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SR-401-001-03ATTACHMENT C HCD Correspondence (w/o attachments) Electronic version of attachment is not available for review. Document is available for review at the City Clerk's Office and the Libraries. 57~~~TE 4F. C.SLSF4BrllA-BSiS[1ESS~TBANSL'4BT_ATION DEPARTIVIENT OF HOUSING AND Division of Housing Policy Develop I S~0 Thini So-eci. Suite -730 n n a S.icr.~~nenlo, C' 4y 9a 252-2fr5 i w.hcd. ~:n. rov August 3, 2001 DEVELOPMENT Ms. Suzanne Frick, Director City of Santa Monica Planning and Community Development Department 1685 Main Street, Room 212 Santa Monica, California 90407 Dear Ms. Frick: KF.: Review of the City of Santa Monica's Draft Housing Element _(jK \Y uA V IS t~~ Ymnr nVS~'G qw. : ~. 3r'~,' 4 1' :w 3G~~''yF ~Y oEVE`' CORRECTED COPY Thank you for submitting Santa Monica's draft housing element, received for our review on June 6, 2001. As you know, we are required to review draft housing elements and report our findin~s to the localitv nursuant to ('Tnvernment Code Section 65585(bl. ~___ _ _ r _.i.~_._a L_. ._ ~_1_~L..~„ ., ~A,..f.._.." . ]~l~ ~.r,, v,...,..; ~ar,..-..,,..- nrt~ T,i,..-1. u„FF..-..,T, vui icVic"w rVa~ ia~uiiaicu uy a~cicj'u~iic ~vuicicu~c wiui iv~~. nn~ci~ rva~iici, ivu. iviain iwi~,~.n~. and Mr. Paul Silvern, the City's consultants and Ms. Laura Beck, Ms. Susan Healy-Keane and Mr. Jay Travino, of the City's staff on July 31, Z001. Pursuant lo Government Code Section 65585(c), this Department has also considered comments about the City's housing element from Mr. Christopher Harding of Harding, Larmore, Kutcher and Kozal; Mr. Craig .iones of JSM Construction, Inc.; and Mr. Howard Jacobs of Calstar Equities, Inc. While the element provides much information about the City's housing needs and resources and documents recent increases in the development of new units in Santa Monica, revisions to the draft element will be necessarv to comnlv with State housing element law (Article 10.6 of the Government Code}. Specifically, the Santa Monica should analyze various regulations as potential constraints tl.,. ..... ....1 ,1,...,.1,.....,.,.....a .,F 1..,_....:...,! F .. .,I1 : o lo.,ot~ iiYvii u~c iuaiiiiciiaii~c, iiTij~ivv~iiiciii, auu ucvcivYiucu~ vi ii~uaiiig ivi aii iiiCviTi~ i~r~m. For your information, ~ve have enclosed a bnef description of ne~v and existing housing and community development programs administered by this Department along with funding levels for the current fiscal year. ~Ve are pleased to rcport a historic increase in housing funds available through Nf'Tl Tnfnrmatinn nn thece nrnaramc inrlnr~inv rPrantlv rPlPaseri Nnlices nf Fnn~lino Availahilitv --~.~. ~__"__--_`-"-- _" `---"- r-~~'_....., ----'.___--a ------'v --'--"-- - "'----' -- - °------a ----------v (NOFA), has been posted to our website. Please consult our homepage at wwu~.hcd.ca.QOV for new pr~r;rdrn iiliurmaii~n. ~~~~' re~ Ms. Suzanne Frick, Director Page 2 We hope our comments are helpful. We are willing to meet in Santa Monica with City staff to assist in revising the housing element. If you would like to schedule a meeting ar have any questions, please contact Robert Maus, of our staff, at (916) 323-3180. In accordance with requests pursuant to the Public Records Act, we are forwarding copies of this letter to the persons and organizations listed below. Sincerely, ~~ 4 ,c~_ ~' ~t~i~// Cathy E reswell Deputy Director cc: Karen Warner, Cotton, Bridges & Associates Mark Hoffinan, Cotton, Bridges & Associates Laura Beck, City of Santa Monica Susan Healy-Keane, City of Santa Monica Jay Travino, City of Santa Monica Paul J. Silvern, Hamilton, Rabinowitz and Alschuler, Inc. Howard A. Jac.obs, Calstar Equities, Inc. Craig D. Jones, JSM Construction, Inc. Chris Harding, Harding, Larmore, Kutcher & Kozal Carlyle W. Hall, Hall & Phillips Law Firm Fair Housing Council of the San Fernando Valley Mark Johnson, Legal Aid Foundation of Los Angeles Dennis Rockway, Legal Aid Foundation of Long Beach Stephanie Knapik, Westside Fair Housing Council Mona Tawatao, San Fen~ando Va11ey Neighborhood Legal Services Mihn Tran, lnland Counties Legal Services David Booher, California Housing Council Jonathan Lehrer-Graiwer, Attorney at Law Ana Marie Whitaker, California State University Pomona Joe Carreras, Southern California Association of Governments Won Chang, Attorney at Law, Davis and Company RUG-~3=-28e1 12~32 HCD 9~6 S~'t 2b4J r.u~.i~ ~!~; ac' APPENDIX ~i City of Santa Monica The following changes wou[d bring Sattta Monica's housing element into compliance with Article 10.6 of the Government Code. Accompanying each recommended change we cite the supporting section of the Govemment Code. The particular program examples or daca sources listed are suggestions for your use, A. Housing Needs, Resources and Constraints 1. Anulyze poFential and actual governmentul constraints upon rhe mainte~ance, improvement, and developrneni of housing for all income levels, including land use controds, fees and exactions and proeessing and permit procedures (Section 65583(a)(4)). Santa Monica documents its ability to accommodate its Regional Hausin~ Needs Assessment (RHNA) through a combination of units approved or constructed since the beginning of I998 and an identi~cation of adeqaate sites, with appropriate zoning, sufficient to accommodate its rema;n;ng RHNA of 255 very low-, 164 low-, and 232 moderate-income households. While it does not appear that existing development regulations will act to cons~train the City's ability to accommodate the RHNA for alt income levels duri.ng the 200Q-2005 planning periad (much of the residential approvals and construction for the current planning period apparently occurred before the implementation of most of the development regulations mentioned below); Santa Monica must analyze the impacts of its la»d-use regulatians upon the maintenance, improvement and development of housing for all income levels in Santa. Monica. The RHNA is only a minimum of new constr-~ction to he accommodated; regulations that act to delay or limit housing and add additiona] costs io housing must be analyzed as potential consLraints. The City shouid analyze not only the individual impacts of each regulation that couid potentially constrain the maintenance, improvement, and development of housing, but also the cumulative impact. Regulations that should be analyzed include, hut are not lirnited to: • reduced building heights, floor-area rarios and densities in muttifamily districts (Ordinance 1977}, •]imitations on simultaneoas construction projects within a SOQ foot radius during a IS month periocl (Ordinance 1984), • restrictions on the removal of existing units from rent control law jurisdiction, . chareges in the age that structures become subject io the jurisdietion of the I,andmarks Commissian (Ordinance 1977), • new square Pooi threshold for seebjecting projects in certain commercial districts to a discretianary review before the planning commission and/or the city council, including the implications of extending this regulation to the remaini.ng commercial distri~ts in the City (Ordin.ance 1999}, • design permit requirement for condominium projects, . Ihe timeliness of the City's processing of develapment applications within statutory time limits of the Permit Streamliuing Act, CEQA and Santa Moniea zoning code, • possible denial of projects complying with govennmentai regulations but subject to discretionary review, and • increased Affozdabte Housing Fee for condomutium projects (Resolution 9498). ~ _ AUG-~3~-2091 12~33 HCD 916 327 ~645 r,G~~~~ ; ~~ _ ,~ ~~ 2. Coastal jurisdictions aze required to quant~: I) the number of new units approved for construction within the coQStaI zone since January 1, 1982, 2) the number of low- and maderaze-income unirs that have been required to be provided in new housing developments within the coastal zone or wi[hin three miles of the coastal zone, 3J) the number of ex~sting units occupied by low- and moderate-income units that were authorized to be converted or dernolished irr the coastal zone and 4) the number of units required to replace low- and moclerate-income ur+its that were aurhorized to be converted or demolished in the coastal zo»e and to identify the locaaion of the replacement units (Government Code Sectton 65588 (d)(1-4). Santa Monica provides some, but not all of the required data. The ~lement should be zevised to include ihe necessary infozmation. S. Housine Pro~rams 1. The housing elernent shall contain progrums, which "address, and where appropriate anc! legally possible, remove governmental constraints to the maintenance, amprovernent, and development of hoarsing" (Section 65583(c)(3)). As noted above (A.1), Santa Monica's element requires a more thorough description and analysis of the City's land-use controls as potential governmental constraints. Depeoding upon the results of that analysis, the City may need to add programs to remove or mitigate any identi~ed constraints. Additionally, given the number ofnew City actions imposed since 1998 that regulate development in Santa Monica, the City should revise and/or give high priority to strengthening and implementing the following programs: Pro~rarr~ l.a: The periodic review and potenrial revision of housing zoning and development regulations necessary to pmmote residential development in non-residential distriets shouid occur annually and not be delayed until fiscal yeaz ~883f~69=t. r'~ U~~''~ -tv Z.o6 2~~~ ~ Program l,b: T}vrd party comments and the housing element both indicate that 5tate and local deadlines for processing development applications are not always adhered to. The City needs to commit to promptly remedy this appazent problem as opposed to reviewing and madifying procedvres as needed to comply urith CEQA and permit streamlining requirements. , Program 7.f: The City Council enacted Ordinanee 1984 (limiting sinauJtaneous construction of new residential projects within some zones to no more than one withia SQO feet of another during the same 15 month period) in March 2000. Program 7.f corcunits the City to monitor the rate of development activity in multifamily districts and repori on constnLCtion applications annually. The First report should be completed and the data summarized in the constrainks analysis described in A.1, above. ~ __ __ __ AUG-~~-2R~1 12~33 HCD ylb SG( Gb4J r.ai~~~ . ' ,~ ~Y ...:~;,,~ _-~ JSN1 429 SaataMonieaHl~d. #270, SaaraMonica, CA 9040I (3]0) 260-1236Fax (31~ 260~{946 J,,~ s, zoa~ Escsimile 8t U.S. lV~ail: (91~ 3Z7-2643 Ms. Cathy Creswe~l Actiug I}eputy Direcxoc Depafiment of Housing & Couimunity Development State of Califomia ` 1800 Third St., Itoom d30 Sacramento, CA 94252-2053 Re: Ctity ofSanta Monica's Draft Aor+singEleineAr bear Ms Creswell: I am submitting this lettts to commeat upon tt:e City of Santa Monica's dsaft of iu Housing Sieme~s, which your Depertment is currently reviewing_ I am the President of JSM, Inc., a company tbat develaps multi fami~y rental. hous~ng in south~ern Califoruia. Most of our projects have been built in Sanca Monica, whrxe we tpaintain our oflfices. Since 1993, JSM sad related companies have built 8 ptojects, wbich includa 232 units in Santa Monica. We also have an additional 13 projcets with 6~6 units cuirendy under CoriSttucaon or iII vetious stages of the approval ptoeess. All of these projects are located in Sama Moniea's downtown. Although JSM is a"for profiY' developa, we bui~d both market-nte a~nd a,ffardable bousing. Of the 838 units we have built or are in the process of developing, 260 units arc deed restricted as affordable units. In developiag at~ Sarzta Monica projecis, we bave taacen advaatage of the City of Santa Monica's varioas incentives for new hovsing. The most signi.ficaat such incentive is the r'sgb~t to obtaia a besie planaing approval quickSy thrau$h a aon-discretionary process lanown as Administ[ative ApprovaL Tl~t availability of this process !~s givea us a cotnpetitivc advautage in comparison to eommercial developers, who otherwise would be able to pay aiore for ava7able Iand thea a resideatial developer. Our abiliry ta build addiuonal bousimg in downcown Saata Monica is threatened by a~ least two factors- First, the Admimistrative Appraval pracess is takiug loa~er aad Ioager, Altfiough the Zonin.g Ordinance reqnires a final decisi~ on an A,dministrativc Appnoval AUG-~3-2001 12~33 HCD 916 32'r ~bUJ r.~o~ii . ~ ` M5. CS[hv Cro5WCI1 ~`~ . ~ JuIY $, 20f11 ~ _ pa.ge 2 uf 2 application within sixty days of a co~apleted applicatsoa, t~e City ttoa takes fo~a montbs ar longer w complete this process. Sxond, the City Council bss d'uected its staff to look at teducing the development chre,abolds doamtocv~ whieh wauld force vizh,ally all new honsiag int4 a loag aad very unce~rtain development ~view process_ This p~ssble change, which the (~ty has akeady enacted for mast of its com~mercial distiic~, noa talaea between one and two years to secu~e a basic plaaning appro~-a1- Such delays would make it very difficul,t if aot impossiblc for our Srm and others l~ce us to compete successfully with cammercial develapers for th~ acarce land t~et is availabte. I 2sk that yot~ De~artmcnt F~aY sPecial atteatioa to t~e Ciry's housmg in its cominerciai zoning districts. Atthovgh J3M and other firms hava been successful receNly ia developing hoasing ia cammercial zones, I am concetaed tbat the Gyty is in the proeess of elimiaatimg the key inr.entives that have made such housing passible (inohedi~ag the aace-expeditiaus Admip3strative Approval process). 5anta Moaiw condnues to have a gz+eat deal of untapped pot~ential for new hoasing. Tn addi6on, to ifs downtown; mixed-use projeets on Sa~ Monica's commercial banlevards {e.g., Wilshire Boulevard and Santa Monica Boulevard) would be possible with the right pacIcage of zoning iaemtives. The Ciry coutd alsa allow housing ia its LMSU and Ma dist~ic~s, at least on appropriate sites, Santa Monica could dn a much better jvb af encouragiag housisg thau it is presendy. Sinee the City adopted its Housiag L~7ement severai yesrs ago, those of us ~c+l~o build honsin$ ia San~s Monica have wimessed a lot of "city baekslidiag" as new reg~ila6ons and praodces he,ve been put in place that maice it more and more diffscult to build hou,simg here. I hope that your Departmeat will, ia the course of rcviewing Santa Monica's ~ of its Honsmg Elcment, do wbat you can to reverse this tread. Sincerely, ~ ~. Ltaig D. J es CD7rpslfc cc: Copy Chtistophes M. Harding r RUG-~~-29~1 12-34 HCD ~ ~ ~~ CS~SL'c~ll $'~J.t'i.~ESr I11C. c 42~ Eroadway. Suite 101 ganta MonicB. ~+ 909f11 (310) 943-73D0 PRX: 943-"~301 July 12, 2oa~- 'Via Face3~le ~~live : (916} 327-2643 Ms. Cath'y Cx~~well Depucy ~ixector Develop~~nt 'Departcaent of Eiousin5 & GOnA°un}ty State of C~~-~-t° ~am 430 1800 Third. 5t-, g4Z52-2453 SaCramento, CA ~Q: ,5anta Manica's Dratt 13ousing' ~x~~t 0 z x m ~ ~ a 0 a Dear Ms Cxeswell: z am wsiting wit~s ~espeeC C~o the City ~f being reviewed byaft of iLS upda~ed houaiz,g el~ment currenc~.Y your agency• As a builder and aperatar of ren~al housing in Santa Klonica, as~d as a 8anta Moni.ca residenc who also maintains mY offi,ce here, I am vexy familiar with 1oca1 housing practiCes. S am also an attorney with a w~=kin9 }movrledge o~ housing elementi law- I am especial.ly con.cerned with the City~~ inabili~y to meet ~~g legal obligations to procesa plantl.ing applicat~.on.9 in a timely maaner• T currently laave two applications pendin5 for mi.xed-use projects an Main S~reet whioh wi11 include 133 reatal hcausing ~uaztis. These two appJ.ications were deemed complete more ~han ?4 monCk~e ago, aad yet tk~e City planners have not evezz ze~.eased the drafC FIR for public reviGw. TYtis has caused me subsCalstial financia7. hardship and loss, as I have had to elose escrow be~ore seeuxi~.g my laasic pJ.anning entitleMenta and am now incu~ring carryiz~g cost,8 whiCh exDe~d $']5,00o per month. Cicy planniag staff is now prpjectz~g' ~ City Plannzng Cammission hearillg i:; Oetober (ox Ie ~th5 afCeY~ these applications were deerned comple~e), notwita9caa.c.- ing a Cit~r zanirig requirement chat che City render a fina~ decision ozx my applications ~~ncl"*~~ ~ any appeais} no later than 12 mantha aPter they weze deemed cornpl,ete. 916 s~r Gb4J ~.G, yy RUG-0~-2001 12:3q HCD . ~ 916 .5~'f ~b4J r. ir~, i~ CatYzy creswell '_ Ju1X 12, 2001 Page 2 `These delaye have occurred despire the faat that I have assembled a vexy ~owlaflgreable pzoj~ct team (including ~.n. architecC and legal counsel very fam3.liar with loCal, pzacricas), I haae been very diligent in respOnding to City r~que9LS ~ox informatiox~, and T_ have ragularly monztored zhe City's grogxess (or 7.ack tbereof) in pxocessiag' mY applicatioas. At tihi.a point, howevex, Y run the very real risk of losing ~hese properties thzough fozecJ.osure because oE City delays. Ironically, z decided to ~vzsu~ these projeets in respons~ to City polia~r enc~auragang n~W housing ~,n the Cxty' s coam~arcial zones. i also seli.ed os~ CiGy assurances that the ETR would be finished in time for a~'ebruarY' 2001 PlanniA~ Cotaraission hearing. At ehis poiat, hawever, t hawe nr~ conficience that the City :~5,11 me~r. its pro-jected October Planning Commisszos~ hearing date. The City has adva.sed us that these delayp are due to peXforrnance difficulties vsith their environmental con,aulcant. yet I knaw that zn tbe 1aeC few year~ the City has rarely cvmpletea~ an EIR on ticne. Thus, despi~e th~ Ci~~'s claims of suppart for houaing in commercial ~ox~rig districts, lengthy delays in City permit processixsg have become $ ma7~X impediment to such new hauszng- ~he pxobl,e,ns I am easperiencirus with crcy Main 8treeL projec~s are evidence af ~. muck~ 1arg~r problem, Vp until sevexal years ago. the Ci~y wae malcing real pxogresa in eslcourag~.ng nevo housing in its eommezCial zones. That, ir~ fact, is what attracted rne Sand severa7. other housing buildex~ I know) ~c explore building new bousing in San~a Monica. Un~arCunately, it now appears obvious that the CiLy has zevexsed caurse arzd is rio longez committed Go encoufaging aew housing. I aon~inue to be committed to buildiAg ksigh quality°, e~vizonn~ental].y sensitive housing and mixed-use pxoject~ in existing uxhaz~ areas. {7uite frankly, laowever, I am not inGerested in building aay furthe~ in Santa Mozii.ca given my un£ortunate Main Streez~experience. As I was one af only a handful o~ builders willing to make a substan~ial eommitment ~o housing development ia Santa Maniaa over the Z2st few years, unleas the City implements meanix~gfui refvrms to its housing regulations and procedvres that eriaourage aew Uausirig, Y know ~hat Saz~ta Moaica's late 199Q°s impravement xn xcs 2aausing psoduction tr3ck r~oord will prove aberrational, as RUG-e?-2@p1 12:34 HCD . 916 327 ~b~s r.i1~il ~;~ ~athy Cz'eewell ~ ~.~ .7`tzly 12, z401 - Page 3 tihe City return~ to its historic °nv gxrn~kh° Pattezu of tl~e past 25-3a years. The pYOOf of th~ City's past "no-yrcwtl?" palicia~ anci pract3cea is the decline zn Santa Monica'a pogulation in tihe past 30 yeaxs irom more than 88,0~0 to only approxitnately 84,QU0, while moat othez areas af th~ State have experienced aubstanti.31 populatiozi gz'owth. In con~lusion, I ask your agency~ to look care~ully at the City~s aetual prac~iaes and new regulations *-hi~h di~courage new housing nonstruction_ In Che pas~, the Cit~ Y~as limited it~ °anti-housing" ~aolici~s ax-d practices to its Xesider~.tia~. distsicts. xhese policies and practices have, unfcrtunaeely, recently crept into the City's commercial districts, even thcngh. Gha ~i.t,~~~9'?"ees ~~t its commercial clS.stricts have th~ greazest capac~ty i"or n~w houaing. Ahs~~lt &ex5.ou~ oaersight by your agesscy, there is no reason ta believe that'the City will take its housing produation obligatiorss serinuely. Sincerely, owa . Jacnbs Pres d t ca: Rabert Maus, hSgr. Aiwision of Housi.xu,~ Policy DeQt. TOTAL P.11 PlanrF ~ W& Community ~evelopment Department ~ ~~ Planning Division 1685 Pdlain Street PO Box 2200 _. ;..~w, Santa Monica, California 90407-2200 c~~y ct ~at~f~ Dlooiic~," October 4, 2001 Robert Maus, Manager Division of Housing Policy Development Department of Fiousing and Community Development 1800 Third Street, Ro~m # 430 Sacramento, CA 95814 Re: City of Santa Monica Draft 2000-2005 Housing Element Dear Mr. Maus: This letter transmits the proposed revised sections of the Draft 2000-2005 Housing Element of the City of Santa Monica and Technical Appendix #2 for your review. In the letter from Cathy Creswell dated August 3, 2001 and clarified during our September 5, 2001 meeting, you indicated that additional analysis and revisions to the City's Draft 2000-2005 Housing Element were required. The areas requiring further analysis and or information were as follows: • Analyze the cumulative impact of City regulations to determine if they act as potential or actual govemmental constraints upon the maintenance, improvement, and development of housing for all income levels. m Amend the existing summary table in the Draft Element to provide all required statistics regarding construction, conversion and demolition of residential units within the coastal zone since 1982. o Prioritize implementation ofi the first item in the action plan for Program 1.a. • Clarify the City's commitment to implement the fourth item in the action plan for Program ~.b. + Provide a copy of City's annual report produced by the Housing Division on new housing construction. • Provide updated data to reflect the current status of pending housing projects and to include new housing projects that have been submitted since the earlier draft of the Element was prepared. You indicated that if the City provided this additional information and undertook the additional constraints analysis, and if the conclusion vvas that none of the policies, programs and regulations, were founc! to operate as an actual constraint tel: 310 458 8341 ~ „~~ on the production of new housing, then HCD would be able to determine that the City's EPement is in compliance with State law and could be certified as such. The City and its consultants have completed the required analyses and have made the following revisions to the proposed Draft 2000-2005 Housing Element: • Chapter II, Section C. Housing Stock, Subsection 7 regarding Coastal Zone Housing has been revised to include all available data on units built, demolished and converted in the Coastal Zone from 1982. In addition, data on affordable units demolished or converted and affordable units built in the Coastal Zone and affordable units built within three miles of the Coastal Zone from 1982 until 2000 is presented in the revised Table II-21. (Attachment A) • Chapter II I, Section C. Additional Constraint Analyses has been revised to address the degree to which eight City policies, programs and regulations, or features of them cumulatively operate as actual or potential governmental constraints on the production of new housing. (Attachment B) The technical analysis that supports these conclusions has been substantially revised. (Attachment C) A brief summary of the new analysis can be found at pages 9-10 of Attachment C and a more detailed discussion begins at page 31. (Attachment B and Attachment C) • Chapter IV, Section C. Compliance with the RHNA Allocation, Subsection 2 regarding credits for new housing production since January 1998 has been revised to reflect the status of pending housing projects as of August 2001 and to include units for which applications have been submitted since publication of the Draft Element through August 2001. (Attachment ~) • Chapter VI, Section C. Goals, Policies and Programs, Program 1.a. has been revised to reflect that the implementation time frame for the first item in the action plan regarding promotion of residential uses in non- residential zoning districts is "ongoing". (Attachment E) o Chapter VI, Section C. Goals, Policies and Programs, Program 1.b. has been revised to clarify the action plan regarding City procedures for processing CEQA documents. (Attachment F) As we discussed in our September 5th meeting, we will be taking the revised Draft Element back to the Planning Commission for review. The public hearing has been set for November 14, 2001. We appreciate that you will fry to provide us with your comments within the next 30 days so that we can adhere to that schedule. Based on the enclosed revisions, we are confident that you will determine that the City's 2000-2005 Fiousing Element is in compliance with State ~3 ~k. .._.-ro.-x.~ ".v;_.~V law and merits NCD certification. The Santa Monica City Council has not yet reviewed the proposed revisions and is scheduled to take action on the revised Element in December 2001. Please, do not hesitate to contact us by phone, fax or e-mail should you require any clarification. Sincerely, J M. Trevino, AICP anning Manager cc: Christopher M. Harding Harding, Larmore, Kutcher & Kozal {with attachments) Craig D. Jones JSM Construction, Inc. (with attachments) Howard A. Jacobs Calstar Equities, Inc. (with attachments) 3 Planning & Community Development DeparimenY -.-____...,,.„.. Planning Division 9685 Main Street PO Box 2200 _..K,.,.__ Santa Monica, California 90407-2200 . IIV U` .~~il~3t 1~'~06g1i.~l;, November 28, 2001 Robert Maus, Manager Division of Housing Policy Development Department of Housing and Community Development 1800 Third Street, Room # 430 Sacramento, CA 95814 Re: City of Santa Monica Draft 2000-2005 Housing Element Dear Mr. Maus: This letter transmits the proposed revised sections of the Draft 2000-2005 Housing Element of the Ciry of Santa Monica and Technical Appendix #2 for your review. These sections replace and supercede the submittal dated October 4, 2001. As we discussed over the telephone today, the Santa Monica City Council is scheduled to take action on the revised Element on December 11, 2001. We would appreciate receiving your comment letter by December 5~h so that the City and the public will have adequate time to review it prior to the December 11t'' public hearing. We understand the unique time constraints that exist within your office and truly appreciate your efforts. Immediately after the City Council takes action on the 2000-2005 Housing Element, it will be re-submitted to your office for certification. As you know, the City has an aggressive program to develop affordable housing. Housing Element certification prior to the end of the year is critical to these efforts. According to the City's Hosing Division, there are at least two funding applications (The Time Extension for Redevelopment Tax Increment Funds and the Multi-Family Housing Funds) that will be jeopardized if the City is unable to meet the end of the year deadline. We appreciate the efforts of you and your office to expedite the processing and certification of the City's 2000-2005 Housing Element. It has been a pleasure working with you, Rob. Sincerely, ~ J y M Tr~o, AICP ~ Py nning Manager I`~/ tel: 310 458-8341 ~* cc: Christopher M. Harding Harding, l.armore, Kutcher & Kozal (with attachments) Craig D. Jones JSM Construction, Inc. (with attachments) Howard A. Jacobs Calstar Equities, Inc. (with attachments) 2