which
permitted demolition of a single family house if the new residence did IInot
exceed either the floor area, height, or bulk of the former structure by more
than 10 percent". The current draft LCP, consistent with the current Zoning
Ordinance, eliminates that provision, instead specifying that if more than 50%
of exterior walls or structural supporting members are removed, it is
considered new construction, and is subject to coastal access criteria. '
28. The fee has been deferred for now. Imposition of a developer fee requires a
nexus study that justifies the fee by assessing each developer's fair share
contribution to beach access.
29. This was a specific policy recommended by the Coastal Commission in 1986 and
approved by the Planning Commission In 1987.
30. Such requirements upon new development are being considered in the
proposed City-wide Transportation Management Plan ordinance.
31. Visitors, residents, and commercial uses alike are protected by the City-wide
Noise Ordinance.
32. Policy #48 is proposed because underwater pilings just south of Ocean Park
Boulevard preclude swimmmg and other direct ocean activities. As a result,
the City proposes to encourage other coastal-related activities that do not
endanger the participants, such as fishing.
-8-
Policy #49 is proposed to implement an on-going City Council project and
objective. That specific process has begun and will proceed Independently
from the LUP.
33. The neW' LCP stdl Includes language that "assures that the recreational needs
of new residents will be met. II The deletion of the specific language and
mOnitoring program is a result of the Housing and Parks Mitigation Fee,
imposed on new office development as a means for improving both housing and
park opportunities City-wide.
In addition, a QUimby fee of $200.00 per new residential unit is assessed to
fund park improvements among other items.
3~. Policy #:68 in the New Development Policies section of the May 1990 Draft LCP
addresses this issue. It states that:
"New development wIthin the Downtown Parking Assessment
District may rely on the public parking structures within the
District in lieu of providing on-site parking pursuant to District
regulations, provided that the District assures that sufficient
parking eXists to accommodate that parking demand of new
development. The City shall assure as a part of the coastal
development permit review process of each development located
within the District, that there is parking available within the
District to adequately support the proposed development. II
35. A public process will be ensuing that will include public hearings and
opportunities for comments on the proposed Natural Elements Sculpture Park.
36. Agreed. Language that allows new non-residential development to use public
beach parking lots for required support parking will be deleted.
37. Seaview Terrace is a walkstreet for which the City has an access easement.
ThiS provision is written into the deed of each property owner along the
walkstreet. Thus, pursuant to Policy #34, the public easement extending from
Ocean Avenue to Appian Way can be maintained for public access and can not
be gated off by the residents.
Both hotels in question were required to improve access to the coast. The
Loews Hotel was required to improve a walkway from Appian Way to the coast
adjacent to the hotel while the Maguire Thomas hotel will make improvements
to Seaview Terrace, including lighting.
38. The impact section in the updated LCP does not address commercial
development throughout Santa Mon ica because the LCP focuses on the coastal
section of the City. The proposed Land Use Plan of the LCP does not propose
an Increase in commercial densities from the existing zoning and General Plan.
Therefore, the LCP does not need to re-evaluate the impacts of existing land
use policies because these impacts were addressed in the environmental
evaluations conducted for the zoning ordinance and General Plan.
-9-
39. Please see comment #23. All traffic Impact studies follow approved City
gUidelines for such studies. These gUidelines have evolved overtime and are
continually evaluated and Improved. They Jobs/housing balance issue IS
addressed In the Housing Element of the General Plan.
~O. The comment under the Ocean Park Commercial Streets subsection states that.
IIAlong Pico Boulevard, the commercial uses are well established.
New development will be required to respect the relationship to
the abutting residential area ,II
This simply means that certain standards will have to be met by any new
development In this area to ensure that the impact on residential uses IS
minimized.
4- 1. The public review process for the updated LUP and the Implementation Plan
is just beginning. The Draft lCP is in no way fixed in content at this point
and several more opportunities for public input are forthcoming, including
public hearings by the Planning Commission and City Council. Furthermore,
the Implementation Plan was simply developed to implement the policies of the
lUP and many of the proposed implementation programs were incorporated at
the suggestion of the Coastal Commission.
Response to the Coastal Commission
1. Requiring contributions to a public access fund requires a nexus study that
correlates the amount of development with its impact upon coastal access.
However, the City.s current policy requires mitigation of adverse
environmental impacts. The City establishes development thresholds that
trigger a public review process and the CEQA review process to determine
whether there are significant environmental impacts. Any proposal that
individually or cumulatively impacts access to coastal resources is required to
mitigate them to a level of inSignificance. This is accomplished through direct
improvements or ad-hoc payments into the shuttle system fund, contribution
to access improvements, traffic improvements, or similar mitigation measures,
2. Pursuant to land Use Policy No. 15, the City will initiate a Comprehensive
Signing Program to improve traffic flow and circulation from the Freeway and
other major access routes to beach parking lots. The signage will also provide
information on alternative transit modes.
The program will consolidate various existing directional signs into a unified
system, and will be divided into five basic categories:
1. Direction signs to direct traffic to specific destinations.
2, Identification signs that indicate specific facilities, services, or
destinations at their location.
3 Information signs give specific details of a facility's or services's
operation.
4. Restriction signs function as warning or limitations for parking. public
access, or safety.
5. Monument signs to indicate main City boundaries at key entry points.
-10-
Tl,e :mplementation of this program shall be phased with the initial signage
located in the area to the south of Colorado Boulevard to the southern City
limits, and between 4th Street and the beach area. This area Includes the
Pier, Civic Center, Main Street, and state beach parking lots.
3 In 1987, the Coastal Commission recommended that the City include In its Pier
policy that IInew development of the existing Pier area shall not require
additional parking as long as the 471 Pier parking spaces are replaced and
maintained.. II Nevertheless, a parking supply/demand study will be
conducted in conjunction with a Pier Redevelopment EI R that will ascertain the
actual demand for parking. Ultimately, intensity of new development on the
Pier shall correspond to that which can be accommodated by 471 parking
spaces, as determined by the parking analysis. Any further intensity of
development shall mitigate Its parking impacts with additional parking, shuttle
program, or other mitigation measure( s).
~. Agreed. This will be added to Policy 1*23.
5 Agreed. This comment misreads the City's policy regarding off-site parking.
Such a lot must be!=Jin within 300 feet of the building site and end within 1000
feet from the building site.
G. Agreed. This is the City's policy regarding residential uses and required
parking.
7. Determination of the shuttle's feasibility will be based on general program cost
versus benefit criteria. Further criteria may include cost per boarding, cost
per service hour, and subsidies per boarding, though specific criteria will be
determined once the shuttle is implemented and comprehensive criteria can be
ascertained.
8. This policy refers to new development on non-residentially zoned parcels. As
such, visitor-serving commercial uses shall have priority over single and
multi-family residential uses and general commercial development. Consistent
With this policy I residentially-zoned parcels currently utilized as visitor-
serving commercial recreational uses shall be rezoned RVC (Residential-
Visitor Commercial) in the two most visible oceanfront subareas 11a and 1bl.
I n addition, residential uses are prohibited from the ground floor on R VC
parcels.
Finally, while the term "private residential use" refers to single and multi-
family residential usesl it is inconsistent with the City's definitions in the
Zoning Ordinance. The revised language of the policy will retain consistency
with City terminotogy.
9. Policy ~~ reflects the boundaries of the Rve (Residential Visitor Commercial)
zoning designation in that subarea. The remamder of the subarea includes
R3 I residential) zoned parcelsl except for those parcels currently occupied
with non-residential uses. These parcels wHl be rezoned RVC to ensure
retention of visitor-serving commercial or recreational uses. Allowing visitor-
serving or tourist-related uses on parcels currently utilized with residential
-11-
u::.es is not appropriate or consistent with the City's zoning west of Ocean
Avenue - frontmg parcels. As shown in the Land Use Maps, the City has
ensured a proper balance in this subarea of residential and visitor-servmg
commercIal zoning.
10. The land use policy regarding the RAND site will be determined with adoption
of the CIVIC Center Specific Plan which governs the RAND and other sites.
It is true, however, that the 1986 version of the LCP did permit ground floor
office uses on the northern portion of the Ocean Avenue frontage.
11. Agreed. This language will be added to Policy *45.
12. The policy will be modified to be consistent with Coastal Act policy 30251.
13. Agreed. Language will be added to Policy #64 that protects public view of
coastal areas from new development.
14. Agreed. Such references will be added to that policy.
, 5. The City's policy regarding the on-site recreational needs of residents of new
development IS entirely consistent with the policies of the Coastal Act. The
City has development standards that ensure the provision of onsite
recreational facilitIes necessary to serve the development. These includes
standards for open space per dwelling unit. The City has two existing
mitigation fees that correlate the amount of residential and commercial
development with the provision of recreational facilities to serve the new
development. The City's Quimby fee of $200 per residential unit (including
apartments, condominiums, and hotels) is imposed by the City and earmarked
for park Improvements and expansion. In addition, the City imposes a
Housing and Parks mitigation fee on new office development, and is based on
floor area. These fees are earmarked for housing and parks development.
16. As the eventual permitti ng agency for coastal development, the City wants the
ability to refine or modify the language to further the goals of the LCP. As
State law allows a local jurisdiction to adopt temporary moratoriums, inclusion
of Policy 71 is appropriate.
With respect to Policy 72, the City believes that reduction of densities in the
Coastal Zone. when deemed necessary to further the goals of the City and the
LUP, should be allowed without approval by the Coastal Commission. As
opposed to intensification of development standards, reducing of densities
wou ld not create more impacts upon coastal resources.
17 . All residential development in the Coastal zone must provide on-site parking
pursuant to the City-wide parking requirements. As such, residential uses
will not pose a burden on the limited beach parking supply. Regarding
visibility of public parking lots, development of any type is likely to impede
view of beach lots. Improved signage can be used as a mitigation. In
addition, the City will require residential development that exceeds two
stories or 2810" to be subject to discretionary site review to assess the impact
on coastal access and resources. Regardless, the residentially zoned parcels
along PCH will be rezoned to an R 1 single family designation. Such zoning will
-12-
reflect eXisting land use patterns, where single-famay uses predominate. \t
also reflects the general development potentials. where most lots are 25' wide
and allow single family uses anyway. Finally, the rezoning will result In
further intensification of multi-family reSidential uses along PCH. Thus, the
revised policy does not allow a higher density of land uses. but allows those
eXisting high-density residential uses to remain.
18. The LUP proposes guest parking at a one-to-five ratio to ensure consistency
with the City-wide policy regarding guest parking. P'ease note that for the
vast majority of residential development this small difference will not result In
any difference in the number of guest spaces provided. Finally, rezoning of
high densIty residential lots along PCH to a single family designation results
in no new multi-family development, which makes the parking ratio obsolete.
The revised policy reflects this.
19 As the City has zoned the majority of this area R3 residential, it is appropriate
to allow residential uses on the gr'ound floor. Nevertheless. the sizable
portion of the subarea will be rezoned Residential-Visitor commercial to reflect
eXIsting non-residential land use patterns. As shown on Map ,~. the City has
ensured an approprIate mix of residential and non-residentiaL visitor-serving
commercial uses.
20. Please see response to Comment ;18. In addition, this guest parking ratio
exceeds the Coastal ComJT1ISSlon's requirements for the remainder of the
Coastal Zone, where development pc +ential for mu\ti-family residential units
is far greater than Subarea 1 b. whio '.... is largely built-out.
2' . The City Council has yet to revie\lj tne J. "Iroposed changes to the Main Street
Ordinance. which among other things, go verns permitted uses. However. the
City proposes to allow residential uses in . an artist studio arrangement.
22. To be consistent with the City's current zoning for Pico Boulevard between
Ocean Avenue and the Promenade, th e development standards win be
amended. On the north side of Pico Izor led RVCL west of Ocean Avenue to
Appian Way. building height shall' 1'10\ (exceed 3 stories. 45'0", t with a 2.0
floor area ratio). Between Appian WillY and the Promenade. building height
shall not exceed 1. stories. 301, with a , .0 FAR. To the south of Pico. parcels
along the Promenade zoned R~ will have a building height limit of 4 stories.
45'0" .
JD;sl
04605 0408 045
R 1/34
-13-
__ _ ;.u;,-1o-'~ F,q .i.4:4l ,: ,:....J,J 10'-<\ LuN".. ~u-i ~ i'D";;lJ 5S0-4936 , 8/635- IU4b Pa;2
"/to 1'1 Of ~ul'QllltCl.-,.c .wo,.II C:. ~ 0CI'fC'T
.
010II01 Dl\!I(,M,I"I"IoN, eo-_-._.-
, ,
CAUFQRNIA COASTAL COMMI5.t;ION
ICUT1t tDo\IT Ar.A
UI wnr MOA~AY, SUIT! _
LCNO ....CH. C.A OOI.."':!
('J'U1~1
Au~us t a. '990
SUZlOfle F r1 tic
C1t~ of ~~r.ta Kon~ca
proor.~ & pol1cy OlvI1opmant
'~85 ~ain Stra.t
S.n~l "~niel. CA ~Q:Ol-32~~
I)~H M$. Frick:
Thi!nio. you for the Oili:OrtiOn1ty -::0 COlT1'Mnt on th;l dr-....ft Loc:\1 CcuUl Progrlm
(Lr.P~. Pit apol09'\2t for "lubrtlHt1ng our ccnrnflnt,. lilt. but due to S;Ch'Clu~1ng
IInd other Ioiork ilI'iljignnell't,c:; WA cO:Jl~ not mAGt :lour t~mQ !tcnedull.
gec!us~ 0' the ti~e con~trdint5 th~~ of~1ce n~s '1m~ted t~Q comrnent~ to the
Lind Use- portion of the LCP W1t.h re9~r-tlc; to the 11'1l1'1nentat1on portion of
the L~?, thl!! i'l'l?1ementation pr.rt1on shotJld tl')nfoNfl with and be adequatl! to
tarry Ollt t;,e pro.....1s1on"i 0' the eel"t1Hpd Lll.nd lJ~p P1il.n. F!lr ei'lch land use
Dolley 1i1ted 1~ the I~nd U~a portion of th~ ICP there ,hou1d be a
corre'pond1ilg 1r;1i'lem~ntins .,ct1nn to ~d"f]llftt!"ly corry OIJt the ,.....ci uu
pol1=~. We ~1ii prQv1dp. additio~a' r.omment~ wh~n th~ I r,p ;s fo~oi'y
subm1t:e1 for i.~1~s1on ~ct1onr
Ccrrrnen":t Ofl Tht ~~nLUu P11:'l
Aece~s P~1191a~
Po11t~ III
Hew development ft)tlnd to 1t",dh1dlJa11y or c:ulllulative1y hllve ~n ~dHrse 'mpact
I on pllol~~ I\c:ce~'!o to the 5hcrel1ne or er...~h' ruources should enhanct public
· acc:u, to the beacn through cnn'trihutinn tn a public ftccess f=und, or beach
s~u~t'e oro;ram. t~~ff=ic: 1mpro/~ment~t Qr si~i'ftr ty~e ~it~;ation Mta,ure.
Po' 1 cy 1 ~
2.
Ooes the C1tV cllrrently hay~ r.r4t~r1~ F~r a ~comprehe~s1~ft sign p~o~r!mD1
Is it hdequrstpll' addra~sed in the 1mplP.rrenT:.At1on t)ort'on of the LCP?
@
4.
5.
G.
7.
10.
II.
,?.,.I3-:~'3el ~! l~: 42 !!i T5::J 1<-4 L:ll-fj SE!:lQ-i TEL NJ:21:l ~~4':l315: 8/63::5- ~:~ P0::
Page 2
3.
p,011ev 23
~.oeve1Dpmant or the ~1er ean n~~ceed wit~out prnvid1ng ~ddit~on~' park1ng 5Q
long !~ the t"ten~ity of u~e o~ tn~ ~edeve'oped P1pr i, not increas.d b.~ond
that w~1ch w~~ suppcrted b~ 47' ~arkin; ~O~tes. 1f the 1r.ten~\ty of use ;s
1ner.Ri~d l~d1t1on~' oarti~Q ~y be required
It ~ho~ld h. ~dA c18a~ tn tn~ pnl1cy ~h!t 1f pa~k1ng 1~ to be re10cated off
tht Pier, t~At the p~rki~g ~h~l' bp. fAr-laced on a one to one bas1s.
poH Co)' ~5
Al'o~~ng r~mctG park1ng to bo 1or.at.~ A d1~~ane. of ',100 fiAt is ~~ces51ve.
A ~ik~~i d~~t.r.r. of 400 f,at 1~ mora appropr1a~._
If res1der:t.1,,1 u1;e 1s p"ovidltd 1n th9 ctlmen:hl or 1Mulijtr1~1 d1'itr1cts tnl!
p~rlcir~ for the re~idE"rtl.l' lJC;~ Im;st be pr"vid.c on-sit,.
PO'~cy 26
If th~ City i~ to detf'~1np t!-! fe,,,~n;'h:y of t~e ,hIJttle !ly~tetll aftel" the
two-ye~~ p11ct progl"~m t~~ t~1teria u5~d t~ dpt~nni~~ the fe~1i~i1ity should
b& mad~ a part Qf t~e LCP.
~lcre~T'on ~nQ V1~'tor~~tr~1ng po'~~1es
P011Cy 38
8 Th. ~~ra;n9 N~;ngl.-f~~1;~ ra~1dent1~1' ~hQuld b~ changed ~o >>pr1v~te
. res1denti~1 use- cor.s1~tent _1th 'pr.~ion 30~?? of the r.o~'tal Act.
9~
Po'~cy 44
Po11cy ~7 cf the lQS6 l ~JP inl"1uderl thF' flMire Ocellnfront ~UMrt!"" u an area
for- tOul"illlt l\eCOlm'Qdattor." ar:d re14tAd F:.LlpT'ort hr.i11t18'\ ""Ii v1l1to,.-s.e1",,1n~
eu ltura 1 U'ies. The c!~rreTlt ":.orrll\pond1 ng pnl1cy limit, tt'le~' u,es to only
nC84n Aven,le. Th1$ pr~r.os.d new pol1c~ ~~ be 1necn\1!tent with Sect10n 30'-22
of the Caletal A't.
Furthe~. t~e SUQgested Mod1fitftt1ons to the '~B6 ver510n of Policy 37 ,11owed
nff~ce ilse on the ground f'Qor 1nl:l on e pc:-tion of the ftllnd property. TJoIit
W2~ ntcn~@nded by r.ommission s~aff after negott~t1on~ with tne property owner
Ino repre~entA~1v.~ from the t1t~. Th\s prnv1s1on 'or limited tround f'oor
off1cI USIf h not retiline:d ; I'l the curnnt pnlicy 44 or poHcy 97. Will thh
use be a penn1 t'tad use 1 ft the new LCP?
Polity 46
Sect10n ~C~'3 ~f ~nA ~o~,t~~ ~ct rA~u1rA' th4t lo~~r cn'~ v1!'~Qr and
rec....~tioM' f~c1 1 1t1es bA prn~'ll:'t.d, AnC'nur~gAd Itnd, whl'rl! ha,1b'!.
/2.
/3.
/4.
/5.
_ C;LG-le-'~ R~ 14'42 1[. Ts.-.::: ;;'-<1 LO\(i BEACH l"EL NJ'213 590-4936' 6/635- ~n46 Pa4
'IVI 3
,~oY14.d. Therefore, 'ow to,t 'od;ing f~c1'1tie~ ~h~uld he ~~fttAined. tf
ce\'t1opment removes k'lol CO"!lt. 'ndg1nV hdlH""'\t the h.",1b1"t~ of ".placing
t.r.1!!' IJn1ts oi'l-~1te shouid be r.o0'\01dftrfld. Tf it ~~ dl'termincd tl'lAt on-site
r~p'~c.ment 's not f~d~inlp then ~n ^~tUft' on~~tn-on~ replftcemt~t w1t~ift t~e
eo,nal znne ,,!u)111d be tOl"l~11'1erl!d If 'thfl''''''' ll1t.-rnlltives lire net fefl~ibl.
t"an an 1 n.. "eu fee p~ )fI'IIl='nt shllll be requ 1 rid.
~Citf' 1 r.. ~nct V_~.5U" 1 Rno H'~l! s pol1 C_U
Pol~c)' 5Y
CO~tBrr. 1~ w~th th~ con~i~~ency of t~A wording w~th ~'Gt1on 102~1 Of tn.
Couu.1 At t.
Po HCjI 64
The p~11cy ~houlr. ensurR T~a~ vi~~ to thp r~~'t ~n~ ~cen1c cOft~tft1 areas are
~retet.ted trom ne~ d~v.laomtnt.
?~~1Ci ~hculd ref~~enr~ ~he ,..~n1c rnrridor~ ~~th th~ ~cen1c end ~i5U!'
"&,\ourceti nl1SP inc: ltJr.ed of" ttle I,.CP.
Hl:w Oevel~nm'!'nt P'1211:1!!
P~11(~ LioSf
Th~ wO~d1~~ of t~4; p~~1cy 1c:; 1nt~n~'ct~nt w1th spr~1on 301~? of the tOlstal
Act.
Po 11 tv "} ~ and 73
16. CorreroM 15 ....ith the 1nr1'J..1c}n ~f t:htu twn polich..
/7..
".
~o11ty 14
CD')C~rn h with the type .,f ;ie...."npm"Jht il'l this iU"1!'a 31'1d t". po!:,;1b1e 1mp.ct5.
Qn Qub1iC ac:.~s. io~ r.OA5~~1 Ar.t requ1re, that new re,io,ntial dtvtlcpmtnt
b9 joc~~ed in ~i~as ~ble tn arconmo~~t. it and wnere it wi" not adverse'~
ilr.p1lct c:o""ital resource", Tne Ml""th b."ch area h 1111pedel't c.\rtly due to the
111lhed pH'\d"g sUPD1~ i'Fld 'o'h1bility ,roblltft1\ of tne pubHc parkint 1ot5
call~te b~ UP p~tti1l"'n [)f adj!lc f'n-: Qfrv,,1opnlJIIJl.'t. Thp. propnvd po11 cy 'Would
..11QItI. 1n many l::JUS, a n1gnp.r dfl'111ty th~n tnl'! lenti h rur-rently deve1Qped
with, Thh m&)' adveru1y .mllllc't UCP$S I1nd caltHal rnOlJrces,
rliY'thtr. the on-sit" 9uec;'t park1"a rn1n for- mlJlt1p'!-fam1'y ~s1centes.
Ht",bl1sheti 0:1 the r.c.'II'I:'u1nn. 15 on~ park1n; 'Pc'\Clt fo:' eilch four ~nit:5.
Po' '1 c.)I '?6
I'. Aesider.tl1!1 U!'iP. "holJld Mt hA J:ll'nwRr, Of'!. 1.,," g!"olJnd "oor.
_ ALG-l~"~ ~I 1~:43 :J TSC) ~-4 LOr-G EE.~ TE..... P1J 213 5~-493G. 8/'635- l:I~46 Pe5
,.g. .
2,D. Gu."t pArk1ng hone p,uldnCl ~plce for nth four u"1ts.
poHey 103
21. W111 reli1dinthl Ult b. p.m1tted1
POlicy 109
22.
Coft~e~ i~ w1th the A11owRb1. height ~lQn, the promenAde. T~. r.~1SlioftIS
Suggl~t,d Mod1ficat1on\ to policy &4 in t~p lqA~ lUP 11m1ted the he1ght to 15
and ~O feet 1" t~e South beath are~. A nigner al1o~abl. height may h.vt an
Idvlrse v1\ual 1mpact on the area.
If yau ~~ve any que~t1on' p'!!~e cnntftct thi~ office It (?13) 590-5071. Thonk
yOU.
~~
A' J. pa/.1nl.
COA~ta1 Progrlm AnA1yst.
seOLe
~
,
1
Sharon Gllp1.n
1725 The Promenade #324
Santa Mon1.ca CA 90401
July 6, 1990
,-:
c:S
n
:J-I
::::;-<
-~0
Clty Pla~n~~g Dlvlslon/PPD
1685 Ma1.n Street, Roo~ 212
Santa Monica, CA 90401
-J --I
I
'.::l
21
Re:
Co~~ents on the Draft Local Coast~l pro~am
Dear Clty Planning Dlvislon/PPD:
The short tlme frame avallable to the public to comment
on thlS LUP/Implementat1.on Plan necess1.tates comments from
thlS wrlter that are a blt dlsorganized, dlsjolnted, and
rlddled wlth nlsspelllngs and non-sentences. I apologlze
for thlS but want the comments on the record for thls most
lmportant POllCY for the coastal zone ln Santa Monica.
Many clt1.zenS are d1.sturbed by the rapld rate of
developnent occurrlng In Santa Monlca coastal zone and are
concerned about the City controlllng the perrnlt process for
development In the coastal zone. The cornerstone of plannlng
lS the Environmental Impact Report. The recent past l.n Santa
Monlca shows many EIR's that are lnadequate wlth slgnificant
adverse lmpacts overlooked and not mltlgated. Even more
a~armlng are the 100,000 sq. ft. proJects that are bUllt on
Ocean Avenue by negatlve declarat~on. Based on the recent
past hlstory of the City, th~s clt~zen shares that concern.
~hlS LUP/Implementation Plan should have many nore
rounds of publlC hearlngs before ~ts adopted by the Councll
and presentat~on to the Coastal Commission. The
General Comments:
1
A quick review of the prior [1985] and thlS 1990
LUP/lmplementation Plan shows many differences that change
pol~cy d1.rection. For example, PCR ~s def~ned ~n the
orlglnal LUP as a hlghway whose Itcapaclty cannot be
Increased". In this ne~ vers~on, PCR is descrlbed as
h~ghway that ~can only be Increased w~th dlfflculty".
1989 Clt~~lde C1.rculation and M1.t~gat1.on study deflnes
as a hlghway nWlth the most ~ntractable surface street
capacIty shortfalls In the c~tyl1. In fact the trafflc
clrculat~on on PCH has become more difflcult - not easier
a
The
PCH
2
3
,
2
with the passage of time. The Clty needs a new round of
pUblic hearlngs that focuses on current conditions in Santa
Monlca In the coastal zone.
The c1tlzens lnvolved ln the 1985 draft concluded, and
the councll adopted, a polley recogn1zing the llmltatlons of
PCH and the new 1990 version reaches Oppos1te conclUS1ons -
the publlC POllCY has changed wlthout publlC hearlng. In
fact, thlS new LUP POllCY contradicts current 1989 data.
The 1985 LUP has chapter heading photographs reflectlng
modern coastal zone amenities and Vlews. This new document
features photographs of the 1890's the 1900's and 20's and
60's - and no photographs of the modern coastal zone. It
seems inappropriate to couch POlICY wlth a nostalgIc
perspective as th1S is a document that 1S supposed to plan
the future of the coastal zone.
The city has developed over a million square feet of
hotel development ln the coastal zone Slnce 1985. Close to
70% of those hotels are luxury facillties. These faCllities
have replaced budget and mid-level accommodat1ons.
Chapter I
4 Please IlSt all public hear1ngs held after the City
Councll adopted the LUP May 6, 1986 and those held after the
1987 Coastal Commission hearlngs that recommended
modif1cat1ons.
5
6
7
It lS my recollectlon that the last public hearing held
on the draft over three years ago at Council at wh~ch t~me
staff was olrected to d~scuss and negot1ate changes wlth
Coastal Cornm~SSlon staff. I sent a letter to the C1ty at
that t~rne express1ng my des~re to be contacted in the event
that any public hearings, meet~ngs, planning sess~ons,
discussion groups were convened. I have never been
contacted and, to my knowledge, no publ1C meeting has been
held in the three years pr~or to this draft.
This is the first time the publlC has seen the proposed
Implementation Plan. The commenting period set for this
extremely ~mportant planning tool for the Coastal Zone has
been too short. A six month extens~on of t~me for the
publlC comment and study and review of the document lS a
reasonable request.
The City obviously has not been in any hurry to
conclude the past 18 year process 1n br~nging the LUPjLCP
before the public in any fash10n to guide land use pol~cy ln
the Coastal Zone. Development ln Santa Monica's coastal
zone has been rap1d and lntense ~n the past 5 years. A delay
ln collect1ng comments lS warranted as the effects of the
8
9
10
11
3
past construction boom have not been suff1c1ently
ascertalned. The publlC hearlngs for the p1er restoration
program, main street plan, commerclal and industrlal
develooment task force, resldent1al task force, ocean park
redeveiopment project do not, by themselves, constitute
hearlngs on the LUP/LCP. These other public hear1ngs d1d
not lnvalve connection wlth one another, the cumulatlve Vlew
of the coastal zone was not considered.
Chapter II
page 1: The comment 15 made that all future
development occurring In the lnland coastal zone wlll be In
the form or recycling and urban lnfill, rather than
co~mitment of undeveloped land. In fact, the civic center
11eS in thlS zone and the current discussion In the civic
center speciflc plan group include the probablllty that some
of the land may be committed to increaslng open space. Why
conclude development?
The co~ent is made that availability of freeway
offramps enables Vlsltors easy access to the beach. It
should be noted that the rapld rate of commerclal
development has lncreased trafflc to the point that a
illaJority of the maJor lntersections in the coastal zone [all
SUb-areas] have been classified as Level of Service F.
Clearly, as the reglonal populatlon lncreases the beach area
w~ll need to serve as an open space resource so that
reglonal vls~tors w2ll continue to have access to the state
beaches In Santa Monica.
Sub Areas - In general, a broader, curnulatlve view
should be taken of the a-b-c subareas. For example, subareas
band c are served by the same freeway Off-ramps and surface
streets and planning for access, circulation, V1ew
corridors, etc for these two subareas could be comblned for
a broader, cumulative planning gU1del1ne.
Sub Area I A: In the June 1986 LUP - PCH 15
descrlbed as follows: "The capacity of the highway cannot be
tncreased because the palisades bluffs rlse on the 1nland
side ..." [pg. 10] In this version of the LUP the
descr2ption 15 as follows: "The capaclty of the roadway can
only be lncreaseq with d1fficulty because the pal1sades
bluffs rise abruptly on the inland Slde..." [pg.rr-4]. The
1989 CltT~lde Clrculation and Traffic Mitigation Study
ldentlfles PCH as one of three routes with existing hlgh
levels of congestlon and "the most intractable surface
street capaclty shortfalls wlthin the Clty."
12
13
14
15
16
4
The 85 LUP states that the Jonathan Club's lease has a
l~m~ted term, the 90 plan has no statement, please clar~fy.
It seems lnappropriate to conclude that an aquarium
will be bu~lt on the Deauvl1le s1te. No permlt has been
flied for such an enterprise - no ErR's have been
commlssioned. It lS important to allow for options such as
addltional parklng, open space, and beach related
recreat10nal use.
page 1I-5: concludes that the proposed hotel will be
built, the proJect has not been given approval. As the
faClllty is publicly owned, alternatlves that have been
suggested lnclude use of the present facility as a public
day use fac1l1ty, addit~onal public parking or open space.
Sub Area IB: page II-6 - this area has allowed hotels
only by condltional use permit. Current zoning would permit
contlnued recycling of res1dential uses.
Please note that reSldents park in existing lots as
many of the older resldentlal structures were built without
parking facllitles.
It lS important that the LUP note the loss of view
corridors because of the current luxury hotel bUl1dlng boom.
Over 750 luxury rooms ~n subarea IB and on the IB border
have been bUlltjapproved In the past 2 years.
Subarea 2:
17 Care should be taken so that the pol~cy advocated in this
LUP is one that acknowledges the current congested state and
one that encourages open space and preservat~on of eX1sting
recreat~onal uses, view corrldors, parking 50 that reglonal
V~sltors can contlnue to access the Santa Monlca coastal
zone. The number of regional visitors is increasing - not
decreas~ng.
18
Subarea 6:
ThlS subarea is integral to the beach area. Ocean Avenue is
the maln north-south route along the beach area ln Santa
Monlca. The intersections around the Pier and Pico are all
currently operating at LOS F. The Civic Center Specific
Plan is far from being completed at this stage and has
lncluded ldeas for land-swapping and conservation and
creatlon of open space.
However, at present the Rand Corporation has announced
~ts desire to develop the land on Ocean Avenue bounded by
Maln Street, Colorado and Pico Blvd., wlth 1.3 mlll10n
square feet of development. The proposed 6 story offlce
19
20
21
5
buildings, the proposed 16 story tower would cause all V1ew
corrIdors to dIsappear - the Guest Quarters hotel on 4th
street destroyed many mounta~n V1e~s and palm tree level
VIews from Ocean Avenue. The proposed CIvic Center plans
would dramatlcally Increase denslty, traff1c, Increase aIr
qualIty problems and cause an increase In commercial denslty
at the expense of open space In the coastal zone.
III Coastal Zone CondItions and Issues
Santa MonIca is on the brink of deciding whether it
should allow addItIonal hotels/motels and large restaurants
along the zone bordered by north santa Monica CIty boundary
to the south city boundary - west of the center 11ne of
Ocean Avenue [and its contlnuatlon into NeIlson Way] to the
ocean. Over 10,000 Cltlzens slgned the Save Our Beach
InltIatlve 1n 1989 and w1ll vote on it in November 1990. If
It passes, the in1tlatlve dictates that it be included 1n
~hIS LUP. [The Inlt1atIve exempts the PIer and the block
south of the pIer]. Publ1C opInIon polls and the rapid rate
of SIgnature gather1ng ~ndicate that Santa Mon~can/s support
for the 1972 Coastal Initlatlve and its conSIstent support
of reasonable growth IlIDlts on development in the coastal
zone are still strong. The rapid rate of development in the
coastal zone over the past 5 years, the approval of 750
luxury hotel rooms near the beach SInce 1987, the dIScussion
occurring 1n the C~VIC center specific plan with square
footage estlmates ranging from 1.3 - 1.8 million sq. ft.
WIll draMatlcally lrnpact this land use POllCY.
Please comment how the proposed inItIative, ~f passed
by the voters, WIll be added to thIS LUP/Implementation
Plan.
ThlS coastal zone is extremely fragile. POlICY
determInations must Include a VIew toward day use VISItors
and the realIzatIon that urban Los Angeles is contInUIng to
grow and that day use vIsItorshlp of this regIonal resource
~~ll increase and not decrease. WhIle hotels may be
consIdered "visltor servingrl the developments 1n Santa
Monica WIll serve only 2% of the population. The resource
mus~ be avaIlable to all income groups. Care must be taken
in Santa Monica policy that encourages preservation of this
resource and insures accessibllity to the greater Los
Angeles reSidents who need and use thlS rapidly diminishing
beach recreatIonal resource.
scenic and v1sual resources have disappeared wlth the
rapld rate of development. The palm line used to be clearly
vlslble from the beach - the 6 story hotels have obliterated
thlS Vlew. VIews of the Santa Mon~ca mountains have been
blotted out. The VIew corridors from the hotels are not
22
6
ava~lable to most clt~zens - th~s represents a loss to the
pUblic of thelr beach resource.
Access:
C1ty has recently contracted out the1r respons1bility
for rnanag1ng the park1ng lots. The company that now manages
the lots frequently closes the lots close to the Pier. ThlS
adds to congest1on on the small side streets off of Ocean
Avenue. The hotels off-load dellvery trucks on the street,
th1S combined wlth closed beach lots leads to gridlock on
the streets lead1ng to the beach.
The Clty recently began removing metered public parking
along Ocean Avenue in front of the hotels and on slde
streets. The street from Colorado to P1CO has lost over 1/2
of ~ts meters 1n the past year and they are not be~ng
replaced. The red zones are Ilned wlth wa~ting taxlS.
PUblic parklng was removed at the foot of Pica Boulevard,
further decreaslng parking access for visltors. Although
the P1CO Blvd. parklng 15 supposed to be replaced in the
hotel h1story has showTI that the public is often confused as
to the charge and ava1lab1lity of the park1ng [most people
dr1ve past valets]. An example of thlS 1S the public
parking at the Bay V1ew Hol1day Inn. Mandated by Development
Agreement a certain number of spaces were to be prov1ded for
free to the public at all t~mes. This has all but
dlsappeared and the publlC is no longer able to park in that
garage as valets discourage any pUblic parking and the
slgnage has d1sappeared. This is the continu1ng trend 1n
Santa Mon1ca's coastal zone and the polic~es should reflect
that fact.
The 1n-deoth analVS1S described on I11-3 for the pier
15 an lmportant part of this polley. Unless the Clty
lmaglnes a 10 story parking garage it wl1l be dlfficult to
plan a facility that can accommodate the loss of metered
park1ng and the parking needed for all the planned
commercial ventures on the Pier. The intersections in this
area are at current LOS F and it will be difficult to plan
cohes~ve circulatlon for this area. An environmental lmpact
rev~e~ will need to be done for the entire Pier master plan,
the planned parklng structure, the CiV1C center spec1f~c
plan. These planned uses are within one - two blocks of one
another. The zone is super congested.
Many of the new development on the Third Street Mall
have been excused from the1r responsibility to provlde
park1ng. Instead, the City has allocated spaces 1n the
C1tylS park1ng structures. The expansion referred to
structure 5 has been completed and yet no analysis has been
conducted to show how many of the publlC parking spaces have
been used for the prlvate development on the Third st. Mall.
23
24
7
As pub11C spaces are "givenll to conunercial developments
on Th1rds st. Mall - how many are left for the beach g01ng
pub11C? No analys1s has been conducted.
The City's method of calculating signlf1cant adverse
impact, lack of serlOUS mitigat1ons, and use of double
mlt1gat1ons at LOS F intersect10ns 1S lead1ng to a traff1c
cr1S1S 1n the coastal zone of Santa Mon1ca - leading to a
denial of public access to the most heavily used beach in LA
County.
A shuttle system has been explored for the past 13
years 1n the SM coastal zone - the time has never been
better for serious consideration.
B1cycle Access
The b1cycle lanes existing in the Coastal Zone are
dangerous 1n that they are on the busiest streets in the
zone. The City continues to grant sldewalk easements to
restaurants for s1dewalk d1n1ng 1n the coastal zone and has
constricted 1tS ability to increase bicycle lane ways and
w1den sldewalks for improved pedestrian circulation now and
for the future.
The bicycle path 1S a safe route weekdays but on
weekends skaters ~nd pedestrlans use the path for walk1ng
and skating rnakln~ lt unsafe for blcycle trafflc.
Pedestr1an Access
The recent development along Ocean Avenue 1n sub area
1B has reduced pedestrian access to the beach. The hotels
have not been conditioned to maintaln the previous access
ways to the beach. This los$ of pedestrian access from
Ocean Avenue to the beach encourages people to walk down the
middle of the small side streets and alleys to access the
beach creating addltional c~rculat1on problems for autos,
b1kes, and pedestrians. The area south of the Pler to Pico
is almost a sol~d front with no pedestrian access. Side
walk streets have gated themselves so that the~r previous
access ways have been pr1vat~zed. The Loew's hotel, the
Maguire Thomas hotel has no public pedestrlan access so that
pedestrian must walk blocks out of their way to access an
alley for beach access.
Recreat~on and vis1tor-Serving Faclllties
Santa Monica provides the most commerc1al vlS1tor
serving fac1l1ties on the southern Californ~a coastline in
1tS coastal zone. In Vlew of the exploding populatlon of
urban Los Angeles which will mandate heavier use of the open
space resource - the beach - lt lS lncumbent upon Santa
8
Monica's LUP to focus on ma1nta1n1ng open space, beach
resources and limiting further commerc1al development in the
coastal zone.
This pol1cy should reflect a move toward slow-growth
1n the coastal zone - po11c1es that reflect conservatlon of
open space beach resources so that all income groups and the
day use V1s1tor - a major1ty user of the beach resources be
able to access the coast11ne ln Santa Monlca. The planning
goals should be to preserve as much open space as poss1ble.
Map 9A is cur10US 1n 1tS lack of markers denotlng all
the theaters, restaurants, pool halls, nlght clubs, and
other V1s1tor serving services on the Third street Mall.
This 1S 1n the coastal zone and this map should reflect
those uses. Clearly the development 1n the past 5 years en
the Mall has favored Vlsltor serving uses over ne1ghborhood
uses. Map 9B does not show vlsitor servlng uses on Main
Street a street filled with restaurants, bars, nlghtclubs,
retail shops. A map reflecting the above would show a
coastal zone jam packed w1th commercial visitor servlng
uses.
25
Mention should be made of the number of on-sale alcohol
outlets in the coastal zone in Santa Monica. For 1nstance,
census track 7019 - almost fully in the coastal zone -
encompasslng subareas lb and c - has 2,621 people and ABC
gUldellnes call for 3 on-sale alcohol outlets and 3 off-sale
outlets. Yet in 1990 neighbors have found that there are 87
on-sale alcohol outlets and 15 off-sale alcohol outlets -
400% above the allowable n11mher of off-sale outlets and
2800% above the allowable number of on-sale outlets.
Serious questions of health and safety ln the coastal
zone should be addressed ln this policy document.
Quallty of Storm Water and Other Run-Off - pg. III-24
24& Reference to the pl10t program at the Pico-Kenter storm
dra1n must be deleted as the latest report from general
servlces in Santa Monica indlcate that the technology needed
to create the sensor/alarm slide gate system detectlng
hydro-carbon vapors limiting discharge does yet exist.
Please remove this as it creates a false assumption that
storm drain run off is Itbeing taken care ofn when the
reverse is true. While the storm drain may have been
upgraded - the runoff is still the same.
The policy should encourage leadership in storm dra~n
runoff treatment.
27
28
29
30
31
32
33
9
Chapter IV - Policles
page IV-5: "new development" b. The 85 LUP provldes that
reconstructed resldences not exceed bulk of former structure
by more than 10% - thls new LUP states 50% flgure - please
explaln. c. - llkewlse states 10% ln 85 and 50% ln the new
LCP.
page IV-6: prevlous POllCY [pg. 64 - 1985 LUP] OlScusses a
fee from new development that would asslst 1n enhanclng
publlC access to the beach - thlS fee is dropped 1n th1s new
~U? - please comment.
page IV-8: 22. Resldents 1n sub area Ib llve in apartment
bUlldlngs/homes that were built 1n the 20's and 30's and
have no parking ava1lable to them except for the beach lots.
This POllCY must reflect that residents have no alternat1ve
park1ng Solut10ns and must use the lots 1n eX1stence wlth
permlts at all tlmes.
Blcycle
ThlS policy should reflect the city's deS1re to
~ncourage blcycle travel 1n the coastal zone and should
cons1der new development w1th over 50 parklng spaces to
prov1de lockers and showers for employees. The policy
should also encourage a publlC locker/shower facillty so
that travelers on the blke path may use such a faclllty.
Recreatlon and V1s1tor Servlng Pollcles
These pol1cies should include a statement that protects
vls1tors from noise pollut1on. Commerclal enterprlses on
the Pler and along the beach front have begun broadcasting
commerclal radlO that affects the entlre sandy beach area.
The effect of thlS lS that the distorted mUS1C and radio
comrnerc1als completely obllterate the sound of the waves.
A comparison between the 85 LUP and thlS new version
shows 2 new pollcies under this sect10n - please comments as
to thelr orlgin and purpose.
New Development
54f in the 85 LUP provided that the recreational needs
of new residents will not overload nearby coastal recreation
areas by correlatlng the amount of development wlth local
paTk acquls1t1on and development plans. This new verSlon has
dropped thlS POllCY language - please comment and explain.
34
35
36
10
Polley 57 ln the 85 LUP provldes that new development
wlthln the downtown parklng assessment d~strlct may rely on
the publlC parklng structures wlthln the dlstrlct In lleu of
provldlng on slte parklng pursuant to the dlstrlct
regulatlons, provided that the district assures that
perrnltted development does not outst~lp avallable parklng
capaclty..... thlS new LUP version drops that language. AS
the development booms roars along on the Thlrd Street
Promenade there has been no study about the nuNber of
parklng spaces assigned to new development. ThlS policy
should be anended to include a study of parking capaclty
that eXlsts as of thlS year. The Clty has no way to know
how much capaclty eXlsts In the publlC parking structures.
Please comment.
Policy regarding hotel and motel development In the
coastal zone must take lnto account the ballot lnltlatives
on the November 1990 WhlCh - lf passed - would restrlct and
In some lnstances forbld thlS kind of development in certaln
areas In the coastal zone.
Please comment.
Subarea IA,B, C
Natural Elements Sculpture Park is a new addltlon to
th~s LUP - please comnent. No public hear~ngs have been
held regarding thlS particular pol~cy - in fact - many
cltlzens approved NES Park as a conflned, slngular sculpture
park proposed to be located ln one place north of the Pler
near the Deauvllle slte. This POllCY would advocate
spread~ng sculptures allover the sandy beach removlng open
space. Please comment.
Subarea IB: 76. This policy should advocate that new
non-resldential development be required to supply parklng
for support parklng ON SITE. There is no further capacity
In the Santa Monlca coastal zone for anythlng less.
C1V1C Center : policy 97 - ~f the Save Our Beach
lnitlative 1S passed by the voters In November 1990 no
hotels would be permitted on the west side of Ocean Avenue
from the northern SM boundary to the southern SM boundary to
the water's edge.
~
._--r
p.
,
37
38
39
40
41
11
Oceanfront Hlllslde - subarea I
99. ReSldents of Seav~ew Terrace own the property that
currently serves as an access route. If they choose to lock
It off as d~d the resIdents of Arcadia Terrace - what then?
The Clty has not requIred the Loew's Hotel or the MaguIre
Tho~as hotel to provIde any pUblIC access on theIr land from
Ocean Avenue through to App1an Way. The or1g1nal access way
Just sou~h of Loew's hotel has been locked - was th1S publIC
access way a cond1tIoned approval of the proJect? Please
comment.
Chapter V - Impacts
In 1984 Santa Monica's Land Use Plan projected a 16
year conmerc1al growth rate of 36~,500 sq. ft per year - or
an addlt10nal 5.8 million sq. ft of new commerClal
development by the year 2000. By 1989 the City had already
approved 5.22 m1llion sq. ft of new lndustrlal and
conrnerc1al development - or 90% of what was to be allowed by
the end of the century. Over 3.35 mill10n sq. ft of
ddd1tlonal development 1S currently pending C1ty Councll
reVlew. Santa Monlca has allowed over 8.6 millIon sq. ft
lnto the pipelIne since 1984.
ThlS realIty 1S not reflected In this Chapter V -
Impacts. Please comment.
The City'S method of studYlng intersectIons and trafflc
lmpacts lS faulty and arcane. ThlS results In 1nadequate
EIR's, Impacts that are not addressed and therefore are not
TI1t1gated. Santa Monica has a severe need for add1tional
houslng and it's Job housing balance lS severely defIcient
[Ie, too many Jobs - no houslngJ. None of these Issues are
addressed 1n this LUP. Please comment.
The comment on V-4 under Ocean Park CommercIal Streets
states that new development WILL BE REQUIRED. Please
comment.
ImplementatIon Plan - There have been no public hearIngs on
thlS remalnlng sect~on of the LUP. Please comment.
This Implementatlon plan has been avallable for comment
for one month - time for comments should be extended. My
comments on thIS portIon of the Plan are not avallable yet
and I reserve my rIght to make comments at a later tlme.
V~fY truly yours,
cil'\fv.vYl. )J~-~'-.
Sharon Gl.lP1~ cr
..
~S\
RTC
C'-,.. (' - -
rl'!-~,JL 4..j,......~.,..,
I I...... .I .... \ .... i-I ~ I
CITY~r :".._1",',:/- -
_ 1._ ~
'90
July 5, 1990 JUL -9 ,lUQ :49
Mr Oouqlas Klm
City Planning Dlvlslon/PPO
1685 Maln Street, Room 212
Santa Monica, Californ1a 90401
~ear Mr K1m:
The Southern Callfornla Rap1d Trans1t 01str1ct (SCRTO) has rev1ewed the Draft
Clty of Santa Mon1ca Local Coastal Program - Land Use Plan and Implementat10n
Plan, and offers the follow1ng comments and concerns.
seRTO operates L1nes 4, 304, 20, 320, 22, 322, 33, 333, 434, and 436 1n the
Sa~ta Mon1ca area. Route and schedule 1nformat1on 1S enclosed. Santa Monlca
Mur1cipal Bus Lines also operates lines 1, 2, 3, 7 8, 9, 10, and 11 in the
project area Culver Clty Mun1c1pal Bus Lines operates L1ne 1 1n the project
area as well Both agenc1es should be contacted for their route and schedule
1nformatlon.
1
As the reg10nal ooerator, the primary lnterest or seRTO is to prOVide and
~alntaln an effective and efflcient regional trans1t system. SeRTO supports
an 1ncrease 1n the tranSit capaCity of Los Angeles County, such as the
pro~osed Santa Mon1ca Shuttle described in the Local Coastal Program, and
suggests that when conSidering an expanSlon of serVice the follow1ng should be
observed;
o Services to be funded under the Propos1t1on A Local Return Program are
required to follow guidel1nes developed by the Los Angeles County
Transportation Comm1ssion (LAClC) Under these gU1del1nes the C1ty 1S
requ1red to seek approval for the proposed proJect from the LACTC,
whlch 1n turn checks w1th other operators to conf1rm non-dupl1catlon
of serVice.
o SeRTO should be notlfied early 1n the plannlng process To maX1m1ze
the effect1veness and coordinat1on of trdns1t serVices 1n the reg1on,
the D1strict is lnterested in worklng clusely wlth your staff,
rev1ew1ng new serV1ces, d1scuss1ng alternatives, and evaluat1ng the
lmpacts of each proposal.
Souther" Call1ornla Rlp.d TranSIt District 425 South MaIn Street Los Angeles California 9001 3 (213) 972-4300
,
Mr. Douglas Klm
July 5, 1990
Page 2
o SC~TD can asslst 1n route plannlng and serVlce deslgn to ensure that
appro~rlate slzed venlcles and serVlce would be prov1ded to
nelghborhocGs currently not served by the larger reglonal buses. We
can further offer the posslblllty of contractlng wlth the Clty of
Santa Monlca to operate the proposed serV1ce.
2
SCR7D suggests that the follow1ng measures be lncorporated 1nto the plannlng
~rocess to further mltlgate any lmpacts resultlng from the proposed Land Use
Plan
o ReVl€W development plans to assure new proJects provlde access to
trans1t facll1tles 1n a manner that 1S at least as conven1ent as
access to automoblles.
o Conslder parklng needs and employee mode of arr1val when reviewlng
development plans. In llght of SCAQMD Regulatlon XV, place l1m1ts on
the number of allowable parking spaces 1n congested areas.
o Sup~ort construct10n of covered llghted bus stops, set back from the
street. ~~courage des1gn of w1de, well llghted sldewalks Wh1Ch
prov1ce easy access to bus stoos and are unobstructed and access1ble
to all patrons lnclud1ng the d1sabled.
SCR.8 IS willlng to cooperate wlth the Clty of Santa Monlca on any translt
re12:ed aspect of thlS proJect. Please forward the F1nal Local Coastal
Prosram when It becomes avallable. Should you have any further questIons on
~hlS ~atter, please contact me at (213) 972-4841.
Slncerely,
lJ~~a,1J~
Dana A. Woodbury
Inter1m Dlrector of Planning
Attachmert
AG r: ", f ~~ ITr= 1\11
-"- J \1 U r\ JlJ~lt-tb\:JEZ DAD
117 PacIfic Street #107
Santa Monica, Callforma 90405
213/399-4563
9/f
April 16, 1991
Mayor Judy Abdo
Councilmembers Ken Genser, Robert Holbrook,
Herb Katz, Kelly Olsen, Tony Vazquez and
Denny Zane
City of Santa Monica
1685 Main Street
Santa Monlca, Callfornia 90401
Re: Local Coastal Program
Dear Mayor Abdo and Councllmembers:
The current draft of Santa Monica1s Local Coastal Pro-
gram, WhlCh has not had the benef~t of public hear1ngs and
publlC workshops, will take precedence over other policy docu-
ments, incluClng the General Plan, wh1ch were fash10ned with
full publlC participation. Yet the LCP makes substantive
changes in policy and 1n specific zonlng. It is not an admln-
1strat1ve matter and not merely an update to conform with prior
documents such as the Land Use Element and the Zon1ng Ordinance.
In fact, 1t departs from those documents and does so w1thout
having had a publlC process for discussion and legitimizatlon.
Polley Changes
1. Fro~ publlC access (free access, recreat10nal wlthout
necessarily enta1ling purchases) to cornrnerClal encouragement
(lndlcatlng prlvatlzation and purchases). The term IIcommer-
cial recrat~onal...tI keeps re-appearing, as 1n Pol~c~es 38
(page 68) and 77 (page 74).
2. From protectlon of resident1al to an encroachment of
cornmerc1al (privatization) both in hav1ng currently reslden-
t1al s~bsumed 1nto RVC in the beachfront area south of the
Pier (~ap-t4) and by changing res1dential, under certain
cond1tlons, to RVC on the north beach (Pol~cy 77, page 74).
3. From allowing those beachfront res1dents whose older
build1ngs do not have sufficient parking to use permit park-
ing 1n the beach lots to prohibiting them from us~ng permit
parklng 1n beach lots during the daytime hours (Policy 23,
page 5).
These are departures from the Local Coastal Plan passed in
~ of 1986 and the changes have been made w1thout any
public workshop process.
~ ...
Mayor Abdo and
Councllmembers
-2-
Zonlng Changes
1. From both single famlly residentlal
and high-density residential to all single
family residential (Rl) on north beach.
Departure from Zoning Ordlnance.
2. From resldentlal to RVC on selected
parcels 1n the area between the Pler and
Pica.
Departure from inter1m zoning agreed to
with residents at time of Zoning Ordinance,
1n WhlCh currently resident1al areas were
zoned R3.
3. Changes in heights and FAR's 1n area
between the Pier and Pica.
Departure from Land Use Element WhlCh gives
he1ght of 2 stories(30') and F.A.R. of 1.0
for the area between Appian and the Promenade,
from pico to the Pier (not to V1cente Terrace,
as changed in thlS LCP).
April 16, 1991
?OllCY #=
Page *
75
76
73
74
Maps, esp.
Hap 14;
policies dealing wlth
area south of P1er.
Implementation
Section
7 & 8 93 & 94
These are certa1nly only a sampling of the Substwitlve changes
1n th1S document which need a thorough public airing. Given
the tlme from which this draft LCP was made available (less
than two weeks ago), the amount of work needed to digest 1t
and compare w1th other documents which it wlll supersede, and
its importance in the Coastal Zone 1t 1S unfortunate -- no,
It is unconsclonable -- to decide on 1t tonlght.
The publlC deserves to have an opportunlty to fully
partlcipate since you are to make POllCY changes and zoning
changes WhlCh affect our city. And, ln addltion to these ltems,
there should be elaboration on the subjects of Translt to in-
clude the probablllty of a llght rail line and its impacts and
the Bicycle Lane section to expand on the north-south streets
since blkes are used as transportation, not Just as recreat10nal
vehlcles.
ThlS document deserves full and publlC attentlon, as
were glven to the Land Use Element, the Zoning Ordinance, and
the 1986 Local Coastal Plan which it supplants.
Very truly yours,
~~f)1Ul
Julie Lopez Dad
cc: John Jalili
Paul Berlant
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PIRCHER, NICHOLS & MEEKS
ATTORNEYS AT LAW
CENTURY CITY NORTH BUILDING
10100 SANTA MONICA BOULEVARD
LOS ANGELES, CALIF'ORNIA 90057
(213) 201 8900
F'AX (21.:3) .201 894-1 OR 8922
1211 AVENUE OF ""''''''IE AMERICASt .29'""' F:..OQR
tiE;:w VOFl'K} NEw YORk. 10036
(212) 76B 9400
HOWARD MILLER
(213) 201-B970
April 16, 1991
HAND DELIVERED TO CITY
CLERK FOR DISTRIBUTION
AND CONSIDERATION AT
SANTA MONICA CITY COUNCIL
MEETING OF APRIL 16. 1991
Mayor and Members of Santa Monica City Council
Council Chambers
1685 Main Street
Santa Monica, California
Re: Agenda Item 9A - Proposed Local Coastal Program
Aaenda Item BC - Emeraencv Ordinance Restrictina He10ht
Dear Mayor and Members of the Santa Monica City Council:
On behalf of Pacific Beach Development Limited
partnership and Michael McCarty, we object to the Local Coastal
Program to the extent it incorporates Proposition "S", wh1ch
purports to prohibit new hotel, motel and restaurant
development on the Santa Monica State Beach. The Proposition
"S" use prohibitions are unlawful and invalid for the following
reasons:
1. The State Beach is State Land and is not subject
to municipal initiatives or legislation restricting its use and
development.
2. Proposition "S" was unlawful from the outset as
the use prohibitions on the State Beach were not "municipal
affairs" and were beyond the authority of the Santa Monica
electorate.
3. Regulating the use and development of State Lands
and State Parks and the granting of concessions thereon is
pre-empte~ by State Law.
4. Proposition "S" was an arbitrary, capr1C10US and
discriminatory action exceeding the police powers of the City.
The propOSition attempted to impose municipal concerns over
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Mayor and Members of the Santa Monica City Council
April 16, 1991
Page 2
those of the region and the State and were not rationally
related to the public's health, safety and welfare.
5. The City's administrative authority to regulate
the use and development of the State beaches is limited to the
admlnistrative authority delegated to it by the State, through
the Operating Agreement with the State. Proposition "S"
exceeded that authority and was unlawful legislation.
6. Proposition "S" is not consistent and does not
conform to the General Plan for the Beach.
Furthermore, we object that the Local Coastal Program
fails to recognize that a Development Agreement was entered
into between the City and the Pacific Beach Development Limited
Partnership and that that Development Agreement remains
enforceable. The Development Agreement provides for a project
consisting of a hotel, restaurant, community center and
parking, among other public uses at 415 Pacific Coast Highway
on the State Beach. The Development Agreement was unlawfully
breached and terminated, notwithstanding Proposition "Z".
Proposition "Z" is an unlawful, invalid and unenforceable
initiative for the same reasons that Proposition "S" is. The
Local Coastal Program also fails to recognize the adverse
impacts on the State Beach from lost revenues if the City
continues to block the development.
To the extent the Local Coastal Program prohib1ts
hotel, motel and restaurant uses on the State Beach and
precludes the Paciflc Beach development, it is inconsistent
with and does not even recognize the existence of the following:
1. The Operating Agreement.
2. The purposes and objectives of the State Park
System.
3. The General Plan for the State Beach (Santa
Monica State Beach Resource Management and Development Plan).
The Beach Plan specifically enumerates appropriate uses for 415
Pacific Coast Highway, including lodging facilities,
restaurants, community center and museums.
To the extent that the Local Coastal Program prohibits
hotel, motel and restaurant use on the State Beach, it is not
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Mayor and Members of the Santa Monica City Council
April 16, 1991
Page 3
consistent with the goals of the California Coastal Act as set
forth at Public Resources Code S 30001.5.
The Local Coastal Program is internally inconsistent
as it adopts the Coastal Act goals and recognizes the benefits
of the development of hotels and other visitor facilities.
Yet, at the same time prohibits hotel, motel and restaurant use
on the State Beach.
Indeed, Proposition "S" and Proposition HZ" favor
local concerns of the City of Santa Monica over the interests
and needs of the region and the State in conflict with the
California Coastal Act and general state law.
with respect to Agenda Item 8C, Pacific Beach
Development Limited Partnership objects to the extent the
emergency ordinance would restrict or apply to the development
project at 415 Pacific Coast Highway for all the reasons set
forth above. The Development Agreement is valid and
enforceable and the project may be developed pursuant to the
Agreement limited only by the height restrictions provided
within the Agreement.
n?~~-4
l~OWARD B. MILLER
HBM:mir/5683c
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