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SR 11-22-2016 4A Ci ty Council Report City Council Meeting : November 22, 2016 Agenda Item: 4.A 1 of 34 To: Mayor and City Council From: David Martin, Director, Planning and Community Development , Planning & Community Development, City Planning Subject: Local Coastal Program Update Study Session: Overview of the Community Outreach Process and Proposed Poli cy Direction for the Land Use Plan Recommended Action Staff recommends that the City Council review and comment on the proposed policy direction for the City’s Local Coastal Program Land Use Plan update and direct staff to proceed with developing a draft LCP Land Use Plan for public release. Executive Summary This report discusses the proposed policy approach to updating the City’s 1992 Local Coastal Program (LCP) Land Use Plan (LUP). The update project began in September 2015 and has proceeded with a c ommunity outreach process, and research and analysis of coastal policy issues relevant to the seven policy areas required by the Coastal Act: 1. Access; 2. Recreation and Visitor -Serving Facilities; 3. Environmental Quality; 4. Scenic and Visual Resourc es; 5. Sea Level Rise and Coastal Hazards (new section based on recent Coastal Commission direction); 6. Cultural Resources and Historic Preservation; and 7. New Development (includes policies for specific LUP subareas). The report summarizes the pub lic outreach process that staff has undertaken in order to educate and learn from the community about coastal issues such as Sea Level Rise, protection of endangered species, and encouraging multi -modal access to the beach area to ensure that Santa Monica’s popular beach and Pier are maintained for and protected from their extensive visitor use. The Planning Commission’s comments from their October 5, 2016 study session are also summarized. Following this Council study session, staff will prepare a draft Land Use Plan for public release early next year. A recommendation from the Planning Commission will be required prior to Council adoption. The LUP will then be submitted to the California 2 of 34 Coastal Commission for certification. It is intended for this p rocess to follow Council’s decision on the Downtown Community Plan in order to incorporate DCP policies for the portion west of 4 th Street that is within the City’s Coastal Zone. Key Questions Council should review, comment and provide direction on staff’s approach, which has been informed by Planning Commission direction, on key policy issues raised by the LUP Update, including: 1. Coastal Access: a. The multi -modal approach to coastal access that focuses on providing automobile, transit and active tran sportation options to help people visit the coast using the supply of parking facilities located throughout the Coastal Zone, including beach lots, Downtown, the Civic Center, and public parking around Main Street, with improved wayfinding both physical an d electronic. b. The approach to future planning to enhance the seaside recreational environment of the Santa Monica Pier with new activity supported by multi - modal access, some reduction of the Pier parking area and TDM programs in place of requiring add itional Pier activities to provide parking. 2. Recreation and Visitor -Serving Facilities: The reformulation of the low -cost visitor accommodation replacement fee; 3. Scenic and Visual Resources: a. The removal of two listed “scenic view corridors” desi gnated in the current LUP that do not appear to offer significant coastal viewsheds (the Santa Monica Freeway and the Third Street Promenade). b. Exploration of other scenic viewpoints as suggested by the Planning Commission and more specific identificatio n of the public view corridors to be protected. 4. Sea Level Rise and Coastal Hazards: A phased approach to adaptation strategies and development restrictions based on measurement and documentation of actual sea level rise and the anticipated life span of proposed projects. This phased approach would create thresholds and “trigger” points at which the City would need to adopt more definitive standards, requirements and adaptation programs applicable to affected coastal areas with favor for lower - impact de terrents such as dunes rather than sea walls; 5. New Development: The approach to adjusting LUP maximum allowable development parameters (i.e. height and density) to be consistent with the LUCE. The map below of the City of Santa Monica’s Coastal Zone is provided for reference. 3 of 34 Background The Local Coastal Program and the City of Santa Monica A Local Coastal Program (LCP) as required by the California Coastal Act is comprised of two components: the Land Use Plan (LUP) and the Implementation Plan (IP). T he LUP describes the planning area’s land use and environmental conditions, identifies issues, and contains land use policies and maps that complement adopted City policy and satisfy the intent of the State Coastal Act. The LUP must comply with the Coastal Act and maintain consistency with the General Plan. LUP policies take precedence within the Coastal Zone. The IP, also sometimes referred to as a Coastal Zoning Ordinance, is a zoning document that contains the standards with which development in the coa stal zone must comply. Once approved and certified by the Coastal Commission, most of the authority to issue coastal permits for new development would be transferred to the City of Santa Monica. The Coastal Commission would retain permanent coastal permit jurisdiction over development proposed on tidelands, submerged lands, and public trust lands, and would also act on appeals of local government coastal development permit decisions within a certain area inward from the coastline. The Coastal Commission als o reviews and approves any amendments to previously certified Local Coastal Programs. The City adopted its current LCP/LUP in 1992, but has never adopted an Implementation Plan, with the result that currently all required Coastal Development 4 of 34 Permits must be issued by the Coastal Commission after City entitlements are approved. Since 1992, some substantial changes have occurred in regard to conditions in the Coastal Zone, including the arrival of the Expo Light Rail Line, substantial implementation of the Civic Center Specific Plan, revival of the Santa Monica Pier and construction of the Annenberg Community Beach House, as well as other public and private development. Also, the City has amended its General Plan through the Land Use and Circulation Element (LUCE), Historic Preservation Element, Open Space Element and Housing Element. In this LCP update, the Coastal Commission is also particularly interested in ensuring that its new programs and policies are incorporated, especially those related to climate change and sea -level rise. Project Grant Funding The City has received two grants from the Coastal Commission to update the LCP Land Use Plan and develop an Implementation Plan. The first grant, for $225,000 was authorized by Council on June 24, 2014, an d awarded by the Coastal Commission in September 2014. The project got underway in September 2015 with the hiring of a grant -funded Assistant Planner, followed shortly thereafter by Council approval for a contract with Dudek, Inc., to provide consulting s ervices on October 27, 2015. Although initially the project scope aimed to complete both LCP components, the scope was revised to complete and submit the LUP for certification before undertaking the IP process. On May 10, 2016, Council approved an applic ation for a second Coastal Commission grant. In July 2016, the Coastal Commission awarded $100,000 to develop the Implementation Plan following LUP adoption and certification. Planning Commission Comments On October 5, 2016, the Planning Commission held a study session and was generally supportive of the staff -recommended approach to the LUP update including ensuring consistency between the LUP and adopted policy documents. The Commission also shared comments about some specific issues including: Sceni c View Corridors : Commissioners asked for clarification as to how scenic 5 of 34 corridors are defined and asked staff to review additional potential vantage points and view corridors, including the Main Street Bridge, Tongva Park viewpoints, Ocean Park Blvd./4 th Street Bridge and the Colorado Esplanade for potential inclusion in the LCP. Access and Mobility : Commissioners stated agreement with policies that focus on a multi -modal approach and encouraging shared use of parking. In particular, there was interest in maximizing public use on weekends of available private parking facilities that are in easy walking distance from the beach. Sea Level Rise Adaptation : Commissioners stated their concern about how LCP policies would deal with projections of a changing coastline and impacts from coastal storms. The Commission was generally favorable toward the phased approach in which policies are triggered based on the proposed project’s expected life span and as actual rise in mean high tide line occurs. The Commissi on emphasized interest in ensuring that any parameters for new development anticipate adaptations for sea level rise. Low Cost Visitor Accommodation : Commissioners discussed the fee imposed by the Coastal Commission for removal of low -cost visitor accomm odations and agreed that it should be reviewed and updated. Mello Act: The Commission requested clarification regarding replacement housing provisions applicable to the Coastal Zone and whether incorporating the requirements of the Mello Act into the L UP would be appropriate. Discussion Project Outreach Between January and July 2016, the LCP planning team undertook an outreach strategy that was designed to inform the public about coastal issues and the LCP’s role in planning to manage sea level rise imp acts. Two workshops were held: Santa Monica's Coastal Area in the 21st Century (2/29/16): Introduced the purpose and timeline of the Update within the context of the history of Santa Monica’s coastal uses and planning efforts. Adapting to a Changing Coastline (4/13/16): Experts explained how climate change is already leading to rising sea levels and the outlook for Santa Monica, with some discussion of adaptation options. This workshop was recorded by CityTV and a link to the video is available on th e LCP project webpage: http://www.smgov.net/Departments/PCD/Plans/Local -Coastal -Plan -Update/. Between January and May 2016, staff presented an introduction to the LCP planning process to the following neighborhood, business and civic organizations: Plan ning Commission Pier Corporation Board Task Force on the Environment Disabilities Commission Landmarks Commission Commission for the Senior Community DTSM, Inc. 6 of 34 Neighborhood groups in conjunction with presentations on the Downtown Community P lan: North of Montana Neighborhood Association and Ocean Park Association Recreation & Parks Commission Kiwanis In addition to this outreach to stakeholders and community members who participate in the civic process, it was felt that the issues of the LCP and the opportunity to educate the public about the environment and a more sustainable approach to beach area planning and access are so compelling that other creative outreach tools are needed. In response, staff developed three additional opportunit ies to reach people where they are and engage them on the issues of sea level rise, multi -modal access and the environmental sensitivity of Santa Monica’s beaches: Pier Visitor Survey : Intercept survey of 632 people on the Pier during 4 weekdays in July focusing on travel patterns, parking locations used and other coastal points of interest visited (See Attachment A). Survey results support a multi -modal planning approach to providing public access and services in the coastal area that is already shifting the emphasis from automobiles and beach parking to support for other modes. Contrasts between the responses from local, frequent visitors, compared with out -of -town and first time visitors, point to the need for wayfinding signage and on -line tools to he lp people gain an understanding of the proximity of the Pier to downtown, the Civic Center, Main Street and Venice to help them find their way to and around the coastal area. Owlized on the Pier: On October 27 th 2016, two augmented virtual reality viewf inders (one ADA accessible) presenting scenarios that visualize the scientific findings of the Coastal Storm Modeling System (CoSMoS) study were installed on the Santa Monica Pier. The interactive tool, called “The Owl” begins with a present day scene look ing north of the Pier, followed by the same scene showing the coastline with two meters of sea level rise. Scenarios of major (100 -year) storms are then projected on the evolving coastlines. 7 of 34 The Owl conducts a survey that gauges users’ level of awarenes s and concern about sea level rise and educates about possible adaptation measures to deal with coastal storm surges that are inspired by natural defenses like sand dunes. The Owl will remain on the Pier for two months and is also available through a phone app. Staff is working with educators and USC Sea Grant to incorporate the Owl as an educational tool in school programs related to climate change. This project has been a joint effort with the City’s Office of Sustainability and the Environment’s Climat e Action and Adaptation Plan outreach program. Beach Nature Walk to the Snowy Plover protected area : Staff participated in an August 2016 visit, co -sponsored by the Audubon Society and the SM Library on the Beach program, to observe the Western Snowy Plo vers, who are currently roosting on the Santa Monica sand in the north beach area, including a fenced -off “exclosure” that has been provided by the City to attempt to keep out disturbances. The Western Snowy Plovers require sensitivity and protection from City maintenance staff and beach users alike while they spend the season at Santa Monica Beach. Staff then organized a second visit with the Audubon Society, bringing 20 community members to the beach on Sunday morning, October 16 th to observe this threa tened bird species’ enjoyment of their Santa Monica wintering home and learn about the City’s plans to strengthen their protection through the LCP. The Draft LUP will reflect comments and suggestions received from the community through the outreach progr am, and input from researchers and Coastal Commission staff in regard to policies that address future shore erosion and coastal storm forecasts. 8 of 34 The Big Policy Picture The State Coastal Act’s key objective is to preserve and maintain the coastline to prot ect its natural beauty and ecosystems and to ensure public access to the beach for recreational purposes. The Act recognizes that public access may appropriately be limited in situations in which there are conflicts between fragile ecosystems and public a ccess. It also provides that “public access policies of this article be carried out in a reasonable manner that considers the equities and that balances the rights of the individual property owner with the public's constitutional right of access.” With a n emphasis on maintaining coastal recreation that is accessible to everyone, the Act seeks to protect lower cost visitor and recreational services, including, to the extent feasible, lower cost accommodations. As a State statute, the Coastal Act takes p recedence over policies that may be established by a local jurisdiction. Policies established in the LUP are reviewed and require certification by the Coastal Commission. These policies then become the basis for the IP, which will be prepared following th e Council’s adoption of the LUP. The LUP, therefore, has the very important function of reconciling State and local policies in a manner that complies with the Coastal Act and achieves the City’s policy objectives established in the LUCE. 9 of 34 Santa Monica ’s land use and circulation policies are grounded in principles of long -term sustainability, both through the form and types of allowable development and through connecting land uses with transportation options to reduce dependence on automobiles. The Sus tainable City Plan, LUCE and all mobility and specific plan efforts applicable to the Coastal Zone have aimed to promote more sustainable practices and reduce the City’s carbon footprint. Zoning regulations and landscape & irrigation requirements have imp lemented these policies through development standards that apply to a variety of residential and commercial projects. The LUP builds on these policies with regard to Coastal Zone -specific matters that are not already covered by existing City policies. T he LUP divides the Coastal Zone into eight subareas, some of which are further divided into sections. Coastal Zone subareas facilitate the establishment of appropriate policies based in particular on the subarea’s proximity to the more sensitive beach and beach -adjacent assets. 10 of 34 The LCP planning team is coordinating with the work of the Downtown Community Plan (DCP) for compatible policy direction, as the central portion of Downtown (with 4 th Street as the eastern boundary) is located within the Coastal Zo ne. Since Downtown Santa Monica is located above the bluffs and out of sensitive habitat areas, it is not anticipated that special environmental policies to be developed for the LCP will apply to Downtown. However, issues related to visitor services and access, including provision of bike and pedestrian pathways and parking to meet the needs of those visiting the coast and arriving by car, do overlap with plans for managing development in Downtown. Likewise, Civic Center planning and proposed projects, p articularly those affecting the Civic Center parcels that make up the large surface parking area between Pico Boulevard and Civic Center Drive, are within the Coastal Zone and LCP policies related to access are also being coordinated with the projects bein g proposed and considered in the Civic Center. LUP Policy Approach The policy approaches discussed in this staff report will eventually be incorporated into the LUP policies in Chapter 4, which will become the basis for future coastal development permit (CDP) decisions. In the early preparation phase of the LUP Update, staff and the project consultants (Dudek) closely reviewed the City’s 1992 LUP, City policy documents and State Coastal Commission policies to identify the key issues for the 2016 update. T he review resulted in a framework that builds on the current LUP structure, includes guiding policy language from the Coastal Act (a standard in recently certified LUPs) and adds policies to reflect circumstances that have changed over time in the coastal area. Chapter 4 will be organized to address the seven policy categories of the Coastal Commission’s jurisdiction under the State Coastal Act: 1. Access; 2. Recreation and Visitor -Serving Facilities; 11 of 34 3. Environmental Quality; 4. Scenic and Visual Resourc es; 5. Sea Level Rise and Coastal Hazards; 6. Cultural Resources and Historic Preservation; 7. New Development. The following discussion summarizes guidance established in the Coastal Act for policies, changes that have occurred since the existing LUP was adopted in 1992, and the proposed approach in the LUP Update. Access Coastal Act Guidance Access policies in the LCP implement the Coastal Act’s mandate to ensure that development does not interfere with the public’s right to access the sandy and rocky c oastlines along the State shoreline. To the extent that the public relies on being able to reach the shore from inland points of departure, the Commission has generally associated this mandate with jurisdiction over transportation, such as provision of roa ds and parking. The Coastal Commission has traditionally looked carefully at any activity that might cut off a route to the beach or affect parking supplies on which visitors depend in order to access the beach. Conditions often include maintaining open p athways through a development and provision of parking that meets the needs of customers and employees of new development proposals. Changes since Existing LUP was Adopted Santa Monica’s roads and pathways to the beach area have been greatly enhanced si nce the 1992 LCP was certified. Improvements to coastal roads and pedestrian connections from Downtown and the Civic Center include the extension of Olympic Drive, the pathway between the end of Pico Boulevard and the beach pedestrian path, the Colorado E splanade, pedestrian bridge upgrades from Palisades Park, and the California Incline upgrade. All beach locations in Santa Monica comply with the Coastal Act’s mandate to make the beaches and ocean available and accessible for the public’s use and enjoyme nt, as evidenced by the 17 million annual visitors who use all points 12 of 34 along the City’s beaches. Last May, the Expo Line opened, bringing a significant new option for accessing Santa Monica’s coastal area. The Colorado Esplanade was completed at the same time, enhancing the arrival experience from the station to the Pier and beach. The completion of the project, and the City’s local street and sidewalk improvements and provision of Breeze Bikeshare represent a major step forward in the City’s goals to cr eate a more sustainable coastal area through a multi -modal approach that provides visitor access while addressing traffic congestion and ensuring availability of parking. Proposed LUP Update Approach LUP policies will ensure continued access, particular ly in the north beach area where private residences and clubs are located on the west side of PCH, punctuated by public parking lots that form visual and physical connections to the beach and ocean. In order to get a picture of how visitors access the coa st, staff conducted an intercept survey on the Pier in July, about two months after Expo opened. People were asked how they arrived to the Pier, where else they were visiting and how they were travelling between destinations in the surrounding area and to other points along the coast. Information about where people came from and how often they visited the Pier, size of the group they were with and where they parked if they drove was also collected. Attachment A contains staff’s analysis of the results, a s well as the survey team’s anecdotal observations and insights gleaned from conversations with survey participants. Some of the findings of interest included the following: Visitors are arriving by a variety of modes, most commonly car, Expo Line, bus, and walking, confirming the City’s planning approach to coastal area visitor access; Fewer than 1/3 of total survey participants parked at the beach/Pier lots; Visitors were more likely to drive and park at the lots closest to the Pier; more returning visitors parked at the Civic Center lots and on the streets than infrequent visitors; improved signage and wayfinding, as well as educational outreach, could help redirect visitors to less used options; Approximately 25% of survey participants only visi ted the Pier; Most of those surveyed who were visiting more than one coastal destination within Santa Monica walked between them; many first time visitors were unaware 13 of 34 of nearby points of interest, such as the Third Street Promenade, within walking dista nce; The majority of those surveyed found it easy to access the Pier. Those that drove to the Pier reported experiencing access barriers at a rate of more than four times that of transit riders. The biggest barrier for drivers was heavy traffic coming in to Santa Monica. A small number of drivers reported parking barriers; The survey picked up significant interest in using transit, particularly the Expo Line. The information from the survey is encouraging in that it seems to imply that policies that faci litate transit use and active transportation have positive impacts on travel behaviors and can be effective in reducing vehicle traffic to the coast. As the City contemplates anticipated changes to the shoreline due to sea level rise (discussed more fully below), flexible policies in regard to provision of beach -adjacent parking will become important in balancing land use demands between vehicle parking and recreational use of the beach. Access for All The LUP will include policies that address special ne eds for access by the elderly, disabled persons, visitors with small children and/or large, heavy equipment being brought to the beach. Through efforts of the City staff, supported by the Disabilities, Recreation and Parks, and Seniors Commissions, improv ed beach access has been provided to support people with mobility disabilities in several locations, through provision of walkways that extend to the sand, availability of beach wheelchairs, and continued provision of dedicated ADA -compliant parking spaces . Multi -modal focus The LUP access policies will approach all modes of transportation with consideration for the City’s clean air and congestion management goals, as well as a recognition that the coastal area is not served by adequate public transportati on to serve the needs of all regional visitors. Automobile Access Policies will carry forward from the current LUP to ensure vehicular access and parking opportunities in compliance with the coastal act to allow visitors to drive to Santa 14 of 34 Monica and vi sit the beach. Along with this, the LUP will be consistent with City policies that seek to balance automobile usage with other travel modes. In terms of policies, this will be expressed with a more nuanced definition of “beach parking” that includes parki ng opportunities within a ¼ mile radius of the beach. There are thousands of public parking spaces in the Downtown area, Civic Center and Neilson Way public parking lots that serve more than one destination, as evidenced by the number of people documented visiting the Pier along with other places. The City regularly monitors the availability of these parking resources and has data that shows that, with few exceptions, parking is available most of the time in these lots. Along with ongoing efforts to prov ide a reasonable level of visitor parking, the City also plans to continue efforts to ensure that residents living in Ocean Park and other parts of the Coastal Zone as needed, are able to access convenient parking to meet their needs through the preferenti al parking program. Staff is working with CCC staff to propose a policy that shares the public streets with beach -goers during daytime hours while recognizing that the historic charm of the Ocean Park neighborhood, and the character of the Coastal Zone re sidential neighborhood north of Wilshire Boulevard, often comes with a lack of on -site parking, making the adjacent street parking in some cases the only parking alternative that residents have. The LUP will include a map documenting existing preferential parking districts and propose parameters for the CCC to approve to guide requests for additional parking protections. Based on input received in the outreach process that indicates that first -time visitors need more help to gain orientation to the beach and its proximity to Downtown and Main Street, LUP policies will emphasize wayfinding and real -time information to connect visitors with active transportation information and directions to parking resources. The City will also continue its parking managem ent strategy using pricing to encourage distribution of use, ensuring at all times that provisions are made for those requiring special accessibility. Parking will be required for new development, consistent with policies in all parts of the City. The po licies proposed in the LUP will be geared toward consistency with the 15 of 34 LUCE and DCP. Currently, City parking requirements and those imposed by the Coastal Commission start from very different assumptions and use different measurements and terms, leading to many situations in which City -approved projects are later held to a different parking standard during the CDP review process. This issue was addressed in the July 2015 zoning ordinance updates and will need to be resolved when the LCP IP is prepared. The Access policies will also address the unique parking situation of the Santa Monica Pier. The Santa Monica Pier Corporation Board is anticipating scheduling a presentation of its Pier Access and Use Study, prepared by ROMA Design Group, to the Council for direction in guiding future activity on the Pier. In the coming years, the City may consider options that add more visitor -serving activities on the deck area now used for parking (and summer events), which may reduce the capacity of the Pier deck park ing lot. In addition, several existing businesses are in the process of expanding or considering expansion to serve the growing number of year -round Pier visitors. The proposed parking policy for the Pier will seek to allow flexibility for new activities on the Pier based on an approach recognizing that most Pier visitors do not park on the Pier and beach lots, arriving by train, bus, bike or walking from parking locations in the Downtown and Civic Center. The City is asking the CCC to look at observed ac cess patterns, consider the modal split and the supply of public parking that already supports thousands of visitors to the Pier and require applicants for new and expanded businesses on the Pier to comply with Transportation Demand Management (TDM) measur es to encourage other modes of travel for employees and customers rather than requiring additional parking, which cannot be provided on the Pier. This type of policy could obviate the need to seek parking variances for all projects proposed on the Pier. Transit Access An important element of the City’s strategy to reduce congestion and GHG emissions is to encourage transit use through integrated land use -transportation planning, Big Blue Bus -Metro coordination, and initiating incentive programs. The Exp o Light Rail line has 16 of 34 been in operation for only a few months, but its impact on travel is already being felt in the coastal area. In conjunction with Expo, the Big Blue Bus has rerouted and adjusted its lines and schedules and aligned its TAP card techno logy, continuing to focus not only on Santa Monica residents but on the larger Westside population wishing to travel to Santa Monica’s coast. LUP policies, consistent with current City policy, reinforce support for the Big Blue Bus and Metro Bus and rail t ransportation through requirements for developers of properties by bus stops to incorporate facilities for bus patrons, development of connections between bus and rail, and first mile -last mile solutions that promote the feasibility of using public transpo rtation. Bicycle Access The Coastal area is a popular cycling destination. Policies for bicycle access to serve visitors to the coastal area are generally proposed to be consistent with the 2010 Bike Action Plan. The Bike Action Plan and Zoning Ordinanc e contain policies and requirements for developers to provide facilities that support employees and customers making a choice to ride a bicycle as their means of transportation. LUP policies will also support the City’s provision of bike facilities and am enities, such as improved paths, lanes and bike racks, as well as the Breeze Bike Share program, and encourage opportunities for bicycle rental. Pedestrian Access Earlier this year, the Council adopted the Pedestrian Action Plan (PAP), recognizing that one of Santa Monica’s greatest assets is its walkability and also acknowledging that facilities still can be improved to meet the community’s expectations for safety and comfort as they walk through City streets. An example of one of the PAP’s near -term p rojects that has already been implemented are the pedestrian scrambles in the Coastal Zone portion of Downtown, which provide separated signal cycles for pedestrians to cross in any direction. With implementation of the scrambles and the Colorado Esplanad e, pedestrian access to the Pier and Palisades Park has been improved tremendously, and the LUP’s policies encourage development of similar pedestrian 17 of 34 facilities in the Coastal Zone. The Pedestrian Access policies will also include language that the Coast al Commission generally requires in regard to maintaining and improving the California Coastal Trail (CCT). The CCT is a network of public trails for walkers, bikers, equestrians, wheelchair riders and others along the 1200 -mile California coastline. It is currently more than half complete. In Los Angeles County, the CCT includes the Marvin Braude Bike Trail (commonly referred to as the beach bike path). After many years of planning, the City has recently begun a project to upgrade the trail, which is sch eduled to begin with a public planning process in the next couple of months. Components include the following: Renovation of Ocean Front Walk from the Pier to Arizona Ave Addition of a pedestrian path for Arizona Ave to northern City limits Addition of a pedestrian path around the 1550 lot and under the Pier Widening the bike path between Pier and Bay St to accommodate pedestrians With $8.2 million dollars allocated in the City’s Capital Improvement Program (CIP) budget, construction of the improve ments is anticipated to get underway in 2018 -19. The CCC will require a policy to provide continuous pedestrian access around the perimeter of the Santa Monica Pier, including during special events to ensure that the public is not deprived of access by pri vate functions. Recreation and Visitor -Serving Facilities Coastal Act Guidance The Coastal Commission has a mandate to ensure that the public can enjoy the coast through recreational opportunities that are widely accessible both physically and financially . Specific guidance is provided in Section 30213 of the Coastal Act, which states that lower cost visitor -serving facilities, which include lower -cost overnight accommodations, shall be protected, encouraged, and where feasible, provided. An in - lieu fee m ay be required in order to mitigate for the loss of lower cost rooms. Also in this policy section, land uses and activities that serve visitors are prioritized in the coast -adjacent subareas and other parts of the Coastal Zone that have traditionally 18 of 34 prov ided recreation and visitor services. Privatization of the beach area is to be avoided and the Coastal Act protects those areas currently open and free to the public from being privatized and commercialized. Although areas may be used for temporary event s, these, too, are to be carefully reviewed to minimize the impacts on the public’s ability to visit the coast. The beach and Pier are the key assets for the City of Santa Monica to protect, but other public spaces in the Coastal Zone, such as parks and t he Third Street Promenade, are also important visitor -serving assets for consideration. Changes since Existing LUP was Adopted Over the last quarter century, the most significant changes to recreation and visitors services have been the development of the Civic Center and Tongva Park in particular, the addition and upgrade of several hotels, and improvements in visitor amenities, such as the expansion of beach -adjacent parks, new playgrounds, restroom facilities, exercise equipment, accessible pathways to the shoreline and improvements along the Marvin Braude Bike Trail. The number of visitors has increased to upwards of 17 million annually, with little change to the beach parking facilities. The Pier has been restored as an amusement center, with Pacific Park, new restaurants and an invigorated program of free public events, including the Twilight Concert series and fall movie nights, as well as regular street performers. The Pier “season” has stretched beyond the summer and has more regular foot traffic throughout the year on weekdays as well as weekends. The City has developed regulations for use of the beach lots for temporary events, such as Cirque de Soleil, during non -peak seasons and has enjoyed success at its bi -annual late -night “Glow” art event . In addition, the City Attorney’s Office has addressed issues of beach encroachment by some residents and beach clubs in the north beach area. This has involved examination of agreements with adjacent property owners to find a fair resolution to situati ons that have developed over many years. Proposed LUP Update Approach The policy concepts would encourage the retention and addition of visitor -serving 19 of 34 activities in the beach area, with design features that support public access to the shoreline, inclu ding accommodations for those with disabilities. Temporary activities that close the beach or Pier are proposed to be minimized, but public events and festivals on the Pier, such as the summer concert and movie series, which are provided at no cost to the public, are allowed. Currently, the LUP prohibits the use of the beach and beach parking lot for special events in the summer months, allowing them during off -peak seasons, for example Cirque du Soleil. This policy would be continued. However, staff is aware that Santa Monica beach is being considered as a possible venue for beach volleyball should the City of Los Angeles be successful in its bid to host the 2024 Summer Olympics. The LUP will propose an exception to the summertime event prohibition for the Olympics, requiring post -event removal of any structures built. Proposition S Proposed LUP policies will be consistent with Proposition S, approved by City voters in 1990, which places limits on the provision of hotels, motels and larger -size restaur ants in the Coastal Zone by prohibiting them in the Beach Overlay District. The City currently provides many dining and hotel options throughout the Coastal Zone at all price points. Although Prop S closes off some opportunities along the coast, zoning in the Coastal Zone and existing uses enable a sufficient supply of visitor -serving businesses in compliance with the Coastal Act. Prop S exempts the Pier deck and 140,000 square feet of new development on the Pier, where the underlying zoning permits resta urants (but not motels and hotels). Smaller restaurants (under 2,000 square feet) are not prohibited by Proposition S and may be developed within the Beach Overlay District if permitted by the underlying zoning. Mitigating Loss of Low Cost Visitor Accom modation The Coastal Zone includes a variety of lower cost accommodations that range from mid - level to luxury. Other lower cost accommodations are available both in the Coastal Zone (the Downtown IYH hostel and Lincoln Boulevard motels) and in other parts of Santa Monica east of the Coastal Zone. Although there may be more relatively affordable 20 of 34 lodging in areas outside of the Coastal Zone, these are not taken into consideration for the purposes of the LUP Update policies because the Coastal Commission’s ju risdiction is only the Coastal Zone. In order to determine an appropriate threshold by which mitigation fees may be required, staff is researching with Coastal Commission staff a reasonable definition of low -cost and moderately -priced visitor accommodat ion. The Coastal Commission has typically used a formula that compares the average daily rate of lower cost hotels in a specific coastal zone area with the average daily rates of hotels and motels across the entire State of California. Under this formula , lower cost is defined as rooms with rates that are at least 25% lower than the statewide average room rate. Higher cost is defined as 25% more than the statewide average room rate. Moderately -priced visitor accommodations fall in between the low -cost a nd high -cost range. As of March 2015, the statewide average daily room rate was determined to be approximately $145/night. According to the California Coastal Commission February 2016 staff report prepared for the Shore Hotel, based on a survey of 18 hot els and motels in the Santa Monica beach area, the average daily room rate is $333/night. Using the Statewide average daily room rate as a basis for establishing a threshold for mitigation could result in a rate that is significantly lower than typical hotel prices in the Coastal Zone. Localized studies of average daily room rates in the particular area in which a project is being proposed might result in more appropriate thresholds. If low cost visitor accommodation is defined at a level that is much lower than typical average daily room rates in Santa Monica, the consequence may that lost accommodations may never trigger requirements to pay a mitigation fee to replace low cost accommodations. Ordinance 1516, adopted on February 20, 1990, establishe d mitigation fees for the removal of low cost lodging in the Coastal Zone. Staff proposes to update the low cost visitor accommodation fee, which is intended to mitigate the loss of low cost accommodations. Updating the in -lieu fee will include review of the construction costs and land costs associated with replacing the loss of each low cost hotel room. 21 of 34 Santa Monica Pier Santa Monica’s most internationally recognized recreational facility, other than the beach itself, is the Pier, as discussed above an d under New Development, below. The Pier is highly valued by the community and its protection and maintenance have long been a priority, even sparking a 1970’s political upheaval and ballot measure (“Save our Pier Forever”) to prohibit its demolition, whi ch had been ordered by the Council. It is a Landmark, with separate designation for two key features (the Looff Hippodrome and Yacht Harbor sign) and has a Council -appointed agency (Pier Corporation) to steward its activities. The Pier is a separate suba rea (Subarea 2) in the LUP, and policies pertaining to the Pier may be contained in multiple LUP policy sections. Environmental Quality Coastal Act Guidance LCP environmental quality policies are concerned with fulfilling the Coastal Act’s mandate to prot ect the coastal and marine environment from human activity that can contaminate or destroy coastal ecosystems and to restore natural conditions where it is possible to do so. Policies related to endangered species habitat protection and activities that ca n affect water quality, including management of stormwater that empties out into the ocean are the primary concerns for this section. The section will include policies for marine habitat protection, which will be considered guidelines for the Coastal Comm ission, which in all cases reserves Coastal Act authority over activities west of the mean high tide line (defined as the Commission’s area of “original jurisdiction”). In addition to protection of endangered species, the second major policy subject in t his section is water quality, an issue that is affected by regional forces and only partly within the City’s sphere of influence. From its earliest development, the Los Angeles region was affected by flooding and drainage issues. In the previous century, cities including Los Angeles and Santa Monica resolved these problems by creating a system in which stormwater was collected from city streets and channeled into the Pacific Ocean. While this system has proven successful for controlling urban flooding, i t has had a major side effect of directing polluted water into the ocean, as along with the collected rainwater, 22 of 34 the storm drains picked up leaves and other plant materials, a variety of chemicals, biological matter and litter that is thrown onto streets a nd sidewalks. To exacerbate the problem, stormwater activity is not limited to the rainy season. During dry weather, the system carries less volume, but the region’s storm drains catch water from irrigation and other activities that also brings pollutant s toward Santa Monica Bay. Changes since the Existing LUP was Adopted Since the LUP was certified, the City has made great strides in its ocean and beach - cleaning efforts including: Construction of stormwater treatment facilities with regional partners, including the Santa Monica Urban Runoff Recycling Facility (SMMURF), which can treat up to 500,000 gallons per day of dry weather run -off and the recent completion of the Penmar retention facility in Venice, which contains large underground tanks to colle ct and treat stormwater; Pilot projects to capture rainwater, such as the Bicknell Green Street and features on Ocean Park Boulevard west of Lincoln Boulevard, both within the Coastal Zone; Education and incentives to residents and businesses to change their practices to keep matter out of the storm drains; Developing ordinances and enforcement mechanisms that Council has enacted to curb irrigation overspray and prohibit release of pollutants into the storm drains, including automobile oil and waste products with harmful chemicals; and Developing additional projects that are intended to protect the marine environment year -round by increasing the capacity to capture and clean wet weather runoff. The most significant project currently in development is the Sustainable Wastewater Infrastructure Project (SWIP), which includes components in two LCP subareas (the beach area and Civic Center), and will require CCC approval of a Coastal Development Permit. Proposed LUP Update Approach The policy approach w ill maintain and update existing LUP policies related to protecting threatened and endangered species, maintaining the improvements to water quality including regulating new development to ensure that it does not result in adverse impacts on the coastal en vironment, and requiring best management practices (BMPs) to achieve coastal sustainability objectives. Stormwater Management The LUP’s approach to stormwater management will be consistent with the City’s 23 of 34 current policies and practices. Although the t oxic mix collected from the streets is channeled toward one of Santa Monica’s three storm drains at the coastline, its origins are both within and outside of the city, and mostly outside of the Coastal Act’s jurisdiction. Nevertheless, there is a strong m andate to address this environmental nuisance in the LCP. LUP policies will support and strengthen the aggressive approach the City takes to this problem, working with other regional partners to reduce the amount of water that reaches the beachfront storm drains and to intervene to clean it before it is released into Santa Monica Bay. The LUP narrative will also describe how the City has developed and continually enforces zoning and building code requirements for new residential and commercial development or additions to existing development through design or installation of features that avoid runoff from the property such as rainwater harvesting or on -site percolation into the aquifer. Endangered Species Habitat Areas The LCP is required to identify Endangered Species Habitat Areas, or ESHA, within its Coastal Zone and to outline the ways in which the identified endangered species will be protected and accommodated. Currently, only one endangered species has been identified as utilizing Santa Monica’s beach as part of its life cycle habitat: the Western Snowy Plover, a small migrating flock of birds that nests in the beaches near Santa Barbara and “winters” in the northern Santa Monica beach area. Working with the Audubon Society, the City has alread y taken steps to protect the plovers’ wintering area, erecting a three -sided fence area around the specific beach territory that they occupy to keep out people, pets, vehicles and beach cleaning equipment that may harm them. In addition, educational tours have taken place over the years to increase awareness of this habitat. The LUP will include specific measures that aim to ensure that these birds are not disturbed during times that they are present on the city’s beach. Two other endangered species were identified in the 1990s as requiring protection, the Brown Pelican and the Least Tern. However, since then, the Brown Pelican has been 24 of 34 removed from the endangered species list and there have been no Least Tern pairs establishing breeding grounds for more than a decade. The LUP will include a policy requiring protection of all endangered species that are identified as becoming established along Santa Monica’s beaches, although the new ESHA map will not include any specific land area associated with them at this time. Scenic and Visual Resources Coastal Act Guidance This LUP policy section relates to preservation of the visual quality of the coastal environment, which the Coastal Act requires to be “considered and protected as a resource of public importanc e.” Generally speaking, this requires maintaining a higher level of aesthetic quality for new development, including landscaping, parking lot landscaping, signage, lighting adjacent to the ocean and beaches or other scenic areas, bluff top setbacks and li mitations on fencing and sea walls. This policy section identifies scenic corridors within the city, along which new development is required to maintain public ocean views from the public right of way. Importantly, the Coastal Act does not protect private views or mandate preservation of a view from one private development that might impact the development potential of another property. Changes Since the Existing LUP was Adopted The General Plan Conservation Element includes the following seven designated scenic corridors within the Coastal Zone: 1. Santa Monica Freeway from the Coastal Zone boundary to Ocean Avenue; 2. Ocean Avenue from the north city boundary to Barnard Way; 3. Pacific Coast Highway (Route 1) within the City limits; 4. Barnard Way fr om Ocean Avenue to the south city boundary; 5. Wilshire Boulevard from 4th Street to Ocean Avenue; 6. Third Street Promenade; and 7. The Santa Monica Pier. During the past quarter century, the City has undertaken public projects that have enhanced the identified scenic corridors. The best examples are the beach greening 25 of 34 and streetscape projects that have been implemented on and around Barnard Way and the coastal development requirements that have ensured that new development along Palisades Beach Road and on the Pier consider the view of both the project itself and of the beach and ocean beyond from Palisades Park. The Draft DCP includes improvements to the pedestrian environment along the Wilshire Boulevard corridor that would be consistent with the LC P’s objectives to protect scenic corridors in the Coastal Zone. Proposed LUP Update Approach Map #13 in the current LUP includes scenic corridors and a public viewing area at Santa Monica Place. Staff is considering proposing the removal of two of the sc enic view corridors: #1 (Santa Monica Freeway) and # 6 (Third Street Promenade). Neither of these corridors provides public views to or from the beach or bluffs. In 2004, when the building at the northwest corner of Colorado Avenue and 2 nd Street was app roved, the Coastal Commission determined that the public viewing area at Santa Monica Place was no longer significant and suggested that the City amend the LUP Map #13 to remove the decks as public viewing decks. Since then, the Coastal Commission approve d the Shore Hotel, allowing its construction to a height of 45 feet, and finding no impacts on public views. Staff proposes to remove the public viewing area from Map #13 as part of the update. As part of their October 5, 2016 study session, the Planning Commission requested that additional scenic viewpoints be studied in addition to some acknowledgement of the I - 10 Freeway as a historical natural and visual resource. Staff will be exploring additional scenic vantage points and proposes an approach that seeks to more specifically identify the scenic elements that are important to protect from each vantage point so that the scenic corridor is more clearly defined. Sea Level Rise and Coastal Hazards Coastal Act Guidance The connection between climate chang e (global warming), sea level rise and coastline shift are now well -established, and impacts are already clear in some sections of 26 of 34 California’s coastline. This issue has been integrated into the Coastal Act’s mandate to protect and plan for the future of the California coastline. New scientific research has yielded more comprehensive and accurate data that can be used to anticipate and plan for coastline changes and cliff erosion. In response, on August 12, 2015, the CCC adopted a document outlining the e xpectations for this policy section entitled: California Coastal Commission Sea Level Rise Policy Guidance: Interpretive Guidelines for Addressing Sea Level Rise in Local Coastal Programs and Coastal Development Permits. Changes since Existing LUP was A dopted Issues related to climate change impacts and sea level rise were not well -understood in 1992 and were not considered in the development of the last LCP. Proposed LUP Update Approach The newest policy section being introduced through the LCP Update will define the City’s approach to adapting to sea level rise (SLR) in combination with coastal storms that have become more frequent in recent years. Policies for this section are being developed in tandem with a regional analysis (the Coastal Storm Mod eling System, or CoSMoS) that is concurrently being prepared by USC Sea Grant through a grant managed by the City’s Office of Sustainability and the Environment (OSE). CoSMoS considers the combined impact of coastal hazards and when complete will map these hazards together, acknowledging that the separate processes cannot be considered in isolation from each other. A separate but similar effort commissioned by USGS (the ESA study) is approaching the topic from a slightly different angle, and the City will be able to gain more perspective on the forecast through a comparison of the two models’ results. The preliminary CoSMoS study results indicate that, in the near term, Santa Monica’s beaches will not be as heavily impacted as other parts of the coast, s ome of which are already losing shorelines and experiencing bluff erosion that impacts homes and businesses. In these places where shoreline loss or bluff erosion is already occurring, 27 of 34 policies of managed retreat and adaptations involving the removal of s tructures or limitations on building new structures may have more immediate relevance. Coastal Erosion and Sea Level Rise Santa Monica’s wide, sandy beaches are, nevertheless, forecast to narrow in the next 20 years and there is definitely expectation of some “coastal erosion” or a higher shoreline. With two meters of SLR, a scenario that may be seen by 2050, the mean high tide line will move landward beyond the current life guard station locations. Such a retreat will eventually bring the beach closer to the historic line that existed in the City’s early years before sand was added and wave action was altered by structures like the breakwater that created the yacht harbor and the Pier. The timeline for coastal erosion depends on global processes, incl uding the melting of the polar ice cap and other influences on oceanic ecology. The height of the Pier places the deck and its activities above the level of sea level rise, according to the preliminary results of both models. A higher shoreline would impl y that major winter storms, which have been gaining globally in number and intensity in recent years, would impact Santa Monica’s beaches differently than in the past. The combined impact of sea level rise and intense storms may see water reaching higher p oints, impacting beach infrastructure, such as recreation facilities for beachgoers, the bike trail and the surface parking lots. Options for Adaptation The City will have to decide on policies to guide its steps when these predicted changes actually b egin to occur. While beach nourishment, in which sand is imported to maintain the shoreline, may be possible, an ongoing beach nurturing program may be too expensive or have unintended consequences and ultimately is not widely believed to be a sustainable option in the long -term. The Coastal Commission has discouraged and recently rejected applications for the construction of sea walls, which tend to actually speed up coastal erosion on the seaward side of the wall, while protecting inland structures. Pr otective sea walls tend to favor the investment of the private 28 of 34 property owner over the public’s right to enjoy the beach. Adaptation measures under consideration include nurturing dunes that may slow down or hold back waves. Council recently approved a p ilot project that The Bay Foundation plans to implement in the coming year to restore a portion of the beach near the northern city boundary line with a dune landscape. The project will utilize existing sediments to passively restore and transform approxi mately 3 acres of the current beach into a sustainable coastal strand and dune habitat complex which would support resilience to sea level rise. The project is expected to have benefits for wildlife that thrive in the dune environment. Phased Approach t o Development Restrictions In the much longer term, some combination of adaptation measures and strategic managed retreat may be necessary. While privately -owned beach -adjacent properties in Santa Monica are not immediately vulnerable to sea level rise im pacts, the need to restrict some forms of development will likely become necessary when triggered by the advent of a significant increase in sea level rise. The LUP will take a phased policy approach to sea level rise impacts, with development restrictions becoming effective based on the progression of sea level rise and the proposed project’s expected life span. A project that represents an investment with a shorter life span, such as a playground or other beach amenity, would, for instance, be reviewed d ifferently from a new home or addition and in both cases, the coastline’s movement at the time of application would determine applicable requirements and development thresholds. As an example of the phased approach, policies requiring disclosure of sea le vel risk in connection with property sales, and risk acknowledgement in connection with permit approvals might go into immediate effect, and sea walls may already be prohibited by the Coastal Commission. Other policies, such as “rolling easements” that li mit the use of property and policies potentially prohibit rebuilding of lost assets, may be included in the LUP, but would only become effective when triggered by measured landward movement of the mean high tide line. The phased approach is intended to al low the 29 of 34 City to take steps to reduce risk without unnecessarily restricting activity that does not yet pose a risk. Cultural Resources and Historic Preservation Coastal Act Guidance The Coastal Act’s primary interest in terms of historic resources is pro tection of archeological remains, particularly those associated with native tribes that lived in specific coastal areas during earlier times. LCP policies will require special protection of these resources and identification and caution to be taken in the event that projects are undertaken in areas that potentially may contain cultural artifacts. In Santa Monica, the discovery of archeological resources is quite rare, but preservation of more modern historic resources is highly valued. The Coastal Act i ncludes a statute that requires new development to: “where appropriate, protect special communities and neighborhoods that, because of their unique characteristics, are popular visitor destination points for recreational uses.” Changes Since the Existin g LUP was Adopted Since the 1992 LUP was adopted, the City took an important step forward to protect its historic resources primarily through adoption of the General Plan Historic Preservation Element (HPE) in 2002. HPE policies have strengthened the Landm arks Ordinance (Chapter 9.56 Of the Municipal Code), which was first codified in 1975 and updated since. These policies and regulations have become the basis for a robust and active preservation program that is integrated into the planning process. The City has also maintained a Historic Resources Inventory (HRI) since the mid -1980s. The HRI has been updated for specific areas or for the entire city on several occasions and is in the process of another comprehensive update to be completed by May 2017. The City’s Historic Resources Inventory (HRI) and list of designated landmarks and historic districts comprise a fairly comprehensive list of Santa Monica’s unique historic resources, but in general these are not neighborhoods that in and of themselves co nstitute popular visitor recreational destinations. The Pier, although not a 30 of 34 neighborhood, is a historic resource and popular visitor destination and it is already protected as a landmark, with separate designations protecting the Looff Hippodrome (carous el building) and the Pier Yacht Harbor sign. Main Street is also a visitor destination and many of its most distinct buildings are either designated as landmarks or listed on the HRI. Specific Plans that the City has adopted have given consideration to protecting and incorporating the historic resources within their plan areas to define character and provide guidance for future development. The policies of the LCP will not attempt to replace the HPE or Landmarks Ordinance, or to affect the policies of the DCP and Civic Center Specific Plan (CCSP), but will support HPE policies such as encouraging adaptive reuse and consulting the HRI as an integral activity in the planning review and plan check processes to ensure that full consideration is given to the proper treatment of historic resources. Proposed LUP Update Approach Due to strong protections and incentives already in place in the Zoning Ordinance and Landmarks Ordinance in addition to policies in the Historic Preservation Element, LUCE, and applica ble Specific Plans, it is not necessary to include additional protections for historic resources in the LUP. One exception is to resolve a conflict between two State mandates with regards to City - designated cultural landscapes. The Coastal Commission ha s determined that plants classified as invasive may not be planted in the Coastal Zone including two iconic species of palm trees. At the same time, the City uses as a standard of review the US Secretary of Interior Standards for the Treatment of Historic Places, which defines the proper treatment for historic resources, including cultural landscapes. The best examples of where these regulations conflict is in Palisades Park, where the Landmark designation lists the iconic Mexican Fan Palms and Canary Isl and date palms as contributing features to a historic landscape, and City Hall, which includes Canary Island date palms in its landscape setting. As elements of designated historic resources, these palm trees should be preserved to the extent possible and the City would like to 31 of 34 have the option to replace them in -kind if it becomes necessary to remove them. The Cultural Resource and Historic Preservation section will include a policy that recognizes designated cultural landscapes and allows replacement of t rees that are called out as character -defining in a Landmark designation with the same species even if listed as an invasive species. New Development Coastal Act Guidance The policy categories are generally applicable to all areas of the Coastal Zone. Ho wever, New Development will include subarea -specific policies to appropriately guide development consistent with each subarea’s unique character and circumstances. LUP policies will reflect the Coastal Act’s prioritization of coastal -adjacent areas for th e public enjoyment, although the Coastal Zone goes as far east as 4 th Street north of Pico Boulevard and Lincoln Boulevard in Ocean Park. Policies will reflect the relative importance of Subareas 1, 2, and 3 (the beach, Pier and bluffs) for coastal access and recreation, and the unique circumstances of Downtown, the Civic Center, Main Street and the residential neighborhoods. Changes Since the Existing LUP was Adopted There have been many changes to the Coastal Area in the last quarter century, but few amendments to the LUP. The CCC removed certain subareas from the policy section of the current LUP, excluding them from their 1992 certification because of pending issues 32 of 34 and policy concerns at that time. These areas included the Civic Center, which was then in the midst of planning the first Civic Center Specific Plan (CCSP), and the whole of Subarea 1 and parts of Subarea 3, which are beach areas within the Proposition S Beach Overlay District. At the time, the CCC expressed concern about the City’s com pliance with the Coastal Act’s intent to provide visitor -serving uses at the beach based on restrictions of Proposition S. With time and the City’s success in providing beach amenities, including the Annenberg Community Beach House, concerns that Proposit ion S would negatively affect beach access and visitor services have been largely alleviated. In the LUP Update, area -specific policies will be established for all subareas. In addition to the Civic Center, Downtown is also currently in the midst of a specific planning process through the Downtown Community Plan (DCP). The LUP Update provides an opportunity to ensure consistency with these plans. Since the LUP and DCP projects are being developed and considered concurrently, the timing for presentatio n of a Final Draft LUP is affected. The final draft of the LUP will be brought forward for adoption hearings after the DCP process has been completed, incorporating policies that ensure consistency between the two documents. Proposed LUP Update Approach Relevant documents were reviewed in the first phase of the LUP project, with the goal of identifying and resolving potential conflicts with the LUP. These included the 2010 LUCE, CCSP and draft DCP. The LUCE is built on a unique Tier structure that regul ates projects to allow height and density maximums that depend on the provision of certain amenities or preferred uses, such as affordable housing, cultural amenities and open space. Specific standards and requirements for the Coastal Zone will be determi ned in the Implementation Plan (Coastal Zoning Ordinance), which will be developed through a separate public process following LUP certification. Until a Coastal Zoning Ordinance is adopted and certified by the CCC, the current Zoning Ordinance will conti nue to apply to the Coastal Zone and the Coastal Development Permit process will continue to be implemented by the CCC based on the updated LUP. The IP project has an anticipated timeline of two to three years. 33 of 34 Attachment B shows a comparison of height l imits in the LUP and LUCE. While the City evaluates applications based on the LUCE and Zoning Ordinance, CDP decisions are guided by the LUP. When the City has a certified LCP that includes both the LUP and IP, City staff will review projects in the Coas tal Zone based on the LCP. Council should provide input on the parameters for height, including whether to adjust the maximum heights to be consistent with the LUCE. Next Steps Following the Council’s direction on LCP policy development, staff will prep are a draft LCP Land Use Plan for public release in early 2017. The Draft LUP may contain a placeholder for Downtown subarea policies, which would be finalized to reflect the Downtown Community Plan (DCP) when the Final Draft LUP is released. In order to present a complete LUP for certification, including policies for all subareas, the public hearing schedule to consider the LUP Final Draft must come after the DCP adoption process. Currently, staff is working toward adoption hearings in Spring/Summer 2017 , after the anticipated adoption of the DCP, to be followed by submittal to the Coastal Commission for certification. Financial Impacts and Budget Actions There is no immediate financial impact or budget action necessary as a result of the recommended po licy action. Prepared By: Elizabeth Bar -El AICP, Senior Planner Approved Forwarded to Council 34 of 34 Attachments: A. May 10, 2016 Staff Report B. October 27, 2015 Staff Report (Dudek contract) C. Getting to the Santa Monica Pier: Survey Summary D. LUP Update Height Limits Policy Comparison Prepared for the Local Coastal Program Update Getting to the Santa Monica Pier: Summary and Analysis of a Travel Mode Survey Conducted in July 2016 Planning and Community Development Department City Planning Division September 21, 2016 2 3 Produced by the Local Coastal Program Update Team: Elizabeth Bar-El, AICP, Senior Planner/ Project Manager Cary Fukui, Assistant Planner Shira Moch, City Planning Intern Cat Callaghan, City Planning Intern Jing Yeo, AICP, City Planning Division Manager Roxanne Tanemori, Principal Planner Acknowledgements Thank you to the following for participating in conducting the survey: Svetha Ambati Nicole Brown Rathar Duong Rosemary McCarron Brett Medeiros Jessica Orellana Jared Thomas Julie Wedig Special thanks to Rod Merl and Jay Farrand at the Santa Monica Pier Office, to the Harbor Unit of the Santa Monica Police Department, and to the Public Works RRR Division for logistical assistance. This project was conducted in conjunction with GoSaMo, a citywide mobility project to move Santa Monica forward. Getting to the Santa Monica Pier September 21, 2016 4 Summary The Local Coastal Program Update team conducted a survey on the Santa Monica Pier to collect information on how visitors are parking, moving about, and accessing the Pier. The survey yielded a total of 631 responses, but accounted for 2,347 total visitors when considering party size. The results are representative of high season, mid-week visitors but not statistically conclusive as the study was conducted as an intercept survey and thus dependent on the willingness of Pier visitors to participate. The data appear to support the following: • Visitors are arriving by a variety of modes, most commonly car, Expo Line, bus, and walking, confirming the City’s planning approach to coastal area visitor access; • Fewer than 1/3 of total survey participants parked at the beach/Pier lots; • Visitors were more likely to drive and park at the lots closest to the Pier; more return visitors parked at the Civic Center lots and on the streets than infrequent visitors; improved signage and wayfinding, as well as educational outreach, could help redirect visitors to less used options; • About one-quarter of survey participants only visited the Pier; • Most of those surveyed who were visiting more than one coastal destination within Santa Monica walked between them; many first time visitors were unaware of nearby points of interest, such as the Third Street Promenade, within walking distance; • The majority of those surveyed found it easy to access the Pier. Those that drove to the Pier reported experiencing access barriers at a rate of more than four times that of transit riders. The biggest barrier for drivers was heavy traffic coming into Santa Monica. A small number of drivers reported parking barriers; • The survey picked up significant interest in using transit, particularly the Expo Line. Purpose The Coastal Act requires that the coastline be accessible for recreation for all, whether local, from the Los Angeles region, or beyond. The purpose of this survey was to get a better picture of coastal accessibility by understanding what travel modes Pier visitors are using to get to the Pier, where people are parking their cars, and whether Pier access choices reflect City policies and recent investments in transit, bike and pedestrian improvements. This data will guide policy development for the Local Coastal Program Land Use Plan (LUP) Update project. Similar to the Land Use and Circulation Element (LUCE), Santa Monica’s updated LUP will contain policies that promote sustainability objectives such as supportive infrastructure for multi-modal travel alternatives to reduce the community’s carbon footprint. Future Coastal Zone access will build on the recent expansion of the Expo Line Light Rail, the opening of the Breeze Bike Share system, and the provision of more “complete streets” that add comfort for pedestrians and cyclists. Methodology The 12-question survey was conducted on July 19, 21, 26, and 28, 2016 between the hours of 10:30 am and 3:00 pm. Mid-week, daytime hours during the height of summer were chosen in order to include people during the high summer season but avoid the bias of the busiest weekend hours. Examples of the survey questions include: “From your origin this morning, how did you get here (check all that apply)?” And, “How did you previously come to the Santa Monica Beach area before the Expo Line opened (please check all that apply)?” The Pier was selected as the focus and location of the survey because of its high visitor traffic volume. The Mobility Kiosk and free sunscreen were used to attract visitors to participate in the survey. There were four to five surveyors administering the surveys on tablets through a web-based platform. Surveyors were stationary and intercepted people who then volunteered to participate in the survey, meaning that it is biased and not a random sampling. The statistics presented in this report are tabulations of the four survey days’ responses. The results are not separated by day, but as totals of the survey period. The results 5 generally refer to the number of respondents unless it is specifically noted that it refers to the total number of people in their parties. The survey analysis is broken down into the following sections: • Who is Visiting the Pier? • Trends in Travel 1. Primary Modes of Travel 2. Serving the Los Angeles Region 3. Serving Families 4. Accommodating All Ages 5. Welcoming First-time Visitors • Where are Pier Visitors Parking? • Traveling Within the Coastal Zone • Barriers to Access Analysis Who is Visiting the Pier? Of the 631 respondents, the largest group, 39%, consists of domestic tourists, coming from across the country (Figure 1). The second largest group, 36%, is Los Angeles regional visitors (within 30 miles of Santa Monica). Only 7% of respondents are from Santa Monica, with the remaining 18% coming from abroad. A majority, 57%, came to the Pier in groups of two to three people (Figure 2). Although the survey yielded 631 total responses, it reflects a total of 2,347 Pier visitors. Trends in Travel 1. Primary Modes of Travel A central purpose for this survey was to learn about how people are getting to the Pier (Figure 3). The survey found that the majority (58%) arrived by car, followed by the Expo Line at 14%, with walking and bus tied for third with 8% each. 6% used a car share or taxi service. It should be noted that the number of bike riders (Breeze Bikes, rental, or personal) observed during the survey is not consistent with these results. Bike riders are underrepresented as, in general, they rode past the surveyors too quickly and declined to participate. Looking at the geographic areas where participants live, the data found some interesting differences in travel 7% 36% 39% 18% Where Visitors Travel From Santa Monica LA Region United States Global Figure 1 7% 28% 27% 17% 11% 10% Group Size 1 Person 2 People 3 People 4 People 5 People 6+ People Figure 2 6 mode. The two groups in which the majority did not arrive by car were Santa Monica residents and global visitors (Figure 4). Most visitors from the LA region arrive by car (61%), but the 39% who arrived using other modes represent a significant share. In Santa Monica, the number is flipped with 40% arriving by car, and the rest by other modes, primarily walking (38%). Even though Expo had been open for less than two months at the time of the survey, already 22% of LA Regional visitors came to the Pier on the Expo Line. The 90 respondents who arrived by Expo Line were further asked how they came to the Pier prior to the light rail line’s expansion to Santa Monica. More than half, or 58 respondents, stated that they used to come by car, representing 9% of the total survey group, indicating a significant shift from car to train in only two months. Over time, with heightened awareness of the option to visit the coast by light rail, it is likely that this percentage would rise. Indeed, some visitors were not informed of this option, like one who told the surveyor: “I am excited to use the Expo when it opens.” 40% 61% 65% 45% 38% 2% 7% 14% 10% 22% 9% 13% 4% 2% 1% 5% 3% 6% 12% 5% <1% 2% 4% 2% <1% <1% 7% 7% 13% 0%20%40%60%80%100% Santa Monica LA Region United States Global Primary Mode of Travel by Residence Car Walk Expo Tour Bus Car Share Bike Motorbike Bus Figure 4 59% 8% 2% 1% 14% 6% 8% 2% Primary Mode of Travel to Pier Car Walk Bike Motorbike Expo Car Share Figure 3 7 Looking deeper into differences within the geographical areas, the maps in Figure 5 show the center of each recorded zip code and the primary mode of travel used. The size of the circle indicates the number of persons using that mode, including all people in a party (all 2,347 people). The results show, for example, that British, French and US visitors coming from the northeast and Montana utilized public transit more than others in their geographic categories. By contrast, Arizona, Canadian and Chinese visitors represented large groups of those driving to the Pier. Figure 5 8 2. Serving the Los Angeles Region Santa Monica’s coastline plays a vital role for the Los Angeles region. The wide, sandy beaches and accessible coastline make Santa Monica a major beach destination for LA residents. Santa Monica’s Local Coastal Program is challenged to ensure that the City maintains the region’s coastal access, while also ensuring that the coastal environment is not degraded by being “loved too much.” It is hoped that the Expo Line, along with recent Big Blue Bus route adjustments will play a significant role in meeting that challenge. Not surprisingly, survey participants who used Expo mostly came from communities directly east of Santa Monica, with close proximity to Expo Line stations, as shown in Figures 6 and 7. Other high transit use (bus lines) by survey respondents with access to major bus routes like Lincoln, Pico and Wilshire Boulevards can also be seen on the map. In terms of serving the region, it is notable that 29 respondents (4.5%) said that before Figure 6 9 the Expo Line opened, they did not come to the Pier at all because it was not easily accessible. When examining access to the Pier from the 798 LA region residents (including Santa Monica), 159 of the 798 (or nearly 20%) regional visitors (within 30 miles, including Santa Monica) live in zip codes with centers within one mile of an Expo Line Station. Of those, only 41 people (5.3%) came to the Pier on the Expo Line. 389 Regional Visitors live in a zip code with a center within one mile of any LA Metro Station (49%). 78 people from within this range (20%) arrived on the Expo Line. Clearly, the closer people are to rapid public transit, the more likely they are to take it. Figure 7 10 3. Serving Families For the purposes of this analysis, “family” is defined as a group of at least two people, one adult and one child (less than eighteen years of age). A majority (72%) of families surveyed drove to the Pier (Figure 8), a much higher car use than the overall finding of 51%. In fact, families represented 32% of those accessing the Pier by car, although they make up only 26% or 165 of survey respondents. The average family size of 3.5 boosts the average vehicle ridership (AVR) of those driving to the beach. The data indicates that providing ample nearby parking for families is important for this group’s beach access, although 12% do come by train or bus. Encouraging other modes of travel to the coast is important to ensure that the nearby parking remains available for families, who generally carry with them a day’s worth of beach supplies. 4. Accommodating All Ages The survey also looked at the influence of age in determining travel mode. The largest age group surveyed was 18-35 years old. The majority of these respondents traveled to the Pier by car, followed by the Expo (Figure 9). Age groups above 35 years see a gradual decrease in car use and increase in walking and transit. The 18–35 and 36–49 age groups have the highest driving rates, reflecting the family factor. 5. Welcoming First-time Visitors There appeared to be a high correlation between the number of respondents driving to the Pier and their frequency of visits (Figure 10). 199 respondents (32%) stated they were visiting the Pier for the first time. Of these, 58% drove, with 12% taking Expo and 5% taking the bus. As respondents returned to the Pier, results show a decrease in car use. From “first visit” to the most frequent visitors, who last visited “less than 1 week ago,” car usage decreased by 16%, 10% 2% 3% 72% 2%11% Primary Mode of Travel to Pier for Families Expo Bus Car Share Car Bike Walk Figure 8 44% 63%59%57%48% 7% 7%13%7% 4% 3%2% 4% 4% 1% 21% 14%9%15% 16% 7% 6%6%4% 8% 12% 5%8%12%20%2% 2%3%1% 0% 10% 20% 30% 40% 50% 60% 70% 80% 90% 100% <18 18-35 36-49 50-64 65+ Primary Mode of Travel by Age Car Walk Bike Motorbike Expo Car Share Bus Tour Bus Figure 9 11 Expo use increased by 8%, bus use increased by 11%, and those walking increased two-fold. One explanation may be that returning visitors are more likely to be aware of alternative transportation modes. This points to the importance of improving transit connections and educating the general public about transit options, including campaigns aimed at tourists, to further reduce coastal visitors’ reliance on cars and parking and meet the environmental goals of the City’s Sustainable City Plan and the LCP. Aside from the data, in discussions with respondents, surveyors often observed that visitors did not know how to take the bus, where Breeze Bikes are located or how walkable or bike-able coastal destinations are to each other. Where are Pier Visitors Parking? In addition to understanding how many people drive to the Pier, the study also sought to learn where people park when they go to the Pier. It is easy in Santa Monica to “park once” and reach multiple destinations by walking or biking, and the Pier is only a short walk from Downtown and the Civic Center. The study was interested in knowing specifically how reliant visitors to the Pier are on the beach and Pier parking facilities. The results showed that only 28% (179) of all 631 respondents used the Pier or beach lots to access the Pier, with the other 72% of visitors either parking elsewhere, or arriving by a mode other than car. Of the 368 respondents that arrived by car, nearly half (48%) parked at the beach or Pier lots (Figure 11). The survey showed that both frequent and infrequent visitors who drove to the Pier mostly parked at the Beach and Pier lots and in the Downtown Structures, shown in Figures 12 and 13. 46% of first-time visitors, and just over half (52%) of infrequent visitors, those that have not visited the Pier in over a year, parked either at the beach or Pier lots. At least 25% of all groups parked Downtown. Only 2% of first-time visitors and infrequent visitors, one or fewer visits per year, parked at the Civic Center. Conversely, visitors that are more familiar with the Pier, those who have visited within the last week, two weeks, or month, appear to use the Civic Center parking facility more, although they also parked mostly at the beach, Pier or downtown lots. The survey hours were not during the peak (weekend) times, and there is generally parking availability at the beach during the weekdays. On the 89 49 17 51 0 50 100 150 200 250 300 350 400 Car Expo Bus Bike Walk Primary Mode of Travel by Frequency of Visits to the Pier First Visit More than 1 year Within the past year Within the past month Within the past 2 weeks Less than 1 week 365 Figure 10 145 34 5 128 12 11 1 3 27 3 0 20 40 60 80 100 120 140 160 Parking Lot Utilization Figure 11 12 weekends, awareness of the Civic Center parking capacity is more important, and the survey results indicate that wayfinding help is needed for efficient parking use in the Coastal Zone. No Santa Monica residents parked at the Pier Lot or the Civic Center Lot and Structure. It is assumed that locals are aware of the congested conditions of the Pier ramp and Pier Lot. Civic Center parking was not used much by survey respondents, which may be because the survey was mid-week when that parking is used for municipal, courthouse and Santa Monica High School users. Mid-week is also the time when parking at the beach is generally available, although often more expensive. Nevertheless, wayfinding to real-time parking options from the I-10 exit would help visitors to find parking more quickly, particularly during higher peak times. Additionally, it is assumed that mapping apps, such as Google Maps, which 50% of respondents stated they use or are aware of, direct visitors straight to the Pier and adjacent Beach Lots, whereas it would be helpful if these apps took into account that the car’s destination is actually to a parking facility, not to the beach itself, and connected with real-time options for drivers. If more people were aware that other parking options are only a short walk away, demand for the beach lots, which were most highly used by those surveyed, could be reduced. Google Maps offers opportunities for organizations to provide alternative points of interest on the map that could show nearby Pier parking options. Technological improvements may have positive impacts in this way. 0% 10% 20% 30% 40% 50% 60% Parking Location for Infrequent Pier Visitors First Visit More than 1 year Within the past year Figure 12 0% 10% 20% 30% 40% 50% 60% Parking Location for Frequent Pier Visitors Less than 1 week Within the past 2 weeks Within the past month Figure 13 13 Traveling within the Coastal Zone While this survey took place on the Pier, it also sought to understand what other coastal destinations people may be visiting and how they will travel there. A significant number of people, 24%, were only visiting the Pier, but many did not know about other Santa Monica attractions or where they are located, such as Third Street Promenade and Main Street. Many did not know the proximity to Venice. Local residents who were only coming to the Pier are using it more for exercise than as a destination, and were observed as predominantly coming in the morning. Nevertheless, the vast majority, (76%) of respondents were also visiting other coastal attractions (Figure 14). Destinations of highest popularity are Downtown Santa Monica (36%), Santa Monica Beach (23%), and Venice Beach (17%). The Aquarium was also noted as a destination by some families visiting the Pier (9%). As a note, a surprising number of people interviewed on the Pier did not know how to get down to the beach by foot or bike, indicating that there may be a need to consider wayfinding through signage or other means. No matter their primary mode of travel to the Pier, 60% of respondents walked to their additional destinations (Figure 15). This is followed by biking, 14%. For visitors driving to the Pier, only 11% continued to use a car as a mode of travel to arrive at their other destinations. 153 57 152 26 3 17 78 162 7 10 21 14 111 8 0 20 40 60 80 100 120 140 160 180 Additional Coastal Destinations Figure 14 60%11% 14% 4% 1%2%1% Travel Mode Between Coastal Destinations Walk Car Bike (personal or rental)Bus (including beach bus) Tour Bus Car Share / Car Service / Taxi Scooter Figure 15 14 Examining the results from a different angle, Figure 16 shows the breakdown of how people planned to travel to specific destinations. For example, 67% of people walk to Tongva Park, 17% bike (personal or rental), and no one drives. To access the Annenberg Community Beach House, half of respondents planned to walk while the rest planned to bike there. A larger number of people driving between destinations were heading to Malibu, Venice or Main Street, or were stopping at the Pier on their way to or from work. Barriers to Access Lastly, this report addresses barriers to accessing the Pier. Of the 365 total respondents who drove to Pier, 145 of them reported experiencing barriers (40%) on their trip (Figure 17). This exceeded the barriers experienced by transit riders by a margin of more than 4:1. Nearly 35% of all respondents that drove to the Pier complained of “heavy traffic coming into Santa Monica”. Of the respondents who arrived to the Pier by public transit, 13 reported barriers (9%), with the biggest complaint being “Long wait for transit; bad route or experience.” Although this was the most commonly recorded complaint, it was only heard from 9 of the total 158 visitors that arrived to the Pier by transit. The lack of barriers reported by transit users is encouraging. Nevertheless, ongoing improvements to the quality and reliability of transit are very important to the visitor experience and more information on using transit should have a positive effect on its proportional use by visitors. Although it is often assumed that difficulty in finding parking is a barrier to accessing the Santa Monica coast, only 8% of all respondents that drove to the Pier had difficulties finding parking. Of those 8%, half of them parked on the Beach or Pier Lots. In other words, despite a majority of respondents accessing the Pier by car, few found it difficult to park in the Coastal Zone. Groups that included mobility-impaired persons mentioned difficulties accessing the Pier because of the uneven and textured surface of the Pier. This is an issue that is known to the Pier facility managers. Solutions are challenging due to the historic nature of the Pier plank surface and expectation that this authenticity will be preserved. 81% 25% 8% 50% 69% 67% 50% 38% 67% 68% 58% 91% 3% 33% 25% 6% 4% 3% 22% 16% 26% 9% 13% 16% 49% 12% 34% 45% 36% 11% 10% 5% 2% 17% 5% 6% 15% 3% 1% 5% 8% 5% 3% 3% 2% 3% 5% 0%10%20%30%40%50%60%70%80%90%100% Santa Monica Beach Malibu Beach Venice Beach Annenberg Palisades Park Tongva park Beach Bike Path Third Street Promenade Main Street Downtown Work or Business Aquarium Travel Mode Between Coastal Destinations Walk Car Bike Bus Tour Bus Car Share Motorbike Figure 16 40% 14% 9%7% 2%0%0%0% 5% 10% 15% 20% 25% 30% 35% 40% 45% Barriers by Mode of Travel Figure 17 15 Conclusion Although the Pier intercept survey may be somewhat biased as it was dependent on voluntary participation that may over-represent certain groups, it did nevertheless include a large sample of Pier visitors with a full spectrum of ages, group sizes and origins. The modal split for Pier access was encouraging, with more than 40% arriving by means other than car, in a region in which 2/3 of people commute by car and the automobile is the highly predominant mode for recreational travel as well. Furthermore, the surveyors believed that bicyclists were under-represented as many rode by and declined to stop and participate. To reiterate the findings discussed in the analysis above, the results indicate the following: • Visitors are arriving by a variety of modes, most commonly car, Expo Line, bus, and walking, confirming the City’s planning approach to coastal area visitor access; • Fewer than 1/3 of total survey participants parked at the beach/Pier lots; • Visitors were more likely to drive and park at the lots closest to the Pier; more return visitors parked at the Civic Center lots and on the streets than infrequent visitors; improved signage and wayfinding, as well as educational outreach, could help redirect visitors to less used options; • About one-quarter of survey participants only visited the Pier; • Most of those surveyed who were visiting more than one coastal destination within Santa Monica walked between them; many first time visitors were unaware of nearby points of interest, such as the Third Street Promenade, within walking distance; • The majority of those surveyed found it easy to access the Pier. Those that drove to the Pier reported experiencing access barriers at a rate of more than four times that of transit riders. The biggest barrier for drivers was heavy traffic coming into Santa Monica. A small number of drivers reported parking barriers; • The survey picked up significant interest in using transit, particularly the Expo Line. The City has demonstrated its commitment to improving wayfinding and establishing safe pathways for pedes - trians and bicyclists through its Bicycle and Pedestrian Action Plans. The survey confirmed that these measures are important, particularly based on the high number who reported that once in the coastal area they would be walking between multiple destinations. The City’s efforts to encourage transit use to access the Pier and beach as a strategy for reducing congestion and GHG emissions also seem to be having some early success, with a 14% modal share for Expo only two months after its opening. More education about transit options, parking facilities within walking distance of the beach, bike paths and the bike share program would allow visitors, particularly those coming to Santa Monica for the first time, to plan their trips more knowledgeably, which would reduce the number of vehicles and traffic congestion at the coast and enhance the beach experi - ence for all. Height Limits Analysis for the LCP Land Use Plan Update 1992 LUP (CHAPTER IV) Subarea Height Limits LUCE /CCSP Height limits for Subareas* SUBAREA 2 (PIER) 30 ft. SUBAREA 3b (Ocean Ave north of Colorado Ave ) 40 -45 ft. SUBAREA 4 (North residential) 28 -45 ft. SUBAREA 5 (Downtown) 45 -84 ft. SUBAREA 7 (Main Street) 27 -47 ft. SUBAREA 8 (Ocean Park) 27 -35 ft. SUBAREA 1 Up to 47 ft. SUBAREA 3 Up to 47 ft. SUBAREA 4 Up to 45 ft. SUBAREA 5 Up to 84 ft. SUBAREA 6 Up to 85 ft. SUBAREA 7 Up to 40 ft. SUBAREA 8 Up to 45 ft. *Height limits in LUCE & Bayside District Specific Plan; DCP pending. *Subarea 3a, 3c left out of LUP new development policy section SUBAREA 2 Up to 47 ft. (Exceptions for amusement park rides) Subarea 6, Civic Center , left out of LUP new development policy section Subarea 1, Santa Monica State Beach, left out of LUP new development policy section *NOTE : The right column reflects the maximum height limits within the range of all land use designations in each LUP Update subarea s , for which slight modifications to the current LUP are proposed . Proposed changes include the Downtown boundaries (Subarea 5 ) for consistency with the LUCE and DCP and a boundary adjustment to Subare as 3 and 6 to incorporate the mixed -use Village structures on the north side of Ocean Avenue into S ubarea 3 for consistency along Ocean Avenue.