SR 03-30-2021 8A
City Council Report
City Council Meeting: March 30, 2021
Agenda Item: 8.A
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To: Mayor and City Council
From: David Martin, Director, City Planning
Subject: Council Direction on Draft Concepts and Framework for Housing Element
Update
Recommended Action
Staff recommends that the City Council review, discuss, and provide direction to staff on
the draft concepts and strategies to include in the 6th Cycle Housing Element Update.
Summary
The City is mandated by the state of California to plan for the community’s housing
needs every eight years through the Housing Element Update. The 2021-2029 Housing
Element planning period takes place against the backdrop of a declared housing crisis
in California highlighting the projected and current unmet housing needs, especially
affordable housing. Santa Monica’s final Regional Housing Needs Allocation (RHNA) of
8,895 units, of which 6,168 units must be affordable, was adopted by the Southern
California Association of Governments (SCAG) Regional Council on March 4, 2021.
The effects of the COVID-19 pandemic have also brought barriers to housing access in
addition to housing insecurity for existing residents more sharply into focus. It has
particularly highlighted equity issues in terms of how lack of housing affordability
disproportionately affects people of color and the need to reexamine land use and
zoning decisions to ensure that they do not perpetuate these inequities. While the
significantly larger RHNA allocation is a planning challenge, the timing of this Housing
Element Update process presents an opportunity to reflect on and assess the City’s
approach to affordable housing production. It is also an opportunity for the City to take
a leadership role in creating solutions to address affordable housing production and
stability in line with Santa Monica’s values to provide secure, livable, and affordable
housing opportunities for all.
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Since the launch of the update process in September 2020, staff has conducted
webinars and study sessions and worked with two technical working groups on housing
production and housing stability to work through concepts to be brought forward for
broader community input and discussion. This report provides baseline information on
the preliminary suitable sites analysis based on the methodology for identifying and
prioritizing potential housing sites presented to the City Council on December 15, 2020
and presents strategies and associated tools that could be used to plan for the RHNA
allocation. Council should discuss and provide direction on the following framing
questions that will inform concepts and strategies to be included in the draft Housing
Element Update to return in June:
1. Where should housing be located to meet adopted goals of locating near daily
needs like open space, schools, jobs, and shops while also overcoming historic
patterns of segregation?
2. The housing production targets heavily favor affordable housing. Provide
feedback on the following 4-point strategy to plan for affordable housing:
a. Maximize inclusionary housing
b. Support 100% affordable housing including moderate income
c. Protect existing units and seek opportunities to convert existing units to
long-term affordability
d. Establish ADU incentives for additional units which may also be affordable
by design (due to their smaller size)
3. Should there be relaxed rules to allow for more housing opportunities on unique
sites like:
a. Religious congregation parking lots
b. A-lots
4. There are approximately 17 acres of City-owned land in Santa Monica that has
greatest potential to accommodate housing. Should housing, especially
affordable housing, be prioritized on these sites? If so, should a policy be
established to require a minimum amount of affordable housing units in any
future development partnership?
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5. With limited available resources, what updates to programs and services should
be prioritized that would best ensure the housing stability of existing Santa
Monica residents?
To assist in answering these questions, this report is organized as follows:
I. Background on the Process & Updated Draft Goals
II. Santa Monica’s Housing Stock & Community Housing Needs Assessment
a. State of Housing in Santa Monica
b. Housing Needs Assessment
i. Housing Needs of Existing Residents
ii. Housing Needs of Workers
III. RHNA Challenge & Opportunity
a. Existing Affordable Housing Production Tools
i. How is Affordable Housing Produced?
ii. Increased Land Value Capture through Regulatory Community
Benefits
b. Overview of Housing Production Approaches Used by Other Cities
i. Elimination of R1 Zoning / Consideration for Missing Middle
Housing
ii. Los Angeles Transit-Oriented Communities Program
iii. Affordable Housing Overlay
c. Barriers to 100% Affordable Housing Production
d. Preliminary Results from Feasibility Analysis Testing
IV. Components of a Regulatory Approach for Meeting the RHNA
a. Where Should Housing be Located – Conceptual Options
b. Suitable Sites Inventory – Preliminary Sites Analysis
i. Determining Whether Sites are Suitable for Housing
ii. Assessment of Unique Sites for Housing Potential
iii. Assessing the Likelihood for Residential Development
c. Evaluating the Preliminary Sites Analysis Through the Lens of
Affirmatively Furthering Fair Housing
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i. Background on Housing Discrimination in Santa Monica
ii. How Redlining Contributed to Housing Segregation
iii. Affirmatively Furthering Fair Housing in Housing Elements
d. How Much Housing Should be on Each Site – Four-Pronged Strategy
for Affordable Housing Production
i. Strategy #1 – Maximize Inclusionary Units in Market Rate
Housing
ii. Strategy #2 – Support 100% Affordable Housing
iii. Strategy #3 – Protect Existing Units for Long-Term Stability
iv. Strategy #4 – Incentives for Accessory Dwelling Unit (ADU)
Production
v. Other Concepts Evaluated for the SSI
V. Programs for Housing Stability
a. Programs to Address Housing Needs of Existing Residents
b. Housing Program Assessment
c. Stability Technical Working Group Concepts & Recommendations
i. Potentially Viable Concepts
ii. Other New Concepts / Future Concepts
VI. Ramifications of Future Non-Compliance
Background
I. Background on the Process and Updated Draft Goals
Outreach Process
Due to social distancing restrictions and stay-at-home orders, the outreach process for
the Housing Element Update shifted to virtual platforms. The outreach process started
in September of 2020 with the launch of the project website. The website has been the
main hub for the community to get information on the Housing Element Update process,
including background information on the City’s status on housing, questionnaires, an
FAQ page, a listing of upcoming events, and various resources from past events, such
as summaries, recordings, and staff reports.
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Following the project launch, staff organized a new process for engaging the community
in a digital forum. The process included two streams for public input and engagement.
The first more traditional engagement included the above-mentioned website,
questionnaires, webinars, and study sessions with boards, commissions, and Council.
The second stream of public input was through the formation of Technical Working
Groups.
Two Technical Working Groups were established, one for Housing Production and
another for Housing Stability. These technical working groups allowed practitioners and
interested community members in the fields of housing preservation and production to
provide their expertise, data, ideas, and feedback. The two groups met four times each
between December 2020 and February 2021, where they reviewed and commented on
past goals, programs related to housing production and preservation, background data,
and assumptions underlying the feasibility analyses.
The draft ideas and concepts from the Technical Working Groups are currently being
filtered back for the community’s review through a static online webinar and
questionnaire in addition to study sessions with the Planning Commission and City
Council. The static webinar is available for the community to take through April 2, 2021.
Figure 1: Draft concepts for broader community discussion have been developed
through Technical Working Groups
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In addition to the direct outreach to the community, Staff distributed a questionnaire to
get feedback on previous goals and programs from the 2013-2021 Housing Element.
The questionnaire consisted of 11 questions, reviewing each of the seven Housing
Element goals and seeking feedback on future housing goals and needs. The
questionnaire (available in English and Spanish) launched on November 14, 2020 and
closed on December 11, 2020, during which time staff received 425 total responses.
The questionnaire was advertised through the project website, weekly email blasts,
Seascape, and the Rent Control Board newsletter. Results of the questionnaire
highlighted that there is room for improving the development and entitlement process,
which can act as a barrier to housing development. Respondents also saw a need to
house the City’s workforce that do not currently live in the City due to the lack of
affordable housing. Overall, the majority of respondents agreed with the seven goals of
the previous Housing Element.
Since the launch of the Housing Element Update, staff held several study sessions with
Boards, Commissions, and City Council to solicit feedback and direction on the general
approach for outreach, the RHNA allocation, and the suitable sites inventory analysis.
Below is a table with the dates and hearing bodies for the study sessions to date.
Date Hearing Body Agenda
December 10, 2019 City Council Study Session
November 18, 2020 Planning Commission Study Session
December 10, 2020 Rent Control Board Study Session
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Date Hearing Body Agenda
December 15, 2020 City Council Study Session
January 7, 2021 Housing Commission Study Session
January 20, 2021 Planning Commission Update Discussion
March 16 & 17, 2021 Planning Commission Discussion and
Recommendation
Additionally, on February 19, 2021 the Mobility Division of the City released a public
survey to gather data and information on commute trends in relationship to housing
needs, with a focus on Santa Monica workers. The survey was sent to all parties on
multiple City mailing lists (housing, mobility, Buy Local, Santa Monica Shines), the
business community, industry partners (Santa Monica Travel and Tourism, Chamber of
Commerce, Hospitality Training Academy, Community Corporation of Santa Monica),
Santa Monica Malibu Unified School District, and the City’s Employee Transportation
Coordinators, and to 9,100 Big Blue Bus customers. The survey was also publicized on
social media, including Facebook, Twitter, and LinkedIn. At the time of this writing, there
were over 2,000 respondents for the survey.
Staff will continue its outreach process, first with a survey to homeowners with onsite
ADUs and renters of ADUs to get a sense of how ADUs are being used and an
understanding of the contribution of ADUs to affordable housing. Future engagement
opportunities will be available to the community including opportunity to learn about the
proposed concepts and provide feedback through a survey. Adjustments will be made
based on feedback received from the Council and community. Staff will also work with
community partners and local housing providers to reach disadvantaged communities
and existing low-income tenants. All future outreach and engagement opportunities will
be posted to the project website.
Updated Goals for Housing Element Update
The following draft updated goals are based on the discussions and feedback provided
during the Planning Commission study session on January 20, 2021, and by the
Technical Working Groups. The Planning Commission also provided more specific
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concepts and language updates on the existing objectives that support each of the main
goals below that will further be evaluated and addressed.
1. Goal 1: Construction and adaptive reuse of resulting in new housing that is high
quality durable, sustainable, compatible appropriate with the surrounding
neighborhood, and offers opportunities for active living.
2. Goal 2: Housing production for all income categories including housing for the
community’s workforce and most vulnerable communities.
3. Goal 3: Protect the existing supply of affordable housing [“affordable” will be
termed in a broader sense].
4. Goal 4: Rehabilitation and continued maintenance of the existing housing stock.
5. Goal 5: Provision of housing assistance and supportive programs and services to
very low–, low-, and moderate-income households and households with special
needs, working families, seniors, and the homeless.
6. Goal 6: Elimination of discrimination in the rental or sale of housing on the basis
of race, religion, national origin, sex, sexual orientation, gender identity
preference, age, income level, disability, family status, aids, or other such
characteristics, and promotion of racial equity in housing distribution.
7. Goal 7: Inform, engage, advance credible information, and promote active
participation of citizens residents, community groups, workers, stakeholders, and
governmental agencies in housing, community development, and neighborhood
public safety activities.
II. Santa Monica’s Housing Stock and Community Needs Assessment
State of Housing in Santa Monica
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While it is recognized that housing is essential for providing safe shelter, opportunity for
work, education, and recreation, housing also promotes health, wellbeing, family
security, and financial stability. Across California, the opportunity to live in safe,
affordable housing that is reasonably located close to a person’s place of work has
become more and more unattainable over the past few decades. During his State of
the Union address on Tuesday January 11, 1944, President Franklin Roosevelt put forth
his Second “Bill of Rights” in which he declared that housing was a critical right to
assure “us equality in the pursuit of happiness”. With the loss of thousands of jobs due
to COVID, and many more facing evictions and homelessness, the City is facing a
deepening housing affordability gap of unprecedented scale. Primary findings of a
detailed assessment (Attachment A) on the City’s existing housing characteristics,
population, and employment include:
Finding One: Housing Costs are High
While it is widely recognized that housing costs in California are the highest in the
nation, the City of Santa Monica ranks as one of the most expensive places to live. The
median cost of a single famiy home in 2019 was at almost $4 million, more than 5 times
the national median cost. While condo ownership offers an easier pathway to
ownership, the median condo cost in 2019 was close to a million and since the
pandemic, has increased to approximately $1.1 millon.
Figure 2: Santa Monica has one of the most expensive housing markets in California
and the nation
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Rental prices are similarly high, with the median monthly rents for a 2-bedroom
apartment at $3200 a month. Since the pandemic, rental prices in the City have
dropped – one study found an approximate 13.8% decrease in rent prices; however, it is
unknown at this time whether this drop in rent is a temporary phenomenon.1 Even with
this decrease in market rents, housing cost still makes up a large proportion of
household spending in the City. The general rule is that no more than 30% of gross
monthly income should be spent on housing. Households that spend more than this
percentage are considered to be “housing cost burdened;” according to 2019 American
Communities Survey (ACS) estimates, more than 42% of the City's rental households
are considered housing cost burdened.2
Figure 3: More than 42% of Santa Monica households are cost burdened (spend more
than 30% of their income on housing costs)
1 https://advisorsmith.com/data/cities-where-rents-are-rising-and-falling-the-most/
2 American Communities Survey, 5 Year Estimate 2019
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Finding Two: Lower Income Households are Disproportionately Affected by High
Housing Costs
Lower income households are disproportionately affected by high housing costs. In
Santa Monica, almost 70% of extremely low -income households spend at least 50% of
their income on housing (considered “severely cost burdened”), compared to about 60%
for the rest of the United States.3 Having less money available for non-housing costs
often means that low income households will have less savings in the bank, putting
them at risk for poverty or preventing them from rising out of it.4 This has the associated
effect of forcing households to choose between housing security and meeting basic
needs. The pandemic has worsened this situation - UC Berkeley’s Terner Center for
Housing Innovation estimated that by August 2020, nearly 60 percent of renters in Los
Angeles have experienced a COVID-related job loss – a number that has continued to
grow. Yet the highest wage workers have largely been spared from the financial fallout
of the pandemic. Many higher wage workers are able to work remotely and retain their
wages, while lower wage workers such as those in the essential retail and restaurant
sectors found themselves struggling to pay their monthly rent while also being
disproportionately affected by COVID-19. This is evident in the preliminary results from
3 HUD CHAS 2012-2017 Data
4 Typically, poverty is calculated by the Official Poverty Measure, which defines a family as poor if their pretax cash income is less than a
poverty threshold that is standard across the nation.
Cost-Burdened
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the City’s Mobility Survey which indicate that workers in Santa Monica earning more
than $40,000 a year were more likely to telework than those with lower incomes.
Figure 4: Number of Santa Monica Workers Teleworking by Income Levels since
Pandemic
Income SM Worker Survey
Respondents
Average Telework Days per
week
Less than
$40k/yr
202 2.5
$40k/yr or More 1015 3.4
Finding Three: Black and Latino Households are Severely Cost Burdened
The demographic groups most at risk of evictions andforeclosures are Black and Latino
households, who have the lowest median annual household incomes in the City.
Figure 5: Black and Latino households have the lowest median annual household
incomes with White and Asian households having the highest
$97,415
$64,444
$105,395
$109,528
$42,703
$100,691
$71,483
White Alone
Some Other Race
Two or More Races
Asian
Black
White Alone, Not Hispanic
Hispanic or Latino
Median Household Income by Race of Householder -Santa Monica
Source: American Communities Survey, 5-Year 2019 estimates
With the City’s high housing costs coupled with low wages, approximately 11.7% of
Black and 8.6% of Hispanic/Latino family households in the City were living in poverty
even before the pandemic. The US Census Bureau weekly Household Pulse Survey
(which measures how the pandemic is affecting people’s health, housing, and
livelihoods), indicates about a quarter of Black and Latino renters who responded to the
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survey did not pay or deferred rent in May 2020, compared with 14 percent of white
renters. And while a quarter of white renters expressed slight or no confidence in their
ability to pay rent in June 2020, nearly half of Black and Latino renters expressed similar
concern. While the federal government and State have passed eviction moratoriums to
protect tenants and stem the wave of evictions, these actions are temporary. As the City
recovers from the COVID-19 pandemic, it will be important to rebuild an economy that
provides secure, livable, and affordable housing opportunities for all.
Housing Needs Assessment – Who Is Being Left Behind in the Housing Market?
Housing Needs of Existing Residents - Ensuring Long-Term Stability
Santa Monica has consistently prioritized providing a diversity of housing opportunities
that cater to all household types and income levels. To foster an inclusive and diverse
community, it will be essential to provide housing that meets the needs of everyone,
including low-income households, seniors, people of color, families, and households
with children.
Figure 6: 42% of total households are families and a quarter are Senior households;
40% of total existing households are cost burdened.
Source: American Communities Survey, 5-Year 2019 estimates
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Figure 7: The number of family households has remained relatively stable over the past
30 years.
Source: American Communities Survey, 5-Year 2019 estimates
With renters comprising 73% of households, the city has adopted progressive policies in
rent control, source of income discrimination, and inclusionary zoning coupled with
strong tenant protections. The potential loss of existing units and associated
displacement of existing residents must be considered in the context of planning for the
community’s future housing needs. Figure 6 shows that families and Seniors make up
a significant share of total households. The number of family households has also been
relatively stable over the past 30 years – either because family households are forming
at slower rates or that relatively even numbers of family households are entering and
leaving the City. The census data also shows that 40% of total households in Santa
Monica are considered cost-burdened. The initial phase of outreach on the Housing
Element process revealed that housing affordability continues to be a top concern.
While rent control was enacted to ensure long-term rent stabilization, the Rent Control
Board reports that after over 20 years of vacancy decontrol, 73% of controlled units are
at market rate5, a percentage that will likely continue to increase over time. If existing
residents experience Ellis Act evictions and housing prices continue to remain high,
housing affordability will continue to decline resulting in a squeezing out of the middle
class in Santa Monica. As a result, the housing needs for existing residents largely
center around ensuring long-term housing stability and opportunities to relocate within
Santa Monica in the event of displacement.
5 City of Santa Monica, Annual Rent Control Report, 2019
https://www.smgov.net/uploadedFiles/Departments/Rent_Control/Reports/Annual_Reports/2019%20Annual%20Report%20FINAL.pdf
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Figure 8: Renters are predominantly Black and Latino; Owners are predominantly Asian
and White
Housing Needs of Santa Monica Workers - Priced Out of the Housing Market
The City’s economy includes a diverse variety of industry sectors. With the Information
and Professional/Scientific/Technical Industries comprising over 30% of the City’s
economy, it is not surprising that the City has earned its moniker of “Silicon Beach”. The
City is also a popular tourist and visitor hub, with almost 25% of the workforce in the
Food and Accommodation and Retail Trade sectors.
Figure 9: Santa Monica has a diverse range of employment sectors but 25% of the
workforce works in Accommodation/Food Services & Retail with generally lower wages
than other sectors (source: California EDD)
8%26%43%36%
9%13%19%18%31%
92%74%57%64%
91%87%81%82%69%
Black or African AmericanAmerican Indian and Alaska NativeAsianNative Hawaiian and Other Pacific IslanderSome other raceOtherTwo or more racesHispanic or Latino originWhite alone, not Hispanic or Latino
Renter vs Ownership Household by Race
Owner Renter
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Prior to the COVID-19 pandemic, approximately 91,000 people worked in the City.
Ideally, workers can choose to live close to their place of employment in a neighborhood
that offers abundant retail, services, open space, and good schools. Yet, many cannot
afford to live close to their work since most of their jobs are located in metropolitan
areas where housing costs tend to trend higher. This is especially true in Santa Monica
where only 9% of the 91,000 employees live within the City. The remaining 91%
commute from areas outside of the City, with the majority commuting from the
surrounding areas of the Los Angeles region. Because their wages are not enough to
pay for the high housing cost in the City, lower-wage workers are commuting as far east
as the San Gabriel Valley and Inland Empire and as far north as Ventura County,
driving two to fours hours daily to live in more affordable areas. In 2019, there were
35,046 out-of-town commuters making less than $40k out of 84,186 total out-of-town
commuters, for an estimate of 41.6%.
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Figure 10: Average wages for essential workers that support Santa Monica’s economy
Figure 11: Map showing Jobs Per Square Mile
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Creating housing opportunities for the City’s workers is also critical to curbing
greenhouse gas emissions. In 2019, the City established a commitment to achieve
Carbon Neutrality by 2050 when it adopted the Climate Action and Adaptation Plan.
Transportation is the largest sector contributing to the emissions of greenhouse gases,
accounting for approximately 64% of the City’s greenhouse gas inventory. Studies have
shown that building housing, particularly affordable housing, close to jobs reduces
vehicular miles traveled and in turn reduces commute times and greenhouse gas
emissions. For that reason, linking housing location to transportation and access to daily
services is the foundation of the City’s adopted Land Use and Circulation Element
(LUCE).
Staff surveyed Santa Monica workers to gather data and information on commute
trends in relationship to housing needs. Summary results from the survey are included
as Attachment G to this report. This section focuses on responses from Santa Monica
workers who live outside of Santa Monica as 91% of the City’s workforce lives outside
of Santa Monica. In general, respondents who commute into Santa Monica reported a
median yearly household gross income of $85,000. The majority of respondents rent
their homes (64%), and a plurality live in a 2 bedroom home (36%), with median
rent/mortgage payments of $1,900 per month.
The following two graphs show how the pandemic has affected commuters primary
travel mode, as well as their teleworking habits:
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Prior to pandemic, the majority 74% of respondents drove alone to work with 16%
taking public transit. During the pandemic majority 46% of respondents reported driving
along to get to work while nearly 45% reported telecommuting and 5% reported using
public transit. Post pandemic 70% of respondents anticipate driving alone, with 15%
anticipating taking transit to get to work. While these numbers indicate a return to solo
driving post-pandemic, survey respondents anticipate they will drive slightly less than
pre-pandemic with an estimated 3% increase in teleworking and close to 1% increase in
bike commuting post-pandemic.
An overwhelming majority of respondents reported housing cost (91%) as a barrier to
living and working in Santa Monica. While housing cost was by far the biggest reported
barrier, 14% also cited a desire for home ownership, 7% cited low quality of housing,
and 7% also cited the desire for proximity to family (percentages don’t sum to 100, as
respondents were allowed to identify multiple barriers).
The survey was sent to all parties on multiple City mailing lists (housing, mobility, Buy
Local, Santa Monica Shines), the business community, industry partners (SMTT,
Chamber of Commerce, Hospitality Training Academy, Community Corp of Santa
Monica), Santa Monica Malibu Unified School District, the City’s list of Employee
Transportation Coordinators, and 9,100 Big Blue Bus customers. The survey was also
publicized on social media, including Facebook and Twitter. Over 1,700 Santa Monica
workers responded, with about 900 of these workers living outside of the City. The
respondents represent a diverse cross section of workers in Santa Monica with
approximately 40%, 12%, 6% and 5% from the public education, government,
hospital/healthcare, and restaurant industries, respectively. The median age of in-
commuting respondents was 42 years old, with 35% identifying as white non-Hispanic
and nearly 30% identifying a Hispanic/Latino, 12% identifying as Asian, and another
12% identifying as Black, non-Hispanic.
III. The RHNA Challenge and Opportunity
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The final Sixth cycle RHNA allocation calls for planning for 8,895 housing units, of which
70% (6,168 units) are affordable as shown below. Attachment F provides the final
allocation for the entire SCAG region.
Figure 13: Santa Monica’s 6th Cycle Final RHNA Allocation
Income Category
6th Cycle
RHNA
Allocation
% of
Allocation
Very Low Income
(0-50% AMI) 2794 31%
Low Income
(51-80%AMI) 1672 19%
Moderate Income
(81-120% AMI) 1702 19%
Above Moderate
(>120% AMI) 2727 31%
Total 8895 100%
This number reflects demand from low- to moderate-income residents and workers – a
group that finds itself squeezed out of the Santa Monica housing market. The RHNA
allocation presents a unique challenge and opportunity for Santa Monica to continue to
demonstrate leadership in the arena of affordable housing. Constructing over 6,000
units of affordable housing would require approximately $4B6 in funding, highlighting the
need to explore creative local tools in concert with ongoing advocacy for State and
Federal assistance. The City has a long history of leveraging its assets to produce
affordable housing in support of the community’s core values of equity, inclusion, and
sustainability. Housing diversity and affordability is a shared value that permeates
adopted City policy. Enacting a housing strategy that will resonate beyond the next
eight years would be in line with past ground-breaking actions the City has taken such
as enacting one of the first historic preservation ordinances, voter-approved rent control,
and banning single-use plastic bags.
In order to evaluate possible approaches to this challenge, two working groups on
housing production and stability were convened consisting of a broad cross section of
6 Estimated $700,000/unit total development cost based on recent affordable housing projects
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housing providers, design professionals, service providers, property owners, and
community members interested in housing issues. Staff also reviewed strategies that
other cities have undertaken to spur affordable housing production.
Existing Affordable Housing Production Tools
How is Affordable Housing Produced?
Affordable housing in Santa Monica is generated by two sources: market-rate housing
and the City’s Housing Trust Fund. Market-rate housing generates affordable housing
through the Affordable Housing Production Program (AHPP). The AHPP has its roots in
Proposition R, passed by the voters in 1990 and mandating that at least 30 percent of
new housing must be affordable. The AHPP implements Proposition R by making the
creation of affordable housing a mandatory requirement in new market-rate housing.
Market-rate housing projects have options to comply with the AHPP’s requirements in
the following ways:
• Pay an in-lieu fee that goes into the Housing Trust Fund
• Provide affordable units on-site
• Provide affordable units off-site
• Purchase and contribute land to be used for affordable housing
At the time the AHPP was enacted in 1994, it was among the most aggressive
inclusionary housing programs in California. The goals of Proposition R have not been
achieved through inclusionary units from market-rate housing alone. In the 25 years
since the AHPP was enacted, 38% of total housing units have been affordable. Of that
number, approximately 40% of affordable units have been produced through market-
rate housing while the remaining 60% of units have been funded through the City’s
Housing Trust Fund.
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Figure 14: Market Rate and Affordable Housing Production 1994-2019 shows that
affordable housing production relies on both private and public assistance.
The City also has a tiered land use system where applicants seeking increases in height
and floor area ratio (FAR) (i.e., “Tier 2 projects”) must provide additional community
benefits. This regulatory community benefits system was adopted in the 2015 Zoning
Ordinance update implementing the LUCE concepts to capture the value of increased
development potential on land values.
Increased Land Value Capture through Regulatory Community Benefits
Land Value Capture is a planning mechanism through which increases in land value
resulting from public investments, land-use plan changes, and upzonings, are captured
for public benefit. When understood in this light, it is only fair and equitable for the
community to “capture” a reasonable share of the increased land value in the form of
community benefits, including affordable housing.7 Real estate and economic
development firm HR&A conducted a feasibility analysis in support of the adopted
community benefits structure in the 2015 Zoning Ordinance Update and 2017
Downtown Community Plan that was intended to identify the increased land value to a
project by going to Tier 2 and Tier 3 standards. That value can be assigned to priorities
determined by the City, and in those adopted plans, affordable housing production was
prioritized. This was converted into increased AHPP requirements for Tier 2 and Tier 3
projects in addition to augmented development impact fees for transportation systems,
parks, and childcare.
7 https://www.tandfonline.com/doi/full/10.1080/02673037.2020.1746244
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If the value of the additional requirements (a cost to the developer) is higher than the
value of the overall development (encompassing any development bonus or incentives),
the project will be made infeasible. If the value of the development bonus or incentives
is higher than the value of the additional requirements, the value of the land is likely to
increase.
Figure 15: Illustration of relationship between project costs (including City requirements)
and likelihood of a developer proceeding with a project.
Past performance indicates that moving forward, further incentives will be necessary to
support the development of affordable housing.
Overview of Housing Production Approaches Used by Other Cities
Staff conducted a review of strategies that other cities have taken in planning for the
housing needs of their communities. The discussion of each strategy below includes an
assessment of whether the strategy would be appropriate for Santa Monica.
Eliminating R1 zoning / Consideration for Missing Middle Housing
Description: Minneapolis and Portland were the first cities in the nation to eliminate
single-family zoning in recognition that such exclusionary zoning perpetuates de facto
racial and economic segregation. More recently, a number of California cities
(Sacramento, San Jose, Oakland) have formally adopted resolutions announcing their
intent to eliminate single family zoning. This also includes Berkeley, California – the
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birthplace of single-family zoning. Single-family zoning originated in 1916 as a social
engineering tool to keep Blacks and Asians from the Elmwood neighborhood of
Berkeley. The consultant who penned Berkeley’s zoning ordinance wrote that it served
the “great principle of protecting the home against the intrusion of the less desirable and
floating renter class.” Within California, some cities have taken actions towards
eliminating single-family zoning, recognizing the segregation it has created in their
communities. The City of Sacramento has included such a policy in their General Plan
Update and Berkeley recently passed a resolution committing to ending single-family
zoning by 2022. Implementation actions are still pending on these strategies.
Assessment for Santa Monica – further assessment needed as there may be better
strategies available to accomplish the goal of providing equitable housing access: As
the RHNA is heavily skewed towards affordable housing, the City’s single-family (R1)
zones, which have high land costs, are not likely to have high potential for lot
consolidation necessary to support affordable housing. Some members of the
Technical Working Group on housing production, as well as respondents for the
Housing Element Update survey, have suggested that the City consider the elimination
of single-family zoning. Although approximately 35% of the City is zoned R1 for single-
family housing, only 13% of the City’s housing supply is located in these areas. The
construction of new ADUs in recent years has increased housing opportunities in single
-family zones, areas which have traditionally been out of reach for renters. However,
there has been growing discussion at the local and State level regarding increasing
density in single-family zones to not only open up greater housing opportunities but also
to address historic discriminatory housing practices.
As a more incremental approach, staff also evaluated the potential for rethinking the
form and scale of R1 neighborhoods with allowance for “missing middle”8 housing –
essentially lower-scale development that increases density and diversity of housing
types but still maintains the existing street character. Based on design and feasibility
studies that have been done in similar high land cost communities, such as Mountain
8 www.missingmiddlehousing.com defines “missing middle” housing as house-scale buildings with multiple units in walkable neighborhoods.
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View, it was found that generally a minimum of 6 to 7 units is necessary to support
affordable housing, which would not align with the missing middle development type. If
R1 zoning were to be eliminated, further assessment would need to be done to explore
whether an average-size parcel could accommodate a viable deed-restricted affordable
housing project. Adding capacity to R1 zones could instead be accomplished with
additional ADU incentives that may result in units that are affordable by design.
Los Angeles Transit Oriented Communities (TOC)
Description: The City of Los Angeles has an incentive program to encourage the
construction of on-site affordable housing within ½ mile of major transit stops. The
program provides either density or FAR bonuses if an applicant provides a minimum
percentage of affordable units based on selected “tiers”. Since the program is
voluntary, one of the eligibility requirements is that the project does not seek an
additional density bonus.
Assessment for Santa Monica – somewhat duplicative of Santa Monica’s existing
development system: The TOC program is instructive as it roughly mirrors Santa
Monica’s tiered land use system along with a menu of affordability levels that then relate
to a development bonus for housing projects. The concept of integrating a FAR bonus
into a tier system and relief for development standards is very similar to Santa Monica’s
existing tiered land use system that incorporates an FAR bonus for housing projects
that provide on-site affordable units housing.
Affordable Housing Overlay
Description: Cambridge, MA enacted an affordable housing overlay that allows for
construction of 4-story affordable housing projects citywide with an increase to 7 stories
on commercial corridors, eliminates parking minimums, and generally eliminates zoning
standards that present barriers to the production of affordable housing. This was done
in similar conditions to Santa Monica of high land prices and an affordable housing
crisis. The overlay also creates a by-right process for affordable housing projects.
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Assessment for Santa Monica – somewhat duplicative of existing process and
incentives already in place for 100% affordable housing projects but value in
harmonizing into cohesive program: Santa Monica already has a local system in place
in combination with State density bonus law that allows affordable housing to proceed
through an administrative process, reduced parking standards, and FAR bonuses.
Changes to State density bonus law (AB1763) furthered those process and
development incentives by allowing no density limits, extra 3 stories or 33 feet, and no
minimum parking requirements in areas within ½ mile of a major transit stop. Projects
would also be able to request up to 4 incentives or concessions from zoning standards
that are necessary to construct the affordable housing. These relaxed rules affect a
very large portion of the City except for North of Montana Avenue and some parts of
Sunset Park. The complexity of the City’s requirements coupled with stated barriers to
affordable housing production such as high land cost, means that affordable housing
providers are at a significant disadvantage in the real estate market if there are not
guarantees that they have feasible projects. The administrative process is currently
activated under an interim zoning ordinance and height limits vary throughout the city
providing no distinguishable advantage to affordable housing providers. Therefore,
there is value in considering a simplified system that harmonizes requirements for 100%
affordable housing projects citywide. Council voted to direct staff to evaluate this
strategy at their March 9, 2021 meeting.
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Figure 16: SCAG Map showing half mile from major transit stops. 100% affordable
housing projects can have unlimited density and up to an extra 3 stories/33 feet in these
areas.
Barriers to 100% Affordable Housing Production
Staff held a roundtable with affordable housing providers on February 25, 2020 to
understand how the City’s regulatory environment affects the production of affordable
housing and to explore potential ideas to enhance the competitiveness of affordable
housing developers in the market. Participants were asked to provide comments on the
opportunities to maximize scale/funding for their projects, development barriers in Santa
Monica, partnership opportunities with market-rate developers, and
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innovations/legislative proposals. Representatives from the following housing providers
participated in the roundtable:
• Community Corporation of Santa Monica
• EAH Housing
• Amcal
• Linc Housing
• Step Up
• Abode Communities
• Southern California Association of Non-Profit Housing
Participants stated that while the City generally provides good process and
development incentives in support of 100% affordable housing, there remain the
following major barriers to production of affordable housing:
• Lack of funding
• Land costs
• Insufficient height and density to produce necessary units
• Commercial prevailing wage requirements that trigger at 5 stories
• Construction costs associated with the City’s Fire Code requirements for high-
rise buildings that trigger at the City’s threshold of above 55 feet
These barriers have helped inform the draft concepts to support 100% affordable
housing discussed later in this report.
Preliminary Results from Feasibility Analysis Testing
On November 12, 2019, Council authorized a first modification to agreement #10830
(CCS) with HR&A Advisors, Inc., for financial feasibility analysis in support of the
Housing Element Update. Unlike prior scopes of work completed by HR&A for the City
that modeled a range of standard development prototypes, the scope of work for this
Housing Element Update included a “back-end” testing of the minimum development
standards necessary to feasibly support various percentages of inclusionary affordable
housing. The purpose of the analysis is not intended to assess whether an owner would
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have a fair rate of return under existing regulations. Rather, it is intended to provide an
indicator of what development standards are necessary for residential to likely occur
(versus office) assuming the following percentages of inclusionary affordable housing:
• 7.5% of the units for ELI households,
• 10% of the units for VLI households,
• 15% of the units for VLI households, and
• 20% of the units in the following mix: 25% ELI, 25% VLI, 25% LI, and 25%
Moderate Income households based upon the proportional allocation in the 6th
Cycle RHNA.
• 30% of the units in the same mix as the 20% affordability scenario
Figure 17: Map of Study Areas for HR&A Residential Likelihood Analysis
The project team conducted research of current market conditions, and modeled
construction costs of residential development utilizing inputs from the Housing
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Production Technical Working Group, which included local housing developers,
architects, land use attorneys, housing providers, and other stakeholders. HR&A tested
the likelihood of prototypical residential/retail developments to occur, assuming the
various affordability percentages for the following areas:
• Boulevards
o MUB – Wilshire
o MUBL – Broadway, Colorado, Santa Monica Blvd, Pico
o NC – Main, Montana, Ocean Park
o GC – Lincoln south of I-10
• Downtown
o Transit Adjacent (TA)
o Neighborhood Village (NV)
• Bergamot Area Plan –
o Bergamot Transit Village (BTV)
o Mixed Use Creative (MUC)
Preliminary Results Indicate that Increases in FAR and Height Are Necessary in Most
Areas of the City In Order to Support Increased Inclusionary Housing Levels
HR&A’s preliminary results are presented in Attachment B. The analysis found that,
based on current development standards:
• Retail/residential prototypes in some areas could support the 7.5% ELI
scenario at current zoning standards
• Retail/residential prototypes in Downtown Transit Adjacent (TA) and
Neighborhood Village (NV) zones and in Bergamot could support the 10%
and 15% VLI scenario at current zoning standards
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• Only retail/residential prototypes in the Downtown TA and NV zones could
support the 20% affordable units of varying affordability, at current zoning
standards.
• Only retail/residential prototypes in the Downtown TA and NV zones could
marginally support the 30% affordable units
Figure 18 below summarizes the preliminary HR&A results, which indicate that
increasing the percentages of inclusionary affordable housing above 7.5% ELI would
require an increase in FAR and height limits for housing projects to be most likely to be
developed.
Figure 18: Preliminary Results of HR&A Affordability % Testing at Existing Standards
% Affordability
Scenario
Least Likely Marginal Most Likely
7.5% ELI MUB
NC
MUBL
GC
Bergamot
Downtown
10% VLI
MUB
MUBL
NC
Bergamot Downtown
15% VLI
MUB
MUBL
GC
NC
Bergamot Downtown
20%, with even split
across income
levels
MUB
MUBL
GC
NC
Bergamot
Downtown -
30%, with even split
across income
levels
MUB
MUBL
GC
NC
Bergamot
Downtown -
For comparative purposes, commercial prototypes (office/ground floor retail
development) were also tested against the residential prototypes for a few cases.
When compared against office projects, residential/retail prototypes in all areas require
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the same or less FAR to generate similar profit margins under the 7.5% ELI scenario.
With the 10% or 15% VLI scenario, the residential/retail prototypes would require the
same or more FAR to generate similar profit margins as office (except the Downtown
TA and NV zones). Lastly at 20% and 30% affordability, the residential/retail prototypes
would require more FAR to generate similar profit margins as office (except the
Downtown). In summary, HR&A’s preliminary findings indicate:
Figure 19: Summary of Findings HR&A Preliminary Analysis
Modeled Scenario Finding
7.5% ELI Prototypes along Main, Pico, Montana, and Ocean Park cannot
support 7.5% ELI at current zoning standards due to the high
cost of parking, and land costs which are outpacing rents.
Prototypes along Lincoln and in Bergamot can marginally
support 7.5% ELI units at current zoning standards. This level is
easily supported in Downtown.
10% ELI Most prototypes other than Bergamot and Downtown cannot
support 10% ELI units at current development standards.
Additional height and FAR are needed for the other submarket
areas for 10% ELI units.
15% VLI Most prototypes other than Bergamot and Downtown cannot
support 15% VLI units at current development standards.
Additional height and FAR are needed for the other submarket
areas for 15% VLI units
20% with equally
split affordability
levels
Additional height and FAR are needed to support 20%
affordability in all submarkets except Downtown, which can
support 20% affordable units based on current development
standards.
30% with equally
split affordability
levels
Additional height and FAR are needed to support 30%
affordability in all submarkets except Downtown, which can
marginally support 30% affordable units based on current
development standards
HR&A will be conducting further sensitivity testing to determine how other factors affect
the likelihood of residential including:
• FAR/Height
• Affordability housing income mix
• On-site vs off-site provision of affordable units
• COVID impacts on market
• Bedroom mix and unit size requirements
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• Alternative ground floor uses
• Alternative parking requirements
• Retail/office redevelopment tipping point
• Holding costs
The results of this sensitivity testing will be presented in a final draft report, which will
form the basis of recommendations to modify the AHPP and possibly the Zoning
Ordinance.
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IV. Components of a Regulatory Approach for Meeting the RHNA
Where Should Housing Be Located? - Conceptual Options for Suitable Housing
Sites
When the LUCE was adopted in 2010, the City forecasted an increase of approximately
4,955 new housing units through 2030. Planning for nearly double this many units in the
next 8 years to meet the RHNA requires a revisioning of where new housing should be
accommodated. City staff is exploring three conceptual options for geographically
determining which areas should be identified and prioritized for housing. This section
provides preliminary results of potential housing sites and a rough estimate of capacity
based on existing development standards.
Option A – Adopted LUCE – A Starting Point to Identifying Suitable Housing Sites
At the heart of the LUCE is the strategy to integrate land use and transportation that
would focus new development in areas served by transit – particularly, Downtown,
Bergamot, and the Boulevards. This strategy sought to capitalize on the City’s
extensive transportation system including the Metro E (formerly Expo) Light Rail, but
was also intended to protect the character of the City’s residential neighborhoods. In
2017, the Downtown Community Plan was adopted, which provided greater clarity on
how to implement the LUCE vision in the Downtown. Of all the areas in the City, the
Downtown provides the greatest opportunities for new housing. As discussed later in
this report, the initial phase of Staff’s efforts to identify suitable housing sites followed
this approach as a first step.
Figure 20: Option A: Adopted LUCE Strategy with Potential Housing Sites
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Option B – Dispersed Housing – Activating Housing Potential In Areas That Have
Not Accommodated Housing in the Past
Under Option B, housing growth would be spread out across the City. This would
include areas where new housing has not historically occurred, such as Main Street,
Montana Avenue, and Ocean Park Boulevard. Other areas that have potential housing
opportunity include the Industrial Conservation and Office Campus zones where
multifamily housing is generally prohibited. Option B would increase the number of sites
available for housing and such sites would be dispersed in various areas of the City.
This option, however, would require changes to development standards in order to
incentivize housing production.
Figure 21
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Option C – Transit-Oriented Housing Development on Fewer Sites
Option C would carry forward the policies of the LUCE, but would concentrate new
housing within a 0.5 mile radius of the Metro E Light Rail stations. With Option C,
housing would be intensified and focused in the areas of the Downtown/Civic Center,
Bergamot Area, and Memorial Park. Option C would mean fewer sites with increased
density to meet the RHNA. Integration of housing with transit would be better achieved
with Option C – however, this approach may not align with the goal of Affirmatively
Furthering Fair Housing.
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Figure 22: Option C (Transit-Oriented Housing Nodes)
Suitable Sites Inventory – Preliminary Sites Analysis Based on Initial Suitability
Factors
State law requires that the Housing Element include a Suitable Sites Inventory (SSI),
showing that there is available land for residential development to meet the locality’s
regional housing need by income level. To assist jurisdictions in determining which
sites may be considered suitable for residential development, HCD prepared the
Housing Element Sites Inventory Guidebook. As indicated in the Guidebook, factors that
must be considered in the selection of suitable sites include the rate of redevelopment
of similar properties in the City; the effect of market conditions on the likelihood of a site
being redeveloped for residential use; the availability of incentives for residential
redevelopment; site considerations (such as whether existing uses on the site are
impediments to redevelopment); and whether the site is aligned with the goal of
affirmatively furthering fair housing. Attachment C of this staff report provides a
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summary report of the preliminary sites analysis based on the adopted LUCE growth
strategy, factors indicated below, and consideration of existing development standards.
Sites can be viewed interactively on the City’s Housing Element Update webpage at
www.santamonica.gov/housing-element-update-RHNA
Determining Whether Sites Are “Suitable” for Housing
Methodology
As a first step in identifying suitable sites, Staff reviewed all mixed use and commercial
sites in the City. This approach was undertaken first to be consistent with the City’s
LUCE growth strategy to focus new development in transit centers and along transit
corridors. Sites with existing residential units, Landmarks/Structures of Merit, hospitals,
schools, parks, utilities, government offices, libraries, police/fire stations, and newer
buildings built after 1980 were filtered out since these sites are considered inappropriate
or unlikely to be redeveloped for residential.
The filtered sites were then categorized as follows:
• Category 1 - Approved and Pending Housing Projects
• Category 2 – Prior 5th Cycle Housing Element Suitable Sites Inventory
• Category 3 – Downtown Community Plan Sites
• Category 4 – City-Owned Sites
• Category 5 – Parking Lots
• Category 6 – Auto Sales Inventory Lots
• Category 7 – Recently Sold Sites/Sites for Sale
• Category 8 – Underutilized Sites (20,000 excess sf development potential)
• Category 9 – Large Parcels (15,000 sf+)
• Category 10 – Remaining Sites with less than 0.5 Assessors Value Ratio
Category 1 includes sites with approved projects that have received planning
entitlements and sites with pending projects that are still in the planning process. As of
February 2021, there were approximately 1,670 approved units (of which 401 are
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affordable) and 756 pending units. These units are expected to be constructed in the
next eight years and would count toward the City’s 6th Cycle RHNA.9 Unlike other
jurisdictions where a significant percentage of approved projects are never constructed,
Staff’s review of planning records indicate that historically almost all housing projects
that have been approved are ultimately built.
Sites in remaining Categories 2 through 10 were individually reviewed by Staff to
determine their appropriateness for residential redevelopment. HCD requires that cities
demonstrate that non-vacant sites included in the SSI have the realistic development
potential to be redeveloped for housing. Staff assesses each site’s potential based on
these common factors:
Figure 23: SSI Analysis Factors
Factors Considered for Assessing Residential Potential
Site Physical
Characteristics
With the exception of Downtown, individual parcels less than 7,500
sf are unlikely to be developed. However, if two smaller adjacent
parcels share common ownership, there could be potential for
housing development depending on the remaining factors. In
addition to size, sites were reviewed for any other potential
physical characteristics that could make them more amenable to
residential development, such as access to an alley, shape of the
site (including depth/width), and location relative to the urban grid.
Existing Uses
Staff also reviewed the existing uses on the sites to determine if
such uses will likely be discontinued. For example, uses that are
more unique in a particular location (such as a successful grocer in
a residential neighborhood) have longevity and as such,
redevelopment of the site would be unlikely. Similarly, sites with
multiple tenants are more unlikely to turn over than single tenant
sites.
Location &
Context
Sites were considered to be most appropriate for residential uses if
they were located in areas that have easy access to schools, jobs,
transit, residential amenities such as parks/open space, health
care services, and retail shops such as grocers. Many of the sites
south of Olympic Boulevard lack access to these amenities and
services and as such, were determined to not be suitable. In
addition, Staff considered whether similar properties nearby have
been proposed for new residential development.
9 Housing projects that receive building permits by July 1, 2021 are counted towards the 5th Cycle RHNA. Based on average plan check
processing timeframes, Staff excluded approved projects totaling 814 units that were in plan check as of January 1, 2020 with the anticipation
that these projects will receive their building permits by July 1, 2021.
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Factors Considered for Assessing Residential Potential
Environmental
Constraints
HCD requires that cities identify any environmental constraints
(e.g., fault hazard zones, flood areas, liquefaction zones, very high
fire hazard severity zones) that have the potential to impact the
development viability of the identified sites. There are no high fire
hazard zones in the City. However, there is one newly established
flood hazard area in a small area of the beach that affects 85
coastal properties. Most of those coastal properties are occupied
by single-unit dwellings. There is also the Santa Monica Fault
Hazard zone that runs across the northeastern portion of the City.
A number of identified sites located on the eastern end of Wilshire
Boulevard and Santa Monica Boulevard are located within this
zone. The State does not prohibit housing in these zones, but
instead requires that structures built for human occupancy in these
zones be assessed for potential fault rupture risks.
Developer
Interest
If a developer has expressed interest in the past on a site, then
there is a higher likelihood that the site will be redeveloped.
There are 375 High Potential Housing Sites on the Preliminary SSI
Using the factors described above, Staff identified approximately 237 parcels that have
high to medium potential based on the factors above. This number excludes 109
parcels that have approved/pending projects (Category 1) and 29 City-owned (Category
4) parcels.
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Figure 24: High/Medium High Potential SSI Sites
Comparing this preliminary sites analysis to the SSI in the last (5th) Cycle Housing
Element, 30 sites comprising 34 parcels overlap (Category 2). According to
Government Code Section 65583.2, if the SSI contains sites that were used in a prior
housing element planning period, the City must allow by-right a development that
includes at least 20% of the units as affordable. Sites where zoning already permits
residential “use by right” as set forth in Government Code section 65583.2 (i) at the
beginning of the planning period would be considered to meet this requirement. Since
the City currently allows by-right housing projects through an interim zoning ordinance,
therefore, in order for the reused sites identified in the preliminary SSI to qualify for
inclusion, the by-right process must be included as an action in the Housing Element.
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A capacity analysis was conducted for the identified SSI sites (except for Category 1 –
approved/pending projects) using existing development standards to gain an
understanding of the outcomes from the parcel filters and priority rankings. The analysis
yielded a preliminary total of approximately 10,133 units. With the allowance to assume
the production of 700 accessory dwelling units (ADUs) during the Housing Element
planning period, the preliminary analysis estimates a land capacity buffer of 1,938 units.
While the sites analysis identified sufficient land area, the challenge is planning for the
RHNA’s allocated 6,168 affordable units. With a 7.5% ELI inclusionary requirement, the
estimated number of affordable units that could be produced by the SSI sites is 1,159
units. Up to 2,123 affordable units could be produced if the inclusionary required was
modified to 20%.
Figure 25: Capacity Analysis of Preliminary Sites
Summary of Estimated Preliminary Unit
Capacity
Affordable Units at Inclusionary%
7.5% 15% 20%
Category 1 Pending
Projects
756 165 165 165
Category 1 Approved
Projects
1670 416 416 416
Category 4 City owned
Sites
1,399 105 210 280
All Remaining Sites
(exclude 1 and 4)
6,308 474 946 1262
Total 10,133 1,159 1,735 2,123
ADUs 700 - - -
RHNA Targets 8,895 6,168 6,168 6,168
Buffer/(Shortfall) 1938 (5009) (4,433) (4,045)
Assessment of Unique Sites for Housing Potential
Staff also identified a number of other sites as having significant capacity for housing,
but requiring further City Council consideration including:
City-owned Sites
The City owns a variety of property in various zones, including the parcels surrounding
the Downtown Santa Monica Station, parking lots on Main Street and along Wilshire
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Boulevard, the Bergamot Arts Center, Parking Structure 3, and the site at 4th
Street/Arizona. These sites merit special consideration as they could be prioritized for
the production of affordable housing. With the exception of the Downtown properties,
these City-owned sites are zoned with relatively low FAR – rezoning these sites would
be desirable to provide significant affordable housing.
The City could consider restricting development on these City-owned sites to 100%
affordable housing projects. In December 2019, the Los Angeles City Council restricted
development of housing on public land by adopting a motion (CF 19-1362) which limits
projects on public land to 100% affordable housing, unless it is determined that an
increased number of affordable units can be achieved through a different business
model. The City could enact a similar policy or alternatively, require a minimum number
or percentage of affordable housing to be developed on City-owned sites.
State/Institutional/Public Utilities Controlled Sites
Several underutilized sites in the City are owned by other public entities that have the
potential to accommodate housing, including the Department of Motor Vehicles site at
2235 Colorado Ave, Southern California Gas site at 1701 Stewart, and the UCLA
parking lot site at 1521 & 1601 Santa Monica Blvd. If these public entity-controlled sites
are included in the SSI, HCD requires documentation be provided that shows that
housing can be accommodated within the Housing Element planning cycle.
Documentation could include an agreement between the public entity and the City
granting local authority for approving, permitting, certifying occupancy, and/or reporting
new units or a document from the public entity that demonstrates planned housing will
be built. Council gave direction at their February 23, 2021 meeting for staff to ask all
public entities to review highest/best use for their current properties throughout Santa
Monica and specifically demand that the State commit the DMV site at Cloverfield and
Colorado as a suitable site for deed-restricted affordable housing development in Santa
Monica’s housing element.
Religious Congregations
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AB1851 was passed in 2020 to remove an important barrier to housing construction on
lands owned by a religious institution. The law states that a jurisdiction cannot deny a
housing project proposed by a religious institution on the sole basis that it will remove
parking. A number of religious congregations with large surface parking lots are located
throughout the City. These lots could play an important part in providing affordable
housing; however, many of the sites are located in R2/OP2 zoning districts which
severely limits the housing potential of these sites. Rezoning would be necessary in
order to accommodate meaningful production of affordable housing on these sites.
“A”-Lots
Within the City, there are 42 residentially zoned (R1/R2/R3/R4) parcels with an “A” Off-
Street Parking Overlay (known as A-lots). These parcels are intended to support the
parking needs of commercial corridors and neighborhood commercial areas, and to
serve as a buffer between commercial and residential uses. There are 9 A-lots identified
as highest potential for residential due to their association with their commercial fronting
buildings that have been identified for high housing potential. A-lots should be
considered to determine if they could be utilized to maximize the affordable housing
potential of sites.
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Figure 26 – City Owned Sites, State Controlled/Institutional/Public Utilities Sites, and
Religious Institutions with Parking, and A-Lots
An additional 99 sites were identified as having medium potential – these include A-lots
mentioned above, properties in the lower-density Neighborhood Commercial, Creative
Conservation Sector, and Industrial Conservation zones. Staff anticipates that changes
to the current zoning standards would be necessary to increase the housing viability of
these sites.
Assessing the Likelihood of Residential Development
In addition to viability for residential development, HCD requires that jurisdictions
analyze the effects of market conditions on the likelihood of a site being redeveloped for
residential use. As discussed above, HR&A Advisors conducted preliminary analysis of
the likelihood for the prototypical residential/residential developments to occur in various
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commercially-zoned areas of the City based on various affordability percentages. At the
7.5% ELI scenario under current zoning standards, retail/residential development in
some areas would likely occur – specifically, along the Boulevards, Lincoln, Bergamot
and in Downtown. Within the MUB zone and Lincoln Boulevard, residential projects
while feasible at 7.5% ELI, retail/residential porotypes would exceed current FAR limits.
Given that at least 60% of the sites identified in the preliminary sites analysis are
located on the Boulevards and NC, additional height and FAR would be necessary for
residential development to likely occur on these sites.
Furthermore, meeting the RHNA housing target of 6,168 affordable units will require an
increase in the inclusionary requirements for market rate housing development.
Increasing the percentage of affordable housing units required would necessitate
increases in height and FAR for all zones except the Downtown.
Evaluating the Preliminary Sites Analysis through the Lens of Affirmatively
Furthering Fair Housing
Background on Housing Discrimination in Santa Monica
Housing Element law requires that the City take, “…meaningful actions in addition to
combating discrimination that overcome patterns of segregation and foster inclusive
communities free from barriers that restrict access to opportunity based on protective
characteristics.” The established neighborhoods of the City today are largely the result
of decades of structural racism deeply rooted in Federal, State, and local housing
policies. In the early days of Santa Monica, the City had a sizeable population of
Blacks/African Americans, who had moved into the City from the 1890s to the early 20th
century, having been inspired by the California dream of opportunity and freedom.
However, they were met with racism from White residents in the City. In 1922,
homeowners formed the Santa Monica Bay Protective League with an agenda of
“eliminating all objectionable features or anything that now is or will prove a menace to
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the bay district ... or prove detrimental to our property values.”10 One of the ways that
this was achieved was through racial covenants on deeds.
City government also contributed to the patterns of segregation through the adoption of
exclusionary zoning. For example, when Blacks/African Americans tried to build a
resort in the Belmar area in the 1920s, City officials used zoning laws to block the
project. Single-family zoning was also seen as a way to economically separate the
wealthier Whites from Blacks/African Americans. Since many Blacks/African Americans
could not afford or were unable to receive mortgages for owning homes, they were
effectively driven out of single-family zoned neighborhoods.
How Redlining Contributed to Housing Segregation
This type of discrimination at the local level was bolstered by the federal policy of
“redlining” that arose during the New Deal era (1930s). The term “redlining” refers to the
discriminatory policy instituted by the federal government to create color-coded maps of
every metropolitan area in the country to indicate where it was safe to insure mortgage.
These maps were based on racial composition, quality of housing stock, access to
amenities, etc. and were color coded to identify best (green “A” grade), still desirable
(blue “B” grade), definitely declining (yellow “C” grade), and hazardous (red “D” grade)
neighborhoods. Within the maps, anywhere where Blacks/African-Americans lived or
lived nearby were colored red to indicate to appraisers that these neighborhoods were
too risky to insure mortgages. The color-coded maps were first used by the Home
Owners Loan Corporation (HOLC) and then the Federal Housing Administration (FHA)
and then adopted by the Veterans Administration (VA). This discriminatory practice of
determining who could qualify for home mortgages based on skin color led to
widespread segregated communities across the country, and prohibited Blacks/African
Americans from buying homes. In Santa Monica, areas that were redlined included the
Pico Neighborhood, portions of the Mid City neighborhood south of Santa Monica
Boulevard, and Ocean Park. Figure 27 shows the redlining boundaries overlaid with
affordable housing that has been constructed or acquired/rehabilitated over the years.
10 https://www.latimes.com/archives/la-xpm-2005-jul-03-me-then3-story.html
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Of the affordable units that have been constructed over the years, 49% are in areas that
were in the redline boundaries.
Figure 27: Affordable Housing and Formerly “Redlined” Areas in the City of Santa
Monica
In the post-World War II era, the Federal government further spurred the creation of
segregated communities through the systematic construction of highways/freeways that
began in the 1950s. Freeways were purposely routed through communities of color or to
create physical barriers to separate White and Black neighborhoods. The Interstate 10
freeway, for example, was purposely constructed to divide the more affluent White
neighborhoods to the north of the Los Angeles from struggling Black communities to the
south. The construction of the I-10 freeway in the early 1960s demolished hundreds of
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homes in the Pico neighborhood, which was predominantly occupied by Santa
Monicans of color.11
The current patterns of renters and owners approximate the redline maps with owners
predominant in the single-unit dwelling zones on the northern and southern ends of the
City and renters concentrated in the central city near the main transportation corridors.
The April 2020 Assessment of Fair Housing (AFH) found that the location of renters and
owners in Santa Monica very highly correlates with patterns of residential racial and
ethnic segregation. The areas with the highest concentrations of homeowners, such as
North of Montana, Ocean Park, and Sunset Park are also the areas that are
predominantly White. The areas with the highest concentrations for renters, such as the
Pico Neighborhood and Downtown, are areas that contain high concentrations of
People of Color and/or those with Limited English Proficiency.12 The AFH also found
that a major contributor to racial and ethnic segregation is the economics of high
housing and land costs created by zoning, which particularly burdens the development
of affordable housing in certain areas of the city.
Figure 28: Housing Tenure of Renters and Owners with Racially or Ethnically
Concentrated Areas of Poverty (R/ECAPs)
11 https://laist.com/2020/12/23/black_santa_monica_history_vintage_los_angeles.php
12 City of Santa Monica and the Lawyers’ Committee for Civil Rights Under Law, April 1, 2020, Assessment of Fair Housing, Page 44.
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Affirmatively Furthering Fair Housing in Housing Elements
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In recognition of the racial disparities in housing that endure to this day, AB 636 (2018)
was passed to require cities and counties to advance social equity through meaningful
actions that affirmatively further fair housing (AFFH). Through the Housing Element
Update, the City has an opportunity to remedy the legacy of housing discrimination that
has influenced the land use patterns that we see today. While the City has long been a
champion of the production of affordable housing and promoting diversity in
neighborhoods, the existing density restrictions of current zoning coupled with
differences in land values (that are the results of past redlining) continue to keep
affordable housing out of reach in the higher resource areas of the City. It is within this
historic context that the questions of distribution of housing sites in the SSI and how
much housing potential is assigned to each site should be viewed. As discussed further
below, new concepts and ideas to affirmatively further fair housing that have arisen from
this Housing Element Update process include:
• Modifying development standards to increase the viability for housing
development in areas where such housing has not formerly occurred, such as
Montana Avenue, Main Street, and Ocean Park Boulevard
New residential construction in the Neighborhood Commercial-zoned areas of Montana
Avenue and Main Street as well as Ocean Park Boulevard have virtually been non-
existent in the past few decades. As indicated by the preliminary results of HR&A
feasibility analysis, a primary reason for this is that with high construction cost and high
land costs, the current zoning standards do not make it likely for residential
development to occur. To increase the likelihood of housing units to be developed in
these areas, increases in density and height would be necessary.
• Providing opportunity for housing development in areas formerly not available
such as Office Campus (OC) and Industrial Conservation (IC)
Under the City’s current Zoning Ordinance, multi-unit dwellings are not permitted in the
OC and IC zones. Permitting all multi-unit housing, including affordable housing, in the
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OC and IC would open up more land to future housing opportunities. This zoning
change would complement the concept of incentivizing and facilitating the potential
conversion of commercial to residential, especially in light of the pandemic’s effects on
the demand for office work space. It should be noted that allowing for housing in
portions of the IC would likely require additional environmental review or as an
alternative, creating a 500-foot buffer from the I-10 freeway.
Allowing housing in all commercial zones is already the subject of several pending State
legislation including Senate Bill 6 and Assembly Bill 115 (Bloom). While still in
discussions, AB 115 would permit housing in commercially zoned areas if certain
conditions apply – specifically that the housing development be subject to a recorded
deed restriction requiring that at least 20% of the units have an affordable housing cost
or affordable rent for lower income households, and be located on an urbanized site that
is not adjacent to an industrial use.
• Eliminating Single-Family Zoning to allow for the development of increased
housing opportunities
As discussed earlier in this Staff report, single-family zoning originated as a form of
exclusionary zoning to economically and racially segregate neighborhoods. The
elimination of single-family zoning would open up 35% of the City land to increased
housing opportunities and would be aligned with the mandate to affirmatively further fair
housing. However, as also discussed, there may be other avenues to increasing
dwelling units in R1 zones through ADU incentives or removing barriers to duplex
construction.
How Much Housing Should be on Each Site? – A Conceptual Four-Pronged
Strategy for Affordable Housing Production
Once suitable sites have been identified, the City is mandated to plan for its RHNA
allocation. As previously explained in this report, achieving the 6,168 affordable
housing units in the RHNA allocation cannot be done by solely private or public
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resources. For example, if the City were to only rely on inclusionary units in market-rate
projects, assuming 20% affordable on-site units would require planning for over 30,000
additional housing units – more than three times the RHNA allocation and an unrealistic
figure to plan for. Similarly, funding challenges dictate that reliance only on 100%
affordable housing projects is also not reasonable. As discussed at the City Council’s
December 15, 2020 study session, the City can submit a request for a lower Quantified
Objective (QO) at the time the draft is submitted to HCD for review, which will not be
until July 2021. The QO process recognizes that the RHNA allocation may exceed
available resources and the community’s ability to satisfy this need within the content of
the general plan requirements. However, it should be noted that under existing Housing
Element law, the QO carries no meaning when it comes to assessing Housing Element
compliance. The development of the SSI and determining realistic capacity is an
iterative process and at this preliminary juncture, staff has continued to plan for the
whole RHNA allocation.
The four-point strategy presented below includes concepts on how each part of the
housing market could be maximized for affordable housing production. The
assessment of realistic capacity of the preliminary sites analysis (based on the LUCE
growth strategy) provides a baseline snapshot of capacity at all income levels based on
existing regulations. Meeting the RHNA affordable housing targets will require re-
assessment of those standards.
Strategy #1 – Maximize Inclusionary Units in Market Rate Housing
Increased Inclusionary Requirements Supported by FAR Necessary to Incentivize
Housing Projects
In order to maximize inclusionary units in market-rate housing projects, a revision to the
AHPP is proposed in order to simplify the program and also ensure continued
consistency with State density bonus law. The market-rate strategy would also need to
be supported by feasibility analyses to study how much development potential is
necessary to support the increased AHPP requirements. Preliminary results from
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updated feasibility analyses demonstrate that existing standards make commercial
projects more likely to develop than housing projects. The following concepts propose a
rethinking of how FAR limits are set for housing projects by establishing a target
percentage for affordable housing and then working backwards into the FAR necessary
to support that percentage.
Concepts for Consideration
Revising the AHPP – Eliminate the “Menu” and Replace with Minimum 15% Very Low
Income
Currently, the AHPP allows market-rate developers to select from a “menu” of options
for the production of housing. The AHPP formerly allowed market-rate projects to
include only 5% of their units as affordable to 30% AMI (Extremely Low Income)
households. This had the effect of producing affordable units at the Extremely LowI
Income level at the cost of production of other income levels with particular shortages
happening at the 80% (Low) to 120% (Moderate) AMI income levels. The following
table shows the options currently available to the market-rate rental housing projects
based on current requirements (minimum 10% for 50% AMI (Very Low Income)
households).
Figure 29: Existing Menu Options of AHPP
# of Units In-Lieu
Fee
On-Site Off-Site
2 X -- --
3 X -- --
4
--
X*
$153,118 based on
0.4 fractional unit
X
5
--
X*
$191,397.50 based
on 0.5 fractional
unit
X
6
--
X*
$229,677 based on
0.6 fractional unit
X
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# of Units In-Lieu
Fee
On-Site Off-Site
7
--
X*
$267,956.50 based
on 0.7 fractional
unit
X
8+ -- X X
*SMMC Section 9.64.050(D) provides instructions for how to address fractional units. When a calculation
results in a fractional unit of 0.75 or more, that fractional unit shall be treated as a whole affordable
housing unit. When a calculation results in a fractional unit less than 0.75, the requirement can be
satisfied through payment of an affordable housing fee for that fractional unit (fractional unit x affordable
housing unit development cost) or by constructing all mandatory on-site units with 3 or more bedrooms.
The affordable housing unit development cost is currently $382,795. This means that currently, up to 7
market-rate units can be constructed without providing any on-site or off-site affordable housing.
In order to increase the number of affordable housing units produced from the City’s
AHPP, the City could consider eliminating the current “menu” option of affordability
requirements and instead establish a base affordability percentage based on project
tier. For example, Tier 1 projects could be required to provide a minimum 15% Very Low
Income (VLI) affordability. This would address the issue of “overproduction” of units at
the Extremely Low Income (ELI) level. Tier 2 could then be required to provide 20% with
equal mix of units across all levels. As indicated in HR&A’s preliminary assessment,
modifications to increase the inclusionary requirement of the AHPP would require
increases in the allowable FAR and height of all zones, except for the Downtown zones.
Revising AHPP – Flexibility in Off-Site Option Location
Developers have indicated that constructing on-site affordable housing can greatly add
to the cost of a housing project, making them less likely to develop. The AHPP
currently allows developers to fulfill their affordable obligation by providing units off-site.
However, the units are required to be located within ¼ mile of the market-rate project.
The off-site requirements vary somewhat for Tier 2 projects. Within the Downtown
Community Plan area, Tier 2 housing developers have the flexibility to locate the off-site
housing anywhere within the Downtown. In addition, the off-site housing project must
be owned or operated in whole or in part by a non-profit housing provider.
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Unlike large scale developers who have a portfolio of properties, smaller-scale
developers with smaller housing projects cannot amalgamate their affordable housing
requirements onto one larger off-site property. HR&A conducted a preliminary analysis
to determine the cost-efficiency for on-site vs off-site affordable housing. Their analysis
indicates that prototypical residential/retail project could support an off-site affordable
housing fee of between $45,000 and $60,000 per market rate unit, as an alternative to
including affordable units on-site. This supportable fee is slightly higher than the current
AHPP in-lieu fee at $36.49 per GSF, or $30,300 per market rate unit with an average
unit size of 830 GSF. The “opportunity cost” of developing an on-site affordable unit
averages approximately $350,000. Based on previous HR&A analysis of 100%
affordable housing projects, the unfunded subsidy gap (i.e., other than tax credits or
City subsidies that could be paid by market rate developers), ranges between roughly
$270,000 and $300,000 and averages $285,000 per affordable unit. As such, the cost of
developing on-site VLI units is approximately 1.3 times the per-unit subsidy gap needed
for off-site 100% affordable housing projects. This could facilitate construction of over
30 percent more affordable units off-site due to the potential for off-site affordable
housing to leverage additional resources and higher tax credit rents.
Through the technical working group discussions, developers have indicated that the
AHPP’s off-site option is too restrictive on location and they would prefer the option to
purchase land wherever in the City it is available. The AHPP requires off-site locations
to be relatively close to the associated market-rate projects to avoid inequitable
distribution of affordable housing throughout the city. However, given the additional
units that could be achieved through the off-site option, it is reasonable to consider how
additional flexibility could be added to the program to make it a more viable alternative
to on-site affordable units. A concept to consider would that the off-site projects can be
located anywhere in Santa Monica but must not be located in a disadvantaged
community. Staff is exploring how to define a disadvantaged community as potential
sources include environmental justice areas as shown on SCAG’s Housing Element
Parcel Tool 13 or ”disadvantaged community” as defined by SB53514.
13 SCAG Housing Element Parcel Tool online at https://maps.scag.ca.gov/helpr/
14 https://oehha.ca.gov/calenviroscreen/sb535
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Other Possible Concepts to Create Flexibility in Off-site Affordable Housing
Through both Technical Working Groups, other concepts for off-site affordable housing
were also raised including:
• Allow the pooling of units among multiple properties to satisfy an obligation as
long as the affordable units received their Certificate of Occupancy prior to the
market rate projects
• Create an acquisition/rehab option that allows developers to purchase existing
units, rehabilitate the units, and convert the units to long-term affordability
through deed-restrictions
o This is a concept that would create new affordable units while also serving
existing residents. Some group members expressed concern about
impacts to existing tenants in such a situation in addition to situations
where the existing tenants may not income-qualify for the newly deed-
restricted units, meaning that the units would not become affordable until
the existing tenants voluntarily vacated the units. Further exploration is
necessary to understand whether this could be a realistic option.
Concepts for Integrating Updates to State Density Bonus Law to Achieve More
Affordable Housing
The Density Bonus Law (Government Code Section 65915) was first enacted by the
California legislature in 1979 to address the shortage of affordable housing in the state.
The Density Bonus law provided an incentive mechanism to encourage developers to
include affordable units within a residential project in exchange for increases in density
(the density bonus) above local zoning law and relief from base development standards
(concessions/incentives). By offering developers varying levels of density bonuses,
incentives and/or concessions in exchange for building affordable housing, the goal of
the Density Bonus Law is to incentivize and encourage developers to create much
needed affordable housing units in California.
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Prior to 2021, the Density Bonus Law permitted a maximum density bonus of thirty-five
percent (35%) for a housing development in which (a) at least eleven percent (11%) of
the total units are for very low income households, (b) at least twenty percent (20%) of
the total units are for low income households, or (c) at least forty percent (40%) of the
total for-sale units are for moderate income households. In other words, a project that
achieved any of these affordability levels could include up to 35 percent more units than
local law otherwise would allow.
In 2020, Governor Newsom signed Assembly Bill 2345 into law, to expand and enhance
development incentives for market rate projects that provide affordable housing. AB
2345 increases the maximum density bonus from thirty-five percent (35%) to fifty
percent (50%). To be eligible for the maximum bonus of 50%, a project must set aside
at least (i) fifteen percent (15%) of total units for very low income households, (ii)
twenty-four percent (24%) of total units for low income households, or (iii) forty-four
percent (44%) of for-sale units for moderate income households. Levels of bonus
density between thirty-five percent (35%) and fifty percent (50%) are granted on a
sliding scale. In addition to this sliding scale bonus, developers can also request
incentives & concessions to development standards necessary to support the on-site
affordable housing units. The number of incentives & concessions varies depending on
the percentage of affordable units, up to a maximum of four incentives & concessions
(only for 100% affordable housing projects).
Figure 30: State Density Bonus Law Affordable Percentage and Associated Density
Bonus for rental units
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The City currently has a tiered land use system consisting of a Tier 1 base and the
opportunity for an applicant to voluntarily request additional height and/or FAR for a Tier
2 project. Between those tiers is an intermediate step that provides a height or FAR
increase if on-site affordable housing is provided.
As part of the 2015 Zoning Ordinance Update, a regulatory community benefits system
was established requiring Tier 2 projects to provide 50% more affordable housing and
also augmented development fees. The community benefits structure was supported
by feasibility analyses. A similar structure was established for the Downtown
Community Plan except that the affordable housing percentage increased up to a
maximum of 30%.
Staff proposes a concept that would expand upon the existing tier structure by taking
the approach that a State density bonus would apply to Tier 1 FAR. The maximum
allowable FAR for each tier would be based on the level necessary to support the goal
of inclusionary housing. As an additional concept, commercial projects would not be
able to request additional height or FAR above the Tier 1 base unless the project
included at least four (4) stories of 100% affordable housing, which is the minimum
project size that affordable housing providers have indicated is necessary to make a
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viable project. The figure below is a conceptual diagram of this proposed expanded
housing bonus system.
Figure 31: Proposed Expanded Tier System with Housing Bonus
Strategy #2 – Support 100% Affordable Housing
For Projects Up to 80% AMI – Affordable Housing Provider Chooses FAR Necessary to
Support Project with No Minimum Parking Requirements Paired with Right of First Offer
Ordinance for Non-Profit Affordable Housing Providers
Affordable housing providers have indicated that the major barriers to the production of
affordable housing are available funding, land cost, and construction cost. Of those
three factors, the only factor that the City can directly address is funding; however, in
light of the effects of COVID-19 on the City’s budget, the amount of affordable housing
necessary to achieve the RHNA and address the community’s needs far exceeds the
funding available through the Housing Trust Fund. Further, while the City continues to
advocate for assistance from State and Federal sources, none of that funding is certain.
As a result, providers are increasingly turning to partnerships with market-rate
developers to finance affordable housing projects.
The City indirectly influences land and construction cost through regulatory restrictions.
As affordable housing providers compete in the same real estate market as market-rate
developers, staff explored potential solutions with housing providers as to how to make
developers of 100% affordable housing projects more competitive as land buyers and
what opportunities are available for the City to help reduce construction costs.
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AB1763 amended State density bonus law (Government Code Section 65915) to allow
100% affordable housing projects unlimited density and up to 3 stories or 33 feet above
maximum height limits. There have already been at least five affordable housing
projects in Santa Monica that have exercised the provisions of AB1763 since it became
effective January 1, 2020. In all cases, the provisions resulted in more affordable
housing units. The changes also provide relief from minimum parking requirements and
allow requests for up to four incentives/concessions from local development standards.
Given the need to provide a significant advantage to affordable housing developers in
the land-buying market, a possible concept to consider would be the following:
• Unlimited FAR and height in commercial zones
• Minimum of 4 stories guaranteed in all residential zones
• No minimum parking requirements
These development incentives could be coupled with a new ordinance requiring that
sales of property in the city must allow non-profit affordable housing developers to
submit a right of first offer as way to enhance their competitiveness in the real estate
market. Other concepts for consideration include:
• Piggy-backing onto developments already in progress
o Partner with commercial developers
▪ Restudy potential to increase affordable housing commercial
linkage fee for commercial development – would require updated
feasibility analyses
▪ Provide development incentives that encourage 100% affordable
housing to be added onto their commercial developments. This
could be incorporated into the density bonus system described
above.
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o Purchase additional “blocks” of affordable housing in market-rate projects
at fair-market value. Preliminary discussions with market-rate developers
have indicated that the concern would be whether the cost of losing units
to long-term affordability would be made up in the payment for those units.
Additional study would be needed as to whether the construction savings
would make this a worthwhile option to pursue.
• Legislative advocacy for funding – staff actively involved in discussions with
legislators through lobbyists
Target up to 120% AMI (Moderate Income Housing) – Affordable By Design
Moderate income units are a category that has no dedicated funding sources and it
historically has been an area where the City has been challenged in meeting its RHNA
allocation. The profile of Santa Monica workers who cannot afford to live in Santa
Monica would suggest that there is a need for housing at this income level, and one
concept to incentivize its production is to enact provisions similar to AB1763 at a local
level. This would allow moderate income projects to receive 50% more FAR and 3
extra stories. As a further incentive, consideration should be given regarding the unit
mix requirement as preliminary research with a moderate-income housing developer
that has successfully completed projects in Seattle and Los Angeles suggests that there
is a workable model if micro-units are permitted. In this scenario, consideration would
need to be given of how to establish zoning standards for enhanced common amenities.
Strategy #3 – Protect Existing Units for Long-Term Stability
There are approximately 52,000 rental units in Santa Monica with approximately 27,000
rent-controlled units. According to the 2019 Rent Control Annual Report, 72% of rent-
controlled units are market-rate units, meaning that the overwhelming majority of units
in the City are market-rate with only a small percentage having not been subject to
vacancy decontrol. This highlights the need to explore strategies to encourage
rehabilitation of existing housing units and potentially require affordable housing deed
restrictions.
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Figure 32: Breakdown of Rent-Controlled Units 2018-2020
# of
Controlled
Units 2018
# of
Controlled
Units 2019
# of
Controlled
Units 2020
Change
from
12/31/2018
to 2019
Change
from
12/31/19 to
2020
Market-
Rate
19,562 19,701 19,936 139 235
Long-Term 6,962 6,753 6,553 -209 -200
Housing
Choice/Sec
8
623 623 618 0 -5
Restricted 143 148 158 +5 10
$0 MAR 155 156 164 +1 8
Total 27,445 27,381 27,429 -64 48
Government Code Section 65583.1(c) allows for use of existing units to address up to
25 percent of the lower income RHNA by counting existing units made available or
preserved through the provision of “committed assistance” to low and very low-income
households at affordable housing costs or affordable rents. This option is referred to as
“Alternative Adequate Sites”. However, there are limited strict parameters under which
substantial rehabilitation, conversion, or preservation of units can be counted and the
Housing Element would be required to identify exactly how the city will guarantee
compliance in order to grant the credit. The units must be:
• Substantially rehabilitated
• In a multifamily rental or ownership housing complex of three or more units that
are converted from non-affordable to affordable rental
• Preserved at levels affordable to low or very low-income households where the
local government has provided those units with continued assistance
Under each of the above categories (substantially rehabilitated, converted, or
preserved), there is a checklist of items that must be met in order for the units to count
towards RHNA. Attachment D provides the Alternative Adequate Site Checklist. The
City provides housing assistance to existing residents through a number of programs
and has a demonstrated history of working with willing property owners and tenants to
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grant project-based housing vouchers that might allow some units to qualify towards this
requirement. Further, this would be an opportunity to consider flexibility in how
developers of market-rate projects meet their AHPP obligations. As noted above, one
concept that staff is considering is allowing market-rate projects to comply with the
AHPP by the acquisition and rehabilitation of existing rental units and converting those
to deed-restricted units. Because the Alternative Adequate Sites approach is rarely
used, further evaluation and consultation with HCD staff is necessary to determine
whether the City would qualify to use this approach. However, as a matter of policy, the
City will continue to offer these programs as a means to increase housing stability for
existing residents that are most vulnerable to displacement.
Housing stability goals, policies and programs will be evaluated to support the housing
needs of existing residents of all income levels. The focus will be on housing security for
existing residents most vulnerable to displacement to ensure they are long-term
residents of the community. This involves continued implementation of a variety of
existing housing programs and services with consideration of additional enhancements
ranging from rental assistance, tenant protections, resident support services, and
maintenance/rehabilitation of housing units. Preserving the existing housing stock
results in maintaining housing affordability.
Housing stability will also focus on maintaining existing housing stock consisting of deed
restricted affordable units at-risk of converting to market-rate, and naturally occurring
affordable housing. Often referred to as “missing-middle housing”,15 naturally occurring
affordable housing refers to existing housing units that maintain low rents without
subsidy and may generally be affordable to households that do not qualify for any of the
conventional categories but are also cost burdened. Preserving these aging housing
units though appropriate maintenance and rehabilitation rather than replacement by
construction of new residential housing that requires Ellis Act eviction can reduce
resident displacement and provide existing tenants with updated residences.
15 Note that “missing middle housing” is also a term commonly used to describe a building typology of generally lower-scale
development intended to provide additional housing choice.
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An outstanding policy question is whether, given limited resources, the City should
expand those programs and if so, whether the priority is on production of new units or
on providing assistance to existing units (acquisition/rehab or rent subsidies). Programs
to protect existing units for long-term stability are discussed further down in the report.
Strategy #4 – Incentives for ADU Production
ADU Production Within Santa Monica
Accessory Dwellings Units (ADUs) play an important role in the production of housing,
particularly within single-unit residential zoning districts where historically only one unit
is permitted. In recognition of this, the State over the past four years has started to
enact laws to help spur the production of housing through the development of ADUs.
Building off of initial State law passed in 2017 that started the process of removing
barriers to ADU production, three new State laws (AB 68, AB 881, and SB 13) came
into effect on January 1, 2020 that significantly expanded potential ADU development.
These new laws revised development standards that sometimes limited ADU
construction, such as eliminating minimum parcel size, establishing larger unit sizes
based on bedroom count, reducing minimum side and rear setbacks, and removing on-
site parking requirements. In addition, the new laws extended ADUs into multiple-unit
residential and mixed-use zoning districts and introduced the new concept of Junior
Accessory Dwelling Units (JADUs) when in conjunction with single-unit dwellings. On
September 8, 2020, City Council approved an ordinance incorporating these State law
requirements into a new ADU/JADU Section of the Zoning Ordinance, SMMC Section
9.31.025 Accessory Dwelling Units and Junior Accessory Dwelling Units. Additionally, to
further encourage the production of ADUs and JADUs, Council expanded upon the new
requirements by exempting all ADUs and JADUs from parcel coverage or floor area
calculations.
Since implementation of these new State laws, the City has seen an increase in ADU
production and interest each year. Based on building permit data as of March 1, 2021,
the table and map below summarize ADU development and location within the City
since 2017, the start of when State law began to focus on incentivizing ADUs. However,
it is important to note that the vast majority of these numbers are from ADU construction
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on R1 (Single-Unit Residential) zoned parcels. The City is just now starting to see
property owners take advantage of the ability to establish sometimes multiple ADUs
with existing multiple-unit residential and mixed-use developments.
Figure 33: Santa Monica ADU Production
Building
Permit Year
In-Progress Permit
Issued
Completed Total
2017 - 1 6 7
2018 2 15 39 56
2019 32 37 14 83
2020 87 12 1 100
2021 4 - - 4
TOTAL 125 65 60 250
Figure 34: Map of ADU Locations
ADU Contribution to RHNA
Pursuant to HCD’s Housing Element Site Inventory Guidebook, a jurisdiction may
satisfy its RHNA through a variety of methods other than identifying sites. One of these
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alternative methods is including the potential development of ADUs and JADUs based
on the following factors:
• The number of ADUs or JADUs developed in the prior planning period;
• Community need and demand for these types of housing units;
• The resources and/or incentives available that will encourage the development of
ADUs;
• The availability of ADUs and JADUs for occupancy;
• The unit must meet the Census definition of a housing unit and be reported to the
Department of Finance as part of the annual City and County Housing Unit
Change Survey; and
• The anticipated affordability of these units.
In order to project the increased potential of ADU development for the new Housing
Element cycle, HCD recommends the following options:
• Use the trends in ADU construction since January 2018 to estimate new
production.
• Assume an average increase of five times the previous planning period
construction trends prior to 2018.
• Use trends from regional production of ADUs.
• Include programs that aggressively promote and incentivize ADU and JADU
construction.
As shown in the above table, based on ADU building permit data between 2018 and
2020, Santa Monica averages 80 ADUs per year. Using this average production
number, it can be expected that over the next eight-year Housing Element cycle,
approximately 700 ADUs will be built and can be used towards our RHNA. This
estimate accounts for possible future interest in ADUs to be incorporated into existing
multiple-unit residential and mixed-use developments, which the City has only just
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started seeing very recently as the new law permitting this only took effect January 1,
2020.
In order for potential ADU development to count towards the RHNA, local governments
must also provide an analysis of anticipated affordability levels. Staff initiated a survey
that began on March 4th targeting individuals that either have an ADU on their property
or live in an ADU to better understand how ADUs are being used and how they
contribute to the City’s housing supply. The survey and outreach materials were
provided in both English and Spanish, and asked questions regarding bedroom count,
occupancy, and rental amount. The survey concluded on March 18th.
In addition to the City’s survey, SCAG conducted a regional analysis of current market
rents that can be used to obtain credit towards each income category in the RHNA.
SCAG’s analysis was pre-certified by HCD and allows cities to assume that the total
anticipated ADU production would be assigned to the following income categories:
• Extremely Low – 15%
• Very Low – 2%
• Low – 43%
• Moderate – 6%
• Above Moderate – 34%
Proposed ADU Incentive Program
While Santa Monica has taken steps beyond what is required by State law to incentivize
the production of ADUs, staff proposes consideration of an ADU incentive program for
the R1 district. Approximately 35% of the City is zoned as R1, which only allows for one
unit per parcel by right. This has resulted in only 13% of the City’s housing supply being
located in one of the largest zoning districts within the City. While ADU construction has
started to increase this number, currently the maximum amount of units by right an R1
parcel can contain is three – one single-unit dwelling, one detached ADU, and one
JADU (which is required to be incorporated into the footprint of the single-unit dwelling).
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The proposed incentive program would allow a property owner the ability to construct an
additional ADU if they would be willing to deed restrict one of the ADUs at an affordable
level. This incentive program would help achieve the Housing Element goal of
affirmatively furthering fair housing by providing more affordable housing opportunities
within the R1 zone district, an area of the city that has largely been unaffordable to
many.
In an effort to help accomplish this incentive program, the City is pursuing a grant to
produce an ADU Accelerator Program that will simplify the ADU process by providing a
handbook detailing all standards and processes attributed to ADU development. The
Accelerator Program would also include ADU designs that have been pre-approved by
the City that could be selected by a property owner to reduce both the time and cost
associated with ADU development.
Other Concepts Evaluated But Not Yet Considered as Primary Tools for the SSI
Several concepts have been raised throughout the process as possibilities to address
affordable housing production. The concepts described below generally include greater
complexity to administer and may not provide sufficient affordable housing opportunities
t to be considered for the Housing Element Update.
Community Land Trust
The idea was raised through the public webinars and also Technical Working Groups of
whether community land trusts might be a model for 100% affordable ownership
housing where the land trust purchases the land and then leases the units to qualifying
home owners. While this idea holds great promise to provide opportunities for
moderate-income households to build equity, it presents several significant challenges
in implementation. This idea has previously been reviewed by the Housing Division and
was also explored for the High Place affordable housing project. It was found that this
method of ownership is very difficult to finance as lenders want their loan interests to be
‘superior’ in title to the deed restrictions, which then undermine the City’s ability to
ensure long-term affordability. Construction lenders were hesitant to finance the project
because of concerns that prospective buyers would be unable to secure mortgages
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given the resale limitations. Another potential issue was whether low- and moderate-
income households could feasibly afford to assume fiscal responsibilities of homeowner
maintenance and repair. It was only feasible to consider this model at the time because
the land was relatively affordable. Land costs have increased significantly since that
time and pursuing a CLT model now would be a very expensive proposition.
Further, the intent of long-term ownership affordability naturally has tensions with the
desire of most homeowners to benefit from real estate gains upon sale. Once a buyer
closes escrow, they have every incentive to have the deed restriction removed,9
compared to a renter, whose every incentive is to see that a deed restriction remains in
place. In a CLT model, the resale formula is intended to balance the interest of the
homeowner to benefit from use of their home as an investment and the CLT’s goal of
long-term affordability for future owners. In addition, community land trusts are typically
owned/operated by a nonprofit, which then needs to be compensated for the
administrative and compliance work, which adds an ongoing cost to the homeowner.
Also, affordable homeownership compliance requires much closer monitoring regarding
occupancy and sales, due to the economic incentive for a homeowner to lease their
home and the difficulty preventing an unauthorized sale. This would require substantial
City staff resources to ensure compliance.
Finally, the City would likely have to provide a significantly greater subsidy to create for-
sale, deed-restricted homes compared to below market rental units. With the need to
prioritize limited funding, it then brings up the issue of providing increased subsidy to
households that have greater resources and more options at the expense of households
with lower resources and fewer options. As a result, this potential tool is not being
considered for the Housing Element Update.
Vacancy Tax
This concept has been previously assessed by City Attorney’s Office and Finance but
not identified as a primary strategy because expected revenue was estimated to be low
and the cost of enforcement high (and difficult to administer). The City of Los Angeles
considered the possibility of a vacancy tax but upon further review, determined that the
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benefit would not overcome the substantial effort and administrative burden. Based on
application of a rate similar to that adopted in the City of Oakland (annual tax of $3000
to $6000 on vacant property), the estimated revenue would be approximately $200-
300K. If the goal of a vacancy tax is to bring vacant units back into the rent housing
pool, there may be other strategies that could be enacted to support housing retention
and stability. The Oakland tax defines vacant as a unit being in use less than fifty days
in a calendar year and provides for ten possible exemptions that would be challenging
to administer. As a result, the program appears structured more towards encouraging
property owners to put units back on the market instead of a punitive measure. From a
revenue-generating perspective, the recently passed Measure SM’s transfer tax for
property sales of $5M and over would produce more revenue than a vacancy tax.
Commercial Conversion into Residential
The COVID-19 pandemic has had a dramatic impact on the City’s commercial real
estate market. Even prior to the pandemic, the retail industry had been struggling to
compete with online retailers and the office market has started to trend downward. Now
a year later in the pandemic, empty storefronts and half occupied office buildings are
not an uncommon sight in the City. With the downturn of retail and office real estate
accelerated by the pandemic, the concept of converting commercial into residential has
gained significant interest as another avenue to increase the supply of housing in the
City.
Although commercial to residential conversion projects have been rare in the City, other
cities in the region have seen such projects. In Santa Ana, under an adaptive reuse
ordinance adopted in 2015, a 1965 office building was recently transformed into a 100%
affordable housing project providing 58 units. There are, however, logistical and design
challenges to converting office buildings to residential. Office and retail buildings with
large floor plates and dedicated core space for example, make it difficult to transform
the space into residential units, as most of the divided space would end up as
windowless caverns. Placement of plumbing and electrical conduits in the right places
can also be difficult. Depending on the particular building, the conversion to residential
may be more cost-prohibitive than new construction. That is not to say that conversion
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of commercial into residential couldn’t occur in the City. Some commercial buildings
may have features that make them more conducive for residential conversion. HR&A
advisors will be reviewing the potential and likelihood for commercial conversions to
occur as part of their final study. The City could also consider policy changes to
incentivize the conversion of existing commercial to retail, such as relaxing parking, unit
mix, open space, and other typical zoning or building code requirements. However even
with such policy changes, it would be speculative to estimate if and how many buildings
would feasibly be converted during the next 8 years. Absent this substantial evidence, it
would not be possible to identify potential housing conversion sites for inclusion in the
SSI.
Flexibility for Residential Ground Floor Uses instead of Active Commercial Use
The Zoning Ordinance currently requires that the ground floor of mixed-use housing
projects include active commercial uses in order to promote pedestrian-orientation. The
City has a significant supply of ground floor retail and with most typical mixed-use
housing projects including relatively small, ground floor commercial spaces (typically
around 6,000 sf or less). As a result, the City may want to consider allowing flexibility
for ground-floor residential uses, which can still be designed to be pedestrian-oriented
and allow what would otherwise be vacant, commercial floor the flexibility to be used for
housing. HR&A will be conducting sensitivity testing of this potential scenario as part of
upcoming work.
V. Programs for Housing Stability
Housing stability goals and policies seek to maintain the City’s existing housing stock
through housing preservation and housing assistance. Housing preservation policies
and programs focus on rehabilitation assistance to maintain, improve, and extend the
use and livability of aging residential buildings. Existing programs include the
Residential Rehabilitation, mandatory Seismic Retrofit, and Lead-Based Paint Hazard
Reduction programs. Housing assistance policies, programs, and services focus on
providing financial and technical assistance for the provision of housing for all income
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groups and household types including families with children, seniors, persons with
disabilities, and others with special needs. Such programs and services address the
special need to provide transitional and supportive housing, and services for the
homeless in the community with an emphasis on at-risk and vulnerable individuals.
Through the continued implementation of housing preservation and assistance
programs, the City strives to maintain housing affordability while assisting residents with
housing security.
Programs to Address Housing Needs of Existing Residents
The Housing Stability Technical Working Group discussed housing barriers and needs
of existing residents that ranged from financial assistance, continued tenant/landlord
assistance, continued support services for homeless/at-risk individuals, and the need to
maintain housing affordability of existing housing stock. Many of the housing barriers
reflect on issues that renters are currently experiencing. Barriers to housing include
credit restrictions and eligibility requirements involving sensitive personal information,
high security deposits, and income-level qualifications. Challenges and experiences
were shared that call for program improvements including the use of alternate forms of
credit scoring recognizing certain housing barriers based on race, income, and other
factors, and the need for additional assistance on a variety of issues. While housing
stability and preservation policies may not directly address the RHNA allocation, the
approach to housing existing residents is imperative in achieving the Housing Element’s
goal of ensuring there is adequate housing for persons and families of all income levels.
1. Rental Assistance
There is a need for financial support for seniors, families, and individuals who are
rent-burdened. Household cash flow and income is an issue. Additional education
and outreach to residents and landlords on the availability of housing vouchers,
including Section 8 vouchers is needed to ensure information and support of state,
federal, and local programs are equally provided to all residents. While established
as a program to fulfill basic needs after housing costs, expansion of the Preserving
Our Diversity (POD) program would be helpful to support others who are also rent
burdened.
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2. Resident Services and Tenant Protections: Landlord/Tenant Support
Continued tenant protection and assistance is needed ranging from legal counsel,
oversight of landlord obligations related to voucher programs and housing
maintenance/repairs, and education/information assistance on tenant rights and
available housing programs.
3. Supportive Services Programs that Serve Homeless/At-Risk Individuals
Continued implementation and enhancements of support services that assist the
homeless and at-risk individuals such as case management to ensure housing
retention.
4. Housing Preservation: Maintain Housing Affordability
In efforts to maintain housing affordability, focus should be on preserving and
rehabilitating existing housing stock including covenant and non-covenant
residential units such as rent-controlled units that are also viewed as at-risk
housing.
Housing Programs Assessment
Existing housing programs and services are being evaluated for effectiveness and
appropriateness considering resident housing needs and limitations such as funding
availability. The Housing Stability Technical Working Group focused on the need to
preserve covenant and non-covenant naturally occurring affordable housing, rental
assistance and support services to ensure housing security for existing residents most
vulnerable to displacement, and the need for additional funding sources to maintain and
implement program improvements or expansions. Existing rehabilitation and assistance
programs/services are listed below:
• Housing Preservation: Existing Preservation and Rehabilitation Programs:
• Conserve At-Risk Housing
• Rehabilitation: Acquisition and Rehabilitation
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• Rehabilitation: Small Grants
• Rehabilitation: Minor Home Modifications for Special Needs
• Mandatory Seismic Retrofit Program
• Lead-based Paint Hazard Reduction Program
• Housing Assistance: Existing Assistance Programs and Services
• POD (Preserving Our Diversity) Program
• Tenant Eviction Protection Program
• Rental Housing Voucher Programs (including Section 8 availability)
• Tenant Relocation Assistance Program
• Temporary Relocation Program
• Tenant/Landlord Mediation and Legal Services
• Support Services Programs that Serve Homeless/At-Risk Individuals
Effects of the COVID-19 Pandemic
It is important to note the likely impact the pandemic will have on available funding and
resources. There is uncertainty on how the pandemic will impact the existing programs
and services provided by the City, however it is anticipated that the need for support will
significantly increase in all areas. Following the Eviction Moratorium currently extended
until the end of June 2021, the City will need to address potential resident loss of
housing. Federal government assistance is uncertain and one-time emergency funds
used to provide rent assistance during the pandemic are not available. The City has
limited resources to continue to provide assistance to residents facing eviction during
this crisis in a broad capacity (e.g., paying back rent).
Funding Challenges
City Emergency Rent Assistance programs have historically been based on limited
flexible general funding for residents who are already being assisted through local non-
profits (case by case) and not based on a systemic program that would assist the
broader population based on limited resources:
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• During FY2020-21, the City provided assistance to 650 out of 1,000 applicants
through the COVID-19 Emergency Rental Assistance Program (ERAP)
• $2.8M in funds provided: $2.55M CDBG funds, $250K General Funds
• Use of CDBG funding for ERAP made possible by HUD’s onetime waiver of 15%
public services cap. CDBG is not viable source of recurring funding.
• City will be relying on County for rental assistance
• Additional staff capacity to manage programs is needed as well.
Current Revenue Sources for Housing Related Programs
• Affordable Housing Revenue Sources:
o In-lieu fees from AHPP and Affordable Housing Commercial Linkage
Program
o Proceeds from sale of City-owned property
• Measure GSH tax
• Community Development Block Grants
• General Fund
Stability Technical Working Group: Concepts and Recommendations
From the technical working group discussions emerged concepts and ideas that warrant
further evaluation and feedback from the City Council and residents within the
community, particularly from residents participating in housing programs. The group
concluded with a prioritized list including potentially viable program enhancements
based on current funding availability and future programs or program enhancements for
future consideration dependent on if and when additional funding and staff resources
become available. Similarly, the Council should also prioritize program improvements or
new concepts that warrant further consideration.
In its discussion, the Council should consider the following:
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1. Given the limited funding and staff resources, consider the Technical Working
Group’s concepts/recommendations and prioritize the program enhancements
and new concepts warranting further evaluation that will help inform the goals
and objectives related to housing stability/preservation.
2. Policy Question: Although the conversion of rent-controlled units or naturally
occurring affordable housing to long-term affordable units may not count towards
RHNA, should there be investment and priorities established in promoting the
preservation of the existing housing stock?
Potentially Viable Program Enhancements
Rental Assistance: Financial Support for Seniors, Families, Rent Burdened, etc.
Need for Assistance/Oversight with Housing Vouchers (including Section 8 Vouchers)
Sentiments were shared of landlord hesitancy to accept Section 8 residents and a
perception that Section 8 residents are higher risk tenants compared to those without
vouchers. The Municipal Code and State law, essentially require rental property
owners to accept Section 8 or housing vouchers and prohibit discrimination against an
applicant based on source of income, including housing vouchers. Technical Working
Group participants expressed frustration on the lack of oversight and enforcement of the
law. Landlords often view the Section 8 process as an administrative burden that
involves home inspections, verified habitability, and other qualifications as part of the
program approval. Delays in approval can be costly from the landlord perspective, and
participation not worth the time. In efforts to address the need for oversight and
enforcement, assistance from the City should include additional education and outreach
efforts to ensure residents and landlords understand their rights and legal obligations
under the program. In efforts to further encourage landlords to accept Section 8
residents, the City could subsidize the resident’s remaining portion of the monthly rent
amount, thereby minimizing landlord risk.
POD (Preserving Our Diversity) Program
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The Preserving Our Diversity (POD) program provides cash-based assistance to low-
income, long-term Santa Monica residents in rent-controlled apartments to help achieve
a minimum monthly after-rent income of $747 for a one-person household or $1,306 for
a two-person household. The program achieves a “basic needs budget” for seniors to
have a minimum amount of income remaining after rent is paid each month for food and
medical expenses. Currently, the program is available for qualifying long-term senior
residents.
Many have expressed support for this program and suggest that the program be
expanded to assist others who are also rent burdened. Any program expansion will be
dependent on funding availability that would inform how the program may be expanded;
whether expansion means assistance to additional seniors or to include families
(including disabled/special needs families). Making the program available to families
would require a long-term commitment to significantly increase funding as families have
higher household expenses compared to seniors. Due to limited resources, it is
important to consider how best to spread the available funding to ensure overall
effectiveness such as monitoring the number of participants.
Resident Services and Tenant Protections: Landlord/Tenant Support
Right to Counsel
A Right to Counsel pilot program (City Attorney’s Office) is underway that would provide
residents with free legal counsel/representation against attempted evictions by
landlords. The pilot program will be evaluated for overall effectiveness, program
capacity, and whether the program can be sustainable. The pilot program was approved
with a budget of $120,000 per year for two years.
Education/Information Assistance for Tenants and Landlords
The technical working group discussed issues related to resident and landlord
relationships, particularly stemming from resident mistrust of landlords. Discussions
were held on the need for additional education and outreach assistance (from City staff)
to both residents and landlords on increasing the awareness of housing programs
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(including Section 8 housing vouchers and landlord acceptance obligation), resident
qualifications, and benefits of program participation. Subject to funding, additional City
staff in the role of outreach coordination would be helpful to assist vulnerable residents
with counseling (including credit counseling) and navigating through housing
applications, programs, and services. Other areas of needed assistance include
additional support in locating housing upon tenant relocation (including follow-up),
coordination with temporary relocation during repairs and maintenance to units, and
additional support in programs that serve homeless and at-risk individuals (case
management). Although funding for additional staff is needed to fill these liaison
positions and would depend on future funding, general program support remains
ongoing.
Supportive Services Programs that Serve Homeless/At-Risk Individuals
Case management support services provided to homeless and at-risk individuals are
provided to ensure housing retention. It was suggested that services improve to better
assist participants long-term and to improve tailoring services to the individual. Currently
funded housing retention programs have a 90% or better (some are 97%) retention rate.
Improving services would require additional investments to increase staffing and lower
the client/staff ratio, and therefore would be considered a future program enhancement
dependent on additional funding. Currently staff ratios can be 1:30 or more (best
practices are 1:10 for high-need individuals).
Housing Preservation: Maintain Housing Affordability
Conserve At-Risk Housing
The City has assisted in the development of a variety of affordable housing projects that
are currently serving the community. Publicly-assisted housing units with Federal rental
assistance subsidies are protected by covenants. Those units with covenants nearing
expiration are considered “at-risk” of potential conversion to market-rate housing. These
units often serve seniors or persons with special needs. The City continues to monitor
the status of at-risk projects and consider the feasibility of ensuring that these units
remain as affordable units.
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Expanding this policy to focus on non-covenant residential units such as rent controlled
units has been discussed. As rent-controlled units continue to age, they become more
at-risk of being removed pursuant to the Ellis Act. The technical working group
discussed the need to reform the rent increase process in conjunction with incentives
(such as permit fee waivers for maintenance/repair) to encourage landlords to
rehabilitate their aging buildings and remain in the rental business.
Housing Maintenance and Rehabilitation
a. Rehabilitation: Acquisition and Rehabilitation
The acquisition and rehabilitation of existing housing and conversion to affordable
units preserve naturally occurring affordable housing while also helping to minimize
tenant displacement and maintain affordable rents. While effective, acquisition and
rehab is expensive and has primarily been accomplished with City assistance. As
discussed earlier in strategies to support the production of 100% affordable housing,
affordable housing providers have expressed difficulty in competing in the open
market to acquire property when they become available for purchase. Establishing a
program similar to the City of San Francisco’s Community Opportunity to Purchase
Act (COPA) which gives qualified non-profit organizations the right of first offer,
and/or the right of first refusal to purchase certain properties offered for sale in the
City would help to address this issue. COPA was created to prevent tenant
displacement and promote the creation and preservation of affordable rental housing
and is supported through funding from the City of San Francsico. The COPA
program would be evaluated to determine whether a similar program could be
implemented for Santa Monica as an acquisition/rehab strategy, particularly because
funding is very limited for acquisition of properties. Because this would be a new
program that would likely need to be sustained through public assistance, feasibility
is unknown at this time and would be considered a future program depending on
funding availability.
b. Rehabilitation: Small Grants
The City implements the Residential Rehabilitation Program that provides small
grants to owners of multifamily rental properties occupied by low- and moderate-
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income tenants. Currently there are rehab projects in-progress scheduled for
completion in FY2021-22 consisting of 38 units at two locations. Aside from this
remaining project, currently there is no additional/continued funding for this program
for the next 5 years in the Community Development Block Grant (CDBG)
consolidated plan. Although the program has been successful, there are
considerable challenges in finding property owners who are willing and eligible to
participate. The City has not received any applications in the past two years. In
terms of priorities, currently the small grants program is not a critical priority relative
to other programs that provide needed benefits, considering all other issues and
limited resources including funding. As such, this existing program while successful
in past years, is less efficient due to the limited funding available that may not
provide landlords with meaningful upgrades to their units.
The Technical Working Group discussed expanding this as an exchange program on
a per unit basis (and not entire property) where grants are provided for ongoing
maintenance/repair in exchange for deed restricting such units for long-term
affordability. However, staff believes there are potential challenges for landlords to
deed-restrict their units long-term as it may not be economically viable and therefore
unlikely, considering the small amount of financial assistance in rehabilitating units
compared to loss of market rents.
Other New Concepts / Future Programs
In addition to the housing program expansion and enhancements above, the working
group recommended further evaluation on the following new concepts and programs
that address the preservation of existing housing.
Rehabilitation Tax Abatement Program
A new program was suggested, similar to the Mills Act program for historic properties,
where small rehabilitation grants are provided to landlords in exchange for property tax
abatement/reduction for a period of time to amortize the cost of the work on a sliding
scale basis (example year to year, 5 years max). This would promote rehabilitation of
existing housing stock while providing short-term affordability.
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Staff’s initial feedback on this concept is that such program may be better suited or
more appropriate in cities experiencing very low rents and where there is a pervasive
maintenance issue with properties. Implementation would require coordination outside
of Santa Monica, similar to the Mills Act program, which is a State program that requires
coordination between local cities and the County Assessor’s Office, including legislative
changes. As with any new program, evaluation must consider overall effectiveness on a
broader scale and balance output with staff resources to administer such program.
VI. Ramifications of Future Non-Compliance
State law requires that each city plan for its housing needs through the Housing
Element process. In recent years, the State legislature has adopted enhanced
enforcement mechanisms to ensure that all local jurisdictions adopt and implement
Housing Elements that are consistent with State law. If Santa Monica fails to produce a
certified Housing Element, or subsequently takes an action that is inconsistent with a
certified Housing Element, the City would be at risk of enforcement action from the
State, up to and including judicial action, fines of at least $10,000 per month, loss of
eligibility for grants and state funding programs, and loss of local control over land use
decisions. The State has in recent years demonstrated its willingness to take legal
action to compel cities to bring their Housing Elements into compliance.
One of the primary tools in State law to further housing production for jurisdictions that
have not met their RHNA targets is SB 35. Specifically, if the City does not meet its
RHNA production goals, based on annual progress reports’ comparison to pro-rated
goals, housing projects would be eligible for the streamlined process available under SB
35, which involves a streamlined ministerial approval process for housing projects that
provide a minimum percentage of affordable units. If the City does not demonstrate
sufficient progress towards Above Moderate units, projects that provide 10% affordable
units, a level that may be lower than that established by the City, would be eligible for a
ministerial process. However, if there is insufficient progress towards the production of
Lower Income units then only projects with greater than 50% affordable units would be
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eligible for the ministerial process. Given that it is unlikely that a market-rate project
would include 50% affordable units, absent a substantial subsidy, it is likely that that the
latter class of projects would be 100% affordable housing projects. Attachment E
provides additional detail on how other provisions of SB35 would impact Santa Monica.
Figure 35: SB35 Ministerial Process Thresholds and Affordability Requirements
Affordability Level SB35
Insufficient
progress towards
Above Moderate
units
Insufficient
progress
towards Lower
Income units
Minimum affordability to qualify
for ministerial approval 10% 50%
VII. Questions for City Council Consideration
The following questions are intended to guide the City Council’s discussion on the draft
concepts:
1. Where should housing be located - Which geographic option for distribution of
potential housing sites best aligns with Santa Monica’s values and also
accomplishes the requirement to Affirmatively Further Fair Housing?
i. Option A – Adopted LUCE
ii. Option B – Dispersed Housing
iii. Option C – Transit-Oriented (½ mile around major transit stops)
b. Are there any other concepts that would meet the requirement to Affirmatively
Further Fair Housing?
i. Review Single Family Zoning to allow for the development of increased
housing opportunities
ii. Activate housing as a permitted use in areas formerly not available
such as Office Campus (OC) and Industrial Conservation (IC)
iii. Modify development standards to increase the viability for housing
development in areas where such housing has not formerly occurred
such as Montana Avenue, Main Street, and the eastern end of Ocean
Park Blvd
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2. How do we plan to achieve the RHNA – Provide feedback on the 4-point draft
strategy to plan for affordable housing:
i. Maximize inclusionary housing
1. Increase inclusionary requirements for market-rate projects
2. Provide flexibility for providing affordable housing units off-site
ii. Support for 100% affordable housing projects
1. For affordable housing projects up to 80% AMI
a. Unlimited height and density
b. No minimum parking requirements
c. Right of first offer by non-profit affordable housing
providers on land for sale
2. For moderate-income housing projects (up to 120% AMI)
a. 50% density/FAR bonus
b. 3 stories or 33 feet
c. Flexibility in unit mix with a trade-off for more common
area amenities
iii. Seek opportunities to create more affordable housing in existing
housing stock
1. Expand property owner and tenant outreach to maximize
participation in project-based voucher program
2. Flexibility in off-site affordable housing requirements for market-
rate projects through acquisition/rehabilitation and conversion of
existing units to deed-restricted affordability
iv. ADU incentives
1. Pursue program to accelerate ADU production including
process incentives like pre-approved plans
2. Allow for additional ADU unit if the extra unit is affordable
3. Would it be appropriate to consider more housing density on unique sites like “A-
lots” and parking lots of religious congregations to support affordable housing
production?
8.A
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4. With approximately 17 acres of City-owned land that has housing potential, should
the City prioritize affordable housing on City-owned sites?
a. Is there interest in establishing a minimum amount of affordable housing for
redevelopment of City-owned sites?
b. Should City-owned sites be re-zoned to maximize affordable housing
potential?
5. With limited resources, which updates to housing programs should be the priority to
promote housing stability for existing residents?
a. Coordinate housing resources to allow tenants and landlords to more easily
access information on resources, programs, rights and obligations
b. Cash assistance
i. Expansion of POD
ii. Outreach for housing vouchers
c. Eviction assistance
i. Right to Counsel
ii. Education for tenants/landlords
d. Relocation assistance
i. Temporary relocation
ii. Permanent relocation
e. Housing preservation
i. Incentives for landlords to rehabilitate aging buildings and remain in
rental business
ii. Increased enforcement of landlords not doing basic maintenance
iii. Enforcement of anti-discrimination in housing
Financial Impacts and Budget Actions
There are no immediate financial impacts or budget actions necessary as a result of the
recommended actions in this report.
8.A
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Prepared By: Jing Yeo, Planning Manager
Approved
Forwarded to Council
Attachments:
A. 6th Cycle Housing Element Update Existing Conditions Report
B. HR&A Preliminary Feasibility Analyses March 2021
C. Summary Report on Preliminary Sites Analysis
D. HCD Alternative Adequate Sites Checklist
E. SB35 Summary Implications for Santa Monica
F. Final 6th Cycle RHNA Allocation
G. Attachment G - Mobility and Housing Survey Summary Results
H. Summary of Planning Commission Recommendations on Housing Element
Update Draft Concepts Final
I. Santa Monica HOLC Map
J. Written Comments
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6th Cycle Housing Element 2021-2029
Existing Conditions Report
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Table of Contents
1. Population, Households and Employment
2. Specialized Household Needs: Seniors, People with
Disabilities, and Households with Children
3. Homelessness and Households in Poverty
4. Housing Stock Characteristics
5. Housing Cost and Overpayment
6. Overcrowding
7. At Risk Units
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Introduction
The California Housing and Community Development Department (HCD) requires that Housing
Elements include a complete analysis of existing housing needs and conditions. This document has
been prepared to provide the background data for the City of Santa Monica’s 6th Cycle Housing
Element Update.
Information regarding the City’s population, housing stock, house, and employment are provided
herein to support the Housing Element Update. Sources of data include the California Department of
Finance (DOF), Census Bureau’s American Community Survey (ACS) 5-Year 2019 estimates, and
California Housing Partnership.
The most recently available data is used. For 2020 population and housing unit counts, the DOF data
is used. The DOF does not provide detailed data regarding housing type, population and household
characteristics - such information are provided in the Census Bureau’s ACS. Since 2020 ACS data are
not yet available at the time of this writing, 2019 ACS data are used for specific demographic and
housing data.
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1. Population, Households, and Employment
Population
Relative to the County and other cities in the Los Angeles metropolitan area, the City of Santa
Monica’s population growth has been modest since 1970. According to the Census and ACS, the City
has grown at a slower rate than the County of Los Angeles over the last 30 years (see Table 3.15-1).
In 2020, the population of Santa Monica was approximately 92,357, accounting for approximately
0.91% of the 10,172,951 countywide population. The City experienced a 0.03% increase between 1970
and 1980, a 4.58% increase between 1980 and 2020; growing by approximately 3,764 residents. This
period of population growth includes three decades where the population declined by 1.6% from 1980
to 1990, and by 3.2% from 1990 to 2000, followed by one decade of population growth of 6.7 percent
from 2000 to 2010, and a growth of 2.92% from 2010 to 2020.
Table 1 Total Population in 1970-2020
1970 1980 1990 2000 2010 2020
City of
Santa
Monica
Population 88,289 88,314 86,905 84,084 89,736 92,357
Growth
previous
10- years
-
0.03% -1.6% -3.2% 6.7%
2.92%
Los
Angeles
County
Population 7,032,075 7,477,503 8,863,052 9,519,338 9,818,605 10,172,951
Growth in
previous
10-years
-
6.3% 18.5% 7.4% 3.1%
3.6%
Source: U.S. Census data for decennial data; Department of Finance Population data for 2020 population estimate.
Although the City is located within Los Angeles County, growth patterns in the City tend to be
independent from the County, as evidenced in Table 1. During the total 40-year period from 1970 to
2010, the County population has consistently grown in larger percentages than the City due in large
part to new development occurring in the outlying areas of the San Fernando Valley and the
Antelope Valley. The largest population increase in the County occurred from 1980 to 1990 which saw
a 18.5% growth. Since 1990, however, County growth has slowed with a 7.4% increase from 1990 to
2000, and a 3.1% increase from 2000 to 2010. While there was an overall small population increase in
the County by 3.6% in the past decade from 2010 to 2020, population data from the State’s
Department of Finance have showed a drop in population for the past three years – 0.2 % drop in
2018, 0.3% drop in 2019, and 0.1 % drop in 2020. The decrease in population growth is likely attributed
to declining birthrate, migration out of the state that is partly driven by a lack and high cost of housing,
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as well as a decrease in immigration. This more recent data may be indicative of a downward
population trend in the County and State as a whole.1
Furthermore, population data since the onset of the COVID-19 pandemic are not yet available at the
time of this writing, and it will be uncertain for awhile what the long term effects of the pandemic will
be on population growth. However, demographers predict that the pandemic has accelerated the
slowdown trend in growth and that the State as a whole have peaked in population and will likely see
a population growth rate of near zero.2
Age
The changing age distribution of a population is an important consideration in assessing the housing
needs of a community. For example, a community with an aging population will require more senior
housing and supportive services for seniors. Similarly, if a community has an increasingly younger
population of persons below age 18, it may signal the demand for more or larger single-family
housing.
By in large, young adults between the ages of 25-44 are the largest representative age group in the
City, comprising 38% of the total population. However, this age group has also experienced the
greatest decrease from 1990 to 2020. As shown in Table 2, the numbers of young adults have
declined by 12.2% - this could be due in part to an aging population, as the numbers of middle age
adults have increased by 36.1% during the same time period. The senior population has increased
also, though at a more modest rate – increasing by 13.4% since 1990. In comparison to most cities, the
1 http://www.dof.ca.gov/Forecasting/Demographics/Estimates/e-1/documents/E-1_2020PressRelease.pdf
2 https://calmatters.org/commentary/california-population-peaking-declining-census/
86,905
84,084
89,736
92,357
1990 2000 2010 2020
Population Trend, 1990-2020
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City has a relatively low percentage (4.9%) of preschool age population – likely due in part to falling
birth rates as well as the City’s low stock of larger sized housing units (see discussion of Housing
Stock).
Table 2 City Population by Age in 1990-2019
Age Distribution - 2019 ACS
Estimates 1990 2000 2010 2019
% Change 1990-
2019
Preschool (<5 yrs) 4,048 3,448 3,696 4,265 5.4%
School Age (5-17 yrs) 7,929 8,866 8,884 9,430 18.9%
College Age (18-24 yrs) 6,238 5,114 6,442 5,621 -9.9%
Young Adults (25-44 yrs) 37,175 33,704 35,552 32,632 -12.2%
Middle Age (45-64 yrs) 17,164 20,874 24,746 23,362 36.1%
Seniors 65 + 14,351 12,078 13,416 16,267 13.4%
Source: American Communities Survey 2019 5-Year Estimates
0
5000
10000
15000
20000
25000
30000
35000
40000
Preschool (<5 yrs)School Age (5-17
yrs)
College Age (18-
24 yrs)
Young Adults (25-
44 yrs)
Middle Age (45-
64 yrs)
Seniors 65 +
Growth by Age Category
1990 2000 2010 2019
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Race and Ethnicity
Unlike our larger, neighboring City of Los Angeles, whites still make up the majority of the City’s
population. However, census data shows that the City’s racial makeup is becoming more diverse.
From 2000 to 2010, the percentage of whites remained dropped from 72% to 70%, and from 2010 to
2018, dropped further to 64%. In the same approximately 18 year period, non-white races have
increased in small percentages, including Hispanics (or Latinos) who make up approximately 15.9%
(an increase of 2.5% since 2000) and Asians who make up 9.8% of the population (an increase of
2.6%). The number of Blacks (African Americans) only slightly increased relative to the proportion of
the population by 0.6%. One of the likely barriers to geographic mobility for non-whites is the high
cost of housing. As indicated in the Household discussion below, Hispanics and Black Households
have the lowest median income in the City and County as a whole, and as a result, are often priced
out of living opportunities in the City.
Table 3 City Population by Race 2000-2019
Category 2000 % 2010 % 2019 %
White 60,482 71.9% 62,917 70.1% 59,200 64.3%
Hispanic or Latino 11,304 13.4% 11,716 13.1% 14,097 15.9%
Asian 6,043 7.2% 7,960 8.9% 9,018 9.8%
Black or African American 3,081 3.7% 3,364 3.7% 3,995 4.3%
Two or more races 2,584 3.1% 3,174 3.5% 4,571 5.0%
Other (American Indian, Alaskan Native,
Native Hawaiian and other)
590 0.7% 605 0.7% 696 0.8%
TOTAL 84,084 89,736 91,577
Source: American Communities Survey 2019 5-Year Estimates
White
65%Hispanic or Latino
15%
Black or African American
Asian
10%
Two or more races
5%Other (American Indian, Alaskan Native,
2019 Population by Race
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Table 4 Population Distribution by Race and Zip Code
Population by Zip Code
Race 90401 90402 90403 90404 90405
Hispanic or Latino (of any
race)
765 1,186 1,784 6,398 4,397
Not Hispanic or Latino 6,346 10,696 22,118 16,531 23,759
White alone 4,825 9,103 17,841 10,622 18,589
Black or African American
alone
691 101 590 1,656 968
Asian alone 499 996 2,321 3,178 2,091
Some other race alone 0 41 84 62 336
Two or more races 320 455 1,252 961 1,695
Other (some other,
American Indian, Native
Hawaiian)
11 41 114 114 416
60,482 62,917 59,200
11,304 11,716 14,097
3,081 3,364 3,995
6,043 7,960 9,018
2,584 3,174 4,571
590 605 696
0%
10%
20%
30%
40%
50%
60%
70%
80%
90%
100%
2000 2010 2019
Demographic Change 2000-2019
Other (American Indian, Alaskan Native, Native Hawaiian and other)
Two or more races
Asian
Black or African American
Hispanic or Latino
White
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Households
The U.S. Census Bureau also tracks the number of households, which is different from the number of
housing units which counts both occupied and vacant units. A household is defined by the U.S. Census
as a group of people who occupy a housing unit. Table 5 shows housing and household
characteristics for the City for the years 1970,1980, 1990, 2000, 2010, and 2020.
Table 5 City of Santa Monica Housing and Households
Year Housing Units
Households
(Occupied
Housing Units)
Owner
Occupied Units
Renter
Occupied
Units
Average
Household
Size
1970 42,106 39,904 9,119 (22.9%) 30,785 (77.1%) -
1980 46,418 43,912 9,718 (22.1%) 34,194 (77.9%) -
1990 47,753 44,860 12,340 (25.8%) 32,520 (68.1%) 1.88
2000 47,863 44,497 13,277 (27.7%) 31,220 (65.2%) 1.83
2010 50,912 46,917 13,315 (26.2%) 33,602 (66%) 1.87
2020 52,629 48,120 Not yet available Not yet available 1.88
As shown in Table 4, the U.S. Census reported that Santa Monica had 46,917 total households
(occupied housing units) in 2010. This represents an increase of 2,420 households or 5.4% from 2000.
0
5000
10000
15000
20000
25000
30000
90401 90402 90403 90404 90405
Population Distribution by Zip Code
Other (some other, American Indian, Native Hawaiian)
Two or more races
Asian alone
Black or African American alone
White alone
Hispanic or Latino (of any race)
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Based on the most recent DOF estimates, in 2020, the City’s housing stock grew to approximately
52,629 units, and the number of households increased to 48,120.
Household Tenure
The City’s residential population is comprised primarily of renters. The highest concentration of
renter households is located downtown and east of Lincoln Boulevard along the Pico Boulevard
Corridor and the highest concentration of owner-occupied households is located north of Montana
Avenue and the eastern portion of the city north of Wilshire Boulevard, as well as certain census
tracts in Sunset Park. The proportion of owner occupied households in 1970 and 1980 stayed
relatively consistent at around 22% with renter households comprised 77% of the total households.
In 1990, owner occupied households increased to 27.5%, and in 2000 increased to 29.8%. However,
since that time, home ownership opportunities have become even more limited. In 2010, the
proportion of owner occupied households was at 28.4%. By 2019, renter households made up 71.4%
of the total households while owner occupied households comprised only 28.6%.
22.9%22.1%27.5%29.8%28.4%28.6%
77.1%77.9%72.5%70.2%71.6%71.4%
0
5,000
10,000
15,000
20,000
25,000
30,000
35,000
40,000
45,000
50,000
1970 1980 1990 2000 2010 2018
Households by Tenure
Owner Occupied Renter Occupied
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Table 6 Household Characteristics by Zip Code
90401 90402 90403 90404 90405
Areas Covered: Downtown,
Civic, parts of
MidCity
NOMA Wilmont,
Northeast
Mid-City, Parts
of Pico
Sunset Park,
Ocean Park,
Parts of Pico
HOUSEHOLDS
Total
households
4,603 4,999 12,739 9,957 13,943
Average
household size
1.5 2.38 1.86 2.21 2
HOUSING
TENURE
Owner-
occupied
6.80% 68.50% 23.70% 22.80% 34.20%
Renter-
occupied
93.20% 31.50% 76.30% 77.20% 65.80%
FAMILIES
Total families 957 3,132 5,271 4,458 5,763
Average family
size
2.52 3.04 2.69 3.18 2.88
OWN CHILDREN
Households
with own children
of the
householder
under 18 years
299 1,314 1,901 2,131 2,401
UNITS IN
STRUCTURE
1-unit
structures
2.90% 65.70% 14.00% 15.50% 30.70%
2-or-more-
unit structures
97.10% 34.30% 85.80% 83.80% 69.20%
Mobile homes
and all other
types of units
0.00% 0.00% 0.20% 0.70% 0.10%
Source: American Communities Survey 5-Year 2019 Estimates
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Tenure by Race
Of the approximately 13,000 owner occupied units, the vast majority of these units (more than 76%)
are owned by White householders (more than the population proportion of 65%). Less than 1,000 of
the City’s housing units are owned by Black and Hispanic/Latino householders.
Due to a number of factors, Blacks and Hispanic/Latinos are less likely to own in the City. Only 8% of
the City’s total Black households and 18% of total Hispanic/Latino households own, as compared to
69% for Whites and 87% for Asians.
8%
43%
13%19%18%31%
92%
57%
87%81%82%69%
Black or African
American
Asian Other Two or more
races
Hispanic or
Latino origin
White alone, not
Hispanic or
Latino
Renter vs Ownership Household by Race
Owner Renter
134
1,789
125
341
930
10,032
Black or African American
Asian
Other
Two or more races
Hispanic or Latino origin
White alone, not Hispanic or Latino
Ownership Units by Race
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Households (Family vs Nonfamily)
Based on the ACS 2019 estimates, there were approximately 45,309 households in the City. More
than half (59.3%) are non-family households, while the remaining 40.7% were family households.
Table 7 Santa Monica Households – Family and Non-family 1990
2000
2010
2019
No. % No. % No. % No. %
HOUSEHOLD TYPE
Family households 18,124 40.4% 16,783 37.7% 17,929 38.2% 18,887 40.7%
Nonfamily households 26,766 59.6% 27,714 62.3% 28,988 61.8% 26,422 59.3%
Total Households 44,860 44,497 46,917 45,309
Source: American Communities Survey 5-Year 2019 Estimates
Employment
Prior to the onset of the COVID19 pandemic, Santa Monica enjoyed a healthy and diversified
economy. Santa Monica’s pre-COVID unemployment rate in January 2020 was at a low 4.2%,
significantly down from a high of 10.4% in 2010 and 4.4% in 2000.3 Although the City weathered the
Great Recession relatively well during 2007-2008, this has not been the case for the current
recession brought on by the COVID19 pandemic. The pandemic has upended the local economy -
resulting in the loss of thousands of jobs. In July 2020, unemployment in the City reached a high of
15.2% as a result of the pandemic. With businesses reopening and adjusting to safety regulations,
unemployment in the City have improved to 10%.
The largest number of jobs were in Professional, Scientific and Technical Services, Accommodation
and Food Services, Health Care and Social Assistance, Information, and Retail Trade. The creative
and tech sector represents the top employment sector in the City with over 3000 businesses, which
include companies such as Activision, Snap, Inc., Cornerstone on Demand, Beach Body, LLC,
Universal Music Group, Amazon, Hulu, Lionsgate Entertainment. Pre-COVID, the creative and tech
sector provided 31,000 jobs, resulting in the City’s moniker – “Silicon Beach”. Santa Monica’s economy
also benefits from the tourism and hospitality sector, which provided over 14,000 jobs pre-COVID
within hotels, retail, restaurant, and entertainment businesses. Additionally, the City is home to UCLA
and Providence Saint John’s Hospitals which have over 6,000 employees.
3 California Employment Development Department (EDD), Local Area Unemployment Statistics
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Table 7 Employment in Santa Monica - # of Establishments and Average Employment
Industry 2008 2011 2019
# of
Firms
Average
Employment
# of
Firms
Average
Employment
# of
Firms
Average
Employment
Professional, Scientific, &
Technical Services
1,217 11,659 1,232 10,133 1,617 14,289
Information 619 7,754 589 8,290 805 14,417
Accommodation & Food
Services
377 11,183 416 12,844 511 14,167
Retail Trade 648 9,781 599 8,422 614 8,643
Health Care & Social
Assistance
843 8,368 836 8,074 2,565 9,761
Local Gov 49 6,279 48 5,437 44 5,985
Other Services 362 3,382 2,845 5,839 1,061 4,407
Real Estate & Rental & Leasing 392 3,268 365 3,096 530 2,864
Finance & Insurance 258 3,155 242 2,778 344 2,840
Admin & Support & Waste
Management & Remediation
230 2,636 195 2,435 264 2,433
Arts, Entertainment, &
Recreation
600 2,128 566 2,059 682 2,472
Wholesale Trade 230 2,355 202 2,613 234 2,419
Educational Services 85 2,359 84 2,712 129 1,785
Construction 227 2,607 196 1,452 201 1,782
Manufacturing 105 1,056 94 935 105 1,366
Transportation & Warehousing 29 359 35 321 38 334
Management of Companies
and Enterprises
22 604 25 346 21 499
Non-Classified 2 *** 612 396 1 ***
Utilities 6 281 3 244 5 218
Federal Gov 6 283 5 233 3 ***
State Gov 1 15 1 14 1 ***
6,315 79,525 9,193 78,677 9,781 90,923
Source: State of California EDD Labor Market Information, Quarter 3 data
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Table 8 Top Employers in City of Santa Monica
Employer # of employees
Providence Saint John’s Health Center 3,310
UCLA Medical Center, Medical Center 2,879
City of Santa Monica 2,298
Santa Monica Malibu School District 1,962
Santa Monica College 1,800
Snap, Inc 1,460
Activision 1,231
RAND Corporation 891
Hulu 882
Lionsgate Entertainment 819
Cornerstone on Demand 700
Rubin Postaer & Associates 630
Amazon 629
Oracle 607
E.T. Whitehall, Inc (Casa del Mar, Shutters on the
Beach) 579
Kite Pharma Inc 562
True Car 546
Bird 517
Red Bull North America Inc. 513
Beach Body LLC 506
Source: City of Santa Monica 2019.
Information, 15.83%
Professional,
Scientific, and
Technical Services,
15.62%
Accommodation and
Food Services, 15.44%
Health Care and
Social Assistance,
10.73%
Retail Trade, 9.44%
Local Government,
7.16%
Other, 25.52%
Santa Monica Employment Sectors
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This figure shows that the City is one of the top employment areas of the region.
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Wage
Many of the City’s workforce are low wage earners that are commuting from the surrounding
areas of the Los Angeles region, particularly in areas that are more affordable than the City. As
shown, the median annual income for food preparation, health care, and housekeeping employees
are well below the median annual income needed to live in a 2-bedroom apartment in the City.
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2. Specialized Household Needs: Seniors People with
Disabilities, Large families, and Households with Children
There are certain segments of the population that may have greater difficulty in finding decent,
affordable housing due to special circumstances. State Housing Element law (Government Code
Section 65583(a)(7)) requires “An analysis of any special housing needs, such as those of the elderly,
persons with disabilities, large families, farmworkers, families with female heads of households, and
families and persons in need of emergency shelter…” Recent passage of SB 812 has added to this law
a requirement to consider the needs of persons with developmental disabilities in the special needs
analysis. Santa Monica includes in its population individuals from each of these “special needs”
groups with the exception of farm workers.
Seniors
Approximately 16,267 seniors over 65 years live in 11,355 households. Approximately 58.7% are senior
households living alone. While many today continue to work beyond age 65, the growing retired
segment of the population generally have fixed incomes (social security, pension, etc.), making it
difficult to afford increases in rent or major home repairs.
Table 9 Senior Households 65+ Years
Households %
Family Households 4,304 38%
Nonfamily
Households
7,051 62%
Living Alone 6,665 58.7%
Not Living Alone 386 3.4%
Total 11,355
Source: American Communities Survey 5-Year 2019 Estimates
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Disability by Type
Persons with a disability often have special housing requirements due to the need for accessibility,
typically fixed and lower incomes and higher health care costs associated with their disabilities. A
“disability” is defined as a long-lasting physical, mental, or emotional condition. This can include those
with vision, hearing, ambulatory, cognitive, self-care, and independent living disabilities.
4,304
Living Alone, 6665
Not Living Alone,
386
0
1,000
2,000
3,000
4,000
5,000
6,000
7,000
8,000
Family Households Nonfamily Households
Senior Households 65+
7051
2,872
1,090
3,421
5028
3,456
4,731
0 1,000 2,000 3,000 4,000 5,000 6,000
Hearing
Vision
Cognitive
Ambulatory
Self-care
Independent living
Disability by Type
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Large Households
Large households, defined as households with five or more members, require larger units that are
generally more expensive. This often results in large households residing in smaller, less expensive
units or doubling up with another family or other persons to save on housing costs, both of which
result in unit overcrowding. Lower income large households are limited by lack of availability of
adequately sized affordable housing units. As shown in the table below, there are 1,384 large
households in the City. The vast majority of the households in the City are 1 person households and
the second most commonly occurring household size are 2 person households. This data on
household size is consistent with the City’s housing unit mix which are comprised mostly of 1 and 2
bedroom units.
Table 10 Tenure by Number of Persons Per Household
Total: Tenure
Owner occupied Renter occupied
1-person household 4132 17069
2-person household 4749 9129
3-person household 2053 3485
4-person household 1551 1757
5-person household 541 534
6-person household 96 176
7-or-more person household 16 21
Large Households (5 or more) 1,384
Total Households
45,309
Source: American Communities Survey 5-Year 2019 Estimates
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Households with Children
Of the 45,309 total households in the City, a total of 7,750 households include children under the age
of 18. Single parent households comprise 1,751 (or 22%) of these households with children. Single
parent households typically have less income than a two parent household since there is only one
wage earner. Approximately 68% of the single parent households are identified as female
households, with no spouse/partner present.
Table 11 Households with Children Under 18
Households with Children 2019
Single Parent Households w/Children Under 18 1751
Cohabitating Couple Households w/ Children Under 18 283
Married Couple Households w/ Children Under 18 5716
Total Households with Children 7,750
Total Households 45309
Source: American Communities Survey 5-Year 2019 Estimates
4132474920531551541961617069912934851757534176210
2000
4000
6000
8000
10000
12000
14000
16000
18000
1 2 3 4 5 6 7
Tenure by # of Persons per Household
Owner occupied Renter occupied
1751
283
5716
45309
Single Parent Households w/Children Under 18
Cohabitating Couple Households w/ Children…
Married Couple Households w/ Children Under 18
Total Households
Households with Children Under 18
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3. Homelessness and Households in Poverty
Homelessness
Despite having a successful economy prior to the COVID19 pandemic, the State has seen a steady
rise in homelessness in the past
decade. While mental health issues,
addiction, trauma, crimimal justice
history, and poverty all are
contributing factors to homelessness,
the cost of housing is the most
important reason why someone can
become homeless.4 Driven by a lack of
adequate supportive housing options
and affordable housing,
homelessness has become one of the
most visible indicators of the State’s
housing crisis. In Los Angeles County and the City, it is a common sight to see people living on the
streets, in shelters, or in their cars.
One-night homeless counts conducted on a yearly basis provide a snapshot of the number of
homeless people in shelters and unshelters. As shown in Table 7, these counts show that the City has
a homeless population of approximately 907 people – an increase of 22.8% from 2015. The homeless
poulation drwopped slightly from 2018 to 2020, but the situation is expected to worsen as the
economic recession effects brought on by the COVID19 pandemic take hold in the next couple
montsh as eviction moratoriums expire.
Table 9 One-Night Homeless Counts City of Santa
Monica
Service Planning
Area 5 - Westside
Los Angeles
County
2015 738 4276 41174
2016 728 4659 43854
2017 921 5411 52442
2018 957 4401 49955
2019 985 5262 56257
2020 907 6009 66436
Source: Los Angeles Homeless Services Authority, https://www.lahsa.org/homeless-count/
4 California’s Homelessness Explained, CalMatters online at https://calmatters.org/explainers/californias-homelessness-
crisis-explained/
0
10000
20000
30000
40000
50000
60000
70000
2015 2016 2017 2018 2019 2020
Los Angeles County Homeless Count 2015-2020
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When looking at racial composition, Blacks/African Americans are overly represented in the
homeless population. Although Blacks/African Americans make up 8% of Los Angeles County
population, they constitute 34% of the County’s homeless population.
Poverty
California has one of the highest poverty rates in the nation due in large part to the high cost of living.
Households in poverty are at the greatest risk to homelessness as they are just at the edge of losing
their home. Households in poverty are very vulnerable to the slightest increase in home costs or
decrease in wages. The table below shows that 5,517 households (11% of the City’s total households)
are living in poverty in the City. Most households in poverty are located in the 90405 zip code.. Black
and Hispanic/Latino families are more likely to be living in poverty more than any other race group –
11.7% of Black families are living in poverty compared to just 3.4% of White families.
Table 12 Households in Poverty
Total Households in Poverty 5157
Non-family Households w/ Income in Poverty 4265
Family Households w/ Income in Poverty: 892
Source: American Communities Survey 5-Year 2019 Estimates
706
450
1287 1234
1513
0
200
400
600
800
1000
1200
1400
1600
90401 90402 90403 90404 90405
Households in Poverty by Zip
Family households:Nonfamily households:
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4265
251
176
265
159
0
500
1000
1500
2000
2500
3000
3500
4000
4500
Non-family Family
Households in Poverty for Past 12 Months
Married w/Children
Married, No Children
No Spouse/Partner w/Children
No Spouse/Partner, No Children
3.4%
4.2%
8.0%
8.4%
8.6%
11.7%
0.0%2.0%4.0%6.0%8.0%10.0%12.0%14.0%
White alone, not Hispanic or Latino
Asian alone
Two or more races
Some other race alone
Hispanic or Latino origin (of any race)
Black or African American alone
% of Families in Poverty by Race of Householder
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4. Housing Stock Characteristics
Housing Growth
The City’s residential neighborhoods have been largely built out since the 1970s – when the rate of
new housing construction started to slow. From 1970 to 1980, the rate of housing growth was
approximately 10.2% - with the housing stock increasing from 42,106 units to 46,418 units. In the
following decade, the rate of new housing dropped drastically to 2.9% between 1980 to 1990. By the
early 1990s, the onset of the economic recession grounded housing construction almost to a halt
resulting in only a 0.2% increase in new housing units from 1990 to 2000. After 2000, as the economy
became stronger, new housing construction increased but slowed down from 2010-2020. Most of
this new housing occurred in the City’s commercial zones and consisted of multifamily residential
units within infill residential and mixed-use buildings. By 2020, the City had a total City housing stock
of 52,629 units. (see Table 3.15-3). Most of this increase occurred in the City’s Downtown area as
multifamily units within mixed use medium-rise and high-rise buildings.
Table 13 Total Housing Stock in 1970-2020
City of Santa
Monica
% Change in past 10
years Los Angeles County % Change in
past 10 years
1970 42,106 - 2,538,910 -
1980 46,418 10.2% 2,855,506 11.1%
1990 47,753 2.9% 3,163,343 9.7%
2000 47,863 0.2% 3,270,909 3.3%
2010 50,912 6.4% 3,445,076 5.1%
2020 52,629 3.2% 3,568,900 3.5%
Source: US Census for decennial estimates; California Department of Finance for 2020 estimate
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10.2%
2.9%
0.2%
6.4%
3.2%
11.1%9.7%
3.3%
5.1%3.5%
0.0%
4.0%
8.0%
12.0%
16.0%
1970-1980 1980-1990 1990-2000 2000-2010 2010-2019
Changes in Housing Stock
1970-2019
City of Santa Monica Los Angeles County
11,193 11,580 11,579
36,381 39,127 40,746
0
10,000
20,000
30,000
40,000
50,000
60,000
2000 2010 2019
Single Family vs Multi-family Housing Units 2000-2019
Single Family Unit Multi-Family Unit
9,740
1,832
5,283
35,570
2040
5,000
10,000
15,000
20,000
25,000
30,000
35,000
40,000
Single Family
Detached
Single Family
Attached
Multifamily, 2-4
Units
Multifamily, 5+ Units Mobile Homes
Housing Type. 2019
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Vacancy
Based on 2019 ACS 5-Year estimates, the City’s housing stock includes 5,815 vacant units, with the
homeowner vacancy rate at 2.2% and rental vacancy rate at 2.5%. Of the total vacant units, 20% of
them are held for seasonal recreational uses. Over half are classified as “other vacant”. Common
reasons a housing unit is labeled “other vacant” is that no one lives in the unit and the owner: 1) does
not want to rent or sell 2) is using the unit for storage; 3) is elderly and living in a nursing home or with
family members. Other reasons the unit is classified as “other vacant” is that the unit is being held for
settlement of an estate, is being repaired or renovated, is abandoned or will be demolished, or is
being foreclosed.
Table 14 Vacancy Data - 2019
Total housing units 51124
Occupied housing units 45309
Vacant housing units 5815
Homeowner vacancy rate 2.2
Rental vacancy rate 2.5
Table 15 Vacant Units by Type
Vacant Units by Type 2019
For rent 823 14.2%
Rented, not occupied 344 5.9%
For sale 302 5.2%
Sold, not occupied 159 2.7%
Seasonal 1,174 20.2%
For migrant workers 0 0.0%
Other vacant 3,013 51.8%
Total: 5,815
Source: American Communities Survey 5-Year 2019 Estimates
14.2%
5.9%5.2%2.7%
20.2%
0.0%
51.8%
0%
10%
20%
30%
40%
50%
60%
For rent Rented, not
occupied
For sale Sold, not
occupied
Seasonal For migrant
workers
Other
vacant
Vacant Units by Type
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Age and Size of Housing Stock
The City’s residential neighborhoods have been largely built out since the 1970s. After this time
period, housing construction slowed significantly as evidenced by the age of the City’s housing stock.
Approximately 75% of the City’s housing stock was built before 1980, with approximately 1900 of
these units in substandard conditions (42 lacking complete plumbing, 964 lacking full kitchen and 911
units without telephone service).
981 880
3,280 2,838
4,426
10,227
9,018
7,116
4,901
7,457
0%
2%
4%
6%
8%
10%
12%
14%
16%
18%
20%
Age of Housing Stock
42
964 911
0.0%
1.0%
2.0%
3.0%
Lacking complete plumbing
facilities
Lacking complete kitchen
facilities
No telephone service available
Substandard Housing
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As a City with mostly multifamily rental housing, its not surprising that one and two bedroom units
make up 32% and 37% of the housing supply respectively. Larger sized units generally consist of
single family units that are located in the City’s R1 (single family) zones.
Rent Controlled Units
Many of the older rental units are subject to the City’s Rent Control Law, which controls most
residential rental buildings constructed prior to April 10, 1979. Rent controlled units are subject to
maximum annual rent increases authorized by the Rent Control Board, and as such, are valuable
assets to the City’s housing market. These rent control units account for slightly more than one‐half
of all housing in Santa Monica and just over two‐thirds of multi‐family housing. The number of rent
controlled units have decreased over time as a result of temporary use exemptions (for example,
owner‐occupancy exemptions on properties of three‐or‐ removal permits, or units being withdrawn
from the rental housing market pursuant to the Ellis Act. In 2019, there were 27,381 Rent Controlled
units in the City.
Studios
10%
1 bedroom
33%
2 bedrooms
36%
3 bedrooms15%
4 bedrooms
4%
5 + bedrooms
2%
Housing Supply by # Bedrooms
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5. Housing Cost and Overpayment
Housing Cost
While it is widely recognized that housing costs in the State are the highest in the nation, the City
of Santa Monica ranks as one of the most expensive places to live. The cost of a single famiy
home in 2019 was at almost $4 million, more than 5 times the national median cost. While condo
ownership offers an easier pathway to ownership – the median condo cost is still high at over
$1.1 millon. Rental prices are similarly high, with the median monthly rents for a 2 bedroom
apartment at $3200 a month. Renters need to earn $61.66 per hour (or an annual income of
$128,000), more than 4 times the minimum wage in the City to afford the average monthly
asking median rent of $3,200 for a two bedroom apartment.
Source: National Association of Realtors and California Association of Realtors
$274,500
$615,090
$3,966,251
$808,322
$1,417,500
$978,000
$765,000
$254,600
$477,000
$915,000 $765,000
$1,100,000
$425,000 $577,500
$-
$500,000
$1,000,000
$1,500,000
$2,000,000
$2,500,000
$3,000,000
$3,500,000
$4,000,000
$4,500,000
National California Santa Monica Los Angeles
City
San Francisco Huntington
Beach
San Diego
2019 Home Prices
Single Family Home Condo
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Spending on Rent
The general rule is that no more than 30% of gross monthly income should be spent on housing.
Households that spend more than this percentage are considered to be “housing cost
burdened”. Not suprisingly, with the high cost of housing in the City, more than 42% of the City's
rental households are considered housing cost burdened.
Table 16 Gross Rent Paid as a Percentage of Monthly Income
Gross Rent as a % of Household Income Rental Households
<10% 2,449
10-14.9% 4,134
15-19.9% 3,928
20-24.9% 3,530
25-29.9% 2,922
30-34.9% 2,128
35-39.9% 1,797
40-49.9 % 2,669
>50% 7,037
Not computed 1,577
Total: 32,171
Total Cost Burdened Households (Rent is 30% or more of Income) 13,631
$-
$500
$1,000
$1,500
$2,000
$2,500
$3,000
$3,500
National California Los Angeles Metro Santa Monica
$1,192
$1,832
$2,235
$3,200 2019 Median Rent Price
Rent price based on a two-bedroom unit
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Table 17 Household Income Level by % of Income Spent on Rent
% Spent of Income Spent on Rent
<30% 30-50% >50% Total
Household Income <= 30%
HAMFI (Extremely Low
Income)
1,240 17.4% 915 12.85% 4,965 69.7% 7,120
Household Income >30% to
<=50% HAMFI (Very Low
Income)
720 17.6% 1,050 25.67% 2320 56.7% 4,090
Household Income >50% to
<=80% HAMFI (Low
Income)
1,800 33.3% 1,875 34.72% 1725 31.9% 5,400
Household Income >80% to
<=100% HAMFI (Moderate
Income)
1,240 38.1% 1,680 51.61% 335 10.3% 3,255
Household Income >100%
HAMFI
22,250 84.0% 3,445 13.00% 795 3.0% 26,490
Total 27,255 58.8% 8,965 19.34% 10140 21.9% 46,360
Source: HUD CHAS, 2012-2017 data
The demographic groups that are the most severely housing cost burdened are Black and Latino
households, who have the lowest median annual household incomes, of $42,703 and $71,483
respectively.
2,449
4,134 3,928 3,530
2,922
2,128 1,797
2,669
7,037
1,577
0
1,000
2,000
3,000
4,000
5,000
6,000
7,000
8,000
Number of Households by % of Income Spent on Rent
Cost-Burdened
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$64,444
$105,395
$109,528
$42,703
$100,691
$71,483
Some Other Race
Two or More Races
Asian
Black
White Alone, Not Hispanic
Hispanic or Latino
Median Household Income by Race of Householder -Santa Monica
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6. Overcrowding
Overcrowding is defined as more than 1.01 persons per room (not bedroom) in a housing unit.
Overcrowding is considered one of many indicators of existing housing need. In the City, there
are 185 overcrowded owner occupied households and 1,360 renter occupied households.
Households of color tend to be more overcrowded than their counterparts. While only 1.93% of White
households were overcrowded, more than 9.5% and 12.1% of Black and Hispanic households
respectively were considered overcrowded.
Table 18 Occupants per Room
Owner Units % of
occupied
Renter
Units
% of
occupied
Total Occupied housing units 13,138 32,171
Occupants Per Room
1.00 or less 12,953 98.6 30,811 95.8
1.01 to 1.50 143 1.1 671 2.1
1.51 or more 42 0.3 689 2.1
Overcrowded Units 185 1360
Source: American Communities Survey, 5 Year Estimate 2019
Owner Units, 143 Owner Units, 42
Renter Units, 671 Renter Units, 689
0
100
200
300
400
500
600
700
800
1.01 to 1.50 1.51 or more
Overcrowded Units by No. of Occupants per Room
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0%5%10%15%20%25%30%
Black
Asian
Some Other Race
Two or More Race
White Alone, Not Hispanic
Hispanic
% of Households Overcrowded by Race of a Householder
% of Households Overcrowded
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7. At Risk Units
Assisted Units at Risk of Conversion
The California Housing Partnership (CHP) provides data on assisted housing units and assesses the
level of risk to converting to market rate. These data identify homes without a known overlapping
subsidy that would extend affordability beyond the indicated timeframe and unless otherwise noted
are not owned by a large/stable non-profit, mission-driven developer.
Table 19 Assisted Units at Risk of Conversion
Risk Level Definition Low-income
units
% of county's low-
income units
Very High At-risk of converting to market rate within the next year 0 0%
High At-risk of converting to market rate in the next 1-5 years 184 9%
Moderate At-risk of converting to market rate in the next 5-10
years 0 0%
Low At-risk of converting to market rate in the next 10 or
more years and/or are owned by a large/stable non-
profit, mission-driven developer.
1,770 91%
TOTAL 1,954 100%
Source: California Housing Partnership, July 2020. Includes HUD, Low-Income Housing Tax Credit (LIHTC), USDA, and CalHFA projects.
Subsidized or assisted developments that do not have one of the aforementioned financing sources may not be included.
Rent Controlled Units at Risk of Conversion
An assessment was conducted to determine apartment buildings at risk of conversion or demolition.
The assessment was conducted by filtering out buildings newer than 1980 and then second,
comparing the number of existing units on the site to its underlying maximum density. If a site was
“underdeveloped” to its density, then it was flagged as “at risk”. Based on this methodology, 915
properties were identified as “high-risk”, of which 471 properties are rent-controlled.
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HR&A Advisors, Inc.Santa Monica AHPP 2020 Update | 1
PRELIMINARY FEASIBILITY MODELING RESULTS
SANTA MONICA PLANNING COMMISSION
CITY OF SANTA MONICA
AFFORDABLE HOUSING PRODUCTION PROGRAM
2020-2021 UPDATE
MARCH 17, 2021
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Packet Pg. 133 Attachment: HR&A Preliminary Feasibility Analyses March 2021 (4433 : Council Direction
HR&A Advisors, Inc.Santa Monica AHPP 2020 Update | 2
INTRODUCTION & APPROACH
INITIAL TAKEAWAYS AND CONSIDERATIONS
ASSUMPTIONS
PRELIMINARY FINDINGS
NEXT STEPS
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Packet Pg. 134 Attachment: HR&A Preliminary Feasibility Analyses March 2021 (4433 : Council Direction
HR&A Advisors, Inc.Santa Monica AHPP 2020 Update | 3CONFIDENTIAL DRAFT –NOT FOR DISTRIBUTION
HR&A SCOPE OF WORK
Determine Objectives and Prepare Prototypes
Develop Market & Cost Assumptions
Financial Feasibility Testing
Technical Working Group Review and Discussion
Further Financial Feasibility Testing
TODAY
Development of Recommended AHPP Requirements
Public Hearings
Planning Commission Discussion
City Council Discussion
Final AHPP Recommendations
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HR&A Advisors, Inc.Santa Monica AHPP 2020 Update | 4
0
1
2
3
4
5
100% Market Rate 7.5% ELI Affordable 15% VLI Affordable
ANALYTIC CONCEPT| Increased development standards could create additional value to support on-site affordable units.
29,000 SF 32,000 SF 34,000 SFNumber of Floors Needed for Market ReturnCurrent Max Height/FAR
Based on an illustrative MUBL project along the boulevards.
Existing development standards generally support lower shares of
affordable units (i.e., 7.5% ELI units under suspended development
standards). Would greater FAR and height limits support higher
shares of affordable units?
ELI: Extremely Low Income
VLI: Very Low Income
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Packet Pg. 136 Attachment: HR&A Preliminary Feasibility Analyses March 2021 (4433 : Council Direction
HR&A Advisors, Inc.Santa Monica AHPP 2020 Update | 5CONFIDENTIAL DRAFT –NOT FOR DISTRIBUTION
ANALYSIS APPROACH | The analysis uses a static pro forma approach to
test the required scale of development to support affordable units.
•HR&A’s analysis tests the required scale of
development (building height/FAR) to support the
inclusion of affordable units.
•HR&A conducted research on pre-COVID real estate
market conditions.
•HR&A prepared static pro forma models to test
alternative affordable housing percentages against
fixed financial feasibility thresholds.
•The analysis uses two metrics to determine financial
feasibility: 1) return on total development cost and
2) developer profit margin.
Illustrative Development Program
Total Development Cost (TDC)
-Hard Costs
-Soft Costs (As % of Hard Costs)
-Land Costs
-Construction Financing Costs
Net Operating Income (NOI)
-Revenues
-Expenses (As % of Revenues)
Project Returns
Return on Total Development Cost
Developer Profit Margin
Financial Feasibility Model
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HR&A Advisors, Inc.Santa Monica AHPP 2020 Update | 6CONFIDENTIAL DRAFT –NOT FOR DISTRIBUTION
Return on Cost Developer Profit Margin
NOI/TDC > 1.0% over cap rate1 (Net Proceeds–TDC)/Net Proceeds > 12.5%
FEASIBILITY METRICS | Profit Margin and Return on Cost thresholds are comparable
to a market responsive IRR derived from multi-year discounted cash flow modeling.
In HR&A’s analysis, both return metrics need to be met for a project to be deemed feasible:
Illustrative Multiyear Discounted Cash Flow vs. Static Pro Forma Analysis
1a margin that would mitigate some risk to developers would require an extra floor for most prototypes.
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Packet Pg. 138 Attachment: HR&A Preliminary Feasibility Analyses March 2021 (4433 : Council Direction
HR&A Advisors, Inc.Santa Monica AHPP 2020 Update | 7
FINANCIAL MODEL| HR&A developed detailed projections of costs, net
operating income and investment returns for each prototype. The interactive
model can evaluate changes to key metrics.
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HR&A Advisors, Inc.Santa Monica AHPP 2020 Update | 8CONFIDENTIAL DRAFT –NOT FOR DISTRIBUTION
DEVELOPMENT PROTOTYPES
R.E. Market Zoning District Lot Size Land Use
1 Boulevard MUBL Double Lot retail/office
2 Boulevard MUBL Double Lot retail/apartments
3 Boulevard MUB, GC (SM Blvd)Double Lot retail/office
4 Boulevard MUB, GC (SM Blvd)Double Lot retail/apartments
5 Main & Lincoln GC (Lincoln)Double Lot retail/apartments
6 Main & Lincoln NC (Main)Double Lot retail/apartments
7 Montana NC (Montana)Double Lot retail/apartments
8 Bergamot Bergamot (BTV, MUC)Large Site retail/apartments
9 Bergamot Bergamot (BTV, MUC)Large Site retail/office
10 Downtown Downtown (TA, NV)Single Lot retail/apartments
11 Downtown Downtown (TA, NV)Double Lot retail/office
12 Downtown Downtown (TA, NV)Double Lot retail/apartments
13 Pico & Ocean Park Pico (NC, MUBL);
Ocean Park (R3, NC)
Double Lot retail/apartments
N 1 mile
8.A.b
Packet Pg. 140 Attachment: HR&A Preliminary Feasibility Analyses March 2021 (4433 : Council Direction
HR&A Advisors, Inc.Santa Monica AHPP 2020 Update | 9
INTRODUCTION & APPROACH
INITIAL TAKEAWAYS AND CONSIDERATIONS
ASSUMPTIONS
PRELIMINARY FINDINGS
NEXT STEPS
8.A.b
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INITITIAL TAKEAWAYS AND CONSIDERATIONS
•Update to 2019 HR&A Affordable Housing Production Program Analysis -Projects along the
Boulevards, Lincoln, Bergamot, and in Downtown are still likely to be developed at current zoning
standards with no more than 7.5% ELI affordable units.
•Development feasibility is highly sensitive to land costs, cap rates, rents, parking ratios, and
construction costs. Most assumptions are adjusted to pre-COVID conditions (2020 Q1) as a proxy
for future stabilized conditions and are adjusted beyond the 2019 modeling.
•The combination of high land costs and low-density zoning standards are a major barrier to
new residential development.
•To the extent that total development costs can be reduced through changes in zoning,
development standards and/or permit processing time, affordability goals can be better
accomplished.
ELI: Extremely Low Income
8.A.b
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INTRODUCTION & APPROACH
INITIAL TAKEAWAYS AND CONSIDERATIONS
ASSUMPTIONS
PRELIMINARY FINDINGS
NEXT STEPS
8.A.b
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CONSTRUCTION HARD COSTS PER GROSS SQUARE FOOT (PGSF)
Hard Costs
Office (Core and Shell)$185 PGSF
Retail (Core and Shell)$160 PGSF
*Prototypes in Downtown include a 10% premium on hard costs.
9+ story buildings assume Type I or II construction, which are associated with higher hard costs for construction materials, labor and fire/life safety.
Source: MGAC, non-union wage construction costs, 2020
Hard Costs
Up to 5 floors $225 PGSF
6-8 floors $240 PGSF
9+ floors $250 PGSF
Office and Retail (Excl. of Parking)Apartment (Excl. of Parking)*
Hard Costs
Subterranean Parking
(Single Level)
$135 PGSF
($67,000 per space @ 450 SF)
Below-Ground Parking
(Multiple Levels)
$165 PGSF
($83,000 per space @ 450 SF)
Parking
8.A.b
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APARTMENT DEVELOPMENT COSTS COMPARISONS
Per GSF Per NSF Per Unit
Hard Cost (Apartments and Retail)$240 $285 $240,000
Parking Costs (Subterranean)$1301 $1551 $130,000
SUBTOTAL: Hard Costs $380 $450 $385,000
Soft Costs $70 $80 $65,000
Financing Costs $60 $70 $55,000
SUBTOTAL: Hard, Soft & Financing $500 $590 $490,000
Land Costs (Boulevards)$130 $155 $130,000
Developer Profit (12.5% of value)$115 $135 $110,000
TOTAL: Development Costs $7452 $8802 $735,0002
1Parking costs are $67,000-83,000 per space, assuming 450 SF per space.
2 Costs are based on a double lot, mid-rise MUBL prototype. In other market areas total development costs range between $700,000 and $815,000 per unit.
8.A.b
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LAND COST ASSUMPTIONS BY SUBMARKET AREA
Source: CoStar; Recent west LA (west of 1-405) land prices average $320 PSF;
Recent Venice land prices average $360 PSF.
Submarkets Area Land Cost (Per Land SF)
Downtown $690
Boulevards $435
Bergamot $420
Lincoln/Main $430
Montana $390
Pico/Ocean Park $430
N 1 mile
West LA:
$320
Venice:
$360
8.A.b
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Main St Lincoln Boulevards Montana Downtown
Current Rents PSF $4.75 $3.64 $4.55 $6.90 $6.40
Residual Land Value PSF $440 $340 $565 $860 $800
Average Market Land Price $430 $430 $435 $380 $690
Land price ≥retail value
RETAIL “TIPPING POINT” | Retail rents in Santa Monica are high, dis-
incentivizing some owners to sell their properties for housing development.
Source: CoStar. Rents are based on Q1 2021 average of 1-story buildings built before 1990
•HR&A estimated the capitalized value of 3,000-8,000 SF standalone retail storefronts.
•Current retail rents are highest along Montana, yielding Residual Land Values (RLV) exceeding $860 PSF for small
retail properties.
•Rents in most other markets also generate RLVs above market land sales, disincentivizing some owners to sell their
properties for housing development.
•Rents along Lincoln are lower, yielding a below market RLV, which supports housing development.
•In the next phase of work, HR&A will further analyze the impact of COVID-19 impacts on the retail tipping point.
8.A.b
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PER-SQUARE FOOT RENT ASSUMPTIONS | Rent assumptions are based on a set of comparable properties for each submarket area.
$5.40 $5.25
$6.60
$5.00 $4.60
$5.80
$4.50 $4.50
$5.60
$4.50
$5.90
$6.90 $6.40
$4.60
$6.05
$0.00
$1.00
$2.00
$3.00
$4.00
$5.00
$6.00
$7.00
$8.00
Office Retail Apartments (Average)
Downtown Boulevards Bergamot Lincoln/Main North of Wilshire Pico/Ocean Park
Office
Retail rent assumptions are based on comparable rents from apartment buildings (North of Wilshire, Pico/Ocean Park) and/or mixed-use properties with ground floor retail uses. Third
Street Promenade rents are not included in this analysis.
8.A.b
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PER-UNIT RENT ASSUMPTIONS | Rents are highest in Downtown, Montana, and Pico/Ocean Park for top of market new construction.
Unit Size Downtown Boulevards Bergamot Lincoln/Main North of
Wilshire1
Pico/Ocean
Park1
Studio $2,900 $2,900 $2,600 $2,900 $3,100 $2,800
1 Bedroom $4,000 $3,500 $3,400 $3,700 $2,800 $3,500
2 Bedroom $5,800 $5,000 $5,000 $4,500 $4,300 $5,200
3 Bedroom $6,700 $5,400 $5,400 $5,000 $4,900 $5,200
Rent assumptions are based primarily on a set of comparable, top of market, new construction properties (not rent controlled)representative of each submarket area.
1 Due to limited new construction in North of Wilshire and Pico/Ocean Park submarkets, rent assumptions are adjusted based on existing market rate buildings to account for
variations in quality and unit sizes.
8.A.b
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MONTHLY AFFORDABLE HOUSING RENTS
Unit Size
Monthly Rent
Extremely Low
Income (30% AMI)
Monthly Rent
Very Low Income
(50% AMI)
Monthly Rent
Low Income
(80% AMI)
Monthly Rent
Moderate Income
(120% AMI)
Studio $406 $676 $812 $1,488
1 Bedroom $464 $773 $928 $1,701
2 Bedroom $522 $870 $1,044 $1,913
3 Bedroom $580 $966 $1,160 $2,126
Source: Santa Monica AHPP Income and Rent Limits, 2020
8.A.b
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OTHER ASSUMPTIONS
Cap Rates
Office 4.7%
Retail 5.0%
Apartments 4.0%
Capitalization Rates (Citywide)Vacancy Rates (Citywide)
Vacancy Rates
Office 8.2%
Retail 4.5%
Apartments 4.8%
Unit Sizes
Studio 440 SF
1 Bedroom 590 SF
2 Bedrooms 920 SF
2 Bedrooms 1060 SF
Unit Sizes (Market Rate and Affordable)Unit Mix (Market Rate and Affordable)
Unit Mix
Studio 15%
1 Bedroom 50%
2 Bedrooms 20%
2 Bedrooms 15%
Source: CoStar
Source: CoStar, 2020 Q1
8.A.b
Packet Pg. 151 Attachment: HR&A Preliminary Feasibility Analyses March 2021 (4433 : Council Direction
HR&A Advisors, Inc.Santa Monica AHPP 2020 Update | 20
For a typical MUBL prototype with 7.5% ELI
units, market rents, and market construction
costs, a 3-story prototype achieves a 1.07%
Return on Cost (RoC) Margin.
Adjusting a single assumption (i.e. increasing
hard costs), requires additional development
capacity in order to achieve the same RoC
Margin.
As construction costs increase, developers
target higher rents, within acceptable
underwriting standards, in order to achieve
the same RoC Margin and meet
development standards.
Apartment Rents
(Average)$5.80
Apartment Hard
Costs PSF $225
ASSUMPTIONS| HR&A’s model is highly sensitive to variations in single real
estate metrics. In reality, costs and revenue targets often move together.
3-Story Prototype
2.13 FAR
1.07% RoC Margin
=
Apartment Rents
(Average)$5.80
Apartment Hard
Costs PSF $250
=
4-Story Prototype
2.35 FAR
1.07% RoC Margin
Apartment Rents
(Average)$6.10
Apartment Hard
Costs PSF $250
3-Story Prototype
2.13 FAR
1.07% RoC Margin
=
8.A.b
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HR&A Advisors, Inc.Santa Monica AHPP 2020 Update | 21
INTRODUCTION & APPROACH
INITIAL TAKEAWAYS AND CONSIDERATIONS
ASSUMPTIONS
PRELIMINARY FINDINGS
NEXT STEPS
8.A.b
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0
1
2
3
4
5
Scenario 1 Scenario 2 Scenario 3
ANALYSIS | HR&A tested a range of affordability scenarios to determine the likelihood of a developer to undertake an apartment project.Number of Floors Needed for Market ReturnCurrent Max Height/FAR
LEGEND
Least Likely –This prototype exceeds current
development standards. This prototype would require
significant cost savings or lower developer returns in order
to satisfy current development standards. Therefore, it is
least likely to be developed.
Marginal –This prototype’s return metrics are marginally
feasible, or approach maximum height and FAR limits. By
achieving rent targets, or with certain cost savings or
creative design, the prototype could be developed.
Most Likely –This prototype is financially feasible at a
height and FAR that does not exceed current development
standards. This prototype is likely to be developed.
Least Likely
MarginalMost Likely
HR&A’s analysis uses the development return metrics to
determine how likely a developer would be to pursue an
apartment project with 7.5% ELI, 10% VLI, 15% VLI, a
20% mix of affordable units, and a 30% mix of
affordable units. The analysis also determines if additional
development capacity (FAR/height) would change that
decision.
8.A.b
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0
1
2
3
4
5
Boulevards
(Parking Overlay
1)
Boulevards
(Citywide Parking)
Lincoln Main Montana Pico/Ocean Park Bergamot Downtown Single
Lot
Downtown Double
LotBoulevards
MUBL
Boulevards
MUB
Lincoln
GC
Main
NC
Montana
NC
Pico/Ocean
Park NC
Bergamot Downtown
Single Lot
Downtown
Double Lot
Parking Req.Overlay 1 Citywide Overlay 1 Citywide Citywide Citywide Bergamot Downtown
Maximum
Downtown
Maximum
FEASIBILITY FINDINGS –FORMER AHPP STANDARDS | Some
prototypes are likely to develop at current zoning standards with 7.5% ELI
affordable units.Number of FloorsMarginal
Max Tier 2 Height and FAR
7.5% ELI Affordable
Least Likely Least LikelyLeast Likely
Marginal
Most Likely Most Likely
Least Likely
60’ 2.0 FAR
27’ 1.0 FAR
36’ 1.5 FAR
45’ 2.25 FAR
36’ 1.75 FAR
32’ 1.0 FAR
Marginal
8.A.b
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Marginal
0
1
2
3
4
5
Boulevards
(Parking Overlay
1)
Boulevards
(Citywide Parking)
Lincoln Main Montana Pico/Ocean Park Bergamot Downtown Single
Lot
Downtown Double
Lot
60’ 2.0 FAR
FEASIBILITY FINDINGS –CURRENT AHPP STANDARDS | Only
Bergamot and Downtown prototypes could support 15% VLI at current zoning standards.Number of FloorsMax Tier 2 Height and FAR
15% VLI Affordable
Least Likely Least Likely Most Likely Most Likely
Least Likely
Least Likely Least LikelyLeast Likely
Boulevards
MUBL
Boulevards
MUB
Lincoln
GC
Main
NC
Montana NC Pico/
OceanPark NC
Bergamot Downtown
Single Lot
Downtown
Double Lot
Parking Req.Overlay 1 Citywide Overlay 1 Citywide Citywide Citywide Bergamot Downtown
Maximum
Downtown
Maximum
27’ 1.0 FAR
36’ 1.5 FAR
45’ 2.25 FAR
36’ 1.75 FAR
32’ 1.0 FAR
8.A.b
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0
1
2
3
4
5
Boulevards
(Parking Overlay
1)
Boulevards
(Citywide Parking)
Lincoln Main Montana Pico/Ocean Park Bergamot Downtown Single
Lot
Downtown Double
LotBoulevards
MUBL
Boulevards
MUB
Lincoln
GC
Main
NC
Montana
NC
Pico/Ocean
Park NC
Bergamot Downtown
Single Lot
Downtown
Double Lot
Parking Req.Overlay 1 Citywide Overlay 1 Citywide Citywide Citywide Bergamot Downtown
Maximum
Downtown
Maximum
FEASIBILITY FINDINGS –ALTERNATIVE SCENARIOS | Similar to the 15% VLI,
most prototypes require an additional 1 or 2 floors and FAR over current development standards in order to support 10% VLI.Number of FloorsMax Tier 2 Height and FAR
10% VLI Affordable
Least Likely Least LikelyLeast Likely Marginal Most Likely Most Likely
Least Likely
60’ 2.0 FAR
27’ 1.0 FAR
36’ 1.5 FAR
45’ 2.25 FAR
36’ 1.75 FAR
32’ 1.0 FAR
Least LikelyLeast Likely
8.A.b
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0
1
2
3
4
5
6
Boulevards
(Parking Overlay
1)
Boulevards
(Citywide Parking)
Lincoln Main Montana Pico/Ocean Park Bergamot Downtown Single
Lot
Downtown Double
Lot
Max Tier 2 Height and FAR
20% Affordable
Boulevards
MUBL
(Overlay 1
Parking Req.)
Boulevards
MUB
(Citywide
Parking Req.)
Lincoln/
Main
(Overlay 1
Parking Req.)
Lincoln/
Main
(Citywide
Parking Req.)
Montana NC Pico/
Ocean Park
NC
Bergamot Downtown
Single Lot
Downtown
Double Lot
FEASIBILITY FINDINGS –ALTERNATIVE SCENARIOS | Most
prototypes require an additional 1-3 floors and FAR over current development standards in order to support 20% affordable units.Number of FloorsLeast Likely Least Likely
Marginal
Marginal
Most LikelyLeast LikelyLeast Likely Least Likely
Least Likely
Boulevards
MUBL
Boulevards
MUB
Lincoln
GC
Main
NC
Montana NC Pico/
OceanPark NC
Bergamot Downtown
Single Lot
Downtown
Double Lot
Parking Req.Overlay 1 Citywide Overlay 1 Citywide Citywide Citywide Bergamot Downtown
Maximum
Downtown
Maximum
25% ELI, 25% VLI, 25% LI, 25% MI
Height and
FAR varies
60’ 2.0 FAR
27’ 1.0 FAR
36’ 1.5 FAR
45’ 2.25 FAR
36’ 1.75 FAR
32’ 1.0 FAR
8.A.b
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Max Tier 2 Height and FAR
30% Affordable
0
1
2
3
4
5
6
7
8
9
10
11
Boulevards
(Parking Overlay
1)
Boulevards
(Citywide Parking)
Lincoln Main Montana Pico/Ocean Park Bergamot Downtown Single
Lot
Downtown Double
Lot
FEASIBILITY FINDINGS –ALTERNATIVE SCENARIOS | Most
prototypes require an additional 1-6 floors and FAR over current development
standards in order to support 30% affordable units.Number of FloorsLeast Likely
25% ELI, 25% VLI, 25% LI, 25% MI
Height and
FAR varies60’ 2.0 FAR
27’ 1.0 FAR
36’ 1.5 FAR
45’ 2.25 FAR
36’ 1.75 FAR
32’ 1.0 FAR
Least Likely
Least Likely
Least Likely
Least Likely
Least Likely
Least Likely
Boulevards
MUBL
Boulevards
MUB
Lincoln
GC
Main
NC
Montana NC Pico/Ocean
Park NC
Bergamot Downtown
Single Lot
Downtown
Double Lot
Parking Req.Overlay 1 Citywide Overlay 1 Citywide Citywide Citywide Bergamot Downtown
Maximum
Downtown
Maximum
Marginal Marginal
8.A.b
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0
1
2
3
4
5
Boulevards (Parking Overlay 1)Boulevards (Citywide Parking)Bergamot Downtown Double Lot
APARTMENTS VS. OFFICE |With 7.5% ELI units, apartments require the
same or less density than office buildings to generate similar profit margins.
Apartments with 7.5% ELI Affordable
Office
Height limit is 75’ for Tier 3 in Bergamot
Height limits is 84’ for 30% affordable in DowntownNumber of Floors2.13 FAR
2.60 FAR
2.34 FAR
2.47 FAR
Boulevards MUBL Boulevards MUB Bergamot Downtown Double Lot
Parking Req.Overlay 1 Citywide Bergamot Downtown Maximum
ROC Margin 1.07%1.21%0.90%1.00%1.09%1.25%1.16%1.31%
Profit Margin 20.3%20.3%17.5%17.5%20.8%20.8%21.8%21.8%
2.13 FAR
2.60 FAR
2.57 FAR
3.13 FAR
ROC Margin: Return on Cost/Prevailing Cap Rate
8.A.b
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0
1
2
3
4
5
Boulevards (Parking Overlay 1)Boulevards (Citywide Parking)Bergamot Downtown Double Lot
APARTMENTS VS. OFFICE | With 15% VLI units, apartments require the
same or more density to generate similar profit margins, except for Downtown.
Boulevards MUBL
(Overlay 1 Parking Req.)
Boulevards MUB
(Citywide Parking Req.)
Bergamot Downtown Double Lot
Apartments with 15% VLI Affordable
Office
Height limit is 75’ for Tier 3 in Bergamot
Height limits is 84’ for 30% affordable in DowntownNumber of Floors2.27 FAR
2.87 FAR 2.69 FAR 2.67 FAR
Boulevards MUBL Boulevards MUB Bergamot Downtown Double Lot
Parking Req.Overlay 1 Citywide Bergamot Downtown Maximum
ROC Margin 1.11%1.21%1.04%1.16%1.10%1.25%1.04%1.19%
Profit Margin 20.5%20.5%19.5%19.5%20.8%20.8%20.2%20.2%
2.13 FAR
2.87 FAR 2.57 FAR 3.00 FAR
ROC Margin: Return on Cost/Prevailing Cap Rate
8.A.b
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0
1
2
3
4
5
6
Boulevards (Parking Overlay 1)Boulevards (Citywide Parking)Bergamot Downtown Double Lot
APARTMENTS VS. OFFICE |At 20% affordability, apartments require more
density to generate similar profit margins, except for Downtown.Number of Floors2.47 FAR
3.27 FAR 3.00 FAR 2.87 FAR
Boulevards MUBL Boulevards MUB Bergamot Downtown Double Lot
Parking Req.Overlay 1 Citywide Bergamot Downtown Maximum
ROC Margin 1.20%1.37%1.08%1.21%1.12%1.29%1.16%1.31%
Profit Margin 22.3%22.3%20.5%20.5%21.1%21.2%22.0%22.0%
2.33 FAR
3.07 FAR 2.63 FAR 3.13 FAR
25% ELI, 25% VLI, 25% LI, 25% MIApartments with 20% Affordable
Office
ROC Margin: Return on Cost/Prevailing Cap Rate
8.A.b
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ANALYSIS | Off-Site vs. On-Site Affordable Units
•A prototypical development project could support an off-site affordable housing fee of
between $45,000 and $60,000 per market rate unit, as an alternative to including affordable
units on-site. This supportable fee is slightly higher than the current AHPP in-lieu fee at $36.49 per GSF,
or $30,300 per market rate unit with an average unit size of 830 GSF.
•The “opportunity cost”1 of developing an on-site affordable unit averages approximately $350,000.
Based on previous HR&A analysis of 100% affordable housing projects, the unfunded subsidy gap (i.e.
other than tax credits or City subsidies that could be paid by market rate developers),ranges between
roughly $270,000 and $300,000 and averages $285,000 per affordable unit.
•As such, the cost of developing on-site VLI units is approximately 1.3 times the per-unit subsidy gap
needed for off-site 100% affordable housing projects.This could facilitate construction of over 30
percent more affordable units off-site due to the potential for off-site affordable housing to leverage
additional resources and higher tax credit rents.
1 The opportunity cost reflects the lost revenue and associated value of an affordable unit, as compared to the market rate
unit that could be built in its place in exchange for paying an in-lieu fee.
8.A.b
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PRELIMINARY FINANCIAL FEASIBILITY FINDINGS
General Feasibility Findings:
•Projects along the Boulevards,Lincoln,Bergamot and in Downtown are likely to develop at current
development standards with no more than 7.5%ELI affordable units1.
•Total development costs are a barrier to development,especially the cost of parking and land.Total
development cost increases have outpaced rent growth.
•Downtown and Bergamot are the only prototypes likely to develop with up to 20%affordable,due
to lower parking ratios (or no parking requirement)in Downtown,lower land cost in Bergamot,and
higher height and FAR limits in both submarkets.
•At 7.5%ELI,apartments can compete with office by generating the same profit margins at the same
or lower densities.At higher affordability levels,apartments are less competitive as they require the
same or more density than office to generate the same profit margin except for Downtown.Meanwhile,
office might still be preferred over apartments due to a higher Return on Cost margin.
1 MUB and Lincoln, while feasible at 7.5% ELI, exceed current FAR limits.
8.A.b
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PRELIMINARY FINANCIAL FEASIBILITY FINDINGS
Affordable Housing Findings:
7.5% ELI
affordable units
Prototypes along Main, Pico, Montana, and Ocean Park cannot support 7.5% ELI at current zoning
standards due to the high cost of parking, and land costs which are outpacing rents. Prototypes along
Lincoln and in Bergamot can marginally support 7.5% ELI units at current zoning standards. This level is
easily supported in Downtown.
10% VLI
affordable units
Most prototypes other than Bergamot and Downtown cannot support 10% VLI units at current
development standards. Additional height and FAR are needed for the other submarket areas for 10%
VLI units.
15% VLI
affordable units
Most prototypes other than Bergamot and Downtown cannot support 15% VLI units at current
development standards. Additional height and FAR are needed for the other submarket areas for 15%
VLI units.
20%
affordable units (equally
split across four income bands)
Additional height and FAR are needed to support 20% affordability in all submarkets except
Downtown, which can support 20% affordable units based on current development standards.
30%
affordable units (equally
split across four income bands)
Additional height and FAR are needed to support 30% affordability in all submarkets except
Downtown, which can marginally support 30% affordable units based on current development
standards.
8.A.b
Packet Pg. 165 Attachment: HR&A Preliminary Feasibility Analyses March 2021 (4433 : Council Direction
HR&A Advisors, Inc.Santa Monica AHPP 2020 Update | 34CONFIDENTIAL DRAFT –NOT FOR DISTRIBUTION
CAVEATS
These preliminary findings are qualified by the following considerations:
•Recent construction is limited within the submarket areas, so extrapolation from
data on older buildings was necessary to develop some assumptions.
•Older rental properties include larger units than pipeline projects. HR&A
developed a residential rent adjustment factor to account for smaller expected
average unit sizes in the prototypes.
•HR&A used pre-COVID assumptions as a proxy for future conditions. The
impacts of the pandemic on the market are uncertain.
•Real estate metrics and development standards assumptions are based on
detailed research, input from consulting cost estimator and architects, and
feedback from TWG #1-#4, but may not fit every project.
•Assumed minimum investment return metrics are considered reasonable, but
individual developers may accept somewhat lower or require higher
thresholds to proceed with development.
8.A.b
Packet Pg. 166 Attachment: HR&A Preliminary Feasibility Analyses March 2021 (4433 : Council Direction
HR&A Advisors, Inc.Santa Monica AHPP 2020 Update | 35
INTRODUCTION & APPROACH
INITIAL TAKEAWAYS AND CONSIDERATIONS
ASSUMPTIONS
PRELIMINARY FINDINGS
NEXT STEPS
8.A.b
Packet Pg. 167 Attachment: HR&A Preliminary Feasibility Analyses March 2021 (4433 : Council Direction
HR&A Advisors, Inc.Santa Monica AHPP 2020 Update | 36CONFIDENTIAL DRAFT –NOT FOR DISTRIBUTION
NEXT STEPS
In the next phase of work, HR&A will conduct additional sensitivity tests:
•FAR/height
•Unit Size and Unit Mix
•Alternative ground floor uses
•Alternative Parking Requirements
•Retail/Office redevelopment Tipping Point
•City-owned lands (specific site)
8.A.b
Packet Pg. 168 Attachment: HR&A Preliminary Feasibility Analyses March 2021 (4433 : Council Direction
Summary Report on Preliminary Suitable Sites
Inventory Analysis
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Packet Pg. 169 Attachment: Summary Report on Preliminary Sites Analysis (4433 : Council Direction on Draft Concepts and Framework for Housing Element
City of Santa Monica 6th Cycle 2021-2019 Housing Element – Summary Report of Preliminary Suitable Sites
2
Introduction
The housing element of the general plan must include an inventory of land suitable and available for
residential development to meet the locality’s regional housing need by income level. This inventory
is known as the Suitable Sites Inventory. This document has been prepared to outline the
methodology used for identifying potential housing sites for the City of Santa Monica’s 6th Cycle
Housing Element SSI. The methodology follows the guidance of the Housing Element Site Inventory
Guidebook prepared by the Housing and Community Development Department (June 2020).
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Packet Pg. 170 Attachment: Summary Report on Preliminary Sites Analysis (4433 : Council Direction on Draft Concepts and Framework for Housing Element
City of Santa Monica 6th Cycle 2021-2019 Housing Element – Summary Report of Preliminary Suitable Sites
3
Step 1: Site Filtering for Commercial and Mixed Use Zoned
Parcels
As a first step in preparing the Suitable Sites Inventory analysis, parcels in the City that are not
potential candidates were filtered out based on a set of criteria. In general, parcels meeting any of
these criteria were determined to not be suitable as a housing site:
• Parcels zoned R1 (single family), OP1 (Ocean Park single family), OPD (Ocean Park Duplex),
RMH (residential mobile home), OS (open space), Civic Center
• Parcels with existing Landmarks or Historic Resources
• Parcels that are under construction, have recently completed projects, approved
entitlements, and pending entitlement for commercial uses only
• Parcels that have unique land uses such as hospitals, cemetery, schools, parks,
churches/religious facilities, utilities, government offices, libraries, police/fire stations,
transportation infrastructure/Metro Expo LRT and airport,
• Parcels developed with affordable housing and condos
• Parcels with newer buildings developed post 1980
Based on this first set of filtering criteria, 1,300 potential commercially zoned sites and City-owned
site were initial identified. These sites were then categorized according to the table below:
Category
Description Count of
Parcels Land SF
1
Pending/Approved
Housing Projects
118 2,439,430
2 Prior SSI Sites 50 1,098,659
3 DCP Buildout 20 240,248
4 City-Owned Sites 100 3,641,062
5
Vacant/Parking
Lots/Parking Structures 118 1,037,700
6 Auto Storage Lots 43 422,680
7
Parcels with
recent/active sales 41 340,818
8
Underutilized Sites
(20,000 excess sf
development potential) 217 7,520,075
9 Large Parcels (15,000 sf+) 17 274,850
10
Remaining Sites with less
than 0.5 AVR 576 3,675,065
Total 1300 20,690,587
Definitions
• Count of AIN – count of parcels
• Land SF – total land area of parcels
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Packet Pg. 171 Attachment: Summary Report on Preliminary Sites Analysis (4433 : Council Direction on Draft Concepts and Framework for Housing Element
City of Santa Monica 6th Cycle 2021-2019 Housing Element – Summary Report of Preliminary Suitable Sites
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• Max Development Potential – total amount of square footage that could be built based on
the maximum tier for each site
• AINs>=15,000 sf – the number of parcels that are 15,000 sf or larger in size
Category 1 Sites (Pending/Approved Housing Entitlements)
As of February 2021, there were approximately 1,670 approved units (of which 401 are affordable)
and 756 pending units. These units are expected to be constructed in the next eight years and would
count toward the City’s 6th Cycle RHNA. Unlike other jurisdictions where a significant percentage of
approved projects are never constructed, Staff’s review of planning records indicate that historically
almost all housing projects that have been approved are ultimately built.
Category 2 Sites (Sites listed in the 2013-2021 5th Cycle Housing Element)
83 parcels were listed in the 5th Cycle 2013-2021 Housing Element. Some of these parcels have
undergone entitlements but the remaining have not. These are categorized as Category 2 Sites.
Category 3 Sites (Downtown Buildout Sites)
As part of the Downtown Community Plan, sites in the Downtown were identified for potential
redevelopment. A number of these sites have already undergone pending/approved entitlements,
been constructed, or undergoing tenant improvements (captured in Category 1). In addition, a small
number were previously identified in the prior SSI for the 5th Cycle Housing Element (hence are
captured in Category 2). The remaining DCP sites are classified as Category 3.
Category 4 Sites (City-owned Sites)
An important strategy for the City to meet its RHNA targets is the utilization of existing City owned
sites for housing, particularly affordable housing. All City owned sites that are not currently
developed with open space/parks, community centers, civic uses, utilities, etc are categorized as
Category 4 sites. Public parking structures such as PS#3, PS#2, and PS#4 are included in this
category. Additionally, although zoned R3 or R4, the City’s parking lots on Main St Street are reviewed
as potential housing sites.
Category 5 Sites: Vacant Sites/ Parking Lots /Parking Structures
A handful of sites in the City are either vacant, parking lots, or parking structures. Most of these are
in the MUBL Zoning District. Vacant sites and parking lots are very underutilized and represent the
greatest opportunity for new housing without displacement of existing uses.
Category 6 Sites: Auto Inventory Lots
These are parcels currently being utilized almost entirely as auto inventory surface lots, with the
majority occurring within the GC and MUBL zoning districts. Auto dealerships have indicated
interest in turning over these large surface lots into redevelopment opportunities as they are
rethinking their sales operations.
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Packet Pg. 172 Attachment: Summary Report on Preliminary Sites Analysis (4433 : Council Direction on Draft Concepts and Framework for Housing Element
City of Santa Monica 6th Cycle 2021-2019 Housing Element – Summary Report of Preliminary Suitable Sites
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Category 7 Sites: Recent/Active Sales
Based on a review of the Assessor’s Parcel Data and a review of commercial real estate websites
(such as Loopnet), a number of properties have recently sold in 2019/2020 or have active sales
listing.
Category 8 Sites: Underutilized Sites (20,000 sf excess development potential)
Category 8 sites are sites that do not meet the criteria of Categories 1-7 but have been identified to
have a net new development potential of 20,000 sf or greater (based on their existing built sf
compared against the max density).
Category 9 Sites: (Remaining Large parcels)
Category 9 sites are all remaining sites that are 15,000 sf and larger.
Category 10 Sites: (Remaining Parcels with 0.5 AVR or less)
Category 10 sites are all the remaining sites (not meeting Category 1-9) with an assessors value
ratio (AVR) of 0.5 or less.
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Packet Pg. 173 Attachment: Summary Report on Preliminary Sites Analysis (4433 : Council Direction on Draft Concepts and Framework for Housing Element
City of Santa Monica 6th Cycle 2021-2019 Housing Element – Summary Report of Preliminary Suitable Sites
6
Step 2: Individual Site Review for Housing Potential
As a second step, all individual sites in Category 1-10 were reviewed by the City’s Housing Policy team
using Google Streetview, City Accela database and if necessary, in-person site visits. Each site was
reviewed to determine its viability for residential redevelopment. Factors considered included:
• Site Physical Characteristics - Individual parcels less than 7,500 sf are unlikely to be
developed. However, if two smaller adjacent parcels share common ownership, there could
be potential for housing development depending on the remaining factors. In addition to size,
sites were reviewed for any other potential physical characteristics that could make them
more amenable to residential development, such as access to an alley, shape of the site
(including depth/width), grade, and location relative to the urban grid.
• Existing uses – Existing uses on the site were assessed to determine its future viability and
likelihood for the uses to be discontinued. For example, uses that are more unique in a
particular location (such as a successful grocer in a residential neighborhood) have longevity
and as such, redevelopment of the site would be unlikely. Similarly, sites with multiple tenants
are more unlikely to turn over than single tenant sites.
• Location and Context – The location of the site was also considered in terms of its access to
schools, jobs, transit, residential amenities such as parks/open space, health care services,
and retail shops such as grocers. Many of the sites south of Olympic Boulevard lack access
to these amenities and services and as such, were determined to not be suitable. Additionally,
existing/past housing development trends in the site surrounding area were considered –
reviewing if the project located in an area where there is significant residential growth.
• Known Developer Interest – If a developer has expressed interest in the past on a site, then
there is a higher likelihood that the site will be redeveloped.
• Environmental constraints – The HCD requires that cities identify any environmental
constraints (e.g., fault hazard zones, flood areas, liquefaction zones, very high fire hazard
severity zones) that have the potential to impact the development viability of the identified
sites. There are no high fire hazard zones or floodplains in the City. However, the Santa
Monica Fault Hazard zone runs across the northeastern portion of the City. A number of
identified sites located on the eastern end of Wilshire Boulevard and Santa Monica Boulevard
are located within this zone. The State does not prohibit housing in these zones, but instead
requires that structures built for human occupancy in these zones be assessed for potential
fault rupture risks.
Based on the review of sites, there are 109 parcels approved/pending for residential development
and 268 potential parcels in the City identified to have medium high to high potential for residential
redevelopment. Together these 375 parcels comprise approximately 5.7 million sf of land area.
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Packet Pg. 174 Attachment: Summary Report on Preliminary Sites Analysis (4433 : Council Direction on Draft Concepts and Framework for Housing Element
City of Santa Monica 6th Cycle 2021-2019 Housing Element – Summary Report of Preliminary Suitable Sites
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High Potential for Redevelopment
Category Description Total Land Area Count of Parcels
1 Pending/Approved
Housing Projects
1,524,587 109
2 Prior SSI Sites 909,586 34
3 DCP Buildout 168,346 17
4 City-Owned Sites 778,889 29
5 Vacant/Parking
Lots/Parking
Structures
347,987 41
6 Auto Storage Lots 327,137 29
7 Parcels with
recent/active sales
216,744 20
8 Underutilized Sites
(20,000 excess sf
development
potential)
1,160,143 57
9 Large Parcels
(15,000 sf+)
30,634 2
10 Remaining Sites
with less than 0.5
AVR
235,784 37
Grand Total 5,699,837 375
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Packet Pg. 175 Attachment: Summary Report on Preliminary Sites Analysis (4433 : Council Direction on Draft Concepts and Framework for Housing Element
City of Santa Monica 6th Cycle 2021-2019 Housing Element – Summary Report of Preliminary Suitable Sites
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An additional 99 sites were identified as having medium potential – these include A-lots (residentially
zoned parcels generally used as parking lots), properties in the lower-density Neighborhood
Commercial, Creative Conservation Sector, and Industrial Conservation zones. Staff anticipates
that changes to the current zoning standards would be necessary to increase the housing viability of
these sites.
Medium Potential for Redevelopment
Category
Description Total Land Area Count of Parcels
2 Prior SSI Sites 66,014 2
4 City-Owned Sites 255,982 7
5
Vacant/Parking
Lots/Parking
Structures 198,768 26
6 Auto Storage Lots 7,583 3
7
Parcels with
recent/active sales 22,389 4
8
Underutilized Sites
(20,000 excess sf
development
potential) 814,267 27
9
Large Parcels
(15,000 sf+) 23,398 1
10
Remaining Sites
with less than 0.5
AVR 250,500 29
Grand Total 1,638,900 99
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Packet Pg. 176 Attachment: Summary Report on Preliminary Sites Analysis (4433 : Council Direction on Draft Concepts and Framework for Housing Element
City of Santa Monica 6th Cycle 2021-2019 Housing Element – Summary Report of Preliminary Suitable Sites
9
Step 3: Assessment of Housing Capacity for High Potential
Sites
Category 1 – Approved and Pending Projects
As previously stated, as of February 2021, there were approximately 1,670 approved units (includes
416 affordable) and 756 pending units (includes 165 affordable) on 109 parcels. These sites are listed
in Appendix A.
Category 4 – City-Owned Sites
A number of City-owned sites have the highest potential to accommodate for the production of
affordable housing including the parcels surrounding the Downtown Santa Monica Station, parking
lots on Main Street and along Wilshire Boulevard, the Bergamot Arts Center, Parking Structure 3, and
the site at 4th Street/Arizona. These sites merit special consideration as they could be prioritized for
the production of affordable housing. Based on the current development standards for these sites
and assuming ground-floor retail, these City-owned sites have the realistic capacity to
accommodate 1,400 units. If the City develops 100% affordable housing on all sites, up to 7,300
affordable housing units could be achieved.1 Alternatively, the City could establish a policy to
develop a minimum of a number of housing units on these City-owned sites to maximize affordable
housing production.
1 With the passage of AB1763, 100% affordable housing projects are permitted an extra 3 floors above existing height limits
and unlimited density.
8.A.c
Packet Pg. 177 Attachment: Summary Report on Preliminary Sites Analysis (4433 : Council Direction on Draft Concepts and Framework for Housing Element
City of Santa Monica 6th Cycle 2021-2019 Housing Element – Summary Report of Preliminary Suitable Sites
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City Owned Sites with Housing Potential
Address Parcel Nos. Zoning Existing Use
Land
Area (sf)
Residential
Potential
Potential Capacity
based on Current Max FAR
(Blank) 4281005900 R2 Public parking lot
behind retail 7,500 High 4
(Blank) 4282003901 R3 Public parking lot on
Wilshire/14th 7,500 High 6
1217 14th St 4282003900 R3 Public parking lot 12
behind retail 22,500 High 18
4282004900
(Blank) 4288009901 R3/R4 Public parking lot on
Main St 175,568 High 140
4288010900
4288010901
4288011900
4288011901
4288012902
4288013905
4288015901
402 Colorado 4290011901 TA Downtown Station
parking lot 80,068 High 413
4290011902
4290011903
4290011904
4290011905
4290011906
4290011909
1333 4th St 4291011909 BC Bank of America;
Chase bank 44,609 High 195
4291011910
1324 5th St 4291011900 NV Parking lot 53,300 High 233
4291011901
4291011902
4291011903
4291011904
4291011905
4291011908
1318 4th St 4291012900 BC Parking Structure 3 30,000 High 129
4291012901
2500 Olympic 4268013919 CAC Bergamot Arts Center 410,252 High 194
4268014900
2018 19th St 4274017900 R2 City-owned vacant lot 8,000 Medium High 4
(Blank) 4291020900 NV Old fire station #1 15,000 Medium High 63
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Packet Pg. 178 Attachment: Summary Report on Preliminary Sites Analysis (4433 : Council Direction on Draft Concepts and Framework for Housing Element
City of Santa Monica 6th Cycle 2021-2019 Housing Element – Summary Report of Preliminary Suitable Sites
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Total 1,399
Category 2, 3, 5, 6, 7, 8, 9, 10 – All Remaining Sites
To assess the housing capacity of the remaining Category 2-10 sites that have been identified for the
SSI, the realistic capacity of the sites was assessed by applying the City’s existing development
standards taking into consideration factors such as ground floor requirements (for example retail),
typical ground floor plates, unit sizes, unit mix requirements, etc. This analysis yielded an estimated
housing capacity of 6,308 units.
Summary
The capacity analysis of the identified sites yielded a total of 10,133 units. With the allowance to
assume the production of 700 accessory dwelling units (ADUs) during the Housing Element planning
period, the SSI would providing a land capacity buffer of 1,938 units.
While the sites analysis identified sufficient land area to accommodate the RHNA of 8,895 units, the
challenge is meeting the RHNA’s required number of affordable units of 6,168 units. With the
inclusionary requirement in the City’s Affordable Housing Production Program, the number of
affordable units that could be feasibly produced by the SSI sites is 1,159 units (7.5% ELI requirement).
Up to 2,123 affordable units could be produced if the AHPP was modified to include a 20%
inclusionary requirement.
Summary of Realistic Unit Capacity No. of Affordable Units at % Inclusionary
7.5% 15% 20%
Category 1 Pending Projects 756 165 165 165
Category 1 Approved Projects 1670 416 416 416
Category 4 City owned Sites 1,399 105 210 280
All Remaining Sites (exclude 1 and 4) 6,308 474 946 1262
Total 10,133 1,159 1,735 2,123
ADUs 700 - - -
RHNA Targets 8895 6,168 6,168 6,168
Buffer/(Shortfall) 1938 (5,009) (4,433) (4,045)
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Packet Pg. 179 Attachment: Summary Report on Preliminary Sites Analysis (4433 : Council Direction on Draft Concepts and Framework for Housing Element
City of Santa Monica 6th Cycle 2021-2019 Housing Element – Summary Report of Preliminary Suitable Sites
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SSI Properties – Housing Potential by Zoning District
City Areas Zoning District Land Area % of Total Land Area Existing SF Count of
Parcels
BAP MUC 472,487 8.29% 207,098 13
CCS 41,805 0.73% 24,713 3
BTV 124,596 2.19% 92,218 2
CAC 410,253 7.20% 65,800 2
Blvd MUB 627,891 11.02% 327,080 41
MUBL 1,177,566 20.66% 574,463 77
GC 508,130 8.91% 242,356 51
NC 185,054 3.25% 59,321 24
Downtown BC 134,967 2.37% 51,906 7
NV 350,975 6.16% 214,356 34
TA 378,282 6.64% 213,065 31
LT 262,261 4.60% 93,872 30
OT 190,963 3.35% 257,362 1
WT 97,497 1.71% 224,783 5
Hospital HMU 143,377 2.52% 42,408 7
Industrial IC 126,666 2.22% 65,552 8
Multi-family R2 124,770 2.19% 48,810 16
R3 192,416 3.38% 4,243 11
R4 40,091 0.70% - 4
Office
Campus
OC 20,139 0.35% 4,750 3
(blank) OF 68,537 1.20% - 2
OP2 21,114 0.37% 2,400 3
SubTotal 5,699,837 100.00% 2,816,556 375
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Packet Pg. 180 Attachment: Summary Report on Preliminary Sites Analysis (4433 : Council Direction on Draft Concepts and Framework for Housing Element
City of Santa Monica 6th Cycle 2021-2019 Housing Element – Summary Report of Preliminary Suitable Sites
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Other Considerations
A number of other sites were identified as having significant capacity for housing , but require further
Planning Commission and City Council consideration including:
• State Controlled/Institutional/Public Utilities Sites
Several underutilized sites in the City are owned by State entities, institutional, and public utilities
that have the potential to accommodate housing, including the Department of Motor Vehicles
site at 2235 Colorado Ave, Southern California Gas site at 1701 Stewart, and the UCLA parking lot
site at 1521 & 1601 Santa Monica Blvd (see Appendix B). If these State controlled sites are included
in the SSI, HCD requires documentation be provided that shows that housing can be
accommodated with the Housing Element planning cycle. Documentation could include an
agreement between the State entity and the City granting local authority for approving,
permitting, certifying occupancy, and/or reporting new units or a document from the State
entity that demonstrates planned housing will be built.
• Religious institutions
AB1851 was passed in 2020 to remove an important barrier to housing construction on lands
owned by a religious institution. The law states that a jurisdiction cannot deny a housing project
proposed by a religious institution on the sole basis that it will remove parking. A number of
religious institutions with large surface parking lots are located throughout the City (see
Appendix C). These lots could play an important part in providing affordable housing; however,
many of the sites are located in R2/OP2 zoning districts which severely limits the housing
potential of these sites. Rezoning would be necessary in order to accommodate meaningful
production of affordable housing on these sites.
• A-Lots
Within the City, there are 42 residentially zoned (R1/R2/R3/R4) parcels with an “A” Off-Street
Parking Overlay (known as A-lots). These parcels are intended to support the parking needs of
commercial corridors and neighborhood commercial areas, and to serve as a buffer between
commercial and residential uses. There are 9 A-lots identified as highest potential for residential
due to their association with their commercial fronting buildings that have been identified for high
housing potential in the preliminary SSI. A-lots should be considered to determine if they could be
utilized to maximize the affordable housing potential of sites.
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Packet Pg. 181 Attachment: Summary Report on Preliminary Sites Analysis (4433 : Council Direction on Draft Concepts and Framework for Housing Element
City of Santa Monica 6th Cycle 2021-2019 Housing Element – Summary Report of Preliminary Suitable Sites
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Appendix A – Approved/Pending Projects
PROJECT ID ADDRESS STREET PARCEL NOS. USE SIZE PROJECT STATUS DATE APPROVED APPLICATION DATE
20ENT-0238 1127-1129 2nd St 4292-021-009; 4292-
021-010
affordable housing 42 DU Approved 1/19/21 10/13/20
19ENT-0341 1436 2nd St 4291-015-
028
hostel 37 rooms Approved 7/1/20 9/12/19
20BLD-3932 1530 2nd St 4291-028-
004
restaurant 1.5 KSF Pending 11/6/20
20ENT-0019 2501 2nd St 4287-010-
011
market rate
units
3 DU Approved 7/20/20 1/27/20
20ENT-0111 1360 3rd St 4291-013-
012
restaurant 3.6 KSF Pending
19ENT-0430 1404-
1408
3rd St 4291-016-
002
retail 20 KSF Approved 10/7/20 11/21/19
17ENT-0054 1437 3rd St 4291-017-
013
retail 6 KSF Approved 11/6/17 5/4/17
19ENT-0425 918 5th St 4292-015-
004
market rate
units
3 DU Approved 12/9/19 11/20/19
15ENT-0138 1248 5th St 4291-004-
017
creative office 46.82 KSF Approved 4/20/16 3/5/15
18ENT-0283 1323 5th St 4291-010-
029
market rate
units
8 DU Approved 3/23/20 9/13/18
18ENT-0283 SRO 35 DU
18ENT-0283 affordable
housing
9 DU
18ENT-0283 retail 1.87 KSF Approved
19ENT-0041 1338-
1342
5th St 4291-011-
020; 4291-
011-019
market rate
units
20 DU Approved 1/31/19 8/2/18
19ENT-0041 SRO 80 DU Approved
19ENT-0041 affordable
housing
20 DU Approved
19ENT-0041 retail 2.703 KSF Approved
19ENT-0128 1410 5th St 4291-018-
028
market rate
units
4 DU Approved 9/6/19 4/9/19
19ENT-0042 1415-1423 5th St 4291-019-
021, 4291-
019-020
market rate
units
32 DU Approved 1/30/20 1/31/19
19ENT-0042 SRO 79 DU Approved
19ENT-0042 affordable
housing
23 Approved
19ENT-0042 retail 2.313 KSF Approved
18ENT-0211 1425-1427 5th St 4291-019-019 market rate units 92 DU Approved 10/21/19 7/12/18
18ENT-0211 affordable housing 0 DU Approved
18ENT-0211 retail 4.512 KSF Approved
19ENT-0039 1437 5th St 4291-019-018 market rate units 14 DU Approved 1/31/19 6/22/17
19ENT-0039 SRO 38 DU Approved
19ENT-0039 affordable
housing
11 DU Approved
19ENT-0039 retail/restaurant 1.505 KSF Approved
16ENT-0143 1313-1325 6th St 4291-009-
021
market rate
units
64 DU Approved 11/28/17 6/25/15
16ENT-0143 retail 4.819 KSF Approved
19ENT-0040 1437 6th St 4291-020-016 market rate units 35 DU Approved 3/23/20 9/27/19
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Packet Pg. 182 Attachment: Summary Report on Preliminary Sites Analysis (4433 : Council Direction on Draft Concepts and Framework for Housing Element
City of Santa Monica 6th Cycle 2021-2019 Housing Element – Summary Report of Preliminary Suitable Sites
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PROJECT ID ADDRESS STREET PARCEL
NOS.
USE SIZE PROJECT
STATUS
DATE
APPROVED
APPLICATION
DATE
19ENT-0040 SRO 8 DU Approved
19ENT-0040 affordable
housing
9 DU Approved
19ENT-0040 retail/restaurant 1.658 KSF Approved
18ENT-0200 1238 7th St 4291-006-
006
affordable
housing
37 DU Approved 4/14/20 7/3/18
18ENT-0200 retail 1.543 KSF Approved
18ENT-0200 office 0 KSF Approved
18ENT-0136 1437 7th St 4291-021-029 market rate units 52 DU Pending 5/22/18
18ENT-0136 affordable housing 13 DU Pending
18ENT-0136 retail 10.14 KSF Pending
19ENT-0085 1448 7th St 4291-020-
008
market rate
units
6 DU Approved 4/30/20 3/7/19
19ENT-0085 affordable
housing
2 DU Approved
19ENT-0085 retail 2.175 KSF Approved
18ENT-0212 1514 7th St 4291-023-
002
affordable
housing
50 DU Approved 4/14/20 7/12/18
18ENT-0212 retail 1 KSF Approved
18ENT-0210 1543-
1547
7th St 4291-022-
013; 4291-
022-014
market rate
units
75 DU Approved 11/12/19 7/12/18
18ENT-0210 affordable
housing
25 DU Approved
18ENT-0210 retail 4.4 KSF Approved
18ENT-0206 701 Colorado
Ave
4291-022-
021
market rate
units
14 DU Approved 2/13/20 7/10/18
18ENT-0206 SRO 35 DU Approved
18ENT-0206 affordable
housing
10 DU Approved
18ENT-0206 retail 2.9 KSF Approved
17ENT-0286 2512 7th St 4287-003-
017
market rate
units
3 DU Approved 1/1/18 12/13/17
20ENT-0196 1546 9th St 4282-028-
007
market rate
units
9 DU Pending 8/6/20
19ENT-0258 949 10th St 4281-025-014 market rate units 3 DU Approved 10/2/19 7/2/19
19ENT-0256 1348 10th St 4282-011-011 office 1.432 KSF Approved 12/19/19 7/2/19
19ENT-0256 market rate units 1 DU Approved
17ARB-0043 1754 10th St 4283-018-002 market rate units 3 DU Approved 8/1/18 2/2/17
20ENT-0234 734 12th St 4280-025-015 market rate units 3 DU Pending 10/2/20
05TM-009 1211 12th St 4282-005-
053
market rate
units
9 DU Approved 5/11/16 4/14/05
05TM-009 affordable
housing
4 DU Approved
18ENT-0243 1643 12th St 4283-007-
032
market rate
units
0 DU Approved 12/14/20 8/9/18
20ENT-0104 1640-
1644
14th St 4283-008-
006
creative office 18.75 KSF Pending 4/7/20
20ENT-0104 retail 3.6 KSF Pending
20ENT-0073 817 16th St 4281-001-
021
market rate
units
3 DU Approved 6/17/20 4/17/20
19ENT-0267 1432 17th St 4282-019-
007
market rate
units
6 DU Approved 1/15/20 7/9/19
19ENT-0235 1527 17th St 4275-012-
020
market rate
units
3 DU Approved 1/20/21 6/20/19
8.A.c
Packet Pg. 183 Attachment: Summary Report on Preliminary Sites Analysis (4433 : Council Direction on Draft Concepts and Framework for Housing Element
City of Santa Monica 6th Cycle 2021-2019 Housing Element – Summary Report of Preliminary Suitable Sites
16
PROJECT ID ADDRESS STREET PARCEL
NOS.
USE SIZE PROJECT
STATUS
DATE
APPROVED
APPLICATION
DATE
16ENT-0011 1840 17th St 4283-032-
008
market rate
units
4 DU Approved 6/1/16 2/2/16
16ENT-0011 affordable
housing
1 DU Approved
20ENT-0045 1949 17th St 4274-015-
020
market rate
units
4 DU Approved 5/30/20 3/18/20
20ENT-0045 affordable
housing
1 DU Approved
18ENT-0077 1443 18th St 4275-010-
016
market rate
units
11 DU Approved 7/27/18 4/4/18
16ENT-0048 1242 20th St 4276-013-
033, 4276-
013-032
R&D 65 KSF Pending 4/7/16
16ENT-0048 1925 Arizona
Ave
medical office 16.5 KSF Pending
16ENT-0048 ancillary
meeting
14 KSF Pending
16ENT-0071 1420 20th St 4275-009-
004
market rate
units
3 DU Approved 7/13/16 5/24/16
16ENT-0072 1422 20th St 4275-009-
005
market rate
units
3 DU Approved 7/13/16 5/24/16
17ENT-0105 1900 20th St 4274-019-
056
market rate
units
3 DU Approved 10/18/17 6/29/17
20BLD-1218 1958 20th St 4274-020-
001
market rate
units
2 DU Pending 3/31/20
20ENT-0063 2425 20th St 4273-019-001 market rate units 3 DU Approved 5/20/20 2/27/20
15ENT-0310 2002-2008 21st St 4274-026-001; 4274-
026-003;
4274-026-
005; 4274-026-007
market rate units 19 DU Approved 5/15/19 6/10/04
16ENT-0041 1121 22nd St 4276-005-022 market rate units 3 DU Approved 6/21/17 3/29/16
19ENT-0294 1633 26th St 4268-001-025; 4268-001-026
creative office 129.376 KSF Pending 8/6/19
20BLD-1044 2409 28th St 4270-004-017 market rate units 2 DU Approved 4/15/20 2/1/20
16ENT-0112 1665 Appian Way 4290-018-018 market rate units 3 DU Pending 8/4/16
13DEV002 603 Arizona Ave 4291-006-029 market rate units 39 DU Pending 1/8/13
13DEV002 affordable housing 0 DU Pending
13DEV002 retail 25 KSF Pending
13DEV002 restaurant 1.128 KSF Pending
18ARB-0221 1342 Berkeley 4267-012-
009
affordable
housing
8 DU Approved 10/12/18 5/15/18
18ENT-0229 501 Broadway 4291-019-
027
market rate
units
75 DU Approved 4/22/20 7/31/18
18ENT-0229 affordable
housing
19 DU Approved
18ENT-0229 retail 7.26 KSF Approved
20ENT-0241 710 Broadway 4291-022-
026
market rate
units
206 DU Pending 10/16/20
20ENT-0241 affordable
housing
90 DU Pending
20ENT-0241 retail 99.08 KSF Pending
19ENT-0441 1820 Broadway 4275-013-
003
creative office 9.675 KSF Approved 6/17/20 12/2/19
8.A.c
Packet Pg. 184 Attachment: Summary Report on Preliminary Sites Analysis (4433 : Council Direction on Draft Concepts and Framework for Housing Element
City of Santa Monica 6th Cycle 2021-2019 Housing Element – Summary Report of Preliminary Suitable Sites
17
PROJECT ID ADDRESS STREET PARCEL
NOS.
USE SIZE PROJECT
STATUS
DATE
APPROVED
APPLICATION
DATE
15ARB-0038 610 California
Ave
4292-005-
022
market rate
units
3 DU Approved 6/1/15 4/30/15
20ENT-0293 1319 Centinela
Ave
4267-014-
026
market rate
units
6 DU Approved 2/23/21 12/9/20
17ENT-0027 1649 Centinela
Ave
4268-006-
016
market rate
units
3 DU Approved 6/21/17 1/31/17
18ENT-0362 525 Colorado
Ave
4291-024-
014
market rate
units
30 DU Pending 11/27/18
18ENT-0362 affordable
housing
10 DU Pending
18ENT-0362 retail 6.969 KSF Pending
18ENT-0199 601-609 Colorado
Ave
4291-023-
010
market rate
units
104 DU Approved 7/5/18 7/2/18
18ENT-0199 affordable housing 36 DU Approved
18ENT-0199 retail 8.619 KSF Approved
18ENT-0129 711 Colorado Ave 4291-022-012 affordable housing 56 DU Approved 10/4/19 7/10/18
18ENT-0129 retail 2.8 KSF Approved
18ENT-0129 office 0 KSF Approved
13DEV001 1431 Colorado Ave 4284-034-009 market rate units 42 DU Pending 1/8/13
13DEV001 affordable housing 8 DU Pending
13DEV001 retail 12.585 KSF Pending
17ENT-0297 1707 Cloverfield 4268-014-
013
market rate
units
58 DU Approved 4/18/19 12/19/17
17ENT-0297 affordable
housing
5 DU Approved
17ENT-0297 retail 74.665 KSF Approved
19ENT-0054 1802 Delaware
Ave
4274-016-
002
market rate
units
3 DU Approved 6/14/19 2/24/19
20ENT-0011 1512 Euclid St 4282-032-
003
office 1.6 KSF Approved 11/16/20 1/21/20
20ENT-0011 market rate
units
8 DU Approved
20ENT-0011 affordable
housing
2 DU Approved
18ENT-0398 1643-1651 Euclid St 4283-008-011; 4283-
008-012
creative office 27 KSF Pending 12/20/18
19ENT-0429 1650 Euclid St 4283-007-
035
creative office 39.38 KSF Pending 11/21/19
20ARB-0213 1902 Euclid St 4283-028-
010
market rate
units
3 DU Approved 12/22/20 8/6/20
20ENT-0164 1510 Franklin St 4267-027-
057
market rate
units
3 DU Approved 10/21/20 6/24/20
10FIM002 1021 Grant
Street
4284-015-
017
market rate
units
2 DU Approved 12/7/10 10/12/10
20ARB-0138 2714 Highland 4287-019-
012
market rate
units
2 DU Approved 6/15/20 4/28/20
16ENT-0102 1318 Lincoln Blvd 4291-008-025 market rate units 39 DU Approved 2/7/18 7/28/16
16ENT-0102 affordable
housing
4 DU Approved
16ENT-0102 retail 3.437 KSF Approved
20ENT-0163 1427-31 Lincoln
Blvd
4282-027-
020
market rate
units
24 DU Approved 12/9/20 9/27/18
20ENT-0163 affordable
housing
6 DU Approved
20ENT-0163 retail 4.5 KSF Approved
8.A.c
Packet Pg. 185 Attachment: Summary Report on Preliminary Sites Analysis (4433 : Council Direction on Draft Concepts and Framework for Housing Element
City of Santa Monica 6th Cycle 2021-2019 Housing Element – Summary Report of Preliminary Suitable Sites
18
PROJECT ID ADDRESS STREET PARCEL
NOS.
USE SIZE PROJECT
STATUS
DATE
APPROVED
APPLICATION
DATE
15ENT-0266 1430-
1444
Lincoln
Blvd
4291-021-
006; 4291-
021-007
market rate
units
100 DU Approved 10/18/17 6/25/15
15ENT-0266 retail 5.878 KSF Approved
16ENT-0098 1437-1443 Lincoln Blvd 4282-027-028, 4282-
027-018
market rate units 34 DU Approved 12/6/17 7/21/16
16ENT-0098 affordable
housing
6 DU Approved
16ENT-0098 retail 3.777 KSF Approved
11DEV014 1650-1660 Lincoln Blvd 4290-002-008; 4290-
002-006;
4290-002-
007
market rate units 90 DU Approved 4/4/18 5/25/16
11DEV014 affordable
housing
8 DU Approved
11DEV014 retail 6.372 KSF Approved
20ENT-0079 1413 Michigan
Ave
4283-013-
024
affordable
housing
57 DU Approved 8/24/20 3/12/20
20ENT-0079 market rate
units
1 DU Approved
16ENT-0118 3030 Nebraska
Ave
4268-010-
017
market rate
units
174 DU Approved 12/4/19 8/11/16
16ENT-0118 affordable
housing
9 DU Approved
16ENT-0118 creative office 8.374 KSF Approved
11DEV-003 1133 Ocean
Ave
4292-028-
001
market rate
units
60 DU Approved 9/13/20 5/3/11
11DEV-003 hotel 297.34 KSF Approved
11DEV-003 retail/spa 22.784 KSF Approved
11DEV-003 restaurant 12.5 KSF Approved
11DEV-003 meeting space 14.1 KSF Approved
20ENT-0186 1515 Ocean Ave 4291-028-027 hotel 14 rooms Pending 7/23/20
15ENT-0300 1828 Ocean Ave 4290-020-045 market rate units 67 DU Approved 4/23/19 9/1/15
15ENT-0300 affordable
housing
16 DU Approved
15ENT-0300 retail 2 KSF Approved
15ENT-0297 1921 Ocean Front Walk 4289-025-005 market rate units 22 DU Approved 4/23/19 9/1/15
15ENT-0297 retail 2.985 KSF Approved
18ENT-0005 216-248 Pico Blvd 4289-019-
019
market rate
units
93 DU Approved 11/7/18 1/11/18
18ENT-0005 affordable
housing
12 DU Approved
18ENT-0005 retail 10.606 KSF Approved
20ENT-0020 1819 Pico Blvd 4274-017-
019
affordable
housing
47 DU Approved 4/4/20 1/28/20
20ENT-0020 market rate
units
1 DU Approved
20ENT-0020 retail 4.174 KSF Approved
17ENT-0026 2929 Pico Blvd 4274-032-
025
office 12.066 KSF Approved 3/7/18 3/9/17
17ENT-0026 retail 6.284 KSF Approved
17ENT-0026 auto service 0 KSF Approved
20ENT-0280 1514 Princeton 4267-022-
010
market rate
units
2 DU Approved 12/14/20 11/19/20
8.A.c
Packet Pg. 186 Attachment: Summary Report on Preliminary Sites Analysis (4433 : Council Direction on Draft Concepts and Framework for Housing Element
City of Santa Monica 6th Cycle 2021-2019 Housing Element – Summary Report of Preliminary Suitable Sites
19
PROJECT ID ADDRESS STREET PARCEL
NOS.
USE SIZE PROJECT
STATUS
DATE
APPROVED
APPLICATION
DATE
13DEV004 101-129 Santa
Monica
Blvd
4291-014-
025, 4291-
014-024
market rate
units
82 DU Pending 2/28/13
13DEV004 affordable
housing
18 DU Pending
13DEV004 hotel 165 KSF Pending
13DEV004 museum 40.722 KSF Pending
13DEV004 retail 29.75 KSF Pending
19ENT-0340 825 Santa
Monica
Blvd
4282-010-
013; 4282-
010-014
market rate
units
41 DU Pending 9/12/19
19ENT-0340 affordable
housing
7 DU Pending
19ENT-0340 retail 4.044 KSF Pending
20ENT-0226 1401-1421 Santa
Monica
Blvd
4282-016-
015
other 0 KSF Pending 9/17/20
16ADM-0050 2901-
2907
Santa
Monica
Blvd
4267-011-
020, 4267-
011-021
market rate
units
44 DU Approved 6/21/18 5/12/16
16ADM-0050 affordable
housing
7 DU Approved
16ADM-0050 retail 4.3 KSF Approved
17ENT-0298 2906-2918 Santa Monica
Blvd
4267-018-026; 4267-
018-003
market rate units 42 DU Approved 9/4/19 12/19/17
17ENT-0298 affordable
housing
4 DU Approved
17ENT-0298 restaurant 13.691 KSF Approved
18ENT-0182 1618 Stanford 4268-002-005 market rate units 43 DU Approved 3/6/19 6/14/18
18ENT-0182 affordable housing 4 DU Approved
18ENT-0182 office 0 DU Approved
18ENT-0182 retail/restaurant 4.217 KSF Approved
19ENT-0130 122 Strand St 4289-023-025 market rate units 3 DU Approved 7/9/19 4/16/19
16ENT-0115 601-611 Wilshire
Blvd
4292-005-
026; 4292-005-029
market rate
units
37 DU Approved 12/6/17 8/4/16
16ENT-0115 affordable housing 3 DU Approved
16ENT-0115 retail 6.167 KSF Approved
21ENT-0035 1101 Wilshire
Blvd
4281-020-
012
market rate
units
82 DU Pending 2/11/21
21ENT-0035 affordable
housing
11 DU Pending
21ENT-0035 retail 6.8 KSF Pending
19ENT-0455 2919 Wilshire
Blvd
4266-009-
019
daycare 14.999 KSF Approved 10/20/20 12/9/19
20ENT-0170 3032 Wilshire
Blvd
4267-003-
050
retail 2.25 KSF Approved 11/4/20 6/29/20
18ENT-0244 3223 Wilshire
Blvd
4266-001-
045; 4266-
001-046
market rate
units
49 DU Approved 11/7/19 6/7/18
18ENT-0244 affordable
housing
4 DU Approved
18ENT-0244 retail/restaurant 5.5 KSF Approved
8.A.c
Packet Pg. 187 Attachment: Summary Report on Preliminary Sites Analysis (4433 : Council Direction on Draft Concepts and Framework for Housing Element
City of Santa Monica 6th Cycle 2021-2019 Housing Element – Summary Report of Preliminary Suitable Sites
20
8.A.c
Packet Pg. 188 Attachment: Summary Report on Preliminary Sites Analysis (4433 : Council Direction on Draft Concepts and Framework for Housing Element
City of Santa Monica 6th Cycle 2021-2019 Housing Element – Summary Report of Preliminary Suitable Sites
21
Appendix B. State/Institutional/Public Utility Controlled Sites with Residential Potential
Name of State
Entity
Address Description Land
Area
Parcel No. Zone URL to Google Maps
Department of
Motor Vehicles
2235
Colorado
Ave
DMV with large
parking lot
111,930 4275016900 MUBL https://www.google.com/maps/?q= 34.028403, -118.474825
UCLA 1601
Wilshire
Blvd
Vacant building 14,993 4281004900
MUB https://www.google.com/maps/?q=34.02872996,-
118.48691308
UCLA 1531 Santa
Monica Blvd
Surface parking
lot
8,993 4282017905 GC https://www.google.com/maps/?q=34.02570789,-
118.48423136
UCLA 1525 Santa
Monica Blvd
Surface Parking
lot
9,619 4282017906 GC https://www.google.com/maps/?q=34.02559556,-
118.48438943
UCLA 1521 Santa
Monic Blvd
Vacant
buildings
3,884 4282017907 GC https://www.google.com/maps/?q=34.025487, -118.484457
UCLA 1601 Santa
Monica Blvd
Surface Parking
lot
37,512 428201890
GC https://www.google.com/maps/?q=34.02616071,-
118.48390915
Southern California
Gas company
1717
Stewart St
Utility yard 84,529 4268003805 MUC https://www.google.com/maps/?q= 34.031389, -118.466420
Southern California
Gas Company
1717
Stewart St
Utility yard 80,744 4268003800 MUC https://www.google.com/maps/?q= 34.032004, -118.465652
Santa Monica
Malibu Unified
School District
902
Colorado
Ave
Light Industrial
building
79,768 4283002900 MUBL https://www.google.com/maps/?q= 34.017695, -118.486507
Santa Monica
Malibu Unified
School District
916
Colorado
Ave
Light Industrial
building
10,162 4283001901 MUBL https://www.google.com/maps/?q= 34.017256, -118.487016
Santa Monica
Malibu Unified
School District
1651 16th St SMMUSD offices 161,262 4283010900 MUBL https://www.google.com/maps/?q=34.022350, -118.479167
Southern California
Edison
1721
Cloverfield
Parking lot for
Edison site
23,866 4275030804 IC https://www.google.com/maps/?q=34.025592, -118.473777
Southern California
Edison
1721
Cloverfield
Parking lot for
Edison site
14,754 4275030802 IC https://www.google.com/maps/?q=34.025926, -118.473690
8.A.c
Packet Pg. 189 Attachment: Summary Report on Preliminary Sites Analysis (4433 : Council Direction on Draft Concepts
City of Santa Monica 6th Cycle 2021-2019 Housing Element – Summary Report of Preliminary Suitable Sites
22
Appendix C. Religious Institutions with Large Parking Lots
Name of
Institution
Address Description Parcel No. Zone URL to Google Maps
Church of
Jesus Christ
Latter Day
Saints
1257
Centinela
Ave
15,000 sf
Parking Lot
4267001016
R2 https://www.google.com/maps/?q=34.04006,-118.46992172
Maohr Hatorah
Synagogue
1541 Franklin
St
Vacant parcel 4267028024 R2 https://www.google.com/maps/?q=34.03615605,-118.4661231
Santa Monica
Bahai
3102
Colorado
Ave
5,500 sf
vacant land
on east side
4268005029 R2 https://www.google.com/maps/?q=34.03457501,-118.46582763
Calvary Baptist
Church
1901 20th
Street
6,500 sf
vacant
parking lot
4274020021
R2 https://www.google.com/maps/?q=34.02186199,-118.47164299
First Ame
Church
1823
Michigan Av
Parking lot
adjacent to
freeway
4274027027
R2 https://www.google.com/maps/?q=34.02242762,-118.47438589
Vintage
Church
925-929
California
Ave
Large parking
lot on corner
4281029011
R2 https://www.google.com/maps/?q=34.02506741,-118.49474404
Saint Paul’s
Lutheran
Church
801
Washington
Ave
Large parking
lot on corner
4281033024
R2 https://www.google.com/maps/?q=34.02531311,-118.49765738
Mt Olive
Church
1343 Ocean
Park
Large parking
lot
4284025028
R1 https://www.google.com/maps/?q=34.01065359,-118.47099828
St Clement
Church
3007 2nd St Large parking
lot
4287038054 OP2 https://www.google.com/maps/?q=33.99883965,-118.47814862
St Monica 1140 7th St Parking lot 4292005007 R2 https://www.google.com/maps/?q=34.02175667633935, -
118.49636192664886
St Anne 1519-1527
20th St
Parking Lot 4275015007;
4275015014
MUBL https://www.google.com/maps/?q=34.02693295,-118.47747188
Church of
Jesus Christ
Latter Day
Saints
2311 Main St Parking Lot 4289015038 OP2/NC https://www.google.com/maps/?q=34.00462298,-118.48593222
8.A.c
Packet Pg. 190 Attachment: Summary Report on Preliminary Sites Analysis (4433 : Council Direction on Draft Concepts
Revised August 24, 2012
STATE OF CALIFORNIA -BUSINESS, TRANSPORTATION AND HOUSING AGENCY EDMUND G. BROWN JR., Governor DEPARTMENT OF HOUSING AND COMMUNITY DEVELOPMENT DIVISION OF HOUSING POLICY DEVELOPMENT
1800 Third Street, Suite 430 P. O. Box 952053 Sacramento, CA 94252-2053 (916) 323-3177 FAX (916) 327-2643 Adequate Sites Program Alternative Checklist Government Code Section 65583.1(c) As provided for in Government Code Section 65583.1(c), local governments can rely on existing housing units to address up to 25 percent of their adequate sites requirement by counting existing units made available or preserved through the provision of “committed assistance” to low- and very low-income households at affordable housing costs or affordable rents. The following is a checklist intended to provide guidance in determining whether the provisions of Government Code
Section 65583.1(c) can be used to address the adequate sites program requirement. Please be aware, all information must be provided in the housing element to demonstrate compliance. HE Page #
65583.1(c)(4) Is the local government providing, or will it provide “committed
assistance” during the period of time from the beginning of the RHNA projection period to the end of the first 2 years of the housing element planning period? See the definition of “committed
assistance” at the end of the checklist.
Yes
No
65583.1(c)(1)(A) Has the local government identified the specific source of “committed assistance” funds? If yes: specify the amount and date when funds will be dedicated through a (legally enforceable agreement). $: _________________
Date: _______________
Yes
No
65583.1(c)(3)
Has at least some portion of the regional share housing need for very low-income (VL) or low-income (L) households been met in the current or previous planning period? Specify the number of affordable units permitted/constructed in the previous period. Specify the number affordable units permitted/constructed in the current period and document how affordability was established.
Yes
No
_________
_________
65583.1(c)(1)(B) Indicate the total number of units to be assisted
with committed assistance funds and specify funding source. Number of units: __________Funding source: _________________
65583.1(c)(1)(B) Will the funds be sufficient to develop the identified units at affordable costs or rents?
Yes
No
65583.1(c)(1)(C) Do the identified units meet the substantial rehabilitation, conversion, or preservation requirements as defined? Which option? _____________
Yes
No
Note: If you cannot answer “yes” to all of the general requirements questions listed above, your jurisdiction is not eligible to utilize the alternate adequate sites program provisions set forth in Government Code Section 65583.1(c).
8.A.d
Packet Pg. 191 Attachment: HCD Alternative Adequate Sites Checklist (4433 : Council Direction on Draft Concepts and Framework for Housing Element
Revised August 24, 2012
65583.1(c) Checklist Page 2
SUBSTANTIAL REHABILITATION (65583.1(c)(2)(A))
Include reference to specific program action in housing element. Program #
_________
Page #
_______
65583.1(c)(2)(A) Will the rehabilitation result in a net increase in the number of
housing units available and affordable to very low- and lower-income households? If so, how many units? # of VLI units:____ # of LI units: ________
Yes
No
65583.1(c)(2)(A)(i) (I) Are units at imminent risk of loss to affordable housing stock?
For example, are the units at-risk of being demolished or removed from the housing stock without the necessary rehabilitation?
Yes
No
65583.1(c)(2)(A)(i) (II) Is the local government providing relocation assistance consistent with Government code 7260 or Health and Safety Code Section 17975, including rent and moving expenses equivalent to four (4) months, to those occupants permanently or temporary displaced?
Yes
No
65583.1(c)(2)(A)(i) (III) Will tenants have the right to reoccupy units?
Yes
No
65583.1(c)(2)(A)(i) (IV) Have the units been determined to be unfit for human habitation due the at least four (4) of the following violations (as listed in Health & Safety Code Section 17995.3 (a) through (g))?
Termination, extended interruption or serious defects of gas, water or electric utility systems provided such interruptions or termination is not caused by the tenant's failure to pay such gas, water or electric bills.
Serious defects or lack of adequate space and water heating.
Serious rodent, vermin or insect infestation.
Severe deterioration, rendering significant portions of the
structure unsafe or unsanitary.
Inadequate numbers of garbage receptacles or service.
Unsanitary conditions affecting a significant portion of the
structure as a result of faulty plumbing or sewage disposal.
Inoperable hallway lighting.
Yes
No
65583.1(c)(2)(A)(ii) Will affordability and occupancy restrictions be maintained for at least 20 years?
Yes
No
65583.1(c)(2)(A)(iii) Note: Prior to occupancy of the rehabilitated units, the local government must issue a certificate that
finds the units comply with all local and State building and health and safety requirements.
8.A.d
Packet Pg. 192 Attachment: HCD Alternative Adequate Sites Checklist (4433 : Council Direction on Draft Concepts and Framework for Housing Element
Revised August 24, 2012
65583.1(c) Checklist Page 3
CONVERSION OF MULTIFAMILY RENTAL AND OWNERSHIP UNITS OF 3 OR MORE OR FORECLOSED PROPERTIES FROM NON-AFFORDABLE TO AFFORDABLE (65583.1(c)(2)(B))
Include reference to specific program action in housing element. Program # _________ Page # _______
65583.1(c)(2)(B)
Specify the number of multifamily rental (3 or more units) to be converted.
Specify the number multifamily ownership units to be converted. Specify the number of foreclosed properties acquired.
Date Acquired? Will these units be for rent?
________ ________ ________ ________ ________
65583.1(c)(2)(B)(i)
Will the acquired units be made affordable to low- or very low-income
households?
Yes
No
65583.1(c)(2)(B)(ii) For units to be converted to very-low income, were those units affordable to very low-income households at the time they were identified for acquisition? For units to be converted to low-income, were those units affordable
to low-income households at the time they were identified for acquisition?
Yes
No
Yes
No
65583.1(c)(2)(B)(iii)
If the acquisition results in the displacement of very low- or low-income households, is the local government providing relocation assistance consistent with Government Code Section 7260,
including rent and moving expenses equivalent to four (4) months, to those occupants permanently or temporary displaced?
Yes
No
65583.1(c)(2)(B)(iv) Will units be decent, safe, and sanitary upon occupancy?
Yes
No
65583.1(c)(2)(B)(v) Will affordability and occupancy restrictions be maintained at least 55 years?
Yes
No
65583.1(c)(2)(B)(vi)* For conversion of multifamily ownership units: Has at least an equal share of newly constructed multifamily rental units affordable to lower-income households been constructed within the current planning period or will be constructed by the of program completion as the number of ownership units to be
converted? (Note: this could be demonstrated by providing certificates of occupancy)
Specify the number of affordable multifamily rental units constructed in the planning period.
Yes
No
# of lower-income
units: ________
*NOTE: After January 1, 2015 foreclosed units acquired and converted must meet the requirements
of GC 65583.1(c)(2)(B)(vi)
8.A.d
Packet Pg. 193 Attachment: HCD Alternative Adequate Sites Checklist (4433 : Council Direction on Draft Concepts and Framework for Housing Element
Revised August 24, 2012
8.A.d
Packet Pg. 194 Attachment: HCD Alternative Adequate Sites Checklist (4433 : Council Direction on Draft Concepts and Framework for Housing Element
Revised August 24, 2012
65583.1(c) Checklist Page 4
PRESERVATION OF AFFORDABLE UNITS (65583.1(c)(2)(C))
Include reference to specific program action in housing element. Program # ___________ Page # _______
65583.1(c)(2)(C)(i) Will affordability and occupancy restrictions be maintained for at least 40 years?
Yes
No
65583.1(c)(2)(C)(ii) Are the units located within an “assisted housing development” as defined in Government Code Section 65863.10(a)(3)? See definition on page 4.
Yes
No
65583.1(c)(2)(C)(iii) Did the local government hold a public hearing and make a finding that the units are eligible and are reasonably expected to convert to market rate during the next 5 years, due to termination of subsidies, prepayment, or expiration of use?
Yes
No
65583.1(c)(2)(C)(iv)
Will units be decent, safe, and sanitary upon occupancy? Yes
No
65583.1(c)(2)(C)(v) Were the units affordable to very low- and low-income households
at the time the units were identified for preservation?
Yes
No
NOTE:
• By no later than July 1st of the third year of the planning period, local governments must report on the status of its program implementation for substantial rehabilitation, conversion, and/or preservation (of affordability)
as described above (Government Code 65583.1(c)(7)).
• The report must specify and identify those units for which committed assistance has been provided or which have been made available to low- and very low-income households and document how each unit complies with the substantial rehabilitation, conversion, and/or preservation provisions.
• If the local government has not entered into an enforceable agreement of committed assistance for all units specified in the identified program(s), by the July 1st due date, it must amend its element to identify additional appropriately zoned and suitable sites, sufficient to accommodate the number of units for which committed assistance was not provided. This follow-up action must be taken no later than July 1st of the fourth year of the planning period.
• If a local government fails to amend its element to identify adequate sites to address any shortfall, or fails to
complete the rehabilitation, acquisition, purchase of affordability covenants, or the preservation of any housing unit within two years after committed assistance was provided to that unit, the local government
cannot use the alternate adequate sites program provisions of Government Code Section 65583.1(c)(1) in it next housing element update, beyond the number of units actually provided or preserved due to committed
assistance.
8.A.d
Packet Pg. 195 Attachment: HCD Alternative Adequate Sites Checklist (4433 : Council Direction on Draft Concepts and Framework for Housing Element
Revised August 24, 2012
65583.1(c) Checklist Page 5 DEFINITIONS:
Committed Assistance: When a local government has entered into a legally enforceable agreement within a specific timeframe spanning from the beginning of the RHNA projection period through the end of the second year of the housing element planning period, obligating funds for affordable units available for occupancy within two years of the agreement. Assisted Housing Development: A multifamily rental housing development that receives governmental
assistance under any of the following programs: (A) New construction, substantial rehabilitation, moderate rehabilitation, property disposition, and loan management set-aside programs, or any other program providing project-based assistance, under Section 8 of the United States Housing Act of 1937, as amended (42 U.S.C. Sec. 1437f). (B) The following federal programs:
(i) The Below-Market-Interest-Rate Program under Section 221(d)(3) of the National Housing Act (12 U.S.C. Sec. 1715l(d)(3) and (5)). (ii) Section 236 of the National Housing Act (12 U.S.C. Sec.1715z-1). (iii) Section 202 of the Housing Act of 1959 (12 U.S.C. Sec. 1701q). (C) Programs for rent supplement assistance under Section 101 of the Housing and Urban Development Act of 1965, as amended (12 U.S.C. Sec. 1701s).
(D) Programs under Sections 514, 515, 516, 533, and 538 of the Housing Act of 1949, as amended (42 U.S.C. Sec. 1485). (E) Section 42 of the Internal Revenue Code. (F) Section 142(d) of the Internal Revenue Code (tax-exempt private activity mortgage revenue bonds).
(G) Section 147 of the Internal Revenue Code (Section 501(c)(3) bonds). (H) Title I of the Housing and Community Development Act of 1974, as amended (Community Development
Block Grant Program). (I) Title II of the Cranston-Gonzales National Affordable Housing Act of 1990, as amended (HOME Investment Partnership Program). (J) Titles IV and V of the McKinney-Vento Homeless Assistance Act of 1987, as amended, including the
Department of Housing and Urban Development's Supportive Housing Program, Shelter Plus Care program, and surplus federal property disposition program.
(K) Grants and loans made by the Department of Housing and Community Development, including the Rental Housing Construction Program, CHRP-R, and other rental housing finance programs.
(L) Chapter 1138 of the Statutes of 1987. (M) The following assistance provided by counties or cities in exchange for restrictions on the maximum
rents that may be charged for units within a multifamily rental housing development and on the maximum tenant income as a condition of eligibility for occupancy of the unit subject to the rent restriction, as reflected by a recorded agreement with a county or city: (i) Loans or grants provided using tax increment financing pursuant to the Community Redevelopment
Law (Part 1 (commencing with Section 33000) of Division 24 of the Health and Safety Code). (ii) Local housing trust funds, as referred to in paragraph (3) of subdivision (a) of Section 50843 of the
Health and Safety Code. (iii) The sale or lease of public property at or below market rates.
(iv) The granting of density bonuses, or concessions or incentives, including fee waivers, parking variances, or amendments to general plans, zoning, or redevelopment project area plans, pursuant
to Chapter 4.3 (commencing with Section 65915).
Assistance pursuant to this subparagraph shall not include the use of tenant-based Housing Choice Vouchers (Section 8(o)) of the United States Housing Act of 1937, 42 U.S.C. Sec. 1437f(o), excluding
subparagraph (13) relating to project-based assistance). Restrictions shall not include any rent control or rent stabilization ordinance imposed by a county, city, or city and county.
8.A.d
Packet Pg. 196 Attachment: HCD Alternative Adequate Sites Checklist (4433 : Council Direction on Draft Concepts and Framework for Housing Element
Attachment XX
SB 35 Summary of Impacts on Santa Monica if Streamlining Applies
Affordable Housing Production Program
The City's Affordable Housing Production Program ordinance ("the AHPP") currently
allows development applicants to elect the percentage of inclusionary affordable
housing units, based upon targeted household income levels. For example, multi-family
project applicants may restrict 5% of units, if the units are targeted to 30% AMI
households, 10% of units if the units are restricted to 50% AMI households, and 20% of
total units if the units are restricted to 80% AMI households. While the original intent of
the AHPP was to incentivize the development of deed restricted units for 30% AMI
households, it has resulted in the over-production of 30% AMI units at the expense of
other income categories, which may result in the City not meeting its RHNA goals for all
income categories. Staff anticipates that future legislation will continue to rely on
demonstrating progress to meeting RHNA allocations with requirements to produce
housing at each income affordability level. As such, it is important that any inclusionary
units and market rate units closely follow the percentage mix of RHNA allocations
instead of options or policies that favor one income level over another. This is the
approach taken in the Downtown Community Plan ("DCP") and based on Council’s
direction to study options for housing production on the boulevards and Bergamot, staff
anticipates needing to amend the AHPP so that future housing production is
appropriately allocated to the full spectrum of income levels.
SB 35 requires applicants to provide affordable housing units if the City has not
submitted an annual progress report or the report demonstrates that the RHNA
allocations have not been met for each affordability category. The requirements are
either 10% or 50% or defer to local ordinance (e.g. AHPP) if the local ordinance
establishes a greater requirement. Table 1 outlines the differences in affordability
requirements between the AHPP and SB35 (if applicable):
12
8.A.e
Packet Pg. 197 Attachment: SB35 Summary Implications for Santa Monica (4433 : Council Direction on Draft Concepts and Framework for Housing Element
13
Table 1: Comparison of AHPP and SB35 affordability requirements
Affordability Level AHPP SB35
If City has not submitted
annual progress report or
has not produced
sufficient above-moderate
income units
If City has not submitted
APR or has not produced
sufficient below 80%
income household units
Extremely Low 5%
Greater of 10% or AHPP Greater of 50% or AHPP Very Low 10%
Low 20%
Prevailing Wage
The prevailing wage provision may be a potential deterrent to developers who may be
interested in the provisions of the bill. However, with recent interest in pre-fabricated
construction methods, the increased labor costs associated with this provision may not
be as significant a financial/feasibility barrier as first thought. Currently, the City only
requires prevailing wage for Public Works Projects and Contracts. There is no
requirement for private development.
Concerns on Loss of Local Control/Unintended Consequences
SB 35 explicitly declares housing a matter of statewide concern and is intended to
minimize if not eliminate discretionary review of housing projects. The bill was opposed
by the League of California Cities due to the erosion of local control over local land use
matters. Staff held legislative discussions with the bill’s authors to propose language
that would not result in unintended consequences. While some language was changed
(e.g. adding historic resources on local registers), staff remains concerned about the
loss of local control, in particular the potential limitation on discretionary design review
by the ARB.
Santa Monica has a successful track record of producing not only sufficient housing
units but also projects that are well-designed, context sensitive, and livable for
residents. Feedback from residents and the development community that prior design
standards in Downtown were too prescriptive resulted in a complete overhaul of
8.A.e
Packet Pg. 198 Attachment: SB35 Summary Implications for Santa Monica (4433 : Council Direction on Draft Concepts and Framework for Housing Element
14
Downtown design standards to allow significantly more flexibility in building design. The
bill’s requirement that projects only need meet “objective design review standards”
appears to require the City to establish very prescriptive standards that provide no
flexibility or discretion. This would setback 6 years of work in developing new
approaches to building design and urban form in Downtown. The current design review
process would be largely eliminated with housing projects turning essentially into plan
check review.
Parking Standards
SB 35 eliminates minimum parking requirements in any of the following circumstances:
• Development located within ½ mile of public transit
• Development located within an architecturally and historically significant historic
district
• When on street parking permits are required but not offered to the occupants of
the development
• When there is a car share vehicle located within one block of the development
The City has taken a thoughtful approach to parking standards with reduced or
eliminated parking requirements in transit-rich areas, such as within the Downtown
Community Plan area and the areas immediately around Expo Stations. Council
eliminated minimum parking requirements in the DCP area based on the availability of
alternative modes, the thousands of existing parking spaces with several thousand
anticipated with new development, the potential for housing affordability, and
opportunity to incentivize change of use. Parking standards in the remainder of the City
balance appropriate parking need against constructing too much parking that run
counter to the City’s Mobility goals. These parking requirements take into account
commercial activity adjacent to residential neighborhoods and neighborhoods that are
already experiencing parking impacts due to employee and customer incursions into
residential neighborhood.
8.A.e
Packet Pg. 199 Attachment: SB35 Summary Implications for Santa Monica (4433 : Council Direction on Draft Concepts and Framework for Housing Element
SCAG 6TH CYCLE FINAL RHNA ALLOCATION PLAN
SCAG 6TH CYCLE FINAL RHNA ALLOCATION PLAN (pending HCD approval)
3/4/21
ALLOCATION BY COUNTY
Total
Very‐low
income Low income
Moderate
income
Above
moderate
income
Imperial 15,993 4,671 2,357 2,198 6,767
Los Angeles 812,060 217,273 123,022 131,381 340,384
Orange 183,861 46,416 29,242 32,546 75,657
Riverside 167,351 41,995 26,473 29,167 69,716
San Bernardino 138,110 35,667 21,903 24,140 56,400
Ventura 24,452 5,774 3,810 4,525 10,343
TOTAL 1,341,827 351,796 206,807 223,957 559,267
ALLOCATION BY Regional Early Action Planning (REAP) SUBREGIONS
REAP Subregion Total
Very‐low
income Low income
Moderate
income
Above
moderate
income
CVAG 31,619 6,204 4,664 5,561 15,190
Gateway Cities COG 71,678 20,029 10,391 10,822 30,436
Imperial County 15,993 4,671 2,357 2,198 6,767
Las Virgenes‐Malibu COG 933 362 199 183 189
Los Angeles City 456,643 115,978 68,743 75,091 196,831
North Los Angeles County 15,663 4,001 2,129 2,332 7,201
Orange County COG 183,861 46,416 29,242 32,546 75,657
San Bernardino COG/SBCTA 138,110 35,667 21,903 24,140 56,400
San Fernando Valley COG 34,023 9,850 5,588 5,614 12,971
San Gabriel Valley COG 89,616 25,208 13,400 14,074 36,934
South Bay Cities COG 34,179 10,221 5,236 5,539 13,183
Uninc. Los Angeles County 90,052 25,648 13,691 14,180 36,533
Uninc. Riverside County 40,647 10,371 6,627 7,347 16,302
Ventura COG 24,452 5,774 3,810 4,525 10,343
Westside Cities COG 19,273 5,976 3,645 3,546 6,106
Western Riverside COG 95,085 25,420 15,182 16,259 38,224
ALLOCATION BY LOCAL JURISDICTION
County Jurisdiction Total
Very‐low
income Low income
Moderate
income
Above‐
moderate
income
Imperial Brawley city 1426 399 210 202 615
Imperial Calexico city 4868 1279 655 614 2320
Imperial Calipatria city 151 36 21 16 78
Imperial El Centro city 3442 1001 490 462 1489
Imperial Holtville city 171 41 33 26 71
SCAG Page 1 of 6
8.A.f
Packet Pg. 200 Attachment: Final 6th Cycle RHNA Allocation (4433 : Council Direction on Draft Concepts and Framework for Housing Element Update (90 min))
SCAG 6TH CYCLE FINAL RHNA ALLOCATION PLAN
ALLOCATION BY LOCAL JURISDICTION
County Jurisdiction Total
Very‐low
income Low income
Moderate
income
Above‐
moderate
income
Imperial Imperial city 1601 704 346 294 257
Imperial Unincorporated Imp 4301 1203 596 580 1922
Imperial Westmorland city 3386415
Los Angeles Agoura Hills city 318 127 72 55 64
Los Angeles Alhambra city 6825 1774 1036 1079 2936
Los Angeles Arcadia city 3214 1102 570 605 937
Los Angeles Artesia city 1069 312 168 128 461
Los Angeles Avalon city 2785311
Los Angeles Azusa city 2651 760 368 382 1141
Los Angeles Baldwin Park city 2001 576 275 263 887
Los Angeles Bell city 229 43 24 29 133
Los Angeles Bell Gardens city 503 100 29 72 302
Los Angeles Bellflower city 3735 1015 488 553 1679
Los Angeles Beverly Hills city 3104 1008 680 602 814
Los Angeles Bradbury city 41 16997
Los Angeles Burbank city 8772 2553 1418 1409 3392
Los Angeles Calabasas city 354 132 71 70 81
Los Angeles Carson city 5618 1770 913 875 2060
Los Angeles Cerritos city 1908 679 345 332 552
Los Angeles Claremont city 1711 556 310 297 548
Los Angeles Commerce city 247 55 22 39 131
Los Angeles Compton city 1004 235 121 131 517
Los Angeles Covina city 1910 614 268 281 747
Los Angeles Cudahy city 393 80 36 53 224
Los Angeles Culver City city 3341 1108 604 560 1069
Los Angeles Diamond Bar city 2521 844 434 437 806
Los Angeles Downey city 6525 2079 946 915 2585
Los Angeles Duarte city 888 269 145 137 337
Los Angeles El Monte city 8502 1797 853 1233 4619
Los Angeles El Segundo city 492 189 88 84 131
Los Angeles Gardena city 5735 1485 761 894 2595
Los Angeles Glendale city 13425 3439 2163 2249 5574
Los Angeles Glendora city 2276 735 386 388 767
Los Angeles Hawaiian Gardens ci 331 61 44 46 180
Los Angeles Hawthorne city 1734 445 204 249 836
Los Angeles Hermosa Beach city 558 232 127 106 93
Los Angeles Hidden Hills city 40 17896
Los Angeles Huntington Park city 1605 264 196 243 902
Los Angeles Industry city 176425
Los Angeles Inglewood city 7439 1813 955 1112 3559
Los Angeles Irwindale city 119 36 11 17 55
Los Angeles La Cañada Flintridge 612 252 135 139 86
SCAG Page 2 of 6
8.A.f
Packet Pg. 201 Attachment: Final 6th Cycle RHNA Allocation (4433 : Council Direction on Draft Concepts and Framework for Housing Element Update (90 min))
SCAG 6TH CYCLE FINAL RHNA ALLOCATION PLAN
ALLOCATION BY LOCAL JURISDICTION
County Jurisdiction Total
Very‐low
income Low income
Moderate
income
Above‐
moderate
income
Los Angeles La Habra Heights city 172 78 35 31 28
Los Angeles La Mirada city 1962 634 342 320 666
Los Angeles La Puente city 1929 544 275 275 835
Los Angeles La Verne city 1346 414 239 223 470
Los Angeles Lakewood city 3922 1296 637 653 1336
Los Angeles Lancaster city 9023 2224 1194 1328 4277
Los Angeles Lawndale city 2497 732 311 371 1083
Los Angeles Lomita city 829 239 124 128 338
Los Angeles Long Beach city 26502 7141 4047 4158 11156
Los Angeles Los Angeles city 456643 115978 68743 75091 196831
Los Angeles Lynwood city 1558 377 139 235 807
Los Angeles Malibu city 79 28 19 17 15
Los Angeles Manhattan Beach cit 774 322 165 155 132
Los Angeles Maywood city 365 55 47 55 208
Los Angeles Monrovia city 1670 519 262 254 635
Los Angeles Montebello city 5186 1314 707 777 2388
Los Angeles Monterey Park city 5257 1324 822 848 2263
Los Angeles Norwalk city 5034 1546 759 658 2071
Los Angeles Palmdale city 6640 1777 935 1004 2924
Los Angeles Palos Verdes Estates 199 82 44 48 25
Los Angeles Paramount city 364 92 43 48 181
Los Angeles Pasadena city 9429 2747 1662 1565 3455
Los Angeles Pico Rivera city 1024 299 146 149 430
Los Angeles Pomona city 10558 2799 1339 1510 4910
Los Angeles Rancho Palos Verdes 639 253 139 125 122
Los Angeles Redondo Beach city 2490 936 508 490 556
Los Angeles Rolling Hills city 45 20 9 11 5
Los Angeles Rolling Hills Estates c 191 82 42 38 29
Los Angeles Rosemead city 4612 1154 638 686 2134
Los Angeles San Dimas city 1248 384 220 206 438
Los Angeles San Fernando city 1795 461 273 284 777
Los Angeles San Gabriel city 3023 846 415 466 1296
Los Angeles San Marino city 397 149 91 91 66
Los Angeles Santa Clarita city 10031 3397 1734 1672 3228
Los Angeles Santa Fe Springs city 952 253 159 152 388
Los Angeles Santa Monica city 8895 2794 1672 1702 2727
Los Angeles Sierra Madre city 204 79 39 35 51
Los Angeles Signal Hill city 517 161 78 90 188
Los Angeles South El Monte city 577 131 64 70 312
Los Angeles South Gate city 8282 2136 994 1173 3979
Los Angeles South Pasadena city 2067 757 398 334 578
Los Angeles Temple City city 2186 630 350 369 837
SCAG Page 3 of 6
8.A.f
Packet Pg. 202 Attachment: Final 6th Cycle RHNA Allocation (4433 : Council Direction on Draft Concepts and Framework for Housing Element Update (90 min))
SCAG 6TH CYCLE FINAL RHNA ALLOCATION PLAN
ALLOCATION BY LOCAL JURISDICTION
County Jurisdiction Total
Very‐low
income Low income
Moderate
income
Above‐
moderate
income
Los Angeles Torrance city 4939 1621 846 853 1619
Los Angeles Unincorporated Los 90052 25648 13691 14180 36533
Los Angeles Vernon city 95400
Los Angeles Walnut city 1293 427 225 231 410
Los Angeles West Covina city 5346 1653 850 865 1978
Los Angeles West Hollywood city 3933 1066 689 682 1496
Los Angeles Westlake Village city 142 58 29 32 23
Los Angeles Whittier city 3439 1025 537 556 1321
Orange Aliso Viejo city 1195 390 214 205 386
Orange Anaheim city 17453 3767 2397 2945 8344
Orange Brea city 2365 669 393 403 900
Orange Buena Park city 8919 2119 1343 1573 3884
Orange Costa Mesa city 11760 2919 1794 2088 4959
Orange Cypress city 3936 1150 657 623 1506
Orange Dana Point city 530 147 84 101 198
Orange Fountain Valley city 4839 1307 786 834 1912
Orange Fullerton city 13209 3198 1989 2271 5751
Orange Garden Grove city 19168 4166 2801 3211 8990
Orange Huntington Beach ci 13368 3661 2184 2308 5215
Orange Irvine city 23610 6396 4235 4308 8671
Orange La Habra city 804 192 116 130 366
Orange La Palma city 802 224 140 137 301
Orange Laguna Beach city 394 118 80 79 117
Orange Laguna Hills city 1985 568 353 354 710
Orange Laguna Niguel city 1207 348 202 223 434
Orange Laguna Woods city 997 127 136 192 542
Orange Lake Forest city 3236 956 543 559 1178
Orange Los Alamitos city 769 194 119 145 311
Orange Mission Viejo city 2217 674 401 397 745
Orange Newport Beach city 4845 1456 930 1050 1409
Orange Orange city 3936 1067 604 677 1588
Orange Placentia city 4374 1231 680 770 1693
Orange Rancho Santa Marga 680 209 120 125 226
Orange San Clemente city 982 282 164 188 348
Orange San Juan Capistrano 1054 270 173 183 428
Orange Santa Ana city 3095 586 362 523 1624
Orange Seal Beach city 1243 258 201 239 545
Orange Stanton city 1231 165 145 231 690
Orange Tustin city 6782 1724 1046 1132 2880
Orange Unincorporated Ora 10406 3139 1866 2040 3361
Orange Villa Park city 296 93 60 61 82
Orange Westminster city 9759 1881 1473 1784 4621
SCAG Page 4 of 6
8.A.f
Packet Pg. 203 Attachment: Final 6th Cycle RHNA Allocation (4433 : Council Direction on Draft Concepts and Framework for Housing Element Update (90 min))
SCAG 6TH CYCLE FINAL RHNA ALLOCATION PLAN
ALLOCATION BY LOCAL JURISDICTION
County Jurisdiction Total
Very‐low
income Low income
Moderate
income
Above‐
moderate
income
Orange Yorba Linda city 2415 765 451 457 742
Riverside Banning city 1673 317 193 280 883
Riverside Beaumont city 4210 1229 721 723 1537
Riverside Blythe city 494 82 71 96 245
Riverside Calimesa city 2017 495 275 379 868
Riverside Canyon Lake city 129 43 24 24 38
Riverside Cathedral City city 2549 540 353 457 1199
Riverside Coachella city 7886 1033 999 1367 4487
Riverside Corona city 6088 1752 1040 1096 2200
Riverside Desert Hot Springs c 3873 569 535 688 2081
Riverside Eastvale City 3028 1145 672 635 576
Riverside Hemet city 6466 812 732 1174 3748
Riverside Indian Wells city 382 117 81 91 93
Riverside Indio city 7812 1793 1170 1315 3534
Riverside Jurupa Valley City 4497 1207 749 731 1810
Riverside La Quinta city 1530 420 269 297 544
Riverside Lake Elsinore city 6681 1878 1099 1134 2570
Riverside Menifee city 6609 1761 1051 1106 2691
Riverside Moreno Valley city 13627 3779 2051 2165 5632
Riverside Murrieta city 3043 1009 583 545 906
Riverside Norco city 454 145 85 82 142
Riverside Palm Desert city 2790 675 460 461 1194
Riverside Palm Springs city 2557 545 408 461 1143
Riverside Perris city 7805 2030 1127 1274 3374
Riverside Rancho Mirage city 1746 430 318 328 670
Riverside Riverside city 18458 4861 3064 3139 7394
Riverside San Jacinto city 3392 800 465 560 1567
Riverside Temecula city 4193 1359 801 778 1255
Riverside Unincorporated Rive 40647 10371 6627 7347 16302
Riverside Wildomar city 2715 798 450 434 1033
San Bernardino Adelanto city 3763 394 566 651 2152
San Bernardino Apple Valley town 4290 1086 600 747 1857
San Bernardino Barstow city 1520 172 228 300 820
San Bernardino Big Bear Lake city 212 50 33 37 92
San Bernardino Chino city 6978 2113 1284 1203 2378
San Bernardino Chino Hills city 3729 1388 821 789 731
San Bernardino Colton city 5434 1318 668 906 2542
San Bernardino Fontana city 17519 5109 2950 3035 6425
San Bernardino Grand Terrace city 630 189 92 106 243
San Bernardino Hesperia city 8155 1921 1231 1409 3594
San Bernardino Highland city 2513 619 409 471 1014
San Bernardino Loma Linda city 2051 523 311 352 865
SCAG Page 5 of 6
8.A.f
Packet Pg. 204 Attachment: Final 6th Cycle RHNA Allocation (4433 : Council Direction on Draft Concepts and Framework for Housing Element Update (90 min))
SCAG 6TH CYCLE FINAL RHNA ALLOCATION PLAN
ALLOCATION BY LOCAL JURISDICTION
County Jurisdiction Total
Very‐low
income Low income
Moderate
income
Above‐
moderate
income
San Bernardino Montclair city 2593 698 383 399 1113
San Bernardino Needles city 87 10 11 16 50
San Bernardino Ontario city 20854 5640 3286 3329 8599
San Bernardino Rancho Cucamonga 10525 3245 1920 2038 3322
San Bernardino Redlands city 3516 967 615 652 1282
San Bernardino Rialto city 8272 2218 1206 1371 3477
San Bernardino San Bernardino city 8123 1415 1097 1448 4163
San Bernardino Twentynine Palms ci 1047 231 127 185 504
San Bernardino Unincorporated San 8832 2179 1360 1523 3770
San Bernardino Upland city 5686 1584 959 1013 2130
San Bernardino Victorville city 8165 1735 1136 1504 3790
San Bernardino Yucaipa city 2866 708 493 511 1154
San Bernardino Yucca Valley town 750 155 117 145 333
Ventura Camarillo city 1376 353 244 271 508
Ventura Fillmore city 415 73 61 72 209
Ventura Moorpark city 1289 377 233 245 434
Ventura Ojai city 53 13 9 10 21
Ventura Oxnard city 8549 1840 1071 1538 4100
Ventura Port Hueneme city 125 26 16 18 65
Ventura San Buenaventura (V 5312 1187 865 950 2310
Ventura Santa Paula city 657 102 99 121 335
Ventura Simi Valley city 2793 749 493 518 1033
Ventura Thousand Oaks city 2621 735 494 532 860
Ventura Unincorporated Ven 1262 319 225 250 468
SCAG Page 6 of 6
8.A.f
Packet Pg. 205 Attachment: Final 6th Cycle RHNA Allocation (4433 : Council Direction on Draft Concepts and Framework for Housing Element Update (90 min))
Santa Monica Employee Transportation & Housing Survey:
Summary Results
Introduction
In order to better gauge the housing and transportation needs of Santa Monica’s workforce, the City
administered the following survey via a convenience sample, conducted through Survey Monkey in English and
Spanish language versions. From February 22 through March 12, 2021, 2,647 total responses were gathered,
of which 1,736 provided a valid Santa Monica work zip code. Of these Santa Monica workers, 910 provided a
valid home zip code outside Santa Monica limits. The following tabulations are drawn from this last group of
910 in-bound commuters.
Q1 In what zip code is your home located?
The below map shows the density of the 910 in-bound commuter responses by home zip code.
1
8.A.g
Packet Pg. 206 Attachment: Attachment G - Mobility and Housing Survey Summary Results (4433 : Council Direction on Draft Concepts and Framework for
Q2 In what ZIP code is your work located?
259
9
59
239
344
90401
90402
90403
90404
90405
0 100 200 300
Number of Respondents
Work
Zip
Code
By Work Zip Code (910 Total)
Number of Respondents Working in Santa Monica and Living Elsewhere
2
8.A.g
Packet Pg. 207 Attachment: Attachment G - Mobility and Housing Survey Summary Results (4433 : Council Direction on Draft Concepts and Framework for
Q3 Profession/Trade (open response)
The following table gives a reference for the 40 most common open-ended responses to the question of the
respondents “Profession/Trade”. These responses have been edited to be case-insensitive, but are otherwise
unadjusted. Of the 910 respondents commuting into Santa Monica, 907 provided a response to this prompt,
with a total of 471 unique case-insensitive entries.
Profession Number of Respondents
teacher 107
professor 20
educator 19
administrative assistant 18
analyst 18
education 17
accountant 10
counselor 10
nurse 9
human resources 8
supervisor 8
paraeducator 7
admin assistant 6
chef 6
clerk 6
instructor 6
manager 6
teacher assistant 6
accounting 5
college professor 5
executive assistant 5
maintenance 5
marketing 5
para educator 5
preschool teacher 5
waiter 5
administrator 4
architect 4
artist 4
attorney 4
communications 4
consultant 4
cook 4
custodian 4
engineer 4
general manager 4
hair stylist 4
instructional assistant 4
oce manager 4
sales 4
3
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Packet Pg. 208 Attachment: Attachment G - Mobility and Housing Survey Summary Results (4433 : Council Direction on Draft Concepts and Framework for
Q4 What industry?
110
56
23
294
351
49
25
Hotel
Retail
Restaurant
Hospital/Healthcare
Government
Other
Public Education
0 100 200 300
Number of Respondents
By Industry (908 Total)
Number of Respondents Working in Santa Monica, Living Elsewhere
4
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Packet Pg. 209 Attachment: Attachment G - Mobility and Housing Survey Summary Results (4433 : Council Direction on Draft Concepts and Framework for
Q5 In what year were you born?
27
231
365
248
30
18 to 25
26 to 35
36 to 50
51 to 65
66+
0 100 200 300
Number of Respondents
By Age (901 Total)
Number of Respondents Working in Santa Monica, Living Elsewhere
5
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Packet Pg. 210 Attachment: Attachment G - Mobility and Housing Survey Summary Results (4433 : Council Direction on Draft Concepts and Framework for
Q6 What is the total yearly gross (pre-tax) income for your household?
Median = $85,000Median = $85,000Median = $85,000Median = $85,000Median = $85,000Median = $85,000Median = $85,000Median = $85,000Median = $85,000Median = $85,000Median = $85,000Median = $85,000Median = $85,000Median = $85,000Median = $85,000Median = $85,000Median = $85,000Median = $85,000Median = $85,000Median = $85,000Median = $85,000Median = $85,000Median = $85,000Median = $85,000Median = $85,000Median = $85,000Median = $85,000Median = $85,000Median = $85,000Median = $85,000Median = $85,000Median = $85,000Median = $85,000Median = $85,000Median = $85,000Median = $85,000Median = $85,000Median = $85,000Median = $85,000Median = $85,000Median = $85,000Median = $85,000Median = $85,000Median = $85,000Median = $85,000Median = $85,000Median = $85,000Median = $85,000Median = $85,000Median = $85,000Median = $85,000Median = $85,000Median = $85,000Median = $85,000Median = $85,000Median = $85,000Median = $85,000Median = $85,000Median = $85,000Median = $85,000Median = $85,000Median = $85,000Median = $85,000Median = $85,000Median = $85,000Median = $85,000Median = $85,000Median = $85,000Median = $85,000Median = $85,000Median = $85,000Median = $85,000Median = $85,000Median = $85,000Median = $85,000Median = $85,000Median = $85,000Median = $85,000Median = $85,000Median = $85,000Median = $85,000Median = $85,000Median = $85,000Median = $85,000Median = $85,000Median = $85,000Median = $85,000Median = $85,000Median = $85,000Median = $85,000Median = $85,000Median = $85,000Median = $85,000Median = $85,000Median = $85,000Median = $85,000Median = $85,000Median = $85,000Median = $85,000Median = $85,000Median = $85,000Median = $85,000Median = $85,000Median = $85,000Median = $85,000Median = $85,000Median = $85,000Median = $85,000Median = $85,000Median = $85,000Median = $85,000Median = $85,000Median = $85,000Median = $85,000Median = $85,000Median = $85,000Median = $85,000Median = $85,000Median = $85,000Median = $85,000Median = $85,000Median = $85,000Median = $85,000Median = $85,000Median = $85,000Median = $85,000Median = $85,000Median = $85,000Median = $85,000Median = $85,000Median = $85,000Median = $85,000Median = $85,000Median = $85,000Median = $85,000Median = $85,000Median = $85,000Median = $85,000Median = $85,000Median = $85,000Median = $85,000Median = $85,000Median = $85,000Median = $85,000Median = $85,000Median = $85,000Median = $85,000Median = $85,000Median = $85,000Median = $85,000Median = $85,000Median = $85,000Median = $85,000Median = $85,000Median = $85,000Median = $85,000Median = $85,000Median = $85,000Median = $85,000Median = $85,000Median = $85,000Median = $85,000Median = $85,000Median = $85,000Median = $85,000Median = $85,000Median = $85,000Median = $85,000Median = $85,000Median = $85,000Median = $85,000Median = $85,000Median = $85,000Median = $85,000Median = $85,000Median = $85,000Median = $85,000Median = $85,000Median = $85,000Median = $85,000Median = $85,000Median = $85,000Median = $85,000Median = $85,000Median = $85,000Median = $85,000Median = $85,000Median = $85,000Median = $85,000Median = $85,000Median = $85,000Median = $85,000Median = $85,000Median = $85,000Median = $85,000Median = $85,000Median = $85,000Median = $85,000Median = $85,000Median = $85,000Median = $85,000Median = $85,000Median = $85,000Median = $85,000Median = $85,000Median = $85,000Median = $85,000Median = $85,000Median = $85,000Median = $85,000Median = $85,000Median = $85,000Median = $85,000Median = $85,000Median = $85,000Median = $85,000Median = $85,000Median = $85,000Median = $85,000Median = $85,000Median = $85,000Median = $85,000Median = $85,000Median = $85,000Median = $85,000Median = $85,000Median = $85,000Median = $85,000Median = $85,000Median = $85,000Median = $85,000Median = $85,000Median = $85,000Median = $85,000Median = $85,000Median = $85,000Median = $85,000Median = $85,000Median = $85,000Median = $85,000Median = $85,000Median = $85,000Median = $85,000Median = $85,000Median = $85,000Median = $85,000Median = $85,000Median = $85,000Median = $85,000Median = $85,000Median = $85,000Median = $85,000Median = $85,000Median = $85,000Median = $85,000Median = $85,000Median = $85,000Median = $85,000Median = $85,000Median = $85,000Median = $85,000Median = $85,000Median = $85,000Median = $85,000Median = $85,000Median = $85,000Median = $85,000Median = $85,000Median = $85,000Median = $85,000Median = $85,000Median = $85,000Median = $85,000Median = $85,000Median = $85,000Median = $85,000Median = $85,000Median = $85,000Median = $85,000Median = $85,000Median = $85,000Median = $85,000Median = $85,000Median = $85,000Median = $85,000Median = $85,000Median = $85,000Median = $85,000Median = $85,000Median = $85,000Median = $85,000Median = $85,000Median = $85,000Median = $85,000Median = $85,000Median = $85,000Median = $85,000Median = $85,000Median = $85,000Median = $85,000Median = $85,000Median = $85,000Median = $85,000Median = $85,000Median = $85,000Median = $85,000Median = $85,000Median = $85,000Median = $85,000Median = $85,000Median = $85,000Median = $85,000Median = $85,000Median = $85,000Median = $85,000Median = $85,000Median = $85,000Median = $85,000Median = $85,000Median = $85,000Median = $85,000Median = $85,000Median = $85,000Median = $85,000Median = $85,000Median = $85,000Median = $85,000Median = $85,000Median = $85,000Median = $85,000Median = $85,000Median = $85,000Median = $85,000Median = $85,000Median = $85,000Median = $85,000Median = $85,000Median = $85,000Median = $85,000Median = $85,000Median = $85,000Median = $85,000Median = $85,000Median = $85,000Median = $85,000Median = $85,000Median = $85,000Median = $85,000Median = $85,000Median = $85,000Median = $85,000Median = $85,000Median = $85,000Median = $85,000Median = $85,000Median = $85,000Median = $85,000Median = $85,000Median = $85,000Median = $85,000Median = $85,000Median = $85,000Median = $85,000Median = $85,000Median = $85,000Median = $85,000Median = $85,000Median = $85,000Median = $85,000Median = $85,000Median = $85,000Median = $85,000Median = $85,000Median = $85,000Median = $85,000Median = $85,000Median = $85,000Median = $85,000Median = $85,000Median = $85,000Median = $85,000Median = $85,000Median = $85,000Median = $85,000Median = $85,000Median = $85,000Median = $85,000Median = $85,000Median = $85,000Median = $85,000Median = $85,000Median = $85,000Median = $85,000Median = $85,000Median = $85,000Median = $85,000Median = $85,000Median = $85,000Median = $85,000Median = $85,000Median = $85,000Median = $85,000Median = $85,000Median = $85,000Median = $85,000Median = $85,000Median = $85,000Median = $85,000Median = $85,000Median = $85,000Median = $85,000Median = $85,000Median = $85,000Median = $85,000Median = $85,000Median = $85,000Median = $85,000Median = $85,000Median = $85,000Median = $85,000Median = $85,000Median = $85,000Median = $85,000Median = $85,000Median = $85,000Median = $85,000Median = $85,000Median = $85,000Median = $85,000Median = $85,000Median = $85,000Median = $85,000Median = $85,000Median = $85,000Median = $85,000Median = $85,000Median = $85,000Median = $85,000Median = $85,000Median = $85,000Median = $85,000Median = $85,000Median = $85,000Median = $85,000Median = $85,000Median = $85,000Median = $85,000Median = $85,000Median = $85,000Median = $85,000Median = $85,000Median = $85,000Median = $85,000Median = $85,000Median = $85,000Median = $85,000Median = $85,000Median = $85,000Median = $85,000Median = $85,000Median = $85,000Median = $85,000Median = $85,000Median = $85,000Median = $85,000Median = $85,000Median = $85,000Median = $85,000Median = $85,000Median = $85,000Median = $85,000Median = $85,000Median = $85,000Median = $85,000Median = $85,000Median = $85,000Median = $85,000Median = $85,000Median = $85,000Median = $85,000Median = $85,000Median = $85,000Median = $85,000Median = $85,000Median = $85,000Median = $85,000Median = $85,000Median = $85,000Median = $85,000Median = $85,000Median = $85,000Median = $85,000Median = $85,000Median = $85,000Median = $85,000Median = $85,000Median = $85,000Median = $85,000Median = $85,000Median = $85,000Median = $85,000Median = $85,000Median = $85,000Median = $85,000Median = $85,000Median = $85,000Median = $85,000Median = $85,000Median = $85,000Median = $85,000Median = $85,000Median = $85,000Median = $85,000Median = $85,000Median = $85,000Median = $85,000Median = $85,000Median = $85,000Median = $85,000Median = $85,000Median = $85,000Median = $85,000Median = $85,000Median = $85,000Median = $85,000Median = $85,000Median = $85,000Median = $85,000Median = $85,000Median = $85,000Median = $85,000Median = $85,000Median = $85,000Median = $85,000Median = $85,000Median = $85,000Median = $85,000Median = $85,000Median = $85,000Median = $85,000Median = $85,000Median = $85,000Median = $85,000Median = $85,000Median = $85,000Median = $85,000Median = $85,000Median = $85,000Median = $85,000Median = $85,000Median = $85,000Median = $85,000Median = $85,000Median = $85,000Median = $85,000Median = $85,000Median = $85,000Median = $85,000Median = $85,000Median = $85,000Median = $85,000Median = $85,000Median = $85,000Median = $85,000Median = $85,000Median = $85,000Median = $85,000Median = $85,000Median = $85,000Median = $85,000Median = $85,000Median = $85,000Median = $85,000Median = $85,000Median = $85,000Median = $85,000Median = $85,000Median = $85,000Median = $85,000Median = $85,000Median = $85,000Median = $85,000Median = $85,000Median = $85,000Median = $85,000Median = $85,000Median = $85,000Median = $85,000Median = $85,000Median = $85,000Median = $85,000Median = $85,000Median = $85,000Median = $85,000Median = $85,000Median = $85,000Median = $85,000Median = $85,000Median = $85,000Median = $85,000Median = $85,000Median = $85,000Median = $85,000Median = $85,000Median = $85,000Median = $85,000Median = $85,000Median = $85,000Median = $85,000Median = $85,000Median = $85,000Median = $85,000Median = $85,000Median = $85,000Median = $85,000Median = $85,000Median = $85,000Median = $85,000Median = $85,000Median = $85,000Median = $85,000Median = $85,000Median = $85,000Median = $85,000Median = $85,000Median = $85,000Median = $85,000Median = $85,000Median = $85,000Median = $85,000Median = $85,000Median = $85,000Median = $85,000Median = $85,000Median = $85,000Median = $85,000Median = $85,000Median = $85,000Median = $85,000Median = $85,000Median = $85,000Median = $85,000Median = $85,000Median = $85,000Median = $85,000Median = $85,000Median = $85,000Median = $85,000Median = $85,000Median = $85,000Median = $85,000Median = $85,000Median = $85,000Median = $85,000Median = $85,000Median = $85,000Median = $85,000Median = $85,000Median = $85,000Median = $85,000Median = $85,000Median = $85,000Median = $85,000Median = $85,000Median = $85,000Median = $85,000Median = $85,000Median = $85,000Median = $85,000Median = $85,000Median = $85,000Median = $85,000Median = $85,000Median = $85,000Median = $85,000Median = $85,000Median = $85,000Median = $85,000Median = $85,000Median = $85,000Median = $85,000Median = $85,000Median = $85,000Median = $85,000Median = $85,000Median = $85,000Median = $85,000Median = $85,000Median = $85,000Median = $85,000Median = $85,000Median = $85,000Median = $85,000Median = $85,000Median = $85,000Median = $85,000Median = $85,000Median = $85,000Median = $85,000Median = $85,000Median = $85,000Median = $85,000Median = $85,000Median = $85,000Median = $85,000Median = $85,000Median = $85,000Median = $85,000Median = $85,000Median = $85,000Median = $85,000Median = $85,000Median = $85,000Median = $85,000Median = $85,000Median = $85,000Median = $85,000Median = $85,000Median = $85,000Median = $85,000Median = $85,000Median = $85,000Median = $85,000Median = $85,000Median = $85,000Median = $85,000Median = $85,000Median = $85,000Median = $85,000Median = $85,000Median = $85,000Median = $85,000Median = $85,000Median = $85,000Median = $85,000Median = $85,000Median = $85,000Median = $85,000Median = $85,000Median = $85,000Median = $85,000Median = $85,000Median = $85,000Median = $85,000Median = $85,000Median = $85,000Median = $85,000Median = $85,000Median = $85,000Median = $85,000Median = $85,000Median = $85,000Median = $85,000Median = $85,000Median = $85,000Median = $85,000Median = $85,000Median = $85,000Median = $85,000Median = $85,000Median = $85,000Median = $85,000Median = $85,000Median = $85,000Median = $85,000Median = $85,000Median = $85,000Median = $85,000Median = $85,000Median = $85,000Median = $85,000Median = $85,000Median = $85,000Median = $85,000Median = $85,000Median = $85,000Median = $85,000Median = $85,000Median = $85,000Median = $85,000Median = $85,000Median = $85,000Median = $85,000Median = $85,000Median = $85,000Median = $85,000Median = $85,000Median = $85,000Median = $85,000Median = $85,000Median = $85,000Median = $85,000Median = $85,000Median = $85,000Median = $85,000Median = $85,000Median = $85,000Median = $85,000Median = $85,000Median = $85,000Median = $85,000Median = $85,000Median = $85,000Median = $85,000Median = $85,000Median = $85,000Median = $85,000Median = $85,000Median = $85,000Median = $85,000Median = $85,000Median = $85,000Median = $85,000Median = $85,000Median = $85,000Median = $85,000Median = $85,000Median = $85,000Median = $85,000Median = $85,000Median = $85,000Median = $85,000Median = $85,000Median = $85,000Median = $85,000Median = $85,000Median = $85,000Median = $85,000Median = $85,000Median = $85,000Median = $85,000Median = $85,000Median = $85,000Median = $85,000Median = $85,000Median = $85,000Median = $85,000Median = $85,000Median = $85,000Median = $85,000Median = $85,000Median = $85,000Median = $85,000Median = $85,000Median = $85,000Median = $85,000Median = $85,000Median = $85,000Median = $85,000Median = $85,000
0
20
40
60
80
$0 $100,000 $200,000 $300,000 $400,000 $500,000
Respondent Household Income
Number
of
Resp.
By Household Income (850 Total; scale truncated at $500,000)
Number of Respondents Working in Santa Monica, Living Elsewhere
6
8.A.g
Packet Pg. 211 Attachment: Attachment G - Mobility and Housing Survey Summary Results (4433 : Council Direction on Draft Concepts and Framework for
Q7 Which race/ethnicity best describes you? (Please choose only one.)
2
109
107
275
5
40
52
317
American Indian or
Alaskan Native
Native Hawaiian or
other Pacific Islander
Other
Prefer not to answer
Black, non-Hispanic
Asian
Hispanic / Latino
White, non-Hispanic
0 100 200 300
Number of Respondents
By Race/Ethnicity (907 Total)
Respondents Working in Santa Monica, Living Elsewhere
7
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Packet Pg. 212 Attachment: Attachment G - Mobility and Housing Survey Summary Results (4433 : Council Direction on Draft Concepts and Framework for
Q8 How many working motorized vehicles do you have access to in your house-
hold today?
46
437
342
84
0
1
2
3+
0 100 200 300 400
Number of Respondents
By Household Vehicles (909 Total)
Respondents Working in Santa Monica, Living Elsewhere
8
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Packet Pg. 213 Attachment: Attachment G - Mobility and Housing Survey Summary Results (4433 : Council Direction on Draft Concepts and Framework for
Q9 Has the number of working vehicles you have access to changed during the
pandemic?
788
89
31
No, the same
Yes, Fewer
Yes, More
0 200 400 600 800
Number of Respondents
By Household Vehicle Change During Pandemic (908 Total)
Respondents Working in Santa Monica, Living Elsewhere
9
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Packet Pg. 214 Attachment: Attachment G - Mobility and Housing Survey Summary Results (4433 : Council Direction on Draft Concepts and Framework for
Q10 How many people (including yourself) are staying or living in your house-
hold?
203
303
184
125
58
29
1
2
3
4
5
6+
0 100 200 300
Number of Respondents
By Household Size (902 Total)
Respondents Working in Santa Monica, Living Elsewhere
10
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Packet Pg. 215 Attachment: Attachment G - Mobility and Housing Survey Summary Results (4433 : Council Direction on Draft Concepts and Framework for
Q11 Do you rent or own the place where you live?
21
307
581
Neither
Own
Rent
0 200 400 600
Number of Respondents
By Household Tenure (909 Total)
Respondents Working in Santa Monica, Living Elsewhere
11
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Packet Pg. 216 Attachment: Attachment G - Mobility and Housing Survey Summary Results (4433 : Council Direction on Draft Concepts and Framework for
Q12 How many bedrooms are in your home?
229
325
303
50Studio
1 bedroom
2 bedroom
3 + bedroom
0 100 200 300
Number of Respondents
By Bedrooms in Housing Unit (907 Total)
Respondents Working in Santa Monica, Living Elsewhere
12
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Packet Pg. 217 Attachment: Attachment G - Mobility and Housing Survey Summary Results (4433 : Council Direction on Draft Concepts and Framework for
Q13 What is your monthly rent/mortgage?
Median = $1,900Median = $1,900Median = $1,900Median = $1,900Median = $1,900Median = $1,900Median = $1,900Median = $1,900Median = $1,900Median = $1,900Median = $1,900Median = $1,900Median = $1,900Median = $1,900Median = $1,900Median = $1,900Median = $1,900Median = $1,900Median = $1,900Median = $1,900Median = $1,900Median = $1,900Median = $1,900Median = $1,900Median = $1,900Median = $1,900Median = $1,900Median = $1,900Median = $1,900Median = $1,900Median = $1,900Median = $1,900Median = $1,900Median = $1,900Median = $1,900Median = $1,900Median = $1,900Median = $1,900Median = $1,900Median = $1,900Median = $1,900Median = $1,900Median = $1,900Median = $1,900Median = $1,900Median = $1,900Median = $1,900Median = $1,900Median = $1,900Median = $1,900Median = $1,900Median = $1,900Median = $1,900Median = $1,900Median = $1,900Median = $1,900Median = $1,900Median = $1,900Median = $1,900Median = $1,900Median = $1,900Median = $1,900Median = $1,900Median = $1,900Median = $1,900Median = $1,900Median = 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$1,900Median = $1,900Median = $1,900Median = $1,900Median = $1,900Median = $1,900Median = $1,900Median = $1,900Median = $1,900Median = $1,900Median = $1,900Median = $1,900Median = $1,900Median = $1,900Median = $1,900Median = $1,900Median = $1,900Median = $1,900Median = $1,900Median = $1,900Median = $1,900Median = $1,900Median = $1,900Median = $1,900Median = $1,900Median = $1,900Median = $1,900Median = $1,900Median = $1,900Median = $1,900Median = $1,900Median = $1,900Median = $1,900Median = $1,900Median = $1,900Median = $1,900Median = $1,900Median = $1,900Median = $1,900Median = $1,900Median = $1,900Median = $1,900Median = $1,900Median = $1,900Median = $1,900Median = $1,900Median = $1,900Median = $1,900Median = $1,900Median = $1,900Median = $1,900Median = $1,900Median = $1,900Median = $1,900Median = $1,900Median = $1,900Median = $1,900Median = $1,900Median = $1,900Median = $1,900Median = $1,900Median = $1,900Median = $1,900Median = $1,900Median = $1,900Median = $1,900Median = $1,900Median = $1,900Median = $1,900Median = $1,900Median = $1,900Median = $1,900Median = $1,900Median = $1,900Median = $1,900Median = $1,900Median = $1,900Median = $1,900Median = $1,900Median = $1,900Median = $1,900Median = $1,900Median = $1,900Median = $1,900Median = $1,900Median = $1,900Median = $1,900Median = $1,900Median = $1,900Median = $1,900Median = $1,900Median = $1,900Median = $1,900Median = $1,900Median = $1,900Median = $1,900Median = $1,900Median = $1,900Median = $1,900Median = $1,900Median = $1,900Median = $1,900Median = $1,900Median = $1,900Median = $1,900Median = $1,900Median = $1,900Median = $1,900Median = $1,900Median = $1,900Median = $1,900Median = $1,900Median = $1,900Median = $1,900Median = $1,900Median = $1,900Median = $1,900Median = $1,900Median = $1,900Median = $1,900Median = $1,900Median = $1,900Median = $1,900Median = $1,900Median = $1,900Median = $1,900Median = $1,900Median = $1,900Median = $1,900Median = $1,900Median = $1,900Median = $1,900Median = $1,900Median = $1,900Median = $1,900Median = $1,900Median = $1,900Median = $1,900Median = $1,900Median = $1,900Median = $1,900Median = $1,900Median = $1,900Median = $1,900Median = $1,900Median = $1,900Median = $1,900Median = $1,900Median = $1,900Median = $1,900Median = $1,900Median = $1,900Median = $1,900Median = $1,900Median = $1,900Median = $1,900Median = $1,900Median = $1,900Median = $1,900Median = $1,900Median = $1,900Median = $1,900Median = $1,900Median = $1,900Median = $1,900Median = $1,900Median = $1,900Median = $1,900Median = $1,900Median = $1,900Median = $1,900Median = $1,900Median = $1,900Median = $1,900Median = $1,900Median = $1,900Median = $1,900Median = $1,900Median = $1,900Median = $1,900Median = $1,900Median = $1,900Median = $1,900Median = $1,900Median = $1,900Median = $1,900Median = $1,900Median = $1,900Median = $1,900Median = $1,900Median = $1,900Median = $1,900Median = $1,900Median = $1,900Median = $1,900Median = $1,900Median = $1,900Median = $1,900Median = $1,900Median = $1,900Median = $1,900Median = $1,900Median = $1,900Median = $1,900Median = $1,900Median = $1,900Median = $1,900Median = $1,900Median = $1,900Median = $1,900Median = $1,900Median = $1,900Median = $1,900Median = $1,900Median = $1,900Median = $1,900Median = $1,900Median = $1,900Median = $1,900Median = $1,900Median = $1,900Median = $1,900Median = $1,900Median = $1,900Median = $1,900Median = $1,900Median = $1,900Median = $1,900Median = $1,900Median = $1,900Median = $1,900Median = $1,900Median = $1,900Median = $1,900Median = $1,900Median = $1,900Median = $1,900Median = $1,900Median = $1,900Median = $1,900Median = $1,900Median = $1,900Median = $1,900Median = $1,900Median = $1,900Median = $1,900Median = $1,900Median = $1,900Median = $1,900Median = $1,900Median = $1,900Median = $1,900Median = $1,900Median = $1,900Median = $1,900Median = $1,900Median = $1,900Median = $1,900Median = $1,900Median = $1,900Median = $1,900Median = $1,900Median = $1,900Median = $1,900Median = 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$1,900Median = $1,900Median = $1,900Median = $1,900Median = $1,900Median = $1,900Median = $1,900Median = $1,900Median = $1,900Median = $1,900Median = $1,900Median = $1,900Median = $1,900Median = $1,900Median = $1,900Median = $1,900Median = $1,900Median = $1,900Median = $1,900Median = $1,900Median = $1,900Median = $1,900Median = $1,900Median = $1,900Median = $1,900Median = $1,900Median = $1,900Median = $1,900Median = $1,900Median = $1,900Median = $1,900Median = $1,900Median = $1,900Median = $1,900Median = $1,900Median = $1,900Median = $1,900Median = $1,900Median = $1,900Median = $1,900Median = $1,900Median = $1,900Median = $1,900Median = $1,900Median = $1,900Median = $1,900Median = $1,900Median = $1,900Median = $1,900Median = $1,900Median = $1,900Median = $1,900Median = $1,900Median = $1,900Median = $1,900Median = $1,900Median = $1,900Median = $1,900Median = $1,900Median = $1,900Median = $1,900Median = $1,900Median = $1,900Median = $1,900Median = $1,900Median = $1,900Median = 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$1,900Median = $1,900Median = $1,900Median = $1,900Median = $1,900Median = $1,900Median = $1,900Median = $1,900Median = $1,900Median = $1,900Median = $1,900Median = $1,900Median = $1,900Median = $1,900Median = $1,900Median = $1,900Median = $1,900Median = $1,900Median = $1,900Median = $1,900Median = $1,900Median = $1,900Median = $1,900Median = $1,900Median = $1,900Median = $1,900Median = $1,900Median = $1,900Median = $1,900Median = $1,900Median = $1,900Median = $1,900Median = $1,900Median = $1,900Median = $1,900Median = $1,900Median = $1,900Median = $1,900Median = $1,900Median = $1,900Median = $1,900Median = $1,900Median = $1,900Median = $1,900Median = $1,900Median = $1,900Median = $1,900Median = $1,900Median = $1,900Median = $1,900Median = $1,900Median = $1,900Median = $1,900Median = $1,900Median = $1,900Median = $1,900Median = $1,900Median = $1,900Median = $1,900Median = $1,900Median = $1,900Median = $1,900Median = $1,900Median = $1,900Median = $1,900Median = $1,900Median = $1,900Median = $1,900Median = $1,900Median = $1,900Median = $1,900Median = $1,900
0
25
50
75
100
$0 $2,000 $4,000 $6,000 $8,000
Respondent Monthly Rent or Mortgage
Number of
Respondents
By Monthly Rent or Mortage (864 Total)
Respondents Working in Santa Monica and Living Elsewhere
13
8.A.g
Packet Pg. 218 Attachment: Attachment G - Mobility and Housing Survey Summary Results (4433 : Council Direction on Draft Concepts and Framework for
Q14 Prior to the stay at home orders taking place in March 2020, what was the
predominant (3 times a week or more) mode you used to get to work?
26
40
658
5
5
2
146
6
Telework
Other
Ridehail/Taxi
Walk
Bike
Carpool
Transit
Drive Solo
0 200 400 600
Number of Respondents
By Pre-Pandemic Commute Mode (888 Total)
Respondents Working in Santa Monica, Living Elsewhere
14
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Packet Pg. 219 Attachment: Attachment G - Mobility and Housing Survey Summary Results (4433 : Council Direction on Draft Concepts and Framework for
Q15 Prior to the stay at home orders taking place in March 2020, how many
days a week did you telework?
679
63
32
116
0
1 to 2
3 to 4
5+
0 200 400 600
Number of Respondents
By Number of Days Teleworking Pre-Pandemic (890 Total)
Respondents Working in Santa Monica, Living Elsewhere
15
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Packet Pg. 220 Attachment: Attachment G - Mobility and Housing Survey Summary Results (4433 : Council Direction on Draft Concepts and Framework for
Q16 During the COVID-19 pandemic, starting in March 2020, what is the pre-
dominant (3 times a week or more) mode you have used to get to work?
11
12
380
30
5
373
46
4Walk
Ridehail/Taxi
Bike
Carpool
Other
Transit
Telework
Drive Solo
0 100 200 300 400
Number of Respondents
By Commute Mode During Pandemic (861 Total)
Respondents Working in Santa Monica, Living Elsewhere
16
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Packet Pg. 221 Attachment: Attachment G - Mobility and Housing Survey Summary Results (4433 : Council Direction on Draft Concepts and Framework for
Q17 During the COVID-19 pandemic, starting in March 2020, how many days
a week have you teleworked?
222
77
133
453
0
1 to 2
3 to 4
5+
0 100 200 300 400
Number of Respondents
By Number of Days Teleworking During the Pandemic (885 Total)
Respondents Working in Santa Monica, Living Elsewhere
17
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Packet Pg. 222 Attachment: Attachment G - Mobility and Housing Survey Summary Results (4433 : Council Direction on Draft Concepts and Framework for
Q18 Thinking ahead a year, if the pandemic is fully under control, what is the
predominant (3 times a week or more) mode you expect to use to get to work?
32
36
622
28
4
30
129
2Walk
Ridehail/Taxi
Other
Telework
Bike
Carpool
Transit
Drive Solo
0 200 400 600
Number of Respondents
By Commute Mode Post-Pandemic (883 Total)
Respondents Working in Santa Monica, Living Elsewhere
Q19 Thinking ahead a year, if the pandemic is fully under control, how many
days per week will you telework?
18
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Packet Pg. 223 Attachment: Attachment G - Mobility and Housing Survey Summary Results (4433 : Council Direction on Draft Concepts and Framework for
487
179
105
103
0
1 to 2
3 to 4
5+
0 100 200 300 400 500
Number of Respondents
By Number of Days Teleworking Post-Pandemic (885 Total)
Respondents Working in Santa Monica, Living Elsewhere
19
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Packet Pg. 224 Attachment: Attachment G - Mobility and Housing Survey Summary Results (4433 : Council Direction on Draft Concepts and Framework for
Q20 What are the main reasons why you do not live and work in the same city?
Check all that apply.
56
38
29
758
120
30
20
14
61
26
55
Prefer to rent
apartment
Prefer to rent
single family home
Home does not have
sufficient bedrooms
Schools
Prefer to own
condo
Proximity to
partner...s work
Prefer to live in
a different City
Proximity to
family
Low quality of
housing available
Prefer to own
single family home
Housing cost
too high
0 200 400 600 800
Number of Respondents
By Reason for not Living in Santa Monica (832 Total; Multiple Responses)
Respondents Working in Santa Monica, Living Elsewhere
20
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Packet Pg. 225 Attachment: Attachment G - Mobility and Housing Survey Summary Results (4433 : Council Direction on Draft Concepts and Framework for
Q21 How important is homeownership to you on a scale of 1 to 5? With 1 being
not important and 5 being the most important.
44
22
142
150
520
1
2
3
4
5
0 200 400
Number of Respondents
By Importance of Home Ownership (878 Total, '5' Most Important)
Respondents Working in Santa Monica, Living Elsewhere
21
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Packet Pg. 226 Attachment: Attachment G - Mobility and Housing Survey Summary Results (4433 : Council Direction on Draft Concepts and Framework for
Q22 How much more would you be willing to spend on housing per month (either
rent or own) if it reduced your commute time?
Median = $300Median = $300Median = $300Median = $300Median = $300Median = $300Median = $300Median = $300Median = $300Median = $300Median = $300Median = $300Median = $300Median = $300Median = $300Median = $300Median = $300Median = $300Median = $300Median = $300Median = $300Median = $300Median = $300Median = $300Median = $300Median = $300Median = $300Median = $300Median = $300Median = $300Median = $300Median = $300Median = $300Median = $300Median = $300Median = $300Median = $300Median = $300Median = $300Median = $300Median = $300Median = $300Median = $300Median = $300Median = $300Median = $300Median = $300Median = $300Median = $300Median = $300Median = $300Median = $300Median = $300Median = $300Median = $300Median = $300Median = $300Median = $300Median = $300Median = $300Median = $300Median = $300Median = $300Median = $300Median = $300Median = $300Median = $300Median = $300Median = $300Median = $300Median = $300Median = $300Median = $300Median = $300Median = $300Median = $300Median = $300Median = $300Median = $300Median = $300Median = $300Median = $300Median = $300Median = $300Median = $300Median = $300Median = $300Median = $300Median = $300Median = $300Median = $300Median = $300Median = $300Median = $300Median = $300Median = $300Median = $300Median = $300Median = $300Median = $300Median = $300Median = $300Median = $300Median = $300Median = $300Median = $300Median = $300Median = $300Median = $300Median = $300Median = $300Median = $300Median = $300Median = $300Median = $300Median = $300Median = $300Median = $300Median = $300Median = $300Median = $300Median = $300Median = $300Median = $300Median = $300Median = $300Median = $300Median = $300Median = $300Median = $300Median = $300Median = $300Median = $300Median = $300Median = $300Median = $300Median = $300Median = $300Median = $300Median = $300Median = $300Median = $300Median = $300Median = $300Median = $300Median = $300Median = $300Median = $300Median = $300Median = $300Median = $300Median = $300Median = $300Median = 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$300Median = $300Median = $300Median = $300Median = $300Median = $300Median = $300Median = $300Median = $300Median = $300Median = $300Median = $300Median = $300Median = $300Median = $300Median = $300Median = $300Median = $300Median = $300Median = $300Median = $300Median = $300Median = $300Median = $300Median = $300Median = $300Median = $300Median = $300Median = $300Median = $300Median = $300Median = $300Median = $300Median = $300Median = $300Median = $300Median = $300Median = $300Median = $300Median = $300Median = $300Median = $300Median = $300Median = $300Median = $300Median = $300Median = $300Median = $300Median = $300Median = $300Median = $300Median = $300Median = $300Median = $300Median = $300Median = $300Median = $300Median = $300Median = $300Median = $300Median = $300Median = $300Median = $300Median = $300Median = $300Median = $300Median = $300Median = $300Median = $300Median = $300Median = $300Median = $300Median = $300Median = $300Median = $300Median = $300Median = $300Median = $300Median = $300Median = $300Median = $300Median = $300Median = $300Median = $300Median = $300Median = $300Median = $300Median = $300Median = $300Median = $300Median = $300Median = $300Median = $300Median = $300Median = $300Median = $300Median = $300Median = $300Median = $300Median = $300Median = $300Median = $300Median = $300Median = $300Median = $300Median = $300Median = $300Median = $300Median = $300Median = $300Median = $300Median = $300Median = $300Median = $300Median = $300Median = $300Median = $300Median = $300Median = $300Median = $300Median = $300Median = $300Median = $300Median = $300Median = $300Median = $300Median = $300Median = $300Median = $300Median = $300Median = $300Median = $300Median = $300Median = $300Median = $300Median = $300Median = $300Median = $300Median = $300Median = $300Median = $300Median = $300Median = $300Median = $300Median = $300Median = $300Median = $300Median = $300Median = $300Median = $300Median = $300Median = $300Median = $300Median = $300Median = $300Median = $300Median = $300Median = $300Median = $300Median = $300Median = $300Median = $300Median = $300Median = $300Median = $300Median = $300Median = $300Median = $300Median = $300Median = $300Median = $300Median = $300Median = $300Median = $300Median = $300Median = $300Median = $300Median = $300Median = $300Median = $300Median = $300Median = $300Median = $300Median = $300Median = $300Median = $300Median = $300Median = $300Median = $300Median = $300Median = $300Median = $300Median = $300Median = $300Median = $300Median = $300Median = $300Median = $300Median = $300Median = $300Median = $300Median = $300Median = $300Median = $300Median = $300Median = $300Median = $300Median = $300Median = $300Median = $300Median = $300Median = $300Median = $300Median = $300Median = $300Median = $300Median = $300Median = $300Median = $300Median = $300Median = $300Median = $300Median = $300Median = $300Median = $300Median = $300Median = $300Median = $300Median = $300Median = $300Median = $300Median = $300Median = $300Median = $300Median = $300Median = $300Median = $300Median = $300Median = $300Median = $300Median = $300Median = $300Median = $300Median = $300Median = $300Median = $300Median = $300Median = $300Median = $300Median = $300Median = $300Median = $300Median = $300Median = $300Median = $300Median = $300Median = $300Median = $300Median = $300Median = $300Median = $300Median = $300Median = $300Median = $300Median = $300Median = $300Median = $300Median = $300Median = $300Median = $300Median = $300Median = $300Median = $300Median = $300Median = $300Median = $300Median = $300Median = $300Median = $300Median = $300Median = $300Median = $300Median = $300Median = $300Median = $300Median = $300Median = $300Median = $300Median = $300Median = $300Median = $300Median = $300Median = $300Median = $300Median = $300Median = $300Median = $300Median = $300Median = $300Median = $300Median = $300Median = $300Median = $300Median = $300Median = $300Median = $300Median = $300Median = $300Median = $300Median = $300Median = $300Median = $300Median = $300Median = $300Median = $300Median = $300Median = $300Median = $300Median = $300Median = $300Median = $300Median = $300Median = $300Median = $300Median = $300Median = $300Median = $300Median = $300Median = $300Median = $300Median = $300Median = $300Median = $300Median = $300Median = $300Median = $300Median = $300Median = $300Median = $300Median = $300Median = $300Median = $300Median = $300Median = $300Median = $300Median = $300Median = $300Median = $300Median = $300Median = $300Median = $300Median = $300Median = $300Median = $300Median = $300Median = $300Median = $300Median = $300Median = $300Median = $300Median = $300Median = $300Median = $300Median = $300Median = $300Median = $300Median = $300Median = $300Median = $300Median = $300Median = $300Median = $300Median = $300Median = $300Median = $300Median = $300Median = $300Median = $300Median = $300Median = $300Median = $300Median = $300Median = $300Median = $300Median = $300Median = $300Median = $300Median = $300Median = $300Median = $300Median = $300Median = $300Median = $300Median = $300Median = $300Median = $300Median = $300Median = $300Median = $300Median = $300Median = $300Median = $300Median = $300Median = $300Median = $300Median = $300Median = $300Median = $300Median = $300Median = $300Median = $300Median = $300Median = $300Median = $300Median = $300Median = $300Median = $300Median = $300Median = $300Median = $300Median = $300Median = $300Median = $300Median = $300Median = $300Median = $300Median = $300Median = $300Median = $300Median = $300Median = $300Median = $300Median = $300Median = $300Median = $300Median = $300Median = $300Median = $300Median = $300Median = $300Median = $300Median = $300Median = $300Median = $300Median = $300Median = $300Median = $300Median = $300Median = $300Median = $300Median = $300Median = $300Median = $300Median = $300Median = $300Median = $300Median = $300Median = $300Median = $300Median = $300Median = $300Median = $300Median = $300Median = $300Median = $300Median = $300Median = $300Median = $300Median = $300Median = $300Median = $300Median = $300Median = $300Median = $300Median = $300Median = $300Median = $300Median = $300Median = $300Median = $300Median = $300Median = $300Median = $300Median = $300Median = $300Median = $300Median = $300Median = $300Median = $300Median = $300Median = $300Median = $300Median = $300Median = $300
0
100
200
$0 $1,000 $2,000 $3,000 $4,000
Respondent Addititional Monthly Rent or Mortgage
By Additional Monthly Rent or Mortage Willing to Pay for Shorter Commute (801 Total)
Number of Respondents Working in Santa Monica and Living Elsewhere
22
8.A.g
Packet Pg. 227 Attachment: Attachment G - Mobility and Housing Survey Summary Results (4433 : Council Direction on Draft Concepts and Framework for
Q23 Would you be willing to downsize your home if it reduced your commute
time?
542
337
No
Yes
0 200 400
Number of Respondents
By Willingness to Downsize Home for Shorter Commute (879 Total)
Respondents Working in Santa Monica, Living Elsewhere
23
8.A.g
Packet Pg. 228 Attachment: Attachment G - Mobility and Housing Survey Summary Results (4433 : Council Direction on Draft Concepts and Framework for
Q24 If you did move, what is the smallest home you would consider?
111
150
40
40Studio
1 bedroom
2 bedroom
3+ bedroom
0 50 100 150
Number of Respondents
By Smallest Housing Unit Would Consider (341 Total)
Respondents Working in Santa Monica, Living Elsewhere
24
8.A.g
Packet Pg. 229 Attachment: Attachment G - Mobility and Housing Survey Summary Results (4433 : Council Direction on Draft Concepts and Framework for
Q25 Based on the previous question, what is the minimum number of parking
spaces you would need?
19
170
144
0
1
2
0 50 100 150
Number of Respondents
By Minimum Parking Spaces Needed (333 Total)
Respondents Working in Santa Monica, Living Elsewhere
25
8.A.g
Packet Pg. 230 Attachment: Attachment G - Mobility and Housing Survey Summary Results (4433 : Council Direction on Draft Concepts and Framework for
Summary of Planning Commission Recommendations on Housing Element
Update Draft Concepts
March 17, 2021
The Planning Commission held meetings on the Housing Element Update Draft
Concepts on March 16 and 17, 2021. The following presents a summary of the
Commissions’ recommendations on the Housing Element Update draft concepts.
Where Housing Should be Located
The Commission recommended elements of Options A and B as a preferred locational
strategy. It should be noted that one Commissioner did not agree that Option B is
appropriate due to lack of proximity to daily services and transit. Consistent with the
adopted LUCE, the Commission supported housing on the commercial boulevards and
near the Expo Light Rail to continue to build complete neighborhoods. While most
commissioners sought to encourage transit-oriented housing that would reduce
dependency on automobiles and associated parking, Option C was seen as the least
consistent with equity concerns. In order to take steps towards addressing Santa
Monica’s past history of housing segregation, the Commission supported introducing
housing potential, particularly affordable housing, in areas that have historically not
accommodated housing, such as Montana Avenue, the Office Campus zone, and Main
Street, especially on city-owned properties such as surface parking lots. The
Commission also supported consideration for densifying R1 zone neighborhoods
including expanding the R2 zone into the R1 zone north of Montana while still ensuring
that the tranquility and character of existing single-unit dwelling neighborhoods could be
retained. The Commission sought to minimize displacement pressure on
neighborhoods at greater risk of Ellis evictions and/or conversion of deed-restricted
units, such as segments of Pico or Ocean Park as identified in the Existing Conditions
Report.
However, the Commission was not supportive of introducing housing potential in the
Industrial Conservation zone due to concerns about historic racial inequities associated
8.A.h
Packet Pg. 231 Attachment: Summary of Planning Commission Recommendations on Housing Element Update Draft Concepts Final (4433 : Council Direction
with the areas in the zone, existing overconcentration of affordable housing in proximity
to the area, and the need to ensure the City’s economic sustainability by retaining
former industrial properties for businesses to also locate in the IC zone. The
Commission was also not supportive of introducing housing potential on Ocean Park
Boulevard due to concerns about the potential for displacement of nearby rental
housing units. As a result, the Commission discussed potential consideration for
market-rate housing but not affordable housing in the IC zone.
Draft Four-Point Strategy for Affordable Housing
The Commission generally agreed with the conceptual four-point strategy for affordable
housing and emphasized the following points:
• Support for incentives for ADUs
• Agree with the draft proposal for affordable housing including a citywide
affordable housing overlay as a preferred approach to consolidate available
process and development standard incentives for affordable housing
o The zoning ordinance definition of “100% affordable housing project”
should be revised to include moderate-income housing up to 100% AMI
• Make permanent the administrative approval process for zoning-compliant
housing/mixed-use proposals
• Need for clear development program, similar to Los Angeles TOC program, that
includes policies for administrative waivers and concessions from development
standards to provide strong incentives for housing projects in order to incentivize
the production of more inclusionary housing units
o Ensure AHPP requirements do not discourage housing production;
consider reverting to AHPP requirement for 5% affordable housing for
30%-AMI households
o Consider flexibility for unit mix requirements to allow smaller units and
wider range of unit options particularly in Downtown and Bergamot
o Consider incentives to target housing at 100% AMI to 200% AMI not tied
to inclusionary housing and potentially only in Bergamot and Downtown
o Reduce requirements for ground-floor retail on commercial corridors
8.A.h
Packet Pg. 232 Attachment: Summary of Planning Commission Recommendations on Housing Element Update Draft Concepts Final (4433 : Council Direction
o Allow greater flexibility in the location of off-site inclusionary housing units
provided that it affirmatively furthers equitable distribution of affordable
housing throughout the city
• Reduce the cost of housing construction through consideration of revised
standards
o Eliminate minimum parking requirements for all housing
o Consider aligning the city’s current high-rise requirements with statewide
standards for structures outside seismic hazard areas
o Ensure the city’s building and safety requirements keep pace with
construction innovations, including engineered wood (also known as CLT
or mass timber) and pre-fabrication.
• Embark on an aggressive campaign to establish a permanent funding source to
finance affordable housing
There was one Commissioner who expressed doubt whether incentivizing inclusionary
housing would be an effective strategy to address housing affordability as it requires the
creation of more units of market-rate housing in order to produce proportionally fewer
units of inclusionary housing. As an overall strategy, the Commission also emphasized
that economic sustainability should be balanced with housing production as revenue-
producing uses are still necessary to be able to fund city services to support new
housing units.
Unique Properties: A-Lots, Religious Congregation Parking Lots, City properties
The Commission was supportive of increasing housing potential on vacant parking lots
associated with commercial uses and also on parking lots of religious congregations.
The Commission also recommended that Council should prioritize housing on City-
owned properties including dedicating 50% of the floor area for affordable housing in
future development projects. Similar to prior direction from Council, the Commission
supported further outreach to other institutional property owners (e.g. education,
healthcare) to ensure that they are also planning housing for their workforce.
8.A.h
Packet Pg. 233 Attachment: Summary of Planning Commission Recommendations on Housing Element Update Draft Concepts Final (4433 : Council Direction
Housing Stability
The Commission was supportive with the approach to expand housing preservation
programs where funding could be identified particularly in light of the number of
households at risk of eviction due to the effects of COVID-19. The Commission
expressed support for expanding the Preserving Our Diversity (POD) program to help
keep the most housing-insecure Santa Monicans in their homes. The Commission also
supported both stronger enforcement of housing discrimination law and expanded
incentives for landlords to take on homeless and extremely-low-income tenants, such as
partnerships like LACDA’s Homeless Incentive Program
(https://wwwb.lacda.org/section-8/homeless-programs/hip). Finally, the Commission
expressed strong support for accelerating the restoration of staff in the Housing Division
to be able to prioritize implementation of housing programs, including moving forward
with affordable housing loans on City-owned properties.
8.A.h
Packet Pg. 234 Attachment: Summary of Planning Commission Recommendations on Housing Element Update Draft Concepts Final (4433 : Council Direction
Pico
Neighborhood:
established 1904
for working
class (Irwin
Heights). Clay
pits attracted
new Mexican
immigrants. As African
Americans were pushed out
of other areas, they came
here too. Working class whites
fled to Sunset Park when FHA offered an affordable
way to move. The neighborhood became extremely
segregated. 1950 census: 1961 nonwhite people,
171 whites. Adjacent to industrial zone, cemetery,
garbage dumps. Fwy added next to industry,
removing homes instead.
This untinted area
was clay pits from
1904 until about
1950. When
clay was
exhausted
from pits
they became city dumps for
Santa Monica and Beverly
Hills. Trash was burned to
control rats.
Clay pits were
also smelly,
smoky and
noisy.
The green area was established
as the industrial zone for
“noxious uses” in 1912. After
1922 when we had our first
full zoning ordinance, it only
extended west as far as Lincoln
Blvd.
1 2
3
1. SM’s earliest mixed race area. Was at the edge of town by the railroad tracks and the city dump.
Designated “skid row” and eliminated in the 1950s, replaced with one-story commercial buildings.
2. Bandini Tract (Belmar Triangle). Evolved as second mixed race neighborhood after 1900, occupied
by poor whites and influx of new African Americans that came to Santa Monica. Was tucked up
against abandoned railroad land with trains passing along the north edge. Planning for the Civic
Center began in 1918, which kept it devalued. It was zoned commercial in 1922. Samohi took portions
of it in 1912 and in 1950s. The rest was finally taken for the Civic Center, also in the 1950s.
3. Phillips Chapel District. Mixed race area, mostly African American, grew up around church
established in 1909. In 1922 when the zoning ordinance was first created, residents here requested R1
zoning to preserve their property values but were refused. This neighborhood is still extant.
This area was redlined because
of mixed population including
Italians, Japanese, Mexican,
Portuguese and later, Jews,
in combination with the
proliferation of older housing
types, which were frowned
upon, and the extensive
Ocean Park amusement zone
adjacency.
The rest of this red area was
mostly working class and poor
whites until the 60s or 70s. Was
redlined because poor people
were also considered a bad
investment. Also, housing types
dating back to the late 19th
century remained here and were
frowned upon.
This area was
blue because
there was no
development
here before the
FHA program,
so it grew with
exceptional
compliance with
race restrictions,
and was
buffered from
the red zone by
yellow.
This area was yellow because even though there was a lot of deed restricted FHA activity, there was also multi-unit housing built to accommodate Douglas Aircraft workers in some sections. It was also yellow because it was adjacent to red zones, the airport, and another city dump at Marine Park.
The only non-whites living in blue or
yellow areas were live-in domestics
through at least the 1950 census.
Integration began in the 1960s but
didn’t really build noticeably until the
1980s. The city was about 96% white
during its first and second phases of
development. It dropped to 94% in
1950, which is likely what triggered
redevelopment programs focused on
“slum clearance.” In 1970, the city
was still 92% white.
Green zones had to be surrounded by
blue zones or parkland. Yellow and
red were bad influences that had to
be buffered against.
INTERPRETING THE SANTA MONICA HOLC MAP
Nina Fresco 2021
8.A.i
Packet Pg. 235 Attachment: Santa Monica HOLC Map (4433 : Council Direction on Draft Concepts and Framework for
Santa Monica Census Data
Year Total % Change #White %White
#Not
W or
AfAm
% Not W
or AfAm
#African
American % Af Am #Mex/Span
Californio % M S C #Japanese #Chinese
1880 417 – – 91% – – *15 *3.5% #*7 *1.5% *0 *13
+1890 1580 278.9% – – – – – – – – – –
1900 3,057 93.5% 2,958 96% – – 60 2% *290 *9.4% 7 32
1910 7,847 156.7% 7,589 96% – – 191 2% *399 *5% 66 20
1920 15,252 94.4% 14,866 97% – – 282 2% – – 80 20
%1930 37,146 143.5% 33,539 90% – – 750 2% 2307 5.4% 432 19
1940 53,500 44.9% 51,691 96% – – 1,265 2.4% – – 394 34
?1950 71,595 33.8% 67,955 94% 410 0.5% 3230 4.5% – – – –
1960 83,249 16.3% 78,122 93% 1,067 6% 4,060 5%
1970 88,289 6.1% 81,935 92% 2,136 7% 4,218 5%
1980 88,314 0% 75,676 85% 15,052 21% 3,594 4%
1990 86,905 –1.6% 72,116 82% 15,448 22% 3,973 5%
2000 84,084 –3.2% 60,482 71% 20,521 24.5% 3,081 4%
2010 89,736 6.7% 69,663 70% 16,547 18.4% 3,526 3.93%
Source: United States Census, (grey from secondary sources that used census records, not all subgroups accounted for)
* hand counted using enumeration sheets, probably a little low
# three of these labeled “Indian” and have Spanish surnames, either from Mexico, or refugees from mission era
+ actual 1890 census for Santa Monica lost in flood, and official data reports don’t include details on cities with populations below 2500
% 1930 is the only census year when “Mexican” was considered a race to be counted. This census was the basis for the HOLC maps
? 1950 census report also provides breakdown of non-whites by district
NB: Nationwide, African Americans have always comprised between 10% and 13% of population except in 1930 and 1940 when percentage dipped just below 10%
Compiled by Nina Fresco 2021
8.A.i
Packet Pg. 236 Attachment: Santa Monica HOLC Map (4433 : Council Direction on Draft Concepts and Framework for
1
Vernice Hankins
From:Mathew Millen <matmillen@msn.com>
Sent:Thursday, March 25, 2021 6:14 PM
To:councilmtgitems
Subject:Mlarch 30th item 8 e
Attachments:1629michigan.jpg; 1827 19th.jpg
EXTERNAL
With respect to attachment XX SB 35 Summary : I object to the Staff purely subjective statement on page 13
"Santa Monica has a successful track record of producing not only sufficient housing units but also projects
that are well‐designed, context sensitive, and livable for residents."
attached hereto is the Community Corp of SM low income housing project at 1629 Michigan Ave....it looks like
an Army barracks, the units are 3 bedrooms under 900 square feet. 7 people residing in 900 square feet is not
livable. There are only 4 parking spaces for four units causing parking problems in the neighborhood.
Another horribly designed building is 1827 19th St. CCSM built 4 projects of the same design in the Pico
Neigbhorhood... just a square box...
The elimination of parking requirements close to Expo lines is contrary to the survey that 92 % of people
working in SM would require a parking space at their residence.
Mathew Millen, Santa Monica
Item 8.A 03/30/21
1 of 121 Item 8.A 03/30/21
8.A.j
Packet Pg. 237 Attachment: Written Comments (4433 : Council Direction on Draft Concepts and Framework for Housing Element Update (90 min))
1
Vernice Hankins
From:Peter <pbosen@yahoo.com>
Sent:Saturday, March 27, 2021 12:35 PM
To:councilmtgitems
Subject:City Council Meeting: March 30, 2021 Agenda Item: 8.A
EXTERNAL
Regarding affordable housing mandate:
Santa Monica’s current housing goal: lifelong renting with no chance at home-ownership.
Santa Monica’s aim to build large amounts of affordable rental housing will condemn more families to
a lifetime of renting and dependence on the largess of the city.
Instead of affordable rental housing, the city should build affordable housing for purchase with income
restriction covenants. This will allow the less wealthy to achieve independence and escape from a
lifetime of dependency.
Furthermore, the proceeds of these sales can be used for the construction of additional affordable
housing for sale, and so on - thus turbocharging financing and rapidly accelerating construction.
Simply building ever more affordable housing for rent will condemn generations of lower income
residents to endless renting and hopelessness. Many city councilors own their own homes, why
shouldn’t everyone else in the city have a shot at the American dream?
I believe home ownership is a powerful source for good, both for the owner, who is protected from
eviction, and can build a safe retirement from growth in equity, and for the city, which will have longer
term residents who may be more committed to the place they live.
Yours sincerely,
Peter Boresen,
Santa Monica
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Vernice Hankins
From:Jake Berman <jake@fiftythree.studio>
Sent:Friday, March 26, 2021 6:01 PM
To:councilmtgitems
Subject:Comment: Item 8A
EXTERNAL
To the City Council:
I write as a concerned citizen who would like to settle down in Santa Monica, but who finds it difficult to do so. We will
be moving back to greater Los Angeles next year for my wife's job as a doctor at UCLA Hospital. I write to oppose the
staff report's conclusions, which is totally inadequate to the task of tackling the housing crisis.
In short, the City is planning to fail.
First: The City's new inclusionary zoning proposal is designed to reduce housing construction, not promote it.
The staff report says that they'll require large amounts of new rent‐controlled housing to be built with every new
apartment building ‐ up to 20%. This requirement is a trojan horse, because the requirement makes it much more
difficult to build new apartments. (The City's own analysis says that, too!) This is a feature, not a bug, and it
Second: The City is wrong to claim that single‐family zoning reform is infeasible.
The City planning report says that the City couldn't possibly allow rowhouses or apartment buildings in areas zoned R1
because the cost of land is too high to build affordable housing. This is a dodge. The City's RHNA quota doesn't just
require Santa Monica to build affordable housing ‐ it also requires the City to build 50% more market‐rate housing than
it does currently.
Moreover, the City's approach gets the math backwards: people build apartment buildings because the land is
valuable. If Santa Monica were to allow rowhouses or apartment buildings in R1 zones, the result would likely be similar
to what is occurring in Venice Beach: tearing down old, run‐down single‐family homes and replacing them with
rowhouses. Loosen the zoning to allow full‐size apartment buildings, and you would get full‐sized apartment buildings
on that land. Santa Monica is an extremely desirable area and there is no shortage of demand.
Third: The City staff report actually identifies correct ways of meeting the quota, but refuses to endorse the ideas.
The staff report actually identifies all three components of what a serious attempt to build new housing would look like.
First, you'd allow apartments on particular lots that the City has identified as development sites ‐ that is, Option A.
Second, you'd allow small apartment buildings and small lot subdivisions by right in all parts of the city, including in R1
zones ‐ that is, Option B. Third, you'd allow large apartment buildings within a half‐mile of Expo Line light rail stations ‐
that is, Option C. Doing all three gives Santa Monica a realistic chance of meeting its quota.
Santa Monica should adopt options A, B and C all at once, and upzone everything, with the exceptions of sites too close
to the 10 Freeway.
Fourth: The City should treat the RHNA target as a floor, not a ceiling.
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When surveying workers who lived elsewhere and worked in Santa Monica, "An overwhelming majority of respondents
reported housing cost (91%) as a barrier to living and working in Santa Monica." Simply put, the answer to solving the
housing crisis and promote green living is staring Santa Monica right in the face: to reduce pollution and traffic from
commuters, build as many houses in Santa Monica as the market will bear.
This is not a time for small solutions, and I encourage the Council to think big and to upzone all of the City.
Sincerely,
Jake Berman
‐‐
Jake Berman
Fifty‐Three Studio
www.lostsubways.com
jake@fiftythree.studio
twitter/IG: @lostsubways
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Vernice Hankins
From:Epstein HP <hpewriter@yahoo.com>
Sent:Friday, March 26, 2021 1:47 PM
To:councilmtgitems
Cc:Council Mailbox
Subject:8A on 3/30 agenda
EXTERNAL
In its voluminous report on how (not if) the City can meet the demand for nearly 9,000 more housing units, the staff
neglects a major consideration. Nowhere is there an analysis of whether the infrastructure‐‐schools, water supply,
roads, etc.‐‐can absorb the hugh number of new residents those proposed units will produce. Setting aside for the
moment the cost to the City of building or subsidizing those units, how about the cost to taxpayers of all the additional
services that would be needed? Where are those numbers? Why do we always get a one‐sided picture to support what
the staff wants to push, instead of a balanced look at an issue?
Harriet P. Epstein
Santa Monica resident
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Vernice Hankins
From:Matthew Stevens <mastevens0131@gmail.com>
Sent:Friday, March 26, 2021 12:26 PM
To:Sue Himmelrich; Councilmember Kevin McKeown; Gleam Davis; Kristin McCowan; Phil Brock;
Christine Parra; Oscar de la Torre
Cc:councilmtgitems
Subject:Item 8-A
EXTERNAL
Dear Santa Monica Councilmembers,
I superimposed the draft suitable sites inventory over a historic redlining map of Santa Monica. It's ... not good! Santa
Monica is a segregated city, and the draft suitable sites inventory does nothing to correct that. As has typically been the
case in Santa Monica, we're not requiring anything from our wealthiest, whitest neighborhoods.
Affirmatively Furthering Fair Housing is not optional. And ADUs alone ‐ which most single family homeowners just use
for guest houses or offices ‐ are not a legitimate solution. To better advance equity, we must make our wealthiest,
whitest neighborhoods like North of Montana and Sunset Park share more of Santa Monica's housing requirements. At a
minimum, we need to end exclusionary zoning like Berkeley did last night.
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Berkeley votes for historic housing change: an end to single‐family zoning
Mayor Himmelrich ‐ I hope you become a leader on this. North of Montana is your neighborhood and I don't think it's
fair that the Mayor's neighborhood gets excused from our RHNA obligations.
Regards,
Matt Stevens
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(310) 451-3669
March 26, 2021
VIA E-MAIL
Santa Monica City Council
1685 Main Street, Room 209
Santa Monica, CA 90401
Re: Agenda Item 8-A: Draft Concepts and Framework for Housing Element Update
Our Client: Santa Monica Housing Council
Our File No. 639.67
Dear Councilmembers:
This letter is submitted on behalf of the Santa Monica Housing Council, a non-
profit, all-volunteer organization that has been involved with Santa Monica housing
advocacy for more than 30 years and has recently been engaged in advocacy regarding
the City’s 6th Cycle Housing Element Update.
Based on our review of the materials for this agenda item, including the
Summary Report on Preliminary Suitable Sites Inventory Analysis (“Draft SSI Report”),
SMHC is concerned that the City is not following the legal requirements of State
Housing Element Law nor official guidance for the Housing Element Update issued by
the State Department of Housing and Community Development (“HCD”).
As discussed below, the Preliminary Suitable Site Inventory (“Preliminary SSI”)
includes many sites which are highly unlikely to be redeveloped into housing during the
Sixth Cycle, and thus, the capacity calculations set forth in the Staff Report and Draft
SSI Report are unsubstantiated and wildly unrealistic.
Overall, City Staff appears to suggest that the City can meet its RHNA target
without any changes to zoning, development standards, or the City’s inclusionary
housing program, and that the only challenge will be meeting its affordable unit targets.1
This is not the case.
1 See Staff Report, p. 43 (“A capacity analysis was conducted for the identified
SSI sites (except for Category 1 – approved/pending projects) using existing
development standards to gain an understanding of the outcomes from the parcel filters
kutcher@hlkklaw.com
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The Draft SSI Report claims that the City followed HCD guidelines in identifying
sites for the SSI,2 but the methodology described in the Report disregards the most
important aspects of HCD’s guidance and does not comply with the legal requirement
that capacity calculations must be demonstrable and realistic.3 Among other things, the
Preliminary SSI’s identification of sites as having “high potential” for redevelopment with
housing completely ignores the conclusions in the feasibility analysis (prepared by the
City’s economic consultant) that the City’s current inclusionary program (which requires
15% affordable for Tier 2 projects) renders housing redevelopment infeasible in almost
all cases.4 Indeed, as acknowledged elsewhere in the Staff Report: “Given that at least
60% of the sites identified in the preliminary sites analysis are located on the
Boulevards and NC, additional height and FAR would be necessary for residential
development to likely occur on these sites.”5 The truth is, significant changes to zoning,
development standards, and the City’s inclusionary housing program will be needed to
achieve the City’s total 8,895-unit RHNA allocation.
THE PRELIMINARY SSI’s RESIDENTIAL
CAPACITY PROJECTIONS ARE UNREALISTIC AND
INCONSISTENT WITH STATE LAW AND HCD GUIDANCE
The Draft SSI Report identifies 375 sites within the City as having “high potential”
for redevelopment with housing.6 The Report identifies an additional 99 sites with
and priority rankings. The analysis yielded a preliminary total of approximately 10,133
units. With the allowance to assume the production of 700 accessory dwelling units
(ADUs) during the Housing Element planning period, the preliminary analysis estimates
a land capacity buffer of 1,938 units. While the sites analysis identified sufficient land
area, the challenge is planning for the RHNA’s allocated 6,168 affordable units.”).
2 Draft SSI Report, p. 2 (“The methodology follows the guidance of the Housing
Element Site Inventory Guidebook prepared by the Housing and Community
Development Department (June 2020).”).
3 See Gov’t Code § 65583(a)(3) (“An inventory of land suitable and available for
residential development, including vacant sites and sites having realistic and
demonstrated potential for redevelopment during the planning period” [emphasis
added]).
4 See HR&A, City of Santa Monica Affordable Housing Production Program
2020-2021 Update, Preliminary Feasibility Modeling Results (Mar. 17, 2021), p. 24.
5 City Council Staff Report, p. 47.
6 Draft SSI Report, p. 7.
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“medium potential” for redevelopment.7 For the 99 “medium potential” sites, the Draft
SSI Report states that “changes to current zoning would likely be necessary to increase
the viability of housing.”8 However, the Report makes no mention of necessary zoning
changes and revisions to the City’s inclusionary housing program to facilitate housing
on the 375 “high potential” sites, nor the likelihood that many of these sites will remain in
their longstanding existing conditions, despite making the following unsubstantiated
statement: “Existing uses on the site[s] were assessed to determine its future viability
and likelihood for the uses to be discontinued.”9 The Draft SSI Report goes on to state
that “[t]he capacity analysis of the identified sites yielded 10,133 units.”10 With assumed
production of 700 new accessory dwelling units (ADUs),11 the Draft SSI Report purports
to identify enough capacity to exceed the City’s 8,895-unit RHNA allocation by almost
2,000 units without any changes to zoning.12 This is simply not credible.
SMHC challenges the notion that the City’s total RHNA allocation can be met or
exceeded under current zoning and development standards. As documented in the
feasibility analysis prepared by the City’s consultant, the City’s current inclusionary
program (which requires 15% affordable for Tier 2 projects) renders housing
redevelopment infeasible in almost all cases. Achieving (let alone exceeding) the City’s
total RHNA allocation will require meaningful upzoning for housing development as well
as the removal of other regulatory impediments to housing projects.
The problems with the City’s preliminary approach to the SSI are summarized
below.
7 Id. at 8.
8 Id.
9 Id. at 6.
10 Id. at 11.
11 The 700-unit ADU projection, while not part of the SSI capacity projection, is
highly unrealistic. There have been about 5 ADUs completed in the City each year since
State law changed in 2017 to facilitate ADU production. There was only one ADU
completed last year, and there are currently only 4 applications pending. It is not
reasonable for the City to assume that this number will skyrocket to almost 90 per year
during the 6th Cycle.
12 Draft SSI Report, p. 11 (“With allowance to assume the production of 700
accessory dwelling units (ADUs) during the Housing Element planning period, the SSI
would providing [sic] a land capacity buffer of 1,938 units.”).
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A. The Capacity Projections Were Not Properly Discounted For The
(Un)Likelihood Of Development.
State law requires capacity projections for the SSI to be demonstrable and
realistic.13 HCD has provided detailed guidance as to how cities should calculate
realistic capacity, but thus far the Draft SSI Report has disregarded the most important
aspects of this guidance. HCD’s June 2020 Housing Element Site Inventory Guidebook
cautions that cities should discount their capacity projections by past rates of
development for similar sites during prior cycles, or if no such data is available,
projections should be discounted by the overall rate of development for parcels listed in
the jurisdiction’s prior SSI.14 Yet, the Preliminary SSI did not include such discounts.
In this regard, a December 10, 2019 City Council Staff Report stated that of 77
sites identified in Santa Monica’s 5th Cycle Housing Element, only 8 (or just 10.4%)
were actually developed with housing.15 At a recent Planning Commission meeting,
Planning Staff offered different data, and asserted that 25 of 81 5th-Cycle SSI sites have
been improved with or approved for housing. While the 5th Cycle Inventory does indeed
identify 81 sites, it is unclear what City Staff’s new turnover rate is based on. SMHC’s
recent review of City records for all sites listed in the 5th Cycle SSI indicated that
housing approvals were obtained for only 12 sites in the Inventory, which would amount
to a 14.8% turnover rate. SMHC has reached out to Planning Staff for clarification on its
greater number. Even assuming that 25 of 81 sites have in fact turned over to housing,
this would amount to an unimpressive 31% turnover rate for identified sites, which
means that the 6th Cycle SSI’s “land capacity buffer of 1,938 units”16 is wholly
inadequate.
Furthermore, the 5th Cycle Housing Element stated that the parcels identified in
its sites inventory could accommodate roughly 3,700 units, but according to the above-
mentioned December 2019 City Council Staff Report, less than a third of these potential
housing units were completed or under construction during a much stronger economy.17
13 See Gov’t Code § 65583(a)(3) (“sites having realistic and demonstrated
potential for redevelopment during the planning period”).
14 Megan Kirkeby, Housing Element Site Inventory Guidebook and Memorandum
Regarding Government Code Section 65583.2 (Cal. Dep’t of Hous. & Community Dev.
(June 10, 2020) pp. 20-21.
15 City Council Staff Report, Agenda Item 4.A (Dec. 10, 2019) p. 9.
16 Draft SSI Report, p. 11.
17 Draft SSI Report, p. 18 (stating “The 2013-2021 Housing Element identified
potential for over 2,700 units on the City’s major boulevards and over 1,000 units in the
districts governed by the 2013 Bergamot Area Plan. This housing is not being produced
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Assuming that some additional units were likely produced in 2020 and 2021, this
indicates that capacity in the City’s sites inventory has about a 40% chance of being
developed.18
Had the City followed HCD’s guidance and discounted its capacity projections by
past rates of development, the sites identified for inclusion in the SSI (not including
pending and approved units) would have yielded about 3,100 units of projected
capacity, not the unrealistic 7,707 units projected in the Draft SSI Report.
B. The Draft SSI Report Is Unrealistic Regarding The Likelihood Of
Multifamily Housing Developments Replacing Existing Commercial And
Non-Residential Buildings And Their Uses.
The Draft SSI Report further delineates the 375 sites identified as “high potential”
for housing into various categories.19 For most sites, no good explanation is provided as
to why City Staff believes those sites have “high potential” to be switched from their
current uses to housing. To the contrary, most of the categories of sites identified in the
Preliminary SSI have historically not pursued housing development under existing
zoning and development standards, and there is no reason to believe they will in the
future absent very attractive incentives for housing development. Moreover, the City’s
own feasibility analysis says that redevelopment of these sites with housing is infeasible
based on the City’s current standards and inclusionary housing program. Even with
significant incentives for housing, many sites listed as “high potential” will continue in
their current (non-housing) uses.
For example, these categories of SSI properties should be assumed especially
unlikely to turn over:
“Prior SSI Sites” are sites that were identified as suitable for housing in the
5th Cycle Housing Element but were not developed as had been projected.
No good reason is provided to justify why the City believes housing will
as anticipated, as less than a third of those potential housing units has been built or is
under construction in these areas.”).
18 If a 40% adjustment factor were to be utilized in the City’s 6th Cycle Housing
Element, then the site inventory would need to include at least 2.5 times the City’s
RHNA allocation in order to satisfy California Housing Element Law’s sites inventory
requirement. (See Megan Kirkeby, supra at pp. 20-21, suggesting adjustments to
capacity calculations based on past development rates for similar parcels during the
previous planning period.)
19 See Draft SSI Report, pp. 4-7.
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now be developed on these same sites without any regulatory changes
from the standards that have failed to produce any new housing on these
sites for the past decade.
Various sites identified as “high potential” are currently in longstanding use
as Auto Storage Lots (Category 6). Auto dealers remain crucial to the
City’s economy, and there is no reason to believe that these sites will
convert to housing under current standards. Nor is there any discussion of
where the dealership sales inventory currently stored on those sites would
be moved to. Nonetheless, the Draft SSI Report assumes 29 Auto Storage
parcels consisting of 7.5 acres of land have high potential for
redevelopment.20 But the Auto Storage Lots listed as “high potential” for
housing are essential to the auto dealer businesses they support. In prior
discussions with property owners (who often have long-term leases on
these properties), any redevelopment would need to accommodate extra
subterranean levels in order to allow the inventory storage to be replaced
in the new development. Given the very high costs of excavating, shoring
and constructing subterranean levels for dealership inventory storage,
substantial additional height/stories and FAR and revisions to the City’s
inclusionary program would be necessary for such a project to be even
feasible, let alone enticing, to auto dealers and the property owners of
those sites. Very few Auto Storage Lots are likely to be redeveloped with
housing even if housing incentives are offered for these sites.
Almost all the other categories of sites identified in the Preliminary SSI
consist of lots that have no economic motivation to pursue housing or
mixed-use housing under the existing regulations. There is no reason to
believe that those sites are likely to be developed with housing over the
next eight years absent significant new economic incentives for doing so.
We expect the listing of many of the privately-owned sites on the Preliminary SSI
would come as a surprise to those property owners, many of whom may have long-term
commercial leases. To our knowledge, the City has thus far failed to perform outreach
to owners of those properties to assess what it would take to entice them to pursue
entitling their sites with housing projects. SMHC expects that even with significant
economic incentives, many commercial property owners would be extremely reluctant
and unlikely to abandon the existing uses of their privately-owned properties. The 40%
likelihood of development discussed above (based on past SSI turnover) is surely
20 Draft SSI Report, p. 7.
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significantly lower for sites that are occupied with viable and longstanding nonresidential
uses.
Examples include21:
The southeastern corner of 11th Street/Santa Monica Boulevard has been
used by a number of different auto dealerships for many years.
The northeastern corner of 12th Street/Santa Monica Boulevard is a core
part of the BMW dealership.
Much of the land at the southeastern corner of 12th Street/Santa Monica
Boulevard is part of the Santa Monica Ford dealership.
The site identified near the southeastern corner of Euclid/Santa Monica
Boulevard is used by the Subaru dealership.
The northeastern and northwestern corners of 16th Street/Santa Monica
Boulevard appear to be parking for the UCLA Santa Monica Health
Center.
The southwestern corner of 16th Street/Santa Monica Boulevard is in auto
dealership use.
So called “pending/approved” projects that actually include entirely (or
primarily) non-residential uses, such as:
o Several of Saint John’s properties (including a property where its
current Child and Family Development Center is located) which are
governed by a Development Agreement that has been in place
since 1998 and are part of Saint John’s “Phase II” program (which
Saint John’s has been processing with the City since 2015 and the
City agreed through a 2017 amendment to the Development
Agreement to process in good faith); and
o 1248 Fifth Street (the site of the former Santa Monica post office)
which is improved with a City-designated landmark and for which
21 Please see the chart on page 7 of the Draft SSI Report. Category 6 on that
chart lists 29 parcels of Auto Storage Lots consisting of 7.5 acres of land. Assuming that
all of those lots would turn over to housing use over the next eight years is wildly
unrealistic. At best, a small fraction of those lots might turn over.
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there are no pending development applications and the previously
approved entitlements (DRP 16ENT-0065, VAR 15ENT-0138 &
COA 16ENT-0119) have long since expired.
We expect that nearly all of these sites have virtually no likelihood of turning over to
housing use during the 6th Cycle.22 In order to be included on the SSI, there needs to be
some real-world basis for believing that they are likely to be changed to housing use.
The radically overinclusive nature of the SSI leads to the baseless assumption that no
changes to regulatory incentives for housing will be necessary for the City to achieve its
RHNA allocation.
C. The Draft SSI Report’s Assumptions Regarding City-Owned Lots Are
Unwarranted.
The Draft SSI Report’s 10,133-unit capacity projection includes 1,399 units on
City-owned lots.23 We question whether many of those sites are likely to be developed
with housing over the next eight years.
The preliminary SSI also assumes a total of 427 “pending or approved” units on
Fourth and Fifth Streets (the site of the Plaza at Santa Monica, which the current City
Council has terminated). City development of its own properties has frequently been
extremely challenging to accomplish, with few notable exceptions.
Additionally, the Preliminary SSI includes the City’s surface parking lots west of
Main Street that support the Main Street businesses and visitors to the beach.24 The
loss of beach and business parking from this location would likely not be tolerated by
the California Coastal Commission and would be devastating to the small independent
Main Street businesses trying to survive. It is not clear whether the Preliminary SSI
assumes one-for-one replacement of the vital parking that currently exists on that land.
Moreover, the inclusion of the Bergamot Arts Center on the SSI may make
sense, but only if the City takes the necessary steps to put this site in the position to be
redeveloped with housing. In addition to its absurdly low FAR of 1.0 despite its location
at the Expo station, the site is subject to an Exclusive Negotiating Agreement for a
22 We have no confidence in the accuracy of this assessment in the Draft SSI
Report (“Auto dealerships have indicated interest in turning over these large surface lots
into redevelopment opportunities as they are rethinking their sales operations.”) Draft
SSI Report, p. 4.
23 Draft SSI Report, p. 11.
24 Draft SSI Report, p. 4 (“the City’s parking lots on Main St [sic] Street are
reviewed as potential housing sites”).
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commercial office/hotel/gallery project. At a minimum, in order to include it as a “high
potential” for redevelopment with housing, the City would need to commence the steps
with the developer that would be required to: free up this site for housing, increase the
allowable FAR for housing, and revise the inclusionary housing program to allow for
feasible housing development on this site.
D. The Draft SSI Report Utilizes Unrealistic Assumptions Regarding
Pending And Approved Units.
Another large component of the Draft SSI Report’s 10,133-unit projection is
categorized as pending and approved projects. The Report counts 756 currently
pending units, and 1,670 already-approved units towards the projection.25 It is not
realistic to assume that every single pending and approved unit will ultimately be
produced during the 6th Cycle planning period. For example, the pending/approved
projects appear to include 427 total housing units for the Plaza at Santa Monica project
site; this makes no sense.26
The Draft SSI Report rationalizes the inclusion of all pending and approved units
by asserting that “[u]nlike other jurisdictions where a significant percentage of approved
projects are never constructed . . . historically almost all housing projects that have
been approved [in Santa Monica] are ultimately built.”27 This questionable assertion may
25 Draft SSI Report, p. 11.
26 Id. at 10.
27 Id. at 4.
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support the inclusion of most (not all) approved units, but the same surely cannot be
said of pending units which have not received entitlements yet. Staff indicates their
basis for this assertion is that according to their records, “historically” most housing
projects are “ultimately” built. Given the current economy, we find this assertion
particularly dubious. We are experiencing one of the worst economies since the Great
Depression. Residential rents are down by as much as 35%. Looking to the recent past
is not going to be informative.
E. The Draft SSI Report Does Not Adequately Account For The AHPP As
An Impediment To Achieving Housing On “High Potential” Sites,
Despite That Such An Impediment Is Identified In The HR&A Feasibility
Analysis.
For sites targeted as having “high potential,” the Draft SSI Report projects
residential capacity by mechanically applying maximum existing development standards
without factoring in the real-world impacts of the City’s Affordable Housing Production
Program (“AHPP”).28
The HR&A Feasibility Analysis that the City commissioned for the current
Housing Element Update confirms that projects along the Boulevards, Lincoln,
Bergamot, and in Downtown--where the bulk of the Draft SSI Report’s “high potential”
sites are located--are only likely to develop under the AHPP’s 7.5% Extremely Low
Income (“ELI”) option.29 This ELI option, which allows developers to provide a lower
percentage of affordable units reserved for the neediest category of the population, has
been suspended and unavailable to housing developers since April of 2019.30
Currently, housing developers must set aside at least 15% deed-restricted units
in for Tier 2 projects and more in the Downtown. If, as the Feasibility Analysis found,
housing is unlikely to be proposed outside of Downtown even using the 7.5% ELI
option, it makes no sense for the Draft SSI Report to assume that there is a “high
potential” for development on most of its identified sites under current AHPP conditions,
28 Draft SSI Report, p. 11 (“To assess the housing capacity of the remaining
Category 2-10 sites that have been identified for the SSI, the realistic capacity of the
sites was assessed by applying the City’s existing development standards”).
29 Feasibility Analysis, p. 32 (“Projects along the Boulevards, Lincoln, Bergamot
and in Downtown are likely to develop at current development standards with no more
than 7.5% ELI affordable units.”). And as to the Boulevards and Lincoln, HR&A finds:
“MUB and Lincoln, while feasible at 7.5% ELI, exceed current FAR limits.” Id. at n.1.
30 See Ordinance No. 2605.
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where the 7.5% ELI option has been eliminated and a minimum of 15% affordable is
required for Tier 2 projects.
Additionally, even the Feasibility Analysis understates the chilling impact of the
AHPP on housing production, given that the development standards assumed by the
analysis are more generous than those that actually apply to some of the City’s “high
potential” sites. For example, the Feasibility Analysis concludes that a 7.5% ELI project
would be marginally feasible to develop in the Bergamot area at a 60’ height and 2.0
Floor Area Ratio (FAR).31 The largest site that the City has targeted as having “high
potential” in the Bergamot area is the City-owned Bergamot Arts Center property at
2500 Olympic Boulevard.32 However, the Bergamot Area Plan (BAP) limits FAR for this
site to 1.0, not the 2.0 assumed by the Feasibility Analysis.33 Given the lower FAR and
the suspension of the ELI option, this exceptionally large SSI site has essentially no
potential for housing development under current standards, but despite this, the Draft
SSI Report has unrealistically targeted this site as having “high potential” with capacity
for almost 200 units.34
THE CITY CANNOT POSSIBLY MEET ITS LEGAL
OBLIGATIONS WITHOUT MAKING MAJOR REGULATORY
CHANGES TO SUPPORT HOUSING DEVELOPMENT
As discussed above, SMHC disagrees with the Draft SSI Report’s apparent
position that it will achieve (if not exceed) its total RHNA allocation without any changes
to current zoning or development standards. Indeed, the City Council Staff Report
acknowledges as much under the heading “Assessing the Likelihood of Residential
Development”: “Given that at least 60% of the sites identified in the preliminary site
analysis are located on the Boulevard and NC, additional height and FAR would be
necessary for residential development to likely occur on these sites.”35
In our view, a number of the sites identified in the preliminary SSI as “high
potential” have little-to-no potential for housing, and significant regulatory changes are
needed to expand the economic incentives for private parties to either pursue housing
development or make their sites available to housing developers. Even with incentives,
many sites listed as “high potential” would be unlikely to turn over to housing.
31 Feasibility Analysis, p. 23.
32 https://www.santamonica.gov/housing-element-update-draft-concepts.
33 BAP, Figure 4.B.02, p. 74.
34 Draft SSI Report, p. 10.
35 City Council Staff Report, p. 47.
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A. Regulatory Changes Are Needed To Make Housing Viable.
The Staff Report acknowledges that meeting the affordable RHNA target will
require a combination of inclusionary units provided through market-rate projects, and
100% affordable projects.36 However, (a) market-rate projects with inclusionary units are
impeded by the City’s overly restrictive zoning and development standards in
combination with high, unachievable inclusionary mandates under the AHPP, and
(b) 100% affordable projects generally require scarce government subsidies.
The HR&A Feasibility Analysis confirms that increased FARs and heights are
necessary in most areas of the City in order to support higher levels of inclusionary
housing.37 As noted above, the Feasibility Analysis found that the 7.5% Extremely Low
Income (ELI) inclusionary option is the only AHPP option likely to produce viable
inclusionary projects in most parts of the City, but this option has been suspended since
April 2019 and is not currently available. The Feasibility Analysis also found that
additional heights and FARs are needed to induce housing developers to pursue
projects subject to the 10% very low option (presumably because this option is only for
Tier 1 projects) and other higher percentage inclusionary mandates.38
The City removed the ELI option because it sought to produce higher numbers of
affordable units, but this action was counterproductive because it rendered many
projects economically infeasible altogether, resulting in less housing at all income
levels. The City could facilitate housing production by amending the AHPP to restore
the 7.5% ELI option. This is an important first step that the City should take to increase
the viability of housing and allow for smaller projects with affordable units.39 However,
this action alone without zoning reform would do little to produce the volume of
affordable housing that the City so badly needs.
For the AHPP to produce large numbers of affordable units, development
standards must be increased in areas targeted for housing. The Bergamot Arts Center
site discussed above is illustrative of the City’s issues regarding housing production. It is
a large site that could theoretically accommodate a significant mixed-income housing
36 Id. at 53-54.
37 Id. at 32.
38 Id. (“the preliminary HR&A results, which indicate that increasing the
percentage of inclusionary affordable housing above 7.5% ELI would require an
increase in FAR and height limits for housing projects to be most likely to be
developed”).
39 Id. at 47 (“At the 7.5% ELI scenario under current zoning standards,
retail/residential development in some areas would likely occur”).
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development, but it is saddled with a combination of unduly restrictive development
standards and aggressive inclusionary requirements that render it essentially
undevelopable for housing. If the City were to reinstate the ELI option, the Bergamot
Arts Center site could potentially be developed with housing, but would include a
relatively small number of affordable units given its current density limitation of 1.0 FAR.
Meaningful increases in the FAR would allow the site to feasibly accommodate a larger
number of affordable units.
The Feasibility Analysis found that under current zoning and development
standards, housing projects with inclusionary affordable units are only likely to develop
in a few areas of the City under the currently suspended 7.5% ELI option.40 Thus, at a
minimum, the 7.5% ELI option needs to be reinstated in order for the City to include
properties in these areas on the SSI.
According to the Feasibility Analysis, Downtown and Bergamot are the only
areas of the City that can accommodate 20% affordable projects under current
standards, and even in those areas the viability of such projects is described as
“marginal.”41 However, the FAR assumed in the Feasibility Analysis for Bergamot was
2.0. Thus, even the “marginal” conclusion doesn’t hold up for the areas of Bergamot that
impose a 1.0 FAR (notably including the City-owned site). Most importantly, a
determination of “housing feasibility” does not make it more profitable than the existing
uses.
Upzoning to allow additional height and FAR for housing projects is necessary to
facilitate projects with higher levels of affordability that can realistically help the City
make progress towards its RHNA goals.42 As the Staff Report acknowledges:
“Increasing the percentage of affordable housing units required [above 7.5%] would
necessitate increases in height and FAR for all zones except the Downtown.”43 Thus,
the Staff Report “propose[s] a rethinking of how FAR limits are set for housing projects
by establishing a target percentage for affordable housing and then working backwards
into the FAR necessary to support that percentage.”44
40 Feasibility Analysis, p. 32.
41 Id. at 26.
42 Id. at 33.
43 City Council Staff Report, p. 47. See also page 54 (“Meeting the RHNA
affordable housing targets will require reassessment of those standards.”).
44 Id. at 55.
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B. Changes Are Needed To Incentivize Housing Over Other Uses.
As discussed above, most of the sites that the City has designated as “high
potential” for housing are currently occupied by other, longstanding nonresidential uses.
In order to actually increase housing production, the City will need to not only facilitate
housing, but incentivize it over the existing conditions. Property owners will not abandon
existing conditions unless they are given strong economic incentives to do so, and even
with incentives, many existing uses would be unlikely to turn over. Unfortunately, most
of Staff’s analysis completely ignores this reality.
The increases in development standards referenced above must be significant to
attract these property owners to actually pursue redevelopment of their properties for
housing. Therefore, increases in zoning and development standards should be targeted
specifically towards housing, potentially through the use of overlay zones. As discussed
above, most of the “high potential” sites that are listed in the Preliminary SSI currently
have little-to-no realistic potential for housing. However, if these sites were covered by
an overlay zone that offered generous height and density bonuses for residential uses,
the draft projections could become more realistic. Quite frankly, we do not understand
how this can be determined without in-depth interviews with affected property owners
and their representatives, as well as experienced commercial realtors and developers.
To be effective, any housing overlay zone or other housing incentive must have
feasible inclusionary options that are not merely “marginal”-ly feasible. Otherwise, little-
to-no progress with be made to generate housing, including affordable housing. The
simplest option for most long-term property owners is to make no changes, particularly
during a bad economy such as we are experiencing today. Required percentages of
affordable units must be proportional to the heights and densities permitted to produce
viable projects. Any housing bonus overlay zone or other housing incentive should not
be restricted to 100% affordable projects (which generally depend on scarce
government subsidies) as proposed in the Staff Report.45 Rather, it should widely target
residential projects, and could include even greater bonuses for 100% affordable
projects.
CONCLUSION
The City would be wrong to assume that it can meet its overall RHNA target
without any changes to its zoning/development standards and inclusionary housing
program. In order to produce anything close to the 10,133 total units projected in the
Draft SSI Report, the ELI option will need to be reinstated (or potentially an option
requiring 10% deed-restricted housing for Tier 2 and above projects, which has been
45 Staff Report, pp. 26-27.
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proven as feasible in the past in Santa Monica), and development standards for housing
must increase substantially. Even the Staff Report acknowledges that meeting its
affordable housing goals will be impossible under current standards.46
Significant increases in height and FAR will be required to facilitate market rate
projects with inclusionary units, as well as 100% affordable projects. The City Council
should provide clear direction that major changes to zoning and development standards
are needed to produce more housing. As SMHC has explained in prior correspondence,
these increases can be focused on the City’s commercial boulevards, as well as
Downtown and in the Bergamot area, to facilitate housing production in locations that
avoid disrupting our residential neighborhoods in line with the vision articulated in the
LUCE.47 Additional steps that the City should take to further facilitate market rate and
affordable housing are discussed in the enclosed memorandum that SMHC submitted
to City Planning Staff on December 14, 2020.
Very truly yours,
Kenneth L. Kutcher
Enclosure
cc: Lane Dilg (w/ encl.)
David Martin (w/ encl.)
Jing Yeo (w/ encl.)
Steve Mizokami (w/ encl.)
Rachel Kwok (w/ encl.)
Cary Fukui (w/ encl.)
Ross Fehrman (w/ encl.)
George Cardona (w/ encl.)
Heidi von Tongeln (w/ encl.)
SMHC Board of Directors (w/ encl.)
F:\WPDATA\639\639.67 (Santa Monica Housing Element 2021)\Cor\SMHC to CC 2020.03.26 (Draft SSI
Report).docx
46 Staff Report, p. 24 (“Past performance indicates that moving forward, further
incentives will be necessary to support the development of affordable housing.”).
47 See LUCE, pp. 5, 6, 2.1-3, 2.4-3, 2.6-29 & 2.6-5.
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M E M O R A N D U M
To: David Martin, Director of Community Development
CITY OF SANTA MONICA
From: Santa Monica Housing Council
Date: December 14, 2020
Subject 6th Cycle Housing Element Update (Part Two)
I.
INTRODUCTION
As the Santa Monica Housing Council (“SMHC”) explained in its Part One
memorandum commenting on the City’s 6th Cycle Housing Element Update, the City is
legally obligated under California Housing Element Law1 to substantially increase its
rate of housing production in comparison to the most recent (and prior) Housing
Element planning periods. This requires the City to include in its 6th Cycle Housing
Element a program (or series of programs) with specific action steps that will
significantly increase City housing production.2 SMHC’s recommendations for specific
action steps are included in each section below and are also attached as Exhibit “A.”
Tinkering at the margins of City housing regulations will not come close to
meeting the City’s legal obligations under California Housing Element Law. To meet its
legal obligations, the City will need to increase its rate of housing production from about
1 Gov’t Code §§ 65580, et seq.
2 Gov’t. Code § 65583.
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175 units per year3 to about 1,100 units per year4 in order to achieve its new RHNA
allocation of 8,873 units for the 6th Cycle’s planning period (2021-29).5 This quintupling
of housing production requires fundamental regulatory reforms that prioritize and
incentivize extensive new housing production as a preferable alternative to perpetuation
of existing status quo commercial uses on underdeveloped, low-scale sites (i.e., the
prevailing “no new development” situation).
In this Part Two memorandum, SMHC elaborates further on the ways the City
has impeded rather than incentivized new housing production in recent years. This
memorandum focuses geographically on those areas where the 2010 LUCE
concentrates new housing production: Downtown, Commercial Boulevards, Bergamot,
and Activity Centers. This memorandum also recommends housing incentives for
residentially-zoned lots currently in commercial parking use. This memorandum then
recommends a series of reforms designed to facilitate the increase in housing
production, including affordable housing, that will be necessary in order for the City to
comply with the requirements of California Housing Element Law in its 6th Cycle
Housing Element update.
3 The 5th Cycle Housing element was adopted in December of 2013. The City’s
Proposition R reports from Fiscal Years 13/14, 14/15, 15/16, 16/17, 17/18, and 18/19
show an average of 175.33 completed units per year. Data for Fiscal Year 19/20 was
not available at the time this memorandum was drafted.
4 See SCAG 6th Cycle Draft RHNA Allocation Based on Approved Final RHNA
Methodology (Sept. 3, 2020) https://scag.ca.gov/sites/main/files/file-attachments/rhna-
draft-allocations-090320-updated.pdf?1602188695 (allocating 8,873 units over the
course of the course of the 8 year cycle, for an average of 1,109.13 per year).
5 Id.
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Some have dismissed Santa Monica’s RHNA allocation of 8,873 units for the 6th
Cycle as unrealistic. SMHC disagrees. The City’s 6th Cycle Housing Element update
should be able to achieve Santa Monica’s RHNA allocation -- which represents an
approximately 2.1% annual increase in the City’s housing supply -- provided the 6th
Cycle Housing Element update includes the plan of actions required by California
Housing Element Law.6 And SMHC is confident that the 6th Cycle Housing Element
update can achieve the City’s RHNA allocation while minimizing the displacement of
existing residential units. Indeed, consistent with the LUCE, SMHC’s recommended
reforms have been designed to achieve this objective.
II.
RECOMMENDED ACTION STEPS TO
INCREASE HOUSING PRODUCTION
SMHC will reserve making specific height and density recommendations pending
review of the City’s site inventory and analysis for its 6th Cycle Housing Element.7 But
the overall direction of the needed regulatory reforms is clear: the City needs to:
(1) provide substantial height and density bonuses for housing projects (compared to
other uses), with still further height and density bonuses for 100% affordable housing
projects; (2) streamline its procedures for housing project review by expanding the
Administrative Approval process and eliminating the DA requirement for all housing
projects (including Tier 3 projects); and (3) establish affordable housing requirements
6 According to the presentation from the City’s Housing Element Webinar #1 from
November 2020, there are approximately 52,000 housing units in the City. A RHNA
allocation of 8,873 units over the eight years of the 6th Cycle calls for production of
1,109.13 units per year, which is approximately 2.1% of the existing housing stock.
7 The specific heights and densities will depend in part on whether the City
commits to implementing the State Density Bonus Law in districts where the City
regulates density by FAR.
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for new market-rate housing projects that are both economically viable and do not
render the status quo non-residential uses the preferred outcome for underdeveloped
commercial properties, often with little or no mortgage debt.
An important first step would be for the City to reverse its anti-housing regulatory
changes made since the LUCE was initially adopted in 2010. However, SMHC does not
believe returning to the 2010 LUCE standards by itself will result in the City’s suitable
sites inventory being sufficient to satisfy California Housing Element Law. SMHC
anticipates that further regulatory reforms, including upzoning of non-residential land for
housing, will be necessary in order for the City to meet its obligations under California
Housing Element Law. A key component of SMHC’s recommendations is the use of
housing overlay zones to incentivize housing as recommended by HCD.8
Additionally, the City should take immediate action to fully and wholeheartedly
implement the State Density Bonus Law in its non-residential districts and incorporate
other State law incentives for housing (including for 100% affordable housing projects).
A. Downtown.
1. Pre-2010 LUCE.
Beginning in the 1990s, shortly after the Northridge Earthquake, Downtown was
the central focus of new housing development in Santa Monica. This new housing
occurred primarily on 5th, 6th and 7th Streets. It was fueled by what has been, by far,
the most successful housing incentive in the City’s regulatory history: the 50% floor area
discount for housing. This “2-for-1” incentive was applied to both FAR and the threshold
8 Megan Kirkeby, Housing Element Site Inventory Guidebook and Memorandum
Regarding Government Code Section 65583.2, Cal. Dep’t of Hous. & Community Dev.
(June 10, 2020) p. 15.
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for when an Administrative Approval was available. And the City had workable
affordable housing inclusionary requirements (a/k/a the City’s Affordable Housing
Production Program or “AHPP”) in place that generated affordable housing without
impeding new market-rate housing development.9
2. 2010 LUCE.
The 2010 LUCE did not include development standards for the Downtown
(except for Lincoln Boulevard), deferring such standards until adoption of a specific plan
for the Downtown.10 But roughly concurrent with the 2010 LUCE, the City repealed the
50% housing floor area discount. 11 This change dramatically slowed the pace of
housing development in Santa Monica’s Downtown.
3. The Downtown Community Plan and Housing.
The City adopted a specific plan for its Downtown, known as the Downtown
Community Plan (“DCP”), in July 2017. In comparison to the City’s prior Downtown land
use regulations, the DCP downzoned significant portions of Downtown. Notably, the
DCP does not include the 50% floor area discount that had proven so successful for the
15 years or so prior to the LUCE’s adoption. Instead, the DCP includes minimal FAR
incentives for housing, as shown in the excerpts from DCP Table 4.2 below. 12
9 For much of this period, the City provided housing developers with the option of
providing either 10% very low income or 20% low income units.
10 See 2010 LUCE p. 2.1-48.
11 See City Council Ordinance No. 2345 (2011) creating interim zoning
procedures to replace those not aligned with the LUCE (including the 50% floor area
discount for housing).
12 As shown in the excerpts from DCP Table 4.2, where the DCP allows
additional heights and densities for housing projects, the benefits are minimal and
insufficient to incentivize housing. There are additional incentives for 100% affordable
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The DCP also imposed AHPP requirements on new housing projects in the
Downtown that are much more onerous than previously applied in the Downtown and
much more onerous than the requirements in other non-residential areas of the City.13
Instead of producing more affordable housing, the increased affordable housing
obligations in the Downtown have impeded new housing development, including
affordable housing, in the Downtown.
projects on certain WT-designated parcels which are not shown above, but such
projects are unlikely to ever materialize regardless of the incentives offered.
13 See DCP Action CCP1.3A.
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The Municipal Code’s land use regulations for the Downtown Community Plan
Area also effectively ban ground floor residential uses by restricting multifamily
residential units to upper floors only in almost all Downtown districts.14 This requirement
limits options for residential development, and reduces the number of units that may be
included in new housing projects.
4. Recommended Action Steps for Downtown.
SMHC recommends the following action steps for the Downtown:
a. Adopt a housing overlay zone for all areas in the Downtown
Community Plan where there are viable housing sites. These areas include the
Neighborhood Village (NV), Bayside Conservation (BC) (particularly the BC-Promenade
sites that front on Wilshire Boulevard and the BC - 2nd and 4th Streets subarea), Lincoln
Transition, and Wilshire Transition (particularly the sites that front on Wilshire
Boulevard). The housing overlay zone should provide substantial height and density
bonuses for housing projects in comparison to non-housing projects, with still further
heights and densities for 100% affordable housing projects and preservation projects.
b. Reform the Downtown’s Affordable Housing Production Program
(“AHPP”) requirements as follows:
For Tier 1 housing projects, reinstate the Extremely Low-Income
Option at up to 10% of the total units.
For Tier 2 and 3 (and housing overlay-zoned) housing projects,
eliminate the current scheme which ties increases in the affordable
housing requirement to various height increments and has resulted
14 See SMMC Table 9.10.040, Special Limitation (1).
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in almost no new housing projects.15 Institute affordable housing
requirements based on percentages that have been demonstrated
as feasible in other Downtown housing projects, including:
o 15% for Tier 2 projects; and
o 20% for Tier 3 projects.
c. Eliminate the prohibition on ground floor residential units that is
currently in place for every Downtown subarea except for the Neighborhood Village,
with limited exceptions (e.g., the Promenade).16 This prohibition unnecessarily
constrains how many residential units can be located on a site and can hurt the overall
economic feasibility of housing projects.
B. The Commercial Boulevards.
The 2010 LUCE’s articulated vision called for reconfiguring the City’s boulevards
“from automobile-oriented retail to a mix of residential, pedestrian, and neighborhood-
serving uses.”17 That vision expressly calls for incentives to encourage private
investment in housing along the boulevards,18 and rezoning five “Activity Centers”
located near transit where higher density mixed-use development would be permitted.19
A similar vision has been proposed for boulevards throughout cities and
unincorporated areas of Los Angeles County by the advocacy group Move LA, helmed
by former Santa Monica Mayor Denny Zane. Move LA’s Boulevards of Equity and
15 See SMMC Table 9.10.070.A.
16 See SMMC Table 9.10.040, Special Limitation (1).
17 2010 LUCE, p. 2.4-3.
18 Id.
19 2010 LUCE, p. 2.4-4.
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Opportunity proposal calls for the creation of new mixed-use neighborhoods along
commercial boulevards to increase housing opportunities without disrupting existing
residential neighborhoods.20 To achieve this goal, Move LA states that “state and local
governments should enable and encourage, even prioritize, multifamily mixed-income
housing along commercial boulevards and in downtowns that are well-served by
transit.”21
Santa Monica has the capacity to achieve a substantial portion of its 6th Cycle
RHNA allocation on its boulevards. But doing so will require significant regulatory
reforms that make housing a more attractive option to landowners than perpetuation of
status quo non-residential uses and low-scale infill commercial development.
Unfortunately, the 2010 LUCE contained inadequate housing incentives on Santa
Monica’s commercial boulevards. And the City has moved in the wrong direction since
adopting the LUCE in 2010 by reducing allowable heights and densities for housing
projects on the boulevards.
The severe reductions in the LUCE’s allowable heights and densities for the land
use designations that cover much of the City’s commercial boulevards have
disincentivized housing to such an extent that residential mixed-use projects on the
boulevards have become, with limited exceptions, economically infeasible. The changes
to development standards for the boulevards directly contradict the LUCE’s stated
vision for those streets, which calls for the creation of vibrant, walkable, mixed-use
20 Gloria Ohland, What Recovery Could Look Like: Boulevards of Equity and
Opportunity (Move LA, Apr. 28, 2020)
https://www.movela.org/boulevards_of_equity_and_opportunity#:~:text=Move%20LA%2
0sponsored%20SB%20961,%2C%20called%20NIFTI%2D2%20districts.
21 Id.
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neighborhoods with substantial new housing.22 Such neighborhoods will never be
created if development standards do not make housing (generally located above ground
floor commercial uses) the highest and best investment for properties along the
boulevards.
The chart below illustrates the extent to which the City’s post-2010 LUCE
amendments have reduced residential development potential on the boulevards. There
are exceptions to the general rules expressed by the chart,23 but the City’s changes to
the LUCE have effectively downzoned the bulk of boulevard sites outside the Downtown
from Tier 3 standards (or greater in Activity Centers) down to Tier 2 standards.
2010 vs. 2017 Maximum LUCE Standards for Boulevard Districts24
LUCE Version 2010 2017
District MUBL MUB MUBL MUB
Height 47’ 55’ 36’ 50’ w/ Activity Center 57’ 65’
FAR 2.0 2.75 1.75 2.25 w/ Activity Center 2.5-2.75 3.25-3.5
22 See 2010 LUCE, p. 2.4-7 and 2017 LUCE, p. 2.4-7 (regarding Wilshire
Boulevard); 2010 LUCE Policy B6.7, p. 2.4-25, and 2017 LUCE Policy B6.7 (regarding
Broadway), p. 2.4-25,; 2010 LUCE Policy B10.7, p. 2.4-33, and 2017 LUCE Policy
B10.7 (regarding Colorado Avenue), p. 2.4-33,; and 2010 LUCE Policy B21.7, p. 2.4-59,
and 2017 LUCE Policy B21.7 (regarding Ocean Park Boulevard), p. 2.4-59,.
23 See 2017 LUCE, p. 2.1-35 (allowing Tier 3 for MUBL on the north side of
Broadway, on the south side of Broadway west of the centerline of 20th Street, on
Colorado west of the centerline of 20th Street, or within an Activity Center boundary);
and 2017 LUCE, p. 2.1-38 (allowing Tier 3 for MUB sites within the area bounded by
Colorado Avenue, Olympic Boulevard, 20th Street, and Cloverfield Boulevard).
24 The standards in this chart for 2010 reflect maximum Tier 3 heights and FARs
for the vast majority of MUB and MUBL sites on boulevards outside the Downtown with
and without an Activity Center overlay. Because Tier 3 was subsequently removed for
all MUBL and MUB sites outside the downtown (except for a few limited areas, very rare
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The City has also imposed “active use” requirements for ground floors in
Commercial and Mixed-Use districts.25 Like in the Downtown, these use restrictions
effectively ban ground floor residential uses on the ground floor along much of the
commercial boulevards.
Below, this memorandum describes the City’s 2010 LUCE and current
development standards boulevard-by-boulevard and then recommends an overall
direction for regulatory reform for the boulevards that should be incorporated in the
City’s 6th Cycle Housing Element Update.
1. Wilshire Boulevard.
The LUCE’s vision for Wilshire Boulevard calls for the creation of a “pedestrian-
priority boulevard lined with a mix of local-serving retail and residential uses.”26 The
LUCE’s vision calls for mixed-use development along Wilshire with ground-floor retail
and service businesses below upper levels “devoted predominantly to a variety of
affordable and market-rate housing types.”27 Wilshire Boulevard is a major east-west
arterial street that runs through the entire City from Centinela to Ocean. The street
presents a unique opportunity for significant new housing development if properly zoned
100% affordable and landmark-preserving projects), the 2017 maximums reflect Tier 2
standards. Because only one Activity Center overlay zone remains in the current LUCE,
Activity Center standards are not shown for 2017, though it should be noted that a small
section of Colorado could accommodate greater height and FAR under the remaining
Activity Center overlay.
25 See SMMC Section 9.11.030(A)(2).
26 2010 LUCE, p. 2.4-5; 2017 LUCE, p. 2.4-5 (adds that Wilshire will be
transit/pedestrian-priority, not just pedestrian-priority)
27 2010 LUCE, p. 2.4-5; 2017 LUCE, p. 2.4-5.
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to encourage housing as the highest and best use in comparison to existing or new
commercial uses.
The LUCE designates almost the entirety of Wilshire as Mixed-Use Boulevard
(MUB),28 and identifies the MUB designation as a crucial component to facilitating
Wilshire’s potential for mixed-use investment, stating:
The Mixed-Use Boulevard designation provides the
framework for Wilshire Boulevard to transition over time from
a predominantly regional-serving commercial street to a
mixed-use street with retail to service a diversity of
residential uses along the boulevard.29
However, the 2015 and 2017 LUCE amendments substantially downzoned
Wilshire and made it far less attractive for new housing development. The Activity
Center overlay areas that were designated in 2010 have since been completely
removed, and the MUB designation that applies to almost all of the street was
significantly downzoned, greatly reducing allowable heights and densities.30 In the
current version of the LUCE, Tier 3 heights and densities are prohibited within the MUB
designation except for 100% affordable projects and projects that preserve a City-
designated landmark.31 100% affordable housing projects are rare due to the scarcity of
funding subsidies, and the vast majority of buildings along Wilshire are not landmarks.
This means that in almost every case, maximum heights and densities on Wilshire have
been reduced from 55’ (and up to 65’ in Activity Centers) and 2.75 FAR (and up to 3.25
in Activity Centers) down to 50’ and 2.25 FAR.
28 2010 LUCE, p. 2.4-5; 2017 LUCE, p. 2.4-5.
29 2010 LUCE, p. 2.4-6; 2017 LUCE, p. 2.4-6.
30 See 2017 LUCE, pp. 2.4-5 – 2.4-6.
31 2017 LUCE, p. 2.1-35.
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2. Santa Monica Boulevard.
Like Wilshire Boulevard, Santa Monica Boulevard is a major arterial street that
runs through the entire length of the City from east to west. The 2010 LUCE’s vision for
the street calls for the replacement of the current random mix of land uses with “a
pedestrian-preferred transit street with a mix of local-serving commercial and retail
uses, a variety of residential opportunities, and regional healthcare and auto-related
retail/service.”32 The 2010 LUCE envisions three distinct subareas of Santa Monica
Boulevard: (a) Centinela Avenue to 26th Street; (b) 26th Street to 20th Street; and (c) 20th
Street to Lincoln Boulevard. This same vision is stated in the 2017 version of the
LUCE.33
a. 26th Street to Centinela.
Under both the 2010 and 2017 versions of the LUCE, the eastern segment of
Santa Monica Boulevard from Centinela to 26th Street is designated as Mixed-Use
Boulevard Low (MUBL).34 The LUCE’s vision for this segment states that “[t]he Mixed-
Use Boulevard Low land use designation will ensure the incorporation of local-serving
retail uses, a variety of residential types and community spaces.”35 The LUCE notes that
“current standards do not provide sufficient incentives to promote housing and upgrade
32 2010 LUCE, p. 2.4-11.
33 2017 LUCE, p. 2.4-11.
34 2010 LUCE, p. 2.4-12; 2017 LUCE, p. 2.4-12.
35 Id.
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underutilized properties.”36 The LUCE calls for a revision of standards to encourage
mixed-use development with ground-floor retail below upper-level housing.37
Housing is a vital component of the LUCE’s vision for the eastern part of Santa
Monica Boulevard, but the MUBL development standards render this vision largely
unachievable. The LUCE’s vision lamented that prior standards did not provide
sufficient incentives for housing, yet the City proceeded to adopt inadequate standards
for housing before downzoning even further.
Even before the reductions in allowable height and density, the MUBL’s 47’
maximum height and 2.0 maximum FAR attracted insufficient housing investment along
this portion of Santa Monica. Now that development standards for the MUBL
designation have been slashed to a maximum of 36’ in height with a 1.75 FAR, fewer
housing projects are likely to proceed, and any that do will have fewer units than is
optimal.
b. 20th Street to Lincoln Boulevard.
The middle portion of Santa Monica Boulevard, from 20th Street to Lincoln
Boulevard, is known as Santa Monica’s “auto row” and is dominated by car dealerships.
The LUCE’s vision for this area calls for the continuation of auto dealership land uses
with an improved pedestrian environment due to the transition of dealerships to an
“urban auto dealer format.”38
36 Id.
37 Id.
38 2010 LUCE, p. 2.4–14; 2017 LUCE, p. 2.4-14.
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To accommodate this vision, almost the entirety of Santa Monica between 20th
and Lincoln is designated General Commercial (GC). This land use designation
prioritizes commercial uses with special incentives for auto dealers.39 The chart below
summarizes the current LUCE and Zoning Ordinance development standards for the
GC district:
Maximum Residential Development Standards for GC Designation40
Street Maximum Height Maximum FAR
Santa Monica Boulevard41 35 ft. 1.5
As part of its 6th Cycle Housing Element update process, the City needs to
evaluate whether the GC sites on Santa Monica Boulevard should be incentivized for
new housing development. If realistic housing incentives were adopted for this segment
of Santa Monica Boulevard, the City would be able to add substantially to its suitable
sites inventory. And in the event the City chooses to adopt housing incentives for this
stretch of Santa Monica Boulevard, the City should also create incentives for the
39 The only incentives for housing are for 100% affordable projects, which as
noted above are unlikely to ever materialize. 2010 LUCE, p. 2.1-38; 2017 LUCE, p. 2.1-
41.
40 See 2010 LUCE, p. 2.1-38; 2017 LUCE, p. 2.1-41. (The development
standards in these charts are the Tier 2 maximums for residential projects other than
100% affordable housing projects. Community benefits and/or specified levels of
affordable housing must be provided to allow for some of these maximum standards.)
41 On the GC segments of Lincoln Boulevard (south of the I-10 Freeway) and
Pico Boulevard, the maximum height is 36 feet and the maximum FAR is 2.0.
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R-zoned portions of the auto dealer sites as discussed in Section IV(E) herein, which
are currently improved with surface parking lots.
3. Broadway (Lincoln to Cloverfield Boulevard).
Broadway is another important arterial street that runs east-west through the
center of the City. The LUCE’s vision calls for the portion of Broadway west of 26th
Street to “transition into a mixed-use corridor with residential, creative arts studios,
offices and local-serving retail uses.”42 The portion of Broadway west of 26th Street is
primarily made up of low rise commercial buildings. This portion of the street is almost
entirely designated MUBL.43
As noted above, the MUBL designation as established in the 2010 LUCE was not
sufficient to attract significant housing investment. The City’s decision to slash allowable
residential heights and densities in MUBL-designated areas has further rendered its
vision for mixed-use development along Broadway unachievable.
4. Colorado/Memorial Park Neighborhood Plan Area.
a. The LUCE and the Memorial Park Area.
The LUCE contemplates an area plan for the area surrounding Memorial Park
and describes this area as bounded by 17th Street on the east, Euclid Court on the
west, properties fronting on Colorado Avenue to the north, and the I-10 Freeway to the
south, encompassing both Memorial Park and the Expo light rail station at 17th Street.44
42 2010 LUCE, p. 2.4-19; 2017 LUCE, p. 2.4-19.
43 Id.
44 2010 LUCE, p. 2.5-13.
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However, as part of the Memorial Park Neighborhood Plan (“MPNP”) planning
process (now on hold), this area was expanded to extend westerly along Colorado
Avenue to Lincoln Boulevard. As expanded, this area is comprised of about 95 parcels,
about 85 of which are zoned Mixed-Use Boulevard Low (“MUBL”), with the rest zoned
Neighbor Commercial (“NC”), Industrial Conservation (“IC”), and Low-Density
Residential (“R2”).45
The LUCE’s vision for the Memorial Park area was to provide a range of new
residential housing units.46 Upon adoption of an area plan, the LUCE contemplated an
additional 10 feet of height and 0.75 FAR for development agreement projects.47
The LUCE also contemplated a Memorial Park Activity Center.48 However, the
LUCE did not provide any development incentives for the Memorial Park Activity Center
nor did it provide any other incentives for housing development in comparison to
commercial development. Instead, the LUCE envisioned that additional incentives
would be included in an area plan.
b. The Unfinished Memorial Park Neighborhood Plan.
The Memorial Park Neighborhood Plan (“MPNP”) planning effort was launched in
2013. The “core vision for the MPNP” was to “preserve the character and community-
45 See July 9, 2014 Planning Commission Staff Report re: Memorial Park
Neighborhood Plan, Attachment A.
46 2010 LUCE, p. 2.5-13, stating the Memorial Park overlay provides the
opportunity for a range of residential units; see also 2010 LUCE Policy AC5.2 making it
a policy to bring together involved parties to provide affordable and workforce housing.
47 LUCE Policy AC5.6.
48 See Section II(D)(1) for a discussion of the five Activity Centers as
contemplated in the LUCE.
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serving nature of the neighborhood while integrating the light rail and providing a
suitable amount of family and affordable housing near transit.”49
Despite its intention to create additional housing, the MPNP as proposed by City
Staff included zero incentives to develop housing along Colorado and provided zero
additional height or FAR in this area compared to the LUCE. Likewise, Staff’s proposed
MPNP would have provided only a very modest 0.5 FAR bonus (and no height bonus)
to Tier 3 development agreement projects within the Activity Center overlay area
compared to the LUCE, and would have provided zero extra height or FAR for Tier 1 or
Tier 2 projects in the Activity Center overlay area compared to the standards in the 2010
LUCE and the 2017 LUCE as amended. In addition, the MPNP would not have included
any process incentives for housing projects and would have defaulted to the Zoning
Ordinance’s 30,000 sf maximum (with at least 85% residential floor area) for residential
Administrative Approvals.50
Applicable MPNP Development Standards51
Development
Standard
2010 LUCE Amended LUCE Proposed MPNP Standards
MUBL MUBL
MUBL
(activity center
area)
MUBL
(Colorado, non‐activity area)
Max.
FAR &
Height
Tier 1 1.5 / 32’ 1.5 / 32’ 1.50 / 36’ 1.25 / 36’
Tier 2 1.75 / 36’ 1.75 / 36’ 1.75 / 36’ 1.75 / 36’
Tier 3 2.0 / 47’
2.0 / 47’*
*only allowed in
very narrow
circumstances
2.50 / 57’ 2.0 / 47’
49 Planning Commission Staff Report re: Memorial Park Neighborhood Plan (July
9, 2014), p. 1.
50 SMMC § 9.40.020(A)(4).
51 MPNP proposed standards per July 9, 2014 Planning Commission Staff Report
re: Memorial Park Neighborhood Plan, p. 25.
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The MPNP was never finished. (In fact, a public draft was never released.) And
although the MPNP appeared on the Planning Division’s Priorities List as recently as
2018, our understanding is that the MPNP is “on hold” and there is no current intention
to revive the MPNP planning process.
c. Existing Conditions in the Memorial Park Area.
By far the most significant change to the Memorial Park neighborhood since
enactment of the LUCE in 2010 has been the addition of the Metro Expo Line along
Colorado and the Memorial Park Expo Line Station (also known as the 17th
Street/Santa Monica College station) at 17th Street and Colorado, which opened in May
2016. The availability of convenient public transit makes this area especially appropriate
for new housing development.
Unfortunately, the City’s land use regulations impede, rather than encourage,
new housing in this area. Except for the new light rail line, the Memorial Park area
looks almost exactly like it did when the LUCE was adopted in 2010; little
redevelopment has occurred. Colorado between Lincoln Boulevard and 20th Street is
developed almost entirely with one-to-two story, mostly small commercial buildings.
These buildings are occupied by a variety of commercial uses, but mostly auto-repair,
auto-body, and parking lot uses, as well as a modest number of creative office, media
production, and light industrial uses. The area surrounding Memorial Park is likewise
developed with one-to-two story, mostly small commercial buildings, although it also
includes a modest number of public and semi-public uses—most notably the Park, the
Santa Monica Police Activities League (“PAL”) building, and SMMUSD offices. A large
portion of the plan area was previously zoned Industrial Conservation (“IC”), and the
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scale, uses, and aesthetic of the area generally reflect the historically industrial nature
of this area.
5. Lincoln Boulevard.
Lincoln Boulevard is a major thoroughfare that runs north-south through the City
from Wilshire Boulevard to the southern City limit. The LUCE notes that there are two
distinct sections of Lincoln – north of the I-10 Freeway, which is integrated with the
City’s Downtown, and south of the I-10 Freeway, which is currently a cluttered,
unattractive commercial area.52 The LUCE envisions the northern part of Lincoln
becoming a mixed-use area with housing above ground floor retail.53 And the LUCE
envisions the southern segment of the street as a “distinctive commercial district,” with
some housing above ground-floor retail,54 noting that “there are opportunities for
residential uses such as affordable, workforce and market-rate housing on the upper
floors.”55
a. North of the I-10 Freeway.
The LUCE designates the entirety of Lincoln north of the I-10 Freeway as MUB.
This segment of Lincoln is the primary area of the City where the LUCE’s development
standards have actually worked to encourage significant housing development. The
City’s success in attracting residential development to the northern part of Lincoln
demonstrates how workable development standards can effectively encourage new
housing.
52 2010 LUCE, pp. 2.4-63-64; 2017 LUCE, pp. 2.4-63-64.
53 2010 LUCE, p. 2.4-68; 2017 LUCE, p. 2.4-68.
54 2010 LUCE, p. 2.4-64; 2017 LUCE, p. 2.4-64.
55 2010 LUCE, p. 2.4-65; 2017 LUCE, p. 2.4-65.
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One reason for the City’s success along this segment of Lincoln is likely due to
the fact that the portion between Olympic and Colorado it is one of the few areas that
was carved out from the City’s removal of Tier 3 housing from the MUB designation.56
The northern part of the street stands in stark contrast to the southern portion, where
highly restrictive standards have disincentivized housing.
b. South of the I-10 Freeway.
The southern portion of Lincoln Boulevard is almost entirely designated GC with
a few parcels designated MUBL. Unsurprisingly, this segment of the street has not seen
the same success in attracting new housing as its northern MUB-designated
counterpart. In fact, we believe the City has approved a single project only on Lincoln
Boulevard south of the I-10 since the LUCE was adopted in 2010.57
The LUCE correctly notes that there are opportunities for workforce, affordable,
and market-rate housing on southern Lincoln Boulevard,58 but these opportunities will
never be realized under the City’s current development standards. The majority of
Lincoln south of the I-10 is designated GC. As noted above, the GC designation
prioritizes commercial land uses and has no incentives for housing other than for 100%
affordable projects.59 There are a few parcels on the street designated MUBL, but the
56 See 2017 LUCE p. 2.1-38 (allowing Tier 3 for MUB sites within the area
bounded by Colorado Avenue, Olympic Boulevard, 20th Street, and Cloverfield
Boulevard).
57 To SMHC’s knowledge, an apartment complex at 2903 Lincoln Boulevard is
the only housing project that the City has approved on Lincoln south of the I-10 since
the LUCE was adopted in 2010. (See CIM Group’s 47-unit project clears appeal in
Santa Monica, The Real Deal (Apr. 30, 2018) https://therealdeal.com/la/2018/04/30/cim-
groups-47-unit-project-clears-appeal-in-santa-monica/).
58 Id.
59 2010 LUCE, p. 2.1-38; 2017 LUCE, p. 2.1-41.
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MUBL designation does not allow sufficient height and density to facilitate new housing,
especially after the MUBL standards were slashed in 2015.
6. Pico Boulevard.
Pico Boulevard is an arterial street running east-west through the south side of
Santa Monica. The LUCE breaks Pico down into five distinct sections. Below, this
memorandum focuses on the segments where new housing seems most realistic. At
present, however, the standards in place are not sufficient to attract significant new
housing development.
a. Centinela to Stewart.
The LUCE envisions the easternmost section of Pico as a “mixed-use
neighborhood center,”60 but current land use designations do not support mixed-use
development. The section from Centinela to Stewart is mostly designated Neighborhood
Commercial. The NC designation is not conducive to residential development as it
includes no significant incentives for housing. Other parts of this segment are
designated MUBL, but allowable heights and densities for MUBL are too restrictive to
realistically promote housing development, especially after the reductions that took
place in 2015.61
b. Stewart to 20th Street.
The LUCE also calls for mixed-use development on Pico from Stewart to 20th
Street.62 The north side of the street in this segment is mostly designated MUBL, with
60 2010 LUCE, p. 2.4-44; 2017 LUCE, p. 2.4-44.
61 See 2017 LUCE, p. 2.1-35.
62 2010 LUCE, p. 2.4-46; 2017 LUCE, p. 2.4-46.
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some parks and open space and a few Neighborhood Commercial (NC) lots. The south
side of the street is almost entirely designated NC.63
The LUCE assumes that the MUBL designation will encourage the replacement
of auto-related uses on this part of the street, but unsurprisingly this has not occurred.
There are many potential opportunities for new housing on this section of Pico if
the City were to adopt workable development standards and housing incentives.
c. 20th Street to 16th Street.
The section of Pico from 20th Street to 16th Street (south side) is home to Santa
Monica College. The LUCE envisions “[h]ousing and student-oriented retail and service
uses across the boulevard from Santa Monica College,”64 but almost all non-college
properties are designated NC, with a couple of MUBL sites off of 20th Street.
7. Recommended Action Steps for Boulevards.
SMHC recommends the following action steps for the Boulevards:
a. Consistent with HCD guidance,65 adopt housing overlay zones on the
Boulevards that increase allowable heights and densities for housing projects to, at a
minimum, the levels allowed in the 2010 LUCE, and consider additional height and
density increases as reasonably necessary to make housing the highest and best use
on the Boulevards and facilitate a suitable sites inventory that complies with California
63 Id.
64 2010 LUCE, p. 2.4-47; 2017 LUCE, p. 2.4-47.
65 Megan Kirkeby, supra at 15.
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Housing Element Law.66 Specific areas that appear to have potential for increased
height and density standards for housing projects include:
o Lincoln Boulevard south of the I-10 Freeway
o Wilshire Boulevard, Lincoln to Centinela
o Broadway, Lincoln to 26th
o Memorial Park Neighborhood Plan area, including Colorado
o Santa Monica Boulevard between Lincoln and 20th Street and east of
26th Street
o Pico Boulevard between Lincoln and Centinela67
b. Allow ground floor residential units (eliminating the Active Use
Requirements included in SMMC Section 9.11.030(A)(2)), with limited exceptions.
c. And provide still further heights and densities for 100% affordable
housing projects and preservation projects.
C. Bergamot.
1. 2010 LUCE Vision & Development Standards for the Bergamot Area.
A key part of the 2010 LUCE’s vision for the Bergamot area is the development
of new housing. The 2010 LUCE states that it provides “[i]ncentives … for the creation
of new affordable, workforce and market-rate housing.”68 Likewise, the LUCE includes a
66 The specific heights and densities on the Boulevards and in the other areas
targeted for housing, will depend in part on whether the City complies with the State
Density Bonus Law.
67 The City may wish to prohibit housing in the areas on Pico that are in very
close proximity to the I-10 Freeway.
68 2010 LUCE, p. 2.1-42.
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Policy to support a variety of residential use types in the Bergamot area, including
affordable, workforce, and market-rate housing.69
The 2010 LUCE provided the following development standards for the Bergamot
Area70:
2010 LUCE Standards for Bergamot Area
Tier Tier 1 Tier 2 Tier 3
Height 32' 60' 75'
(39' w/ affordable hous.) (86' w/ decrease in FAR)
FAR 1.75 3 3.5
2. Bergamot Area Plan.
In accordance with the LUCE’s vision to create an area plan for Bergamot,71 the
City adopted the Bergamot Area Plan (“BAP”) on September 11, 2013. The BAP
describes itself as a pro-housing plan. It states: “This Plan encourages and creates
opportunities to develop appropriate housing for all … members of the community….”72
“It includes policies to … promote a variety of housing types that will accommodate
different living arrangements and income levels.”73 And “[t]he removal of long-standing
regulatory barriers to a range of uses, like housing and local-serving retail and services,
will promote a broader range of activities for which there is clearly local demand.”74
69 2010 LUCE Policy D20.4.
70 2010 LUCE, p. 2.1-43.
71 2010 LUCE, p. 2.6-30.
72 BAP, p. 5.
73 BAP, p. 14.
74 BAP, p. 72.
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The BAP split Bergamot into four sub-districts: Bergamot Transit Village (BTV),
Conservation Art Center (CAC), Mixed-Use Creative (MUC), and Conservation Creative
Section (CCS). Development standards in the BAP vary based on the sub-district and
the size of the parcel.
Notwithstanding its pro-housing claims, the BAP significantly downzoned
Bergamot in comparison to the development standards set forth in the 2010 LUCE. Only
one sub-district (BTV) is permitted to achieve the 1.75 Tier 1 FAR envisioned by the
2010 LUCE; no sub-district allows a project—even a Tier 3 project—to achieve the 3.0
Tier 2 FAR envisioned by the 2010 LUCE (much less the Tier 3 standards envisioned
by the 2010 LUCE); the CAC sub-district is limited to a 1.0 FAR for all Tiers; and the
CCS sub-district does not allow Tier 2 or Tier 3 projects at all. Below is a comparison of
the 2010 LUCE standards for the Bergamot area compared to the development
standards adopted in the BAP.
3. Housing Development Since Adoption of the Bergamot Area Plan.
Housing development in the Bergamot area has been very limited since adoption
of the Bergamot Area Plan. A November 20, 2019 Staff Report to the Planning
Commission and Housing Commission addressed the state of housing development in
the Bergamot area:
[S]ince the adoption of the Bergamot Area Plan in 2013, very
few housing projects have been proposed in the area. The
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few projects that have been submitted over the past 6 years
include two Tier 2 mixed-use residential projects, one mixed-
use office project, and one large Tier 1 mixed-use project.
No applications have been received for a Tier 3 mixed-use
project since the Papermate project’s approval was
rescinded by Council in May 2014. Based on anecdotal
evidence, it has been communicated to staff that several
potential reasons for the lack of housing production in the
transit/job-rich Bergamot area may include density and
height parameters that incentivize commercial development
instead of housing as a general concern about risk and
predictability with the development agreement process that
is required to access Tier 3 development standards.75
A 2018 Staff Report to City Council also indicated that there had been a dearth of
production under the BAP, especially housing production. Staff noted:
In the years subsequent to the adoption of the Bergamot
Area Plan, staff has heard from the development community
that the BAP does not contain sufficient height and FAR
incentives to attract housing or commercial development,
and that uncertainty and project risk weigh heavily on larger
projects. Minimal differences in the FAR allowance between
Tier 1 and Tier 2 do not provide incentives to produce
housing or projects that could contribute community benefits
to the area’s transformation. And, while the BAP did identify
certain properties as ripe for Tier 3 mix-use development
projects, the uncertainty of the development agreement
process has led many owners to maintain their properties
“as-is.”76
Without question, the worst anti-housing fiasco in Bergamot involved the ill-fated
Hines project, which the City Council initially approved and later rescinded its approval
in 2014. As approved/rescinded, the project would have included 498 rental housing
75 Staff Report to the Planning Commission and Housing Commission (Nov. 20,
2019) pp. 10-11.
76 2018 City Council Staff Report regarding City Planning Division priorities,
p. 12.
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units77 (including 93 affordable units)78 in addition to creative offices and other uses.
After the City Council rescinded its approval of the Hines project, the property sold and
the buyer remodeled the existing industrial buildings into a commercial creative office
project with no housing.
4. Recommended Action Steps for Bergamot.
The BAP has failed in virtually in every respect to reach its ambitious goals. The
BAP’s failings extend far beyond housing and require the City to take a fresh look at
how best to achieve its goals for the Bergamot area through revised land use
regulations.
But the housing crisis does not afford the City the luxury of waiting for yet another
multi-year planning process to rewrite the BAP before incentivizing housing in
Bergamot. The City needs to address housing in the Bergamot area with a sense of
urgency.
SMHC recommends that the City expedite a housing overlay amendment to the
BAP that creates substantial height and density incentives for housing projects in those
areas of Bergamot where housing would be appropriate (with additional heights and
densities incentives for 100% affordable housing projects). The Housing Element
update should specifically commit the City to expeditiously implementing this overlay to
77 City Council Staff Report (Agenda Item 8-A, May 13, 2014); Hines
Development Agreement Section 2.2(a).
78 Hines Development Agreement Section 2.10; Damien Newton, SaMo City
Council Debates Bergamot Transit Village, StreetsBlogLA (Jan. 24, 2014)
https://la.streetsblog.org/2014/01/24/samo-city-council-debates-bergamot-transit-
village/.
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make housing the highest and best use in those areas of Bergamot targeted for
housing.
D. Activity Centers.
1. The 2010 LUCE and the Activity Centers.
The 2010 LUCE included five (5) Activity Centers as key strategic components of
its vision for Santa Monica’s future. The Activity Centers were strategically located
throughout Santa Monica, well-served by transit, and adjacent to residential
neighborhoods. These locations consisted of the following:79
Wilshire Boulevard/Centinela Avenue
Wilshire Boulevard/14th Street
Broadway /Colorado
Memorial Park Area
Lincoln Boulevard/Ocean Park Boulevard
A key purpose of the Activity Centers was to provide both affordable and
workforce housing.80 LUCE Policy 2.4, for example, established a policy to “[c]reate
diverse housing options along the transit corridors and in the Activity Centers, replacing
some commercial potential with additional affordable and workforce housing, and
encouraging affordable workforce housing near the transit stations.”81 LUCE Policy
H2.3, likewise, committed the City to “[e]ncourage workforce housing as a component of
79 2010 LUCE, p. 2.5-3.
80 See LUCE Policy AC 1.1, which envisions “a wide range of new housing” in the
Activity Centers.
81 2010 LUCE Policy LU2.4, p. 2.1-12.
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Activity Centers at locations accessible to transit.”82 And LUCE Policy CE7.1 stated a
policy to “[e]ncourage affordable and workforce housing in close proximity to new
Activity Center overlays.”83
The current (2013) Housing Element likewise treated the Activity Centers as
significant locations for new housing development. A policy goal of the 2013 Housing
Element, for example, was to “[p]rovide new market-rate and affordable housing in
transit-rich LUCE Activity Centers and at focal points designated along major
corridors,”84 and another was to “[f]ocus housing development in the city’s major Activity
Centers near transit stations.”85
The 2010 LUCE did not establish development standards or land use regulations
for the Activity Centers. Instead, it required an area plan to be created for each Activity
Center in which development standards and land use regulations would be established
to incentivize housing.86
Although the 2010 LUCE did not provide much guidance on what the
development standards or land use regulations in an area plan should look like, it did
require, at minimum, that each area plan must include an FAR bonus for Tier 3
82 2010 LUCE Policy H2.3, p. 3.3-12.
83 2010 LUCE Policy CE7.1, p. 3.5-14.
84 2013 Housing Element, p. 28.
85 2013 Housing Element Policy 1.9, p. 29.
86 See 2010 LUCE p. 2.5-13 (stating that each activity center overlay requires the
preparation of an area plan, and that activity center overlays can provide up to one
additional residential story).
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development agreement projects.87 The Tier 3 development agreement FAR and height
bonus described for each of the original Activity Centers in the 2010 LUCE is as follows:
Potential Bonus in 2010 LUCE for Tier 3 Development Agreement Projects
Wilshire/Centinela Wilshire/14th Memorial Park Broadway/Colorado Lincoln/Ocean Park
Height 10' 10' 10' 10' 10'
FAR 0.5 FAR 0.5 FAR 0.75 FAR 0.75 FAR 0.75 FAR
2. Post-2010 LUCE Amendments Concerning the Activity Centers.
But since the LUCE’s adoption in 2010, the City has amended the LUCE to
eliminate all of the Activity Centers except for the Memorial Park Activity Center Low
Overlay.88 Although the Memorial Park Activity Center Low Overlay remains in the
LUCE, our understanding is that the City has no current plans to revive the planning
process for this area plan (i.e., the Memorial Park Neighborhood Plan).
Moreover, some of these sites have been downzoned further. For example, the
two Activity Centers on Wilshire Boulevard (14th & Wilshire, and Wilshire & Centinela)
were subject to elimination of Tier 3 for all but 100% affordable housing projects and
projects that preserve a historic resource.89
Notwithstanding the LUCE and Housing Element’s clear intentions to make the
Activity Centers key areas for housing development, we are not aware of any housing
built at any of the Activity Center sites since adoption of the LUCE in 2010.
87 Note that it’s not clear whether the FAR bonus described in the LUCE was
meant to describe what a Tier 3 project could achieve in comparison to a Tier 2 project,
or whether it was meant to describe what a Tier 3 project in the Activity Center overlay
area could achieve in comparison to Tier 3 projects with the same underlying zoning
designation. Obviously, this makes a difference as to whether this bonus would provide
a meaningful development incentive.
88 A small Activity Center is still contemplated for the Memorial Park Area near
the 16th Street/Colorado Light Rail Station. See 2017 LUCE, p. 2.5-3.
89 LUCE, p. 2.1-39.
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3. Recommended Action Steps for Activity Centers.
The City should amend the LUCE to increase the potential for housing
development as originally envisioned in 2010. The Housing Element update should
commit the City to restoring the four Activity Centers that were removed from the 2010
LUCE. Moreover, instead of requiring area plans for the Activity Centers (which would
likely take years to develop), development incentives for these areas should be
established in the LUCE and Zoning Ordinance and should be targeted towards
housing. (One mechanism for doing so is a housing overlay zone.) As the 2010 LUCE
recognized, these sites are situated and sized in a way that can accommodate a greater
intensity of development.
E. Residentially-Zoned Lots Currently in Commercial Use as Surface Parking
Supporting Existing Businesses On Adjacent Commercially-Zoned Lots.
1. City Land Use Regulations Affecting Residentially-Zoned Parking Lots.
The City has a significant number of existing residentially-zoned parking lots in
areas adjacent to commercial businesses which provide parking for these businesses.
Common examples include large parking lots adjacent to Wilshire Boulevard that serve
grocery stores and other businesses (e.g., Vons at Wilshire/Euclid and Bristol Farms at
Wilshire/Berkeley). Other examples are the large parking lots that serve auto dealers
along Santa Monica Boulevard.
Many of these parking lots were remapped to a commercial district as part of the
2010 LUCE. But since 2010 those zone changes have generally been reversed through
a remapping process that returned these parking lot sites to their former residential
zoning (typically R-2 or R-3). The apparent purpose of these remappings was to prevent
these sites from being redeveloped with commercial uses, but the unintended
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consequence has been to preserve them as surface parking lots for adjacent
commercial uses and render it impractical to redevelopment them with housing. This is
because the new residential zoning classifications (e.g., R-2 or R-3) permit far less
housing than the 2010 LUCE’s commercial designations, and lot consolidation is
generally prohibited in the residential districts.90
SMHC believes that many of these sites have significant potential for new
housing development if the City would only adopt land use regulations that would
encourage housing.
2. Recommended Action Steps for Existing Residentially-Zoned Parking Lots
Supporting Commercially-Zoned Lots.
To make the City’s residentially-zoned parking lots attractive to housing builders,
the City should revise the Municipal Code to incentivize redevelopment of these
properties (and their adjacent commercially-zoned lots) with housing. Specifically,
SMHC recommends that the City adopt one or more housing overlay zones covering
these lots that makes housing development attractive (both from a Code and financial
perspective). SMHC recommends land use regulations that would allow housing to be
built according to development standards tailored for such sites, including specifically
encouraging comprehensive redevelopment of the R-zoned surface parking lots with the
adjacent/associated commercially-zoned property that the surface parking is currently
supporting. Specifically:
90 See SMMC § 9.21.030(B) (stating that except for 100% affordable projects
residentially-zoned parcels generally may not be consolidated so as to create a lot
larger than 7,500 sf or greater than 125% of the average parcel size within a 500’ radius
in the same zoning district, whichever is less).
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Allow heights and densities at or near what are allowed on the adjacent
commercial boulevards;
Eliminate or modify the other barriers in the Zoning Ordinance that
preclude these sites from being redeveloped with housing projects,
including but not limited to:
o The restriction on continued use of the R-zoned lot with the
commercially-zoned lots if the commercially-zoned lot is
redeveloped, expanded or changes use;91
o The requirement that parking for any addition on the commercially-
zoned lots be located only on the commercially-zoned lots92 (i.e.,
parking for a new housing project should be able to span both the
R-zoned lot and the commercially-zoned lot);
o The anti-lot consolidation provision for such R-zoned sites;93 and
o The requirement that vehicular access for any redevelopment occur
on the commercially-zoned lot (which in some cases is physically
impossible because access is blocked by an existing building).94
The City should also allow for on-site replacement of the existing parking
as part of a new housing project to ensure the adjacent businesses remain
viable and have adequate parking. (Otherwise the new housing project
would likely be infeasible.)
91 SMMC § 9.27.110(A)(1) & (3) and § 9.16.020(B)(1) & (3).
92 SMMC §§ 9.27.110(A)(1)(5) & 9.16.020(B)(4).
93 SMMC § 9.21.030(B).
94 SMMC § 9.16.080(D).
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F. Public Lands.
The City and other public agencies have significant land holdings. Some of these
sites owned by public agencies are potentially appropriate for new housing
development. As part of the City’s 6th Cycle Housing Element process, the City should
inventory publicly-owned sites that may be appropriate for new housing and explore the
land use regulatory reforms that would be needed to facilitate new housing at these
sites.
G. Density Bonus Law.
The State Density Bonus Law95 (SDBL) requires cities to provide additional
density and other incentives and concessions to housing developers who agree to
provide specified levels of affordable housing in their projects. The SDBL was recently
updated with changes that will take effect on January 1, 2021.96
Under the updated version of the SDBL, the City will be required to grant one
density bonus, and other incentives or concessions, when an applicant for a housing
development seeks and agrees to construct a project, excluding any units permitted by
the density bonus, that will consist of:
At least 10% of units for low income households;97
At least 5% of units for very-low income households;98 or
95 Gov’t Code §§ 65915-65918.
96 See Assembly Bill 2345 (2020).
97 Gov’t Code § 65915(b)(1)(A).
98 Gov’t Code § 65915(b)(1)(B).
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At least 10% of units in a common interest development for moderate
income households.99
A density bonus and incentives or concessions must also be provided for certain
types of senior housing,100 housing for various other vulnerable groups,101 housing for
low-income students,102 and 100% affordable projects.103
Density bonuses range from 20% to 50% (and up to no limits on density for
certain 100% affordable projects) depending on the amount and type of affordable
housing provided.104 A project can request no increase in density and still be eligible for
incentives, concessions and waivers under the SDBL.105
Projects eligible for density bonuses are also eligible for one to three “incentives
and concessions” depending on the amount of affordable housing provided, with 100%
affordable projects eligible for up to four.106 Incentives and concessions can include “[a]
reduction in site development standards or a modification of zoning code requirements
or architectural design requirements,” among other regulatory concessions.107
99 Gov’t Code § 65915(b)(1)(D).
100 Gov’t Code § 65915(b)(C).
101 Gov’t Code § 65915(b)(1)(E).
102 Gov’t Code § 65915(b)(1)(F).
103 Gov’t Code § 65915(b)(1)(G).
104 Gov’t Code § 65915(f).
105 Id.
106 Gov’t Code § 65915(d)(2).
107 Gov’t Code § 65915(k).
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Additionally, projects eligible for a density bonus are entitled to specified parking
incentives.108
City compliance with the SDBL is mandatory; the City is required to provide the
SDBL’s regulatory benefits to projects that meet the statutory criteria notwithstanding
any local ordinances. The SDBL applies in the City’s commercial districts as well as in
residential areas.109
The City should implement the updated SDBL provisions both as a matter of law
and as good public policy to facilitate greater production of housing. The Housing
Element update should include clear and unequivocal City commitments to: (1) comply
with the SDBL throughout the City, including in commercial zoning districts that regulate
density by Floor Area Ratio (FAR), and (2) update a SDBL implementing ordinance as
an urgent priority.
H. Streamline Procedures for Reviewing Housing Projects.
As part of its 6th Cycle Housing Element Update, the City should take further
steps to streamline its housing project review procedures.
A recent first step was to eliminate the previous requirement of development
agreements for certain Tier 3 housing projects in Downtown Santa Monica.110 In doing
108 Gov’t Code § 65915(p)(1).
109 The SDBL’s requirements regarding the provision of incentives or
concessions apply for eligible projects throughout the City and are not limited to any
specific zones or land use designations. Additionally, the City should provide FAR
bonuses for eligible projects in commercial zones to implement the SDBL’s density
bonus provisions where density is not measured by dwelling units per acre..
110 See Santa Monica Ordinance No. 2648 (CCS), which allows all Tier 3
Projects in Santa Monica’s Downtown to be processed by Development Review Permit.
Prior to passage of Ordinance No. 2648 (CCS), only Tier 3 projects of 90,000 square
feet or less could be processed by Development Review Permit.
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so, the City Council recognized that requiring a DA essentially eliminated the possibility
of Downtown Tier 3 housing projects; project applicants would choose to pursue
entitlements for smaller Tier 2 projects in order to avoid the uncertainty, delay cost and
one-sided “negotiations” of the DA process. The City should follow up on this Downtown
reform by eliminating DAs for Tier 3 projects City-wide.
Additionally, the City should expand its use of Administrative Approvals by raising
the development review threshold in each land use district to allow conventional 1 to 3
lot projects to proceed via Administrative Approval if they comply with the City’s
development standards. Given the Housing Accountability Act,111 requiring such
housing projects to undergo the more costly and time-consuming Development Review
Permit process serves no public purpose.112 And allowing such projects to proceed via
Administrative Approval will incentivize such projects in comparison to the alternative of
commercial development.
And the Administrative Approval process should be further streamlined.
Currently, Administrative Approval for many projects requires three separate public
meetings. A community meeting must be held before an application may even be
submitted.113 Next, after an application is submitted, a preliminary ARB hearing is
111 Gov’t Code § 65589.5.
112 See David Zahniser, L.A.’s Rejection of a 577-Unit Housing Project Violated
State Law, Judge Finds, Los Angeles Times (Nov. 13, 2020)
https://www.latimes.com/california/story/2020-11-13/district-square-ruling-los-angeles
(discussing recent decision by Los Angeles Superior Court Judge James C. Chalfant
that the City of Los Angeles violated the Housing Accountability Act by rejecting a
project that complied with objective standards based on subjective concerns about
gentrification).
113 See SMMC § 9.39.040(A) (as amended by Interim Zoning Ordinance
No. 2645).
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required for an initial design recommendation.114 Finally, before a building permit is
issued, the project must go back to the ARB for final approval.115
While most applicants are happy to receive community feedback, the required
community meeting should occur after an application for Administrative Approval is
submitted. Requiring a public meeting before submission needlessly extends approval
timelines and drags out what is supposed to be a streamlined, truncated process.
The requirement of multiple ARB hearings should also be reconsidered. The City
should either eliminate the second required hearing or grant the ARB discretion to waive
the second hearing after the preliminary review.
The Administrative Approval process should also be required to be completed
within 45 days after submission of a complete application.
I. Parking Minimums.
Excessive parking minimums for residential projects stifle housing development
by folding the costs of driving into the costs of housing, ultimately reducing both the
amount and variety of available housing.116 These effects are especially pronounced in
areas (such as Santa Monica) with many small lots and high land values.117 “When
cities require on-site parking with every unit, developers cannot build housing explicitly
114 See SMMC § 9.39.040(B) (as amended by Interim Zoning Ordinance
No. 2645).
115 SMMC § 9.52.120(A).
116 Michael Manville, Parking Requirements and Housing Development:
Regulation and Reform in Los Angeles, Access Magazine, No. 44 (Spring 2014),
https://www.accessmagazine.org/spring-2014/parking-requirements-housing-
development-regulation-reform-los-angeles/.
117 Id.
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for people without cars (who are often low-income), or for people who own cars but are
willing to park off-site.”118
Recognizing this reality, Santa Monica wisely decided to eliminate parking
minimums for new development in the Downtown in 2017, and imposed parking
maximums for the DCP Area.119 At the time, former Councilmember Ted Winterer
noted:
Parking has a much broader impact on a city than you might
expect. It’s expensive to build, it incentivizes car travel over
public and active transportation, and it’s been built with
abandon, especially in Southern California. Studies show
drivers are more open to using public transit, walking or
cycling when there’s less access to cheap and easy
parking.120
Eliminating parking minimums in the Downtown was a good start, but the City
has failed to apply the logic behind this decision to the rest of the City, much of which is
still saddled with excessive parking requirements that stifle new housing development.
Today, residential parking minimums outside of the Downtown are essentially the same
as what they were under the 1988 Zoning Ordinance.121 These minimums are not
empirically linked to actual parking demand in the City according to the City’s own hired
118 Id.
119 SMMC Table 9.28.060; Ted Winterer, Why Santa Monica got rid of parking
minimums downtown. And why other cities should consider following suit, LA Times
(Sep. 25, 2017) https://www.latimes.com/opinion/livable-city/la-ol-santa-monica-parking-
minimum-density-transit-20170924-story.html
120 Id.
121 See standards in SMMC Table 9.28.060 compared with those in 1988 Zoning
Ordinance Table 9.04.10.08.040.
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consultants.122 Moreover, in the decades since these parking requirements were
established, non-vehicular transportation options have grown considerably throughout
the City.
Three new light rail stops have come to the City, including two outside of the
Downtown.123 Big Blue Bus service routes have been modified to provide connectivity to
the new rail stations.124 Additionally, the City has made substantial investments in bike
infrastructure. A Bike Action Plan adopted in 2011 expanded protected bike paths,
lanes, and routes, and brought other critical bike infrastructure to the City,125 and an
update to the Plan approved this year will bring additional infrastructure, including 19
new miles of protected bike lanes over the next 5 years.126 The Municipal Code also
now requires bicycle parking in all new or expanded buildings,127 and new
nonresidential buildings are required to include showers, lockers, and changing rooms
122 See Nelson/Nygaard Consulting Associates, Inc., Parking Zoning Ordinance
Update, Draft Report (City of Santa Monica, Jan. 2013) p. 2-6.
123 See Metro Expo Line Extension Map,
http://media.metro.net/projects_studies/exposition_phase2/images/map_expo_line_pha
se2_2016-03.pdf.
124 The Evolution of Blue has Begun. Ride With Us,
https://www.bigbluebus.com/About-BBB/Evolution-of-Blue/The-Evolution-of-Blue-has-
begun--Ride-with-Us-.aspx.
125 See Santa Monice Bike Actin Plan (Nov. 2011)
https://www.smgov.net/uploadedFiles/Departments/PCD/Plans/Bike-Action-
Plan/Bicycle-Action-Plan.pdf.
126 City Council Adopts Plan to Bring More Protected Bike Lanes to Santa
Monica, City of Santa Monica (Oct. 14, 2020)
https://www.santamonica.gov/press/2020/10/14/city-council-adopts-plan-to-bring-more-
protected-bike-lanes-to-santa-monica.
127 SMMC § 9.28.140.
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to encourage cycling as a viable mode of transportation.128 The recent rise of electric
bicycles has further elevated cycling as a viable alternative to local car travel.129
People are more likely to forego cars for these alternative modes of
transportation when there is less access to parking.130 Therefore, SMHC recommends
that the City remove all parking minimums for residential development throughout
Santa Monica or, alternatively, dramatically reduce the existing (outdated) parking
minimums based on an empirical study prepared by a respected parking/mobility
consultant. This step would make housing less expensive and easier to develop and
incentivize residents to utilize the City’s relative wealth of alternative transportation
options.
J. Unit Mix Requirements.
Another way the City stifles residential development is through burdensome unit
mix requirements for residential projects that exceed base (Tier 1) heights and
densities. In addition to providing high percentages of affordable units, applicants for
residential developments seeking additional height and density must ensure that at least
15% of market rate units are three-bedrooms, and 20% of market rate units are two-
128 SMMC § 9.28.170.
129 John MacArthur, Michael Harpool, Daniel Scheppke, & Christopher Cherry,
A North American Survey of Electric Bicycle Owners, Portland State Univ. Transp.
Research & Educ. Ctr. (2018) p. 19, https://www.calbike.org/wp-
content/uploads/2019/02/A-North-American-Survey-of-Electric-Bicycle-Owners.pdf.
130 Ted Winterer, Why Santa Monica got rid of parking minimums downtown. And
why other cities should consider following suit, LA Times (Sep. 25, 2017)
https://www.latimes.com/opinion/livable-city/la-ol-santa-monica-parking-minimum-
density-transit-20170924-story.html
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bedrooms.131 No more than 15% of units may be studios, and the average number of
bedrooms for a Tier 2 or Tier 3 project must be at least 1.2.132 The average number of
bedrooms for affordable units must be equal to or greater than that of the project’s
market rate units.133
While it is understandable for the City to aim to provide a greater share of two
and three-bedroom units in new developments to cater to the needs of families with
children, these requirements, when paired with excessive AHPP inclusionary mandates,
can render projects infeasible, and encourage developers to under-develop sites with
Tier 1 projects.
While there are certain areas of the City where the current required unit mixes
may make sense, SMHC recommends that the City consider removing or revising its
unit mix requirements for Tier 2 and Tier 3 projects in areas that are less attractive to
families with children (such as the Downtown, Bergamot, and certain MUB-designated
areas). This step could give residential developers greater flexibility to produce more
market-rate and affordable housing in places where studio and one-bedroom units are
in demand.
K. “High-Rise” Definition.
The City should revise its “high-rise” definition to be consistent with the California
Building Code (CBC)’s definition. The City’s current definition of a high-rise is 55 feet,
whereas the CBC’s definition (which has been adopted by the City of Los Angeles) is 75
131 See SMMC § 9.23.030(A)(2) (for most of the City) and SMMC
§ 9.10.070(C)(1)(b) (for Downtown districts).
132 Id.
133 Id.
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feet.134 Because of the substantial increase in construction costs for buildings
categorized as “high-rise,” Santa Monica’s lower threshold has been a barrier to
housing production and to providing useable roofdeck open space for residents. We
are aware of both 100% Affordable Housing projects and mixed-income projects that
have foregone a floor or more of much needed housing and/or the development of roof-
top open space in order to avoid triggering the additional construction costs associated
with “high-rise” construction. We are not aware of any safety or other empirical reason
why Santa Monica has a lower high-rise definition than Los Angeles or the CBC and ask
that it be revised to be in alignment so that it no longer serves as a constraint on
housing.
III.
THE CITY’S 6th CYCLE HOUSING ELEMENT UPDATE
AND AFFORDABLE HOUSING
The City’s new RHNA allocation of 8,873 units includes a substantial allocation
for affordable housing. Specifically, the City’s RHNA allocation is broken down into
segments as follows:
2,787 units for very-low income households;135
1,668 units for low income households;136
1,698 units for moderate income households;137 and
2,720 units for above-moderate income households.138
134 See SMMC § 8.44.090; 2019 CBC § 314.1; LAMC § 94.210.0 H.
135 Infra n.4.
136 Id.
137 Id.
138 Id.
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Achieving the City’s RHNA affordable housing allocation will be challenging. To
maximize its chances of success, the City will need to adopt and implement an
aggressive affordable housing strategy that includes the following components:
1. The City needs to provide 100% affordable housing projects with
substantial height and density bonuses in comparison to market-rate housing projects.
An important first step is to comply with State-mandated incentives for 100% affordable
housing projects. The City also needs to adopt additional height and density incentives,
over and above those mandated by State law, for 100% affordable housing projects.
2. 100% affordable housing projects usually require substantial financial
subsidies to be economically viable. As the City recovers from its COVID-19-related
budget crisis, the City will need to devote substantial funds to affordable housing --
much more than in the past. Although the City should lobby the State aggressively for
substantially increased affordable housing funding, the City should not wait for the State
to take action; the City needs to take the initiative on its own to address Santa Monica’s
need for affordable housing.
3. The affordable housing requirements for new market-rate housing
projects, as provided in the AHPP, must be set at a rate that generates affordable
housing without serving as a barrier to market-rate housing development. The City’s
current approach of attempting to achieve 15-30% on-site affordable housing has
impeded housing development. The City needs to adjust its affordable housing
requirements to reflect projects that have been approved, financed and built.
Specifically, the City should incorporate the following AHPP reforms in its 6th Cycle
Housing Element:
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Reinstate the Affordable Housing Production Program’s Extremely-
Low Income (30%) Option either at 5% of the total units or at 7.5%
of the total units (Tier 2 would be 50% more);
Alternatively, require that Tier 1 projects provide 5% total units as
affordable and Tier 2 (or housing overlay-zoned) projects provide
10% total units as affordable and require that the affordable units
be subject to the same affordability level breakdown as Downtown
projects (i.e., 30% of the affordable units at Moderate Income, 30%
of affordable units at Low Income, 20% of the affordable units at
Very-Low Income and 20% of the affordable units at Extremely-Low
Income) or an adjusted breakdown based on the new RHNA
allocation.
4. The City should revise its definition of “Moderate Income Household” to
include households also covered by lower income categories. Currently the “Moderate
Income” definition only covers households that earn between 80% of area median
income (AMI) and the lower of 120% of AMI or two times 50% AMI.139 Households that
earn less than 80% of AMI are not included. This wording precludes Moderate Income
units from being offered to lower income tenants. In contrast, the other AHPP income
categories all encompass the categories below them as well.140 Most developers would
prefer to charge the higher rents allowed for the Moderate Income category, but some
projects that rely on special financing for affordable housing must offer specified
139 SMMC § 9.64.020(T).
140 See SMMC § 9.64.020(A)-(C).
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percentages of units to lower income tenants, and the income floor for Moderate Income
units can jeopardize funding. Therefore, the City should remove the 80% AMI income
floor for Moderate Income units to provide greater flexibility to affordable housing
developers.
As noted above, the City’s recent history with its Downtown affordable housing
requirements underscores the importance of these actions.
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Exhibit A
SANTA MONICA HOUSING COUNCIL’S RECOMMENDATIONS
FOR THE CITY OF SANTA MONICA’S
6TH CYCLE HOUSING ELEMENT PLAN OF ACTIONS
The Santa Monica Housing Council (“SMHC”) recommends that the City include
the following action steps in the City of Santa Monica’s 6th Cycle Housing Element in
order for the City to comply with California Housing Element Law, including its
requirement that the Housing Element identify suitable sites with the realistic potential to
achieve the City’s RHNA allocation of 8,873 units.
A. Downtown.
SMHC recommends the following action steps for the Downtown:
1. Adopt a housing overlay zone for areas in the Downtown Community Plan
where there are viable housing sites. These areas include the Neighborhood Village
(NV), Bayside Conservation (BC) (particularly the BC-Promenade sites that front on
Wilshire Boulevard and the BC - 2nd and 4th Streets subarea), Lincoln Transition, and
Wilshire Transition (particularly the sites that front on Wilshire Boulevard) subareas.
The housing overlay zone should provide substantial height and density bonuses for
housing projects in comparison to non-housing projects, with still further heights and
densities for 100% affordable housing projects and preservation projects.
2. Reform the Downtown’s Affordable Housing Production Program (“AHPP”)
requirements as follows:
Tier 1 housing projects - reinstate the Extremely-Low Income
Option at up to 10% of the total units.
Tier 2 and 3 (and housing overlay-zoned) housing projects -
eliminate the current scheme which ties increases in the affordable
housing requirement to various height increments (Zoning
Ordinance Table 9.10.070.A) and has resulted in almost no new
housing projects. Institute affordable housing requirements based
on percentages that have been demonstrated as feasible in other
Downtown housing projects, including:
o 15% for Tier 2
o 20% for Tier 3
3. Eliminate the prohibition on ground floor residential units that is currently
in place for every Downtown subarea except for the Neighborhood Village, with limited
exceptions (e.g., the Promenade). (Table 9.10.040, Specific Limitation (1).) This
prohibition unnecessarily constrains how many residential units can be located on a site
and can hurt the overall economic feasibility of housing projects.
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B. The Commercial Boulevards.
SMHC recommends the following action steps for the Boulevards:
1. Consistent with HCD guidance,1 adopt housing overlay zones on the
Boulevards that increase allowable heights and densities for housing projects to, at a
minimum, the levels allowed in the 2010 LUCE, and consider additional height and
density increases as reasonably necessary to make housing the highest and best use
on the Boulevards and facilitate a suitable sites inventory that complies with California
Housing Element Law. Specific areas that appear to have potential for increased height
and density standards for housing projects include:
Lincoln Boulevard south of the I-10 Freeway
Wilshire Boulevard, Lincoln to Centinela
Broadway, Lincoln to 26th
Memorial Park Neighborhood Plan area, including Colorado
Santa Monica Boulevard between Lincoln and 20th Street and east
of 26th Street
Pico Boulevard between Lincoln and Centinela2
2. Allow ground floor residential units (eliminating the Active Use
Requirements included in SMMC Section 9.11.030(A)(2), with limited exceptions for
locations where retail/pedestrian-oriented uses should be required.
3. And provide still further heights and densities for 100% affordable housing
projects and preservation projects.
C. Bergamot.
The Housing Element update should commit the City to expedite a housing
overlay amendment to the BAP that creates substantial height and density incentives for
those areas of Bergamot that are deemed appropriate for housing (with additional
height and density incentives for 100% affordable housing projects) to make housing
the highest and best use in those areas targeted for housing.
1 Megan Kirkeby, Housing Element Site Inventory Guidebook and Memorandum
Regarding Government Code Section 65583.2, Cal. Dep’t of Hous. & Community Dev.
(June 10, 2020) p. 15.
2 The City may wish to prohibit housing in the areas on Pico that are in very close
proximity to the I-10 Freeway.
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D. Activity Centers.
The City should include a commitment in the Housing Element Update to restore
the four Activity Centers that were removed from the 2010 LUCE. Instead of requiring
area plans for the Activity Centers (which would likely take years to develop),
development incentives for these areas should be established in the LUCE and Zoning
Ordinance and should be targeted towards projects that are predominantly housing.
One mechanism for doing so is a housing overlay zone.
E. Residentially-Zoned Lots Currently in Commercial Use as Surface Parking
Supporting Existing Business On Adjacent Commercially-Zoned Lots.
The City has a significant inventory of residentially-zoned lots that are in surface
parking use for adjacent commercial uses. SMHC recommends that the City adopt one
or more housing overlay zones covering these lots that makes housing development
feasible (both from a Code and financial perspective). SMHC recommends a housing
overlay zone that would allow housing to be built according to development standards
tailored for such sites, including specifically encouraging comprehensive redevelopment
of the R-zoned surface parking lots with the adjacent/associated commercially-zoned
property that the surface parking is currently supporting. Specifically, SMHC
recommends:
Heights and densities at or near what are allowed on the adjacent
commercial boulevards;
Eliminate or modify the other barriers in the Zoning Ordinance that
preclude these sites from being redeveloped with housing projects,
including but not limited to:
o The restriction on continued use of the R-zoned lot with the
commercially-zoned lot if the commercially-zoned lot is
redeveloped, expanded or changes use (Sections 9.27.110(A)(1)
and (3) and Section 9.16.020(B)(1) and (3));
o The requirement that parking for any addition on the commercially-
zoned lot be located on the commercially-zoned lot (Section
9.27.110(A)(1)(5) and Section 9.16.020(B)(4)) (parking for a new
housing project should be able to span both the R-zoned lot and
the commercially-zoned lot);
o The anti-lot consolidation provision for such R-zoned sites (SMMC
§ 9.21.030(B); and
o The requirement that vehicular access for any redevelopment be on
the commercially-zoned lot (SMMC Section 9.16.080(D)).
Allow for on-site replacement of the existing parking to ensure the
adjacent businesses remain viable and have adequate parking.
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F. Public Lands
As part of the City’s 6th Cycle Housing Element process, the City should
inventory publicly-owned sites that may be appropriate for new housing and explore the
land use regulatory reforms that would be needed to facilitate new housing at these
sites.
G. Citywide: Implement State Density Bonus Law.
SMHC recommends that the City’s Housing Element update should include a
City commitment to comply with the State Density Bonus Law throughout the City,
including in commercial zoning districts that regulate density by Floor Area Ratio (FAR).
In areas where density is not measured by dwelling units per acre, an FAR bonus
should be provided to eligible projects.
H. Project Review Procedures.
SMHC recommends the following reforms to the City’s project review
procedures:
1. Review and revise the Administrative Approval threshold in each district to
accommodate projects at the maximum allowable FAR on sites up to three lots in size
(generally, about 22,500 square feet of land area).
2. All projects above the Administrative Approval threshold should be subject
to the City’s Development Review Permit Process; similar to the City Council’s recent
decision with respect to Downtown, no housing project (regardless of tier or size) should
require a development agreement.
3. The Administrative Approval process should be further streamlined. The
required community meeting should be held after (not before) an application is
submitted, and the City should either remove the requirement for a second ARB
hearing, or allow the ARB to waive the second hearing when it first reviews a project.
4. The Administrative Approval process should have a deadline to be
completed within 45 days after submission of a complete application.
I. Parking.
The City should remove all parking minimums for residential development
throughout Santa Monica or, alternatively, dramatically reduce the existing (outdated)
parking minimums based on an empirical study prepared by a respected
parking/mobility consultant.
J. Unit Mix Requirements.
SMHC recommends that the City remove or revise its unit mix requirements for
Tier 2 and Tier 3 projects in areas that are less attractive to families with children (such
as the Downtown, Bergamot, and certain MUB-designated areas).
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K. “High-Rise” Definition
SMHC recommends that the City revise the Municipal Code’s definition of “high-
rise,” which currently covers all buildings more than 55 feet tall, to cover only buildings
more than 75 feet tall in line with the provisions of the California Building Code and the
codes of neighboring jurisdictions.
L. Affordable Housing.
SMHC believes that to meet its obligations under the California Housing Element
Law, the City needs to adopt the following reforms to its affordable housing policies:
1. The City needs to provide 100% affordable housing projects with
substantial height and density bonuses in comparison to market-rate housing projects.
An important first step is to comply with State-mandated incentives for 100% affordable
housing projects. The City also needs to adopt additional height and density bonuses,
over and above those mandated by State law, for 100% affordable housing projects.
2. 100% affordable housing projects require substantial financial subsidies to
be economically viable. As the City recovers from its COVID-19-related budget crisis,
the City will need to devote substantial funds to affordable housing -- much more than in
the past.
3. The affordable housing requirements for new market-rate housing
projects, as provided in the AHPP, must be set at a rate that generates affordable
housing without serving as a barrier to market-rate housing development. Specifically,
the City should incorporate the following AHPP reforms in its 6th Cycle Housing
Element:
Reinstate the Affordable Housing Production Program’s Extremely-
Low Income (30%) Option either at 5% of the total units or at 7.5%
of the total units. (Tier 2 would be 50% more.)
Alternatively, require that Tier 1 projects provide 5% total units as
affordable and Tier 2 (or housing overlay-zoned) projects include
10% total units as affordable and require that the affordable units
be subject to the same affordability level breakdown as Downtown
projects (i.e., 30% of the affordable units at Moderate, 30% of
affordable units at Low Income, 20% of the affordable units at Very-
Low Income and 20% of the affordable units at Extremely-Low
Income) or an adjusted breakdown based on the new RHNA
allocation.
4. The City should revise its definition of “Moderate Income Household” to
include households also covered by lower income categories to provide greater
flexibility and access to financing for affordable housing developers.
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Vernice Hankins
From:Kimberley H <mskimberleyl@hotmail.com>
Sent:Sunday, March 28, 2021 4:11 PM
To:councilmtgitems
Subject:The People Concern
EXTERNAL
The People Concern is very important because they are here to serve the people of the community. They
provide housing, counseling, resources and linkage to long‐term care. Not only do they support their clients
while they are living in their interim housing facilities but once they are permanently housed, case managers
continue to work with them as needed on an individual basis. It is crucial we keep this program going. They are
doing their part to take people off the streets and provide them with a roof over their heads which they can
call their own. Please give The People Concern your support.
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Vernice Hankins
From:Matthew Stevens <mastevens0131@gmail.com>
Sent:Monday, March 29, 2021 3:52 PM
To:Sue Himmelrich; Councilmember Kevin McKeown; Gleam Davis; Kristin McCowan; Christine Parra;
Oscar de la Torre; Phil Brock
Cc:councilmtgitems
Subject:Item 8-A
EXTERNAL
Dear City Council,
As part of your discussion tomorrow night, I urge you to listen to the comments from Planning Commissioner Nina
Fresco regarding the history of racism, exclusion, and segregation in Santa Monica's land use decisions. She did
extensive research on this over the summer and I believe her comments should be required viewing for anyone wanting
to opine on Santa Monica's land use decisions.
Youtube link here:
https://youtu.be/32YBVr3P1_8?t=4924
Commissioner Fresco suggested several things including expanding R2 into R1 districts, and incentivizing housing on
Montana Avenue and Ocean Park Boulevard. I think those are excellent suggestions and urge you to direct staff to move
forward along those lines.
Regards,
Matt Stevens
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Vernice Hankins
From:Jason Mastbaum <jason.mastbaum@gmail.com>
Sent:Monday, March 29, 2021 3:48 PM
To:Gleam Davis; Phil Brock; Christine Parra; Councilmember Kevin McKeown; Sue Himmelrich; Kristin
McCowan; Oscar de la Torre
Cc:councilmtgitems; Compliance Review@HCD
Subject:City Council Meeting 3/30/2021 Item 8A
EXTERNAL
Dear city councilmembers,
I have been following the Housing Element Update, including the materials presented during the Planning Commission's
meetings two weeks ago. I submitted comments to the Planning Commission regarding concerns I had with the
Summary Report on Preliminary Suitable Sites Inventory Analysis, and I see in the materials posted for the council
agenda tomorrow that those concerns have not been addressed, so I am writing to the city council to urge you to direct
the Planning Commission to address these points to create a more realistic Housing Element plan which will both meet
the city's legal obligations under the RHNA, and making sure Santa Monica actually gets the housing production it so
urgently needs.
As I noted to the Planning Commission, a review of the Summary Report on Preliminary Suitable Sites Inventory Analysis
reveals a number of deficiencies. One is the inclusion of projects which appear to not actually exist. For example, 13 unit
apartment building at 1211 12th St is listed as "approved" in the Inventory Analysis, yet there is no such project listed on
the city's own Plans and Projects website. This is also not the only such apparently nonexistent project listed in the
Inventory Analysis. https://www.smgov.net/departments/pcd/plans‐projects/
Another is the inclusion of a number of extremely unrealistic sites. A proposal for major development at the Bergamot
Arts Center in 2015 caused so much political blowback that the city council wound up stepping in to keep it from
happening; why does the Commission think this would not happen again? Page 21 of the Inventory Analysis lists a
number of sites which the city does not actually control‐‐did anyone on the Commission bother to ask UCLA, SoCal
Edison, or the Santa Monica Malibu Unified School District whether these sites would ACTUALLY be made available for
housing construction? Or were these sites listed precisely because they would let the city meet the RHNA requirements
on paper while being able to be confident that no housing will ever actually be built on those sites?
I cannot imagine that HCD will look favorably on what appears to be multiple attempts to game meeting our RHNA
requirement on paper but which is likely to not actually result in housing production when determining whether Santa
Monica is in compliance, and I hope the city council will give the Planning Commission appropriate guidance on coming
back with a realistic plan.
I will remind the city councilmembers that it will not be difficult for HCD to get context on what the intent is if an
unrealistic plan is submitted, especially since I've cc'ed them on this email. Planning Commissioner Mario Fonda‐
Bonardi, for instance, has repeatedly attacked the RHNA requirements as not just "bogus":
https://smmirror.com/2020/12/santa‐monica‐under‐scags‐boot/
but, in his words, "the greatest fraud perpetrated on all of California and particularly SM":
https://www.surfsantamonica.com/ssm_site/the_lookout/news/News‐2020/October‐
2020/10_13_2020_Mario_Fonda_Bonardi_Candidate_Questionnaire.html
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Councilmember Phil Brock, when asked by local news media if we should meet our RHNA requirement, simply said "no".
https://surfsantamonica.com/ssm_site/the_lookout/news/News‐2020/October‐
2020/10_13_2020_Phil_Brock_Council_Questionnaire.html
Councilmember Christine Parra has explicitly said "the city cannot comply with this requirement".
http://www.wilmont.org/resident‐actions/neighborhood‐council‐2020‐city‐council‐questionaire
Councilmember Oscar de la Torre has said that our RHNA requirement is "unattainable".
http://www.wilmont.org/resident‐actions/neighborhood‐council‐2020‐city‐council‐questionaire
So again, HCD will have plenty of context for determining what the intention of the city government was if Santa Monica
submits a clearly unrealistic plan. I urge the city councilmembers to submit something realistic instead of getting the city
into an unwinnable fight with HCD that will only end with the city being deemed as noncompliant with the housing
element requirement and the ensuing loss of local control that will come with being deemed out of compliance.
Even without the RHNA requirement to meet, though, I would still be writing to urge the city council to make sure we
can build desperately‐needed housing in Santa Monica. As Mayor Himmelrich herself identified in an interview back in
2014, "I drive to Koreatown for my job in the mornings and I sail there in 20 minutes yet I see these people waiting to
get into Santa Monica and I feel for them. It’s terrible, but it’s because of our jobs/housing imbalance."
https://smmirror.com/2014/12/up‐front‐with‐sue‐himmelrich‐incoming‐santa‐monica‐councilwoman/
Having more residents will not increase our traffic. Our traffic, as Mayor Himmelrich noted, is a direct result of Santa
Monica not having anywhere near sufficient housing for its workforce. Even pre‐pandemic, my experience was always
that driving around *within* Santa Monica at 5 PM was fine, the traffic was consistently confined to the freeway and in
the immediate vicinity of the on‐ramps to the freeways. We as a city cannot claim to take climate change seriously if we
continue to refuse to make it possible for those people to live in Santa Monica instead of forcing them to drive in.
There would be numerous other benefits to allowing more housing as well. How much less would our sales tax revenue
have been impacted in March 2020 if more people lived here instead of only spending money here while for work? How
many Main St and Promenade businesses would still struggle if we increased the amount of natural foot traffic they get?
Does anyone seriously think there isn't a straight line from the fact that because we won't let more people live here, to it
being notoriously difficult to get into Santa Monica, to our businesses struggling because people simply aren't going to
shop at those businesses if they have to slog through traffic first to get to them?
Thank you for your time,
Jason Mastbaum
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Vernice Hankins
From:Leslie Lambert <leslielambert92@gmail.com>
Sent:Monday, March 29, 2021 1:13 PM
To:councilmtgitems
Cc:Sue Himmelrich; Kristin McCowan; Kevin McKeown Fwd; Gleam Davis; Oscar de la Torre; Phil Brock;
Christine Parra; David Martin; Jing Yeo; Andy Agle; James Kemper
Subject:Item 8A, March 30, 2021
EXTERNAL
I am writing this as a Santa Monica resident and am not representing the Planning Commission, nor do my views in many
cases reflect those of any organization with which I am affiliated. However, I do support the recommendations
submitted to you by the Planning Commission regarding the Housing Element. These recommendations, which are
found in the supplement to your staff report, were made after eight hours of public testimony and Commission
discussion. Let me also say that the Planning staff deserves a round of virtual applause for their excellent staff reports
and responsiveness to the public and the Commission. The community outreach program they designed and
implemented was broad‐based and certainly strengthens their staff work.
Santa Monica's history of racial, religious and ethnic exclusion is well‐documented and must be acknowledged and
redressed. This history should be in the curricula of our schools and acknowledged by our leaders. Commissioner
Fresco described our city's exclusionary past in stark detail at the March 17 meeting of the Planning
Commission. However, we also need to acknowledge that, since the late 1970's, Santa Monica has been a leader in
progressive housing policy. We must protect the protect the progress we have made by preserving our 27,000 rent
controlled units. At the same time, we need to acknowledge that the 2015 Zoning Ordinance update and its downzoning
was a step in the wrong direction from the standpoint of housing equity. Accessibility to Santa Monica's housing market
and achieving equity can only happen through a substantial increase in our housing supply. The following are my
recommendations.
Protect our rent controlled housing. Santa Monica voters passed one of the two most far‐reaching rent control laws in
the country in 1979. Even though the majority of our rent controlled housing has experienced at least one vacancy
decontrol rent increase, the median rents for rent controlled units are still far less than comparable rents in new market
rate projects. These units remain a housing resource for lower and middle income people. The 2010 LUCE prioritizes
neighborhood preservation as a goal in our land use decisions. For some, the term"neighborhood preservation" has
become synonymous with exclusion. For me, neighborhood preservation means protecting our rent controlled
housing. In the case of the Pico neighborhood, the term also means preserving that community by disincentivizing
gentrification.
Where should new housing be located? New housing construction should be targeted to the high resource commercial
areas of Santa Monica, i.e. areas that are within 1/2 mile of transit and jobs. The northern portion of the north of
Montana neighborhood and the southern portion of Sunset Park are not within this 1/2 mile radius. That said, there is
pressure to rezone our R1 neighborhoods as redress for years of exclusion. This is challenging because of real estate
values. These values are now what create our exclusionary housing market since the vast majority of the region's
households cannot afford to purchase a home in Santa Monica. The asking prices for single family "tear downs" are in
the millions. Ironically, Ocean Park, once red‐lined, is now one of the most pricey neighborhoods on the
Westside. Ninety percent of the single family parcels in Sunset Park are less than 7,000 square feet in size. How many
multi‐family units could these properties accommodate without a significant increase in allowable height. And maybe
not even then.
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With these land prices, the development of affordable housing in these neighborhoods is financially infeasible without
significant upzoning to bring per unit land costs within the realm of reason. Even developing housing that is affordable
to the "missing middle" would be unlikely without major upzoning. Further, the large majority of the rental units on
Montana Avenue, Ocean Park Boulevard and Pico Boulevard are rent controlled and should be protected. That said, the
redevelopment potential of the commercial areas of these streets should be pursued.
The importance of 100% housing projects. The City provided the seed money for the creation of Community
Corporation of Santa Monica, one of the most successful housing non‐profts in California. The City has assisted CCSM in
producing almost 2,000 long‐term affordable housing units since then. With no City housing funds, CCSM now has no
new projects coming into the pipeline. Assuming the same 40% affordable housing production through our inclusionary
programs and the same local per unit contribution to project feasibility ($300,000), $800 million would be needed to
meet our very low and low income RHNA numbers. This is clearly not going to happen.
Here are some ideas for meeting this challenge:
The City should immediately prioritize the use of all suitable City‐owned property for affordable housing
development. The City should also reach out to other public agencies with property suitable for affordable
housing development.
The City should execute interagency agreements with the County of LA to allow nonprofits to access the
County's Project Based Vouchers (PNV's). These subsidies greatly increase project revenues and would provide
nonprofits with access to conventional financing necessary for project development.
An increase in the City's housing staff levels is absolutely necessary to process 100% projects and to execute
interagency agreements necessary for leveraging housing funding.
The share of GS/GH funds devoted to housing by Santa Monica voters should be restored to the Housing Trust
Fund.
The City must lobby at the Federal and State levels for additional housing assistance, including a boost in Project
Based Vouchers.
The Role of Mixed Income Housing and Real World Inclusionary Requirements. The importance of mixed income
housing in meeting a portion of our RHNA affordable housing goals cannot be overstated. Since adoption of the
Affordable Housing Production Program in the early 1990's, forty percent of the affordable units produced in the city
were in mixed income projects. Our DCP and AHPP inclusionary programs must be reworked to reflect the realities of
today's development costs. Further, they should be based on incentivizing the development of mixed income housing
rather than based solely on feasibility. Corresponding FAR and height increases must accompany any changes to our
inclusionary requirements if additional affordable housing is to be produced.
Preference for Off‐Site Housing. Developers should be encouraged to meet their inclusionary requirements by
contributing to the development of 100% affordable housing projects. This is important because extremely low income
and very low income families need the wrap around support services provided by nonprofits in 100% projects. These
services cannot realistically be offered in mixed income projects. The location of these off‐site projects should be
allowed anywhere in the city except in areas where100% AH projects are already concentrated. Finally, developers of
smaller projects should be allowed to pool their inclusionary obligations.
TORCA 2.0. Homeownership is out of reach for the large majority of our existing renters and Santa Monica workers
who would like to live closer to their work and own a home. The City should re‐introduce an updated TORCA program,
enabling tenants to purchase their units.
Amendment of the Bergamot Area Plan (2013). The BAP disincentivizes housing projects larger than tier 1 because of
unworkable FAR and height limits. If the vision of the Plan is ever to be realized through payment of the cost of
community benefits, tier 2 and tier 3 development standards must be changed to incentivize, rather than discourage,
housing development.
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Density Bonus Law. We are still waiting for a density bonus program in commercial districts that better reflects State
Law. This is low hanging fruit since it is already State Law and would result in increased housing production.
Suitable Sites Inventory (SSI). The draft SSI is a listing of all potential housing sites in the city and their housing
development capacity. The SSI includes many properties for which there is no probability whatsoever of housing
development. These properties must be removed from the SSI and a more reality‐based housing capacity projection
prepared.
A question has been raised as to whether pending and entitled project unit counts should be discounted to reflect their
likelihood of development at full capacity. In the case of entitled projects, there is no question that these unit counts
should be used in the SSI. Discounting the number of units in pending projects, based on 5th Cycle trends, is also
questionable. Times have changed. The amended Housing Accountability Act is much stronger and prohibits a local
jurisdiction from denying a housing project, as proposed, if it is compliant with objective zoning and design standards. It
therefore makes little logical sense to discount the number of units in pending projects based on 5th Cycle trends.
It has also been pointed out that only 40% of our 5th Cycle RHNA units were produced on SSI properties, implying that
the City should plan for two and a half times its RHNA obligation in preparing the SSI. The fact that 500 of these units in
the 5th Cycle were projected on one site (Hines Project) questions the significance of this 40% production rate and the
need to plan for 150% more units than the RHNA numbers.
Traffic and other environmental concerns. The heavy traffic in Santa Monica is not caused by more residents since the
city's population has only increased by 0.7% since 2010. The major cause of traffic congestion is the fact that 91,000
people work in Santa Monica (pre‐COVID), but only 9% live here. Of those who commute to work in Santa Monica, 42%
make less than $40,000 per year. NInety‐one percent of the commuters cite high housing costs as the major barrier to
their living in Santa Monica. These numbers make it clear that increasing our affordable housing supply is critical from
the standpoint of reducing greenhouse gas emissions and enhancing the quality of life of our workforce. Other
environmental concerns have also been raised by the public. These issues will be addressed by the Draft EIR for the
Housing Element.
Thank you for your attention to this very important issue. I believe that the future of Santa Monica will be determined
by a meaningful and compliant Housing Element that addresses equity and accessibility through providing more housing
options.
Sincerely,
Leslie Lambert, Sunset Park Resident
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Vernice Hankins
From:Amy Anderson <ananderson27@outlook.com>
Sent:Monday, March 29, 2021 7:50 AM
To:councilmtgitems; Sue Himmelrich; Gleam Davis; Councilmember Kevin McKeown; Phil Brock;
Christine Parra; Kristin McCowan; Oscar de la Torre
Cc:Jing Yeo
Subject:Agenda Item No. 8A Housing Element Discussion - comments
EXTERNAL
Councilmembers,
Thank you for the opportunity to provide input on the Housing Element – a critical policy document given our region’s
current housing crisis. Thank you for investing your time and energy in seeking to create a document that is thoughtful,
effective, and responsive to our community’s severe need.
The need is so urgent that I would strongly encourage the Commission to recommend any and every policy that helps to
advance production, while also protecting the stability of current tenants. A direct line exists between a legacy of
policies that have discouraged housing development in Santa Monica as well as the region and the State at large and the
thousands of families and individuals who now reside in tents on sidewalks. We need more long‐term, restricted
affordable units to serve those that the market never will AND we need housing production generally to expand supply
and impact price.
Santa Monica has a deep history as a progressive City that is welcoming and committed to expanding opportunity.
Policies supporting more housing production are a bold and clear way to reaffirm those values.
Some suggested policies:
‐ Adopt policies that allow for waivers and concessions from development standards on commercial boulevards to
align with the approach of the State Density Bonus program.
‐ Make permanent the administrative approval process for zoning‐compliant housing / mixed‐use proposals,
including projects requesting waivers and concessions per the above suggestion
‐ Staff’s proposed AB1763‐like policy for 100% affordable housing projects, including moderate income, is great
and should also include provisions for waivers and concessions, like AB1763
‐ Align inclusionary requirements and development standards to incentivize (not just make feasible) housing
development, including reduced parking requirements near transit (similar to LA’s TOC program). Given the
intense need for affordable housing and more homes generally, I would urge a higher inclusionary requirement
accompanied by more flexible density and development standards. However, the two must be adjusted in
tandem.
‐ Eliminate unit mix requirements and increase inclusionary requirements to allow the development of smaller
units and a wider breadth of housing options.
‐ Given the effects of the current economic situation on retail and the general trend away from brick‐and‐mortar,
reduce the requirements for ground‐floor retail on commercial corridors.
‐ Allow greater flexibility in the location of off‐site “inclusionary” housing units
‐ Embark on an aggressive campaign to establish a permanent funding source to finance affordable housing
‐ Commit to redevelop all City‐owned properties within the next RHNA cycle, dedicating at least 50% of floor area
to affordable housing
‐ Support staff’s proposed ADU incentive program
‐ Note, First right of refusal programs, like San Francisco’s COPA, have significant administrative costs to
implement effectively
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Thanks for your commitment. Please remember that your decisions have the chance to create real solutions and directly
impact the lives of people struggling to contribute to our greater community.
Amy Anderson
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Michael E. Soloff 337 14th Street
Santa Monica, CA 90402 March 30, 2021
3/30/21 Agenda Item 8.A
Dear Mayor and Councilmembers: I write to urge you to issue the following guidance to Staff regarding its ongoing efforts to
prepare a draft 2021-2028 Housing Element:
First, Council should direct Staff to designate the 11 identified city-owned sites with high housing potential (Category 4 in the preliminary site survey) as sites for 100% affordable housing projects only (subject to adjustment later in the Housing Element process for open-space
uses as well at 4th / 5th and Arizona ). According to the Staff report, these public land sites have
the capacity under existing zoning (supplemented by State height and density bonuses for 100% affordable housing projects) for 7300 affordable housing units1, a figure well above the 5,587 shortfall between our deed-restricted affordable RHNA allocation and the already approved or pending deed-restricted affordable housing units that should come online during the 2021-2028
Housing Element period. Designation of these sites for 100% affordable housing projects will
demonstrate Santa Monica is deadly serious in its commitment to materially expanding affordable housing opportunities to those who need it the most—including our overcrowded and severely rent burdened low income residents, and our lower wage hotel, retail and restaurant workers whose labor in these key sectors generates the sales tax and TOT tax revenues that
contribute so fundamentally to the fiscal well-being of this City. Moreover, because designation
of public land for deed-restricted affordable housing is one of the key strategies for affirmatively furthering fair housing identified by the final report of the Lawyers’ Committee for Civil Rights (a report approved by Council),2 designating all 11 identified city-owned sites for 100% affordable housing would demonstrate that Santa Monica is deadly serious about taking
meaningful actions in response to that report. Furthermore, taking this approach will put the City
in the best position to demand that the State and the County put their money where their mouths are and likewise commit meaningful resources to materially expanding deed-restricted affordable housing in our high resource community.
Second, Council should direct the Staff to provide an update every two weeks on discussions
with the State and other public agencies to commit the DMV site at Colorado and Cloverfield, and other non-City public land for 100% affordable housing projects, so that they too can be included on the suitable sites inventory.
1 See Summary Report on Preliminary Sites Analysis at 9.
2 See 4/1/20 City of Santa Monica Housing and Economic Development and the Lawyers’ Committee for Civil Rights Under Law Report: Assessment Of Fair Housing at 6 (Goal 1, Strategy 1 is “Allocate city-owned land for affordable housing.”)
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Third, Council should direct Staff to evaluate (in conjunction with the Housing Commission)
potential plans for development of 100% affordable housing projects on these public land sites.
While Council provision of granular direction regarding plan development is not reasonable tonight, I respectfully suggest that the planning process should consider, among other issues: (1) the extent to which a portion of the 4th /5th & Arizona site should be set aside for open
space;
(2) the extent to which the development of 100% affordable housing projects would require more than Low Income Housing Tax Credits to finance the development (an issue for which the nine pre-COVID bids on the Fourth Street Garage RFP should provide one useful data
point);
(3) the cost-effectiveness of allowing market rate housing developers to satisfy their Affordable Housing Production Program obligations by providing funds for the construction of affordable housing units on public land and, if it is cost-effective, (a) the realistic potential size
of financial support from the AHPP program, (b) how that realistic potential would change with
potential zoning changes (including the elimination or severe restriction of non-housing development), and (c) how best to structure the AHHP offsite program so that it provides reasonable assurance that the units will be built but also provides greater flexibility and certainty for market-rate developers;
(4) the potential to leverage private capital for 100% affordable housing on public land; (5) the potential to form an enhanced infrastructure financing district, alone or in partnership with Los Angeles County, and to finance construction through tax increment bonds;
(6) the total support needed from the State and County (including LIHTCs) to make development of these 100% affordable housing projects a full reality; and (7) the potential for land swaps to allow for even greater dispersion of 100% affordable
housing projects on public land throughout the City.
This initial planning analysis should not attempt to cannibalize the public land itself to raise development funds. Public land is an irreplaceable resource, fully indexed against land price inflation, for the development of deed-restricted affordable housing projects that are not at risk of
converting to market rate housing after 55 years. Rather, plans to marshal federal, state, local
and private funding resources to develop 100% affordable housing projects on public land (as Santa Monica successfully has done in the past) should be the focus of this initial planning process.
Moreover, given the State’s compressed timeframe for Housing Element submission, this initial
planning process cannot be completed in a competent manner for inclusion in the Housing Element itself, which instead should note the existing fiscal constraints and develop a quantified objective based on that reality (as is permitted under the Housing Element Law). The Housing
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Element also should commit to the completion of this more comprehensive planning process
within a reasonable time.
Fourth, Council should direct Staff to use the Housing Element discussion of constraints and policy to forcefully reject the demonstrably false Sacramento narrative that trickle down housing from supercharged market rate housing development will address in any meaningful way in any
meaningful timeframe the crux of the housing affordability crisis in Santa Monica, the region,
and the State; namely, the massive number of severely rent-burdened lower income renter households (i.e., lower income households who pay more than 50% of their incomes for rent).3 This intolerable rent burden on our most economically vulnerable fellow Californians (including more than one out of every five Santa Monica renter households) is fueling a surge of newly
homeless persons in our region that is outstripping even our recently expanded capacity to move
our neighbors from homelessness to housing.4
3 HUD estimates that some 7500 Santa Monica renter households are both low income and pay more than 50% of their limited income for rent.
As the State level, it is more than one out of every four renter households that are both lower income and pay more than 50% of their limited income in rent. See HUD Comprehensive Housing Affordability Strategy (“CHAS”) Data for Santa Monica and for California at “Income By Cost Burden (Renters Only),” available through HUD query tool at https://www.huduser.gov/portal/datasets/cp.html.
4 See Los Angeles Homeless Services Agency, 2020 Greater Los Angeles Homeless Count
Shows 12.7% Rise In Homelessness Despite Sustained Increase In Number Of People Rehoused (6/12/20) (based on count performed in January 2020, LAHSA concludes that “Steeply rising inflow estimates indicate that economic precarity has made homelessness more volatile as well. . . . Put another way, an average of 207 people exit homelessness every day—while 227 people
become homeless. [¶ ] This year’s Count revealed that two-thirds of the unsheltered adults experiencing homelessness were homeless for the first time last year, and 59% of them cited economic hardship as the cause.”), available at https://www.lahsa.org/news?article=726-2020-
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To date, Sacramento has utterly failed to provide the financial resources necessary to address this
problem. Indeed, the State has not even restored the previously inadequate spending levels on
affordable housing that prevailed prior to the elimination of Redevelopment funding almost a decade ago.5 Sacramento instead pretends that supercharged market rate development will solve the problem, if only local government would get out of the way, and the State therefore does not need to actually devote real resources to addressing the problem. This Sacramento narrative is
utterly false, as even that most ardent advocate of supercharged market rate development—
McKinsey Global Institute—readily acknowledged in 2016: The tools that we have discussed—including identifying housing hot spots, unlocking supply by shifting incentives, and cutting the cost and risk of producing
housing—could unlock millions of new market-rate housing units in California.
This would expand housing supply and reduce housing costs for millions of Californians, but this will not solve the problem for California’s most vulnerable residents. Low-income, special needs, and homeless individuals will require support to access housing.6
greater-los-angeles-homeless-count-
results#:~:text=LOS%20ANGELES%2C%20CA%E2%80%94The%20Los,point%2Din%2Dtime%20count.
5
Source: California Housing Partnership, California Affordable Housing Needs Report (2020),
available at https://1p08d91kd0c03rlxhmhtydpr-wpengine.netdna-ssl.com/wp-
content/uploads/2020/03/CHPC_HousingNeedsReportCA_2020_Final-.pdf.
6 October 2016 McKinsey Global Institute, “A Tool Kit To Close California’s Housing Gap: 3.5 Million Homes By 2025” at p. 36 (emphasis added), available at
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Santa Monica is perhaps the only City with the moral authority to effectively push back on this
false Sacramento narrative and to challenge the State (and County) to put its money where its mouth is on affordable housing. By committing our public land to 100% affordable housing projects, we can effectively challenge the State (and County) to partner with us to make the type of meaningful change that is needed. If (and only if) Santa Monica can succeed in that effort
will it create a real model for affordable housing throughout the State.
While Council provision of granular direction regarding the constraint and policy discussion in the Housing Element is not reasonable tonight, I respectfully suggest that the narrative should discuss, among other issues:
(1) Our most desperate housing needs are (a) to reduce number of severely rent burdened, lower income households, (b) to reduce overcrowding and poor housing conditions among lower income households, (c) to get lower income workers living near their jobs, and (d) to get lower income children into our higher resourced community, given the data demonstrating the life-long
benefits to those children;
(2) Building the maximum number of affordable housing units is not necessarily the most timely and cost-effective way to achieve these goals (e.g., the Preserve Our Diversity program is very timely and highly cost-effective,7 family-size affordable housing units—although more
costly on an individual “unit” basis—are highly cost-effective on a per person helped basis
(particularly when children will then be able to grow up in our highly resourced community), et cetera); (3) The metric this community is going to use for allocation of its resources is what most
helps the most people with housing problems, and what most effectively addresses equity, not
simply counting “units”;
https://www.mckinsey.com/~/media/McKinsey/Featured%20Insights/Urbanization/Closing%20Californias%20housing%20gap/Closing-Californias-housing-gap-Full-report.ashx.
7 Based upon recent historical experience with POD and with senior tax credit 100% affordable housing projects on private land acquired for such projects, here is what the City can accomplish
with less than $1.6 million per year:
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(4) Sacramento policies (Costa Hawkins, Ellis Act, underfunding of affordable housing,
elimination of Redevelopment) have severely harmed efforts at maintaining housing affordability in Santa Monica; and (5) Santa Monica is prepared to devote very substantial public land and other resources to
addressing the issue, but the State and County must partner with us and make a similarly large
commitment of resources to actually address the affordable housing problem. Thank you for considering these views.
Sincerely yours,
Michael E. Soloff
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Vernice Hankins
From:Peter <pbosen@yahoo.com>
Sent:Monday, March 29, 2021 10:16 PM
To:councilmtgitems
Subject:City Council Meeting: March 30, 2021 Agenda Item: 8.A
EXTERNAL
Affordable homes not just affordable housing.
If the city allows condos to be sold with income restriction covenants and gives density bonuses, it is
certain that private developers will finance, build and sell all required affordable housing without
needing city money.
But if developers are restricted to low income rentals they won’t bother unless the city digs deep and
buys the buildings - which means that current residents will be bankrupted from subsidizing new
residents.
Some say that home ownership is bad, but that would be ironic coming from those who own their own
homes. If you ask anyone who currently rents an affordable apartment if they would rather own or
rent, then the vast majority would choose pride of ownership and would laugh at the phrase “pride of
rentership”.
Now is the time for Santa Monica to chart a new course, where low income housing does not mean a
lifetime of rental dependency, but a path to homeownership pride, long term financial security and
freedom from eviction.
Yours sincerely,
Peter Borresen
Santa Monica
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March 29, 2021
Honorable Mayor Himmelrich and Members of the City Council
City of Santa Monica
1685 Main Street, Room 212
Santa Monica, CA 90401
Re: Comments regarding 6th Cycle draft Housing Element
Dear Mayor Himmelrich and members of the City Council:
The Committee for Racial Justice just launched a Housing Committee. We plan to advocate and organize
for racial and housing justice, address systemic injustice for Black people and other disadvantaged
groups, and bring issues of racial justice and equity to the forefront when the city and region are
discussing housing policy.
We are deeply concerned with the loss of the middle class in Santa Monica, the crisis of affordable
housing in the city, the barriers to entry to housing for those receiving Section 8 or who have a lower
credit score, and more. We look forward to working with the City on addressing and improving these
issues.
On the Housing Element in front of you tonight, we appreciate the intended focus on equity and
affordability. We would like to lift up a major priority for us to the City: The Principles of Affirmatively
Furthering Fair Housing (AFFH) MUST be considered in this Housing Element cycle, as a way to
counteract the patterns of systemic racism manifested through redlining and restrictive covenants.
Affordable housing must be placed throughout the city, including North of Wilshire, Montana, and Ocean
Park. We support this even if it means altering zoning accordingly away from R1 exclusively. By keeping
our zoning codes the same, you are making the intentional choice to keep our neighborhoods separated
by class and race.
We are also hopeful that you will include inclusionary unit production in the AHPP. This would create more
likelihood of affordable inclusionary units in the city for our disadvantaged communities not making AMI.
Regarding preservation, we believe the City could preserve housing, by creating programs to incentivize
owners selling properties to first allow nonprofits to bid on them or something similar.
We need to finally, clearly state, that all of this is futile without meaningful funding for production and we
look forward to supporting and advocating for those mechanisms on local, state or federal levels.
We hope that the City Council will join us to stand firmly for a new, racially equitable housing future in our
city.
Sincerely,
The Committee for Racial Justice: Housing Committee
Tara Barauskas, Nancy Charles, Patricia Hoffman, Robbie Jones, Anjuli Kronheim Katz, Angie Mendoza,
Patty Phillips, Rev. Dr. Sidonie Smith
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Vernice Hankins
From:Ann Maggio <annmaggio@gmail.com>
Sent:Tuesday, March 30, 2021 11:07 AM
To:councilmtgitems
Cc:Ann Maggio Thanawalla
Subject:March 30 Agenda Item 8.A. Housing Element Vacancy Rates
EXTERNAL
Dear City Council,
In 2020, the planning Department provided a document to the state that said the City's vacancy rate was 8.7%. On page
19 of the HR&A Preliminary Feasibility Analyses it says the vacancy rate was just 4.8% last year. What number is
correct? How can you formulate direction if the models are wrong?
Please direct staff to provide you with the Housing Data annually prepared by the Planning Department for the year
ending 2020. It is possible that this data has already been submitted to the State Dept of Finance to meet the deadline
for the State's E-5 Housing reports.
Two more points / suggestions:
1. Adaptive Reuse ‐ Why isn't the housing element talking about adaptive reuse instead of new development?
Has staff or a consultant looked at what opportunities exist to convert buildings?
2. What about fines for vacancies? Maybe fines would be the incentive to release the vacant units back into the
marketplace.
Thanks for your consideration,
Ann Maggio Thanawalla
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Vernice Hankins
From:Elizabeth Van Denburgh <emvandenburgh@gmail.com>
Sent:Tuesday, March 30, 2021 11:27 AM
To:councilmtgitems; Sue Himmelrich; Councilmember Kevin McKeown; Phil Brock; Christine Parra;
Gleam Davis; Oscar de la Torre; Kristin McCowan
Cc:David Martin; Andy Agle; Lane Dilg; Susan Cline
Subject:3/30/21 City Council Meeting - Item 8A - Wilmont Board Housing Element Comments
EXTERNAL
March 30, 2021
To: Mayor Himmelrich and City Councilmembers
From: Board of Wilshire Montana Neighborhood Coalition (Wilmont)
RE: 3/30/2021 – City Council item 8A ‐ Four comments on Housing Element Update
The Wilshire Montana Neighborhood Coalition (Wilmont) Board has the following four comments about the Housing
Element Update.
1. No Good Deed Goes Unpunished: SCAG/State Issues an Unfunded Mandate of $4 billion
The final Sixth cycle RHNA allocation calls for planning 8,895 housing units to be built in the next eight years. 70%
(6,168) must be affordable and is an unfunded mandate by SCAG/State. These more than 6,000 new
affordable housing units are triple the number of affordable housing that has been built in the last quarter century.
Council Begins Exploring Ways to Triple Santa Monica's Affordable Housing (surfsantamonica.com).
This is the reward that the city and residents who voted for Proposition R in 1990 (before it became “popular to
establish a framework for affordable housing” that outlined at least 30 percent of new housing must be
affordable. In the 25 years since Proposition R, 38% of total housing units have been affordable[1]. Constructing over
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6,000 units of affordable housing, as outlined in the Sixth cycle RHNA, would require approximately $4.3 billion[2];
approximately each unit will cost $700,000.
Finally, if inclusionary housing were used to build these affordable units, we would have to build 20,560 units
(even at just two people per unit, this increases our population by 41,120 (currently 93,000 residents) to yield
6,168 units i.e., 30%. This increase in population is more than Culver City’s 39,169 population in 2019. And at what cost
to the city and residents for these 20,560 units? Housing does not completely cover the services and
infrastructure needed to support it. Who and how would we pay for additional services, fire, police, teachers and
infrastructure including water, roads, schools, as well as the impact on the ability to support sustainability in
the city as well as impacts on open spaces and recreational spaces?
We support our history of affordable housing and look to support that as we go forward. The city is the poster
child of providing affordable housing due to the passage of Proposition R. We should continue to support that
model; not a fantasy number from SCAG/State.
2. No Zoning Changes for Market Housing; only for Affordable Housing
We do not support any City zoning changes to support the development of market housing and that includes no
increase in inclusionary housing at the expense of building more market housing. We support Option A – Adopted
LUCE as put in place in 2010. The up zoning of sites from what was outlined in the LUCE should not be the
direction the city takes.
3. Do NOT Let Developers Move Forward with Adding State Density Bonuses to the City's Tier System
It has come to Wilmont’s attention that the development proposal (not 100% affordable housing) at 1101 Wilshire
(JP’s Sports Bar & Grill) and 1115 (Cars with Class), northeast corner of Wilshire and 11th St., is two stories taller
than allowed by Santa Monica zoning (MUB – four stories). We believe this is because they are adding state
density bonuses onto the city’s tier structure that already addresses density and FAR bonuses. It is also our
understanding that this has historically not been approved before. We support using the LUCE standards and
want to ensure this practice does not continue across the city.
4. Where Should Housing be Located?
We believe the time and effort spent on the LUCE for the 2010 – 2030 period should guide this decision. We
support Option A: Adopted LUCE as the appropriate framework to use.
Thank‐you for your efforts. We continue to monitor and review the Housing Element discussion and provide additional
comments with future updates.
Board of Wilshire Montana Neighborhood Coalition (Wilmont)
Elizabeth Van Denburgh, Chair
[1] City Council Report, March 30, 2021, Agenda Item: 8.A, pg. 20
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[2] Ibid, pg. 21
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4
Vernice Hankins
From:Council Mailbox
Sent:Tuesday, March 30, 2021 11:13 AM
To:councilmtgitems
Subject:FW: item 8 on the 3/30/2021 agenda.
Attachments:Mar Vista, District 11 proposal (created by Tieira Ryder).pdf; HousingDuplex.jpg; Housingsample2.jpg;
1SampleHousing.jpg; 1Bungalow.jpg; 01Bungalow.jpg
From: T <tie.ryder@gmail.com>
Sent: Monday, March 29, 2021 6:50 PM
To: Council Mailbox <Council.Mailbox@SMGOV.NET>
Cc: ComplianceReview@hcd.ca.gov; Councilmember Bonin <councilmember.bonin@lacity.org>; Tieira Ryder
<tie.ryder@gmail.com>
Subject: item 8 on the 3/30/2021 agenda.
EXTERNAL
Hi council,
Thank you for your time in reviewing the upcoming housing element. When it comes to affordable housing, it should
include both rent and homeownership options for the working class, seniors, students, and others in need of such
housing! 60,000+ residents are unhoused in LA County and that is not by accident! In the last 10 years rent has
increased by over 65%, during that time the number of unhoused residents increased by over 50%! That is not
acceptable. Rent should NEVER take more than 30% of a workers total monthly income after taxes. Workers SHOULD live
as close as possible to where they work, that would prevent much of the congestion we see on the westside.
The Santa Monica airport space SHOULD be included in this upcoming housing element, we cannot wait 8 more years for
that space to close as residents on the westside are in desperate need of housing. Please challenge the FAA to close that
space now and partner with LA City to build the affordable housing that is needed. Overturn MEASURE LC, no resident
has the right to "vote" on whether or not we build the affordable housing we need, we can implement a park in the
walkable community that we build but it cannot be only a park space for the liberal park patrol on the westside.
"North of Montana in Santa Monica has a median home value of $4.1M, is almost exclusively single family
homes, and has a population that is more than 80% white. Objectively, it is one of the most segregated
neighborhoods in the United States. (thread)"
That statement in quotes above was given by a Santa Monica resident on twitter. When it comes to RESTORATIVE
JUSTICE and EQUITY, the city of Santa Monica MUST end it's "redline", racist & classist zoning that has disrupted the
lives of many but especially my fellow Black residents that have been intentionally displaced by the city! Santa Monica
shows off Belmar Park, a place that was once home to Black residents before the city displaced them, how can the city
show off that space so proudly when 100's of Black residents are still displaced today in the city because of racism???
We have a chance to get this right, the time is NOW! I'm looking forward to your progressive leadership when it comes
to affordable housing on the westside!
Thank You for your time!
Best,
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5
Tieira
https://htwws.org/santamonicaairport/
https://laist.com/2020/12/23/black_santa_monica_history_vintage_los_angeles.php
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Richard Brand, AIA, Landmark’s Commissioner
Elena Christopoulos, Commission on the Status of Women
Leonora Camner, Santa Monica Housing Commission
Carl Hansen, Santa Monica Housing Commission
Additional electronic signatures:
Carter Rubin 102162621 3102001088 1937 Euclid St Un Santa Monica CA
Jason Islas 102213152 3109770645 2320 Virginia Ave Santa Monica CA
Joshua Blumenko 102390800 2486721303 290 N Hudson Av Pasadena CA
Frederick Zimmer 102725268 1050 Princeton StSanta Monica CA
Matt Stauffer 102822217 3103939825 908 S Hobart Blvd Los Angeles CA
Mark Yetter 103520618 9174556081 1013 16th St Santa Monica CA
Babak Mozaffari 104178932 3232056435 525 Santa Monica Santa Monica CA
Rayne Laborde 104905632 3105624535 1241 5th St Apt 40Santa Monica CA
Brendan O'Donne 105265524 6167457970 1115 Princeton St Santa Monica CA
Sean Youssefi 106616810 3102610139 1422 19th St Apt BSanta Monica CA
Matthew Stevens 106748677 3109959278 1128 11th St Santa Monica CA
Bradley Ewing 107281853 6619048620 Santa Monica CA
Leonora Camner 108323820 6465122093 1013 16th St Santa Monica CA
Frank Gruber 108603662 3105082626 2442 Beverley Av Santa Monica CA
Edda Spielmann 109180343 3103990267 2503 28th St Apt 4Santa Monica CA
Hank Koning 109282890 909 25th St Santa Monica CA
Catherine Gentile 109338611 3107025292 1128 Ocean Park Santa Monica CA
Geneva Vogelheim 109971051 4153427591 3770 Keystone Av Los Angeles CA
Jeremy Bamberge 110393394 3111 3rd St Santa Monica CA
Kevin Zelaya 110400964 3234933855 1139 S Rimpau B Los Angeles CA
Abby Arnold 110731738 3109223636 668 Marine St Santa Monica CA
Cynthia Rose 110732109 Santa Monica CA
Toby Muresianu 110781005 9787601193 621 S Barrington ALos Angeles CA
Stephen Bergaue 110781983 1133 10th St Apt 2Santa Monica CA
Tieira Ryder 110782087 3236036776 Santa Monica CA
Chelsea Bangass 110883817 Santa Monica CA
Chloe Ney 110883825 Santa Monica CA
Debbie Paperman 110883831 Santa Monica CA
Elena Christopoul 110883834 Santa Monica CA
Richard Brand 110883837 Santa Monica CA
Matthew Stevens 110883839 Santa Monica CA
Julie Rusk 110884148 228 21st St Santa Monica CA
allie landecker 110884376 Santa Monica CA
Natalya Zernitskay 110884638 Santa Monica CA
Tracy Hurtado 110884688 Los Angeles CA
Tony Ma 110884738 Santa Monica CA
Tyler Siemon 110884775 Santa Monica CA
Vivian Rankin-Sca 110884844 Santa Monica CA
Ben Mayne 110885583 Santa Monica CA
Addison Davis 110885681 Santa Monica CA
kyle Lim 110885690 Los Angeles CA
Ashley Denktas 110886237 Santa Monica CA
Pablo Ramirez 110886793 Los Angeles CA
Marissa Thompso 110887393 Los Angeles CA
Tieira Ryder 110887602 Whittier CA
Debbie Mulvaney 110887606 Santa Monica CA
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Tyler Smith 110887627 Santa Monica CA
Kurt Gary 110887630 Los Angeles CA
Troy Fosler 110887675 Santa Monica CA
Judy Abdo 110887703 Santa Monica CA
Gil Leib 110887711 Santa Monica CA
Greg Chasen 110887732 Santa Monica CA
Jason Mastbaum 110887820 Santa Monica CA
Sharon Hart 110887868 Santa Monica CA
Laura Rosenbaum 110887892 Santa Monica CA
Joanne Leslie 110888020 Santa Monica CA
Sandra Gruner-Do 110888027 Santa Monica CA
Ilya Haykinson 110888030 Santa Monica CA
Aaron Benowitz 110888079 Santa Monica CA
Vivian Rothstein 110888087 Santa Monica CA
LoEtte Loshak 110888100 Los Angeles CA
Johnathon Hughe 110888109 Los Angeles CA
Barbara Filet 110888127 Santa Monica CA
Kent Strumpell 110888131 Santa Monica CA
Ron Cohen 110888697 Santa Monica CA
Dwight Flowers 110888698 Santa Monica CA
David Bailey 110888751 Santa Monica CA
Randi Parent 110888778 Santa Monica CA
Samuel Deutsch 110888945 San Francisco CA
Theo Marshall 110888948 Santa Monica CA
Salim Damerdji 110888965 San Francisco CA
Park Guthrie 110888967 Sebastopol CA
Katharine Poole 110888989 New Rochelle NY
Daniel White 110888992 Venice CA
Oscar Duenas 110888999 Santa Monica CA
Naqiy Mcmullen 110889006 Orlando FL
Yasmin Akhtar 110889066 Los Angeles CA
Jennifer Lang 110889138 Beverly Hills CA
Paul Song 110889141 Santa Monica CA
Tim Harter 110889149 Santa Monica CA
Bob Brode 110889156 3104339274 2811 11th St Santa Monica CA
Sara Gersen 110889172 Santa Monica CA
Yonas Eshetu 110889173 Santa Monica CA
Alex D 110889186 Los Angeles CA
Mark Larson 110889244 Santa Monica CA
Joshua Baum 110889290 Los Angeles CA
Bill Parent 110889503 Santa Monica CA
STEPHEN PETTI 110889659 Santa Monica CA
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1
Vernice Hankins
From:Bradley Ewing <bradleywewing@gmail.com>
Sent:Tuesday, March 30, 2021 1:05 PM
To:councilmtgitems
Subject:8A - Housing Element
Attachments:santamonica_climate_reduction.png
EXTERNAL
Council,
Santa Monica has underbuilt housing for decades, to the point where we don't even build enough homes to cover
natural population growth. The consequences of this have been dire: exploding rents and displacement here and forced
car dependency for many of those who work here but cannot live here: driving emissions, traffic and a reduced quality
of life for all involved.
Our city needs to think globally and act locally; our inaction on constructing enough homes here drives sprawl, increased
emissions and increased water usage elsewhere in the state. According to UC Berkeley's local government policy tool,
the biggest reduction potential in our emissions by a significant margin is to construct infill housing (see attached
image). Dense, multi‐family housing in a temperate area like Santa Monica reduces VMT and resource use per capita,
especially when constructed in exclusionary single‐family only neighborhoods.
The upcoming housing element is an opportunity for Santa Monica to live up to its progressive ideals and make a
meaningful impact on housing affordability, climate change and building a more inclusive community. Other cities
throughout the state such as Berkeley, Culver City and Sacramento have taken the lead by embracing action to
encourage the growth of housing throughout their neighborhoods and dismantling segregationist zoning policies.
It is not enough for us to say that we have progressive intent, our actions and outcomes need to live up to that too.
Best,
Brad Ewing
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Created by Tieira Ryder
02/27/2021
To: Asm. Richard Bloom
Asm. Ben Allen
Asm. Sydney Kamlager
President Council Nury Martinez
District 11 Council Member Mike Bonin
Mayor of Los Angeles Eric Garcetti
Mar Vista CC
Venice NC
LDP & Commision
HCID & HCLA
Regarding
- Affordable Housing for district 11 working class residents, seniors, students,
those living with disabilities, and others in need of affordable housing.
- District 11’s incorrect zoning in relation to the Santa Monica airport, Santa
Monica’s intentional and continual displacement of working class residents on
the westside.
Proposal
Requesting closure of the Santa Monica airport by January 2022, with an intention to
use the open & safe space of the airport as early as June 2021. In June, the goal should
be to begin the process (if not sooner) to build affordable housing in the open airport
space that includes both affordable rent and homeownership options. The community is
being proposed as a walkable, affordable community that includes affordable
bungalows, apartments, condos, and townhomes.
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Who
The working class, our seniors, our students, our veterans, and those living with
disabilities are being denied their right to safe, clean, and affordable housing in the city
of Los Angeles. Rent has gone up over 65% in the last 10 years, during that time the
increase in the number of unhoused residents grew by over 50%. The working class is
being pushed into poverty, WE CANNOT afford $2,000 a month in rent for a studio
apartment with no parking on a median income.We need affordable housing that is
community owned, likely through a trust, that protects affordability of housing. If you
look at the maps below, you can see where Mar Vista is shown below on the map, that
is where I’m located. I’m in a small area that really goes unseen and we are in desperate
need of more affordable housing and open park space.We literally have no open
park space even though there are many children in the area!Santa Monica
has taken too much land space from Mar Vista and Venice, both communities run into
the open airport space off bundy.
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How this project can be funded
1.The American rescue plan- states “ the bill provides $5 billion to provide
rental assistance and supportive services,to develop affordable rental
housing, to help acquire non-congregate shelter to be converted into permanent
affordable housing or used in emergency shelter”.
2. Grants and any other state or federal relief.
3. Consider a series as a reality style project in partnership with a T.V network like
HGTV. Should be shown in a positive light of creating affordable housing
communities.
4. If the location is deemed to be in a tourist area and/or a percentage of residents
from the community work in neighboring cities that have high tourist attractions
that generate large sums of revenue, a portion of said revenue from tourism
would go into the community trust fund.
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Opposition/ Needs
1. Correctly rezone council district 11 and assembly district 30 in relation to the
Santa Monica airport open land space.By ending racist & classist zoning
that is negatively impacting residents of the westside, working class
residents of Mar Vista and Venice would have access to more open,
public land space in order to be used for affordable housing & park
space that residents desperately need.The tip of Mar Vista where I live
that runs into Venice beach should be in Asm. District 26 or 50 and part of
Venice & coastal concerns.
2. Santa Monica’s refusal to build enough affordable housing has displaced many
working class residents on the westside,including myself!Santa Monica city
is currently showing off Belmar Park online,a beautiful space that was once
home to black residents on the westside before the city displaced
them.The city shows off this empty park space as many black residents & others
are still displaced today! A resident in the city of Santa Monica recently
mentioned that one of Santa Monica's affordable housing apartment buildings
with over 200 units, is mostly housed with White senior residents from
Eastern Europe,so maybe it’s a senior building, but can the city provide a list
to show the demographics of the inhabited affordable units? I was a tech worker
in the city for a period of time and I was not successful in obtaining affordable
housing from the city.
3. Overturn Measure LC in Santa Monica which requires a public vote on the use of
the Santa Monica airport space if necessary. This may not be necessary if the
district is zoned correctly and the land space is returned to LA City.No group of
people should be able to deny others housing.It is a form of housing
discrimination that a mostly white, well off population from Santa Monica that
has housing, could vote on an issue and possibly deny other residents the right to
the same basic need of housing.Also, if the assembly repeals article 34,
that could?**potentially take care of MeasureLC. Community
members from Mar Vista and Venice need to spread out and we need
more open park space. Long term residents in each of those areas
should get priority for housing.
4.Regarding the FAA;Request that the city attorney, if necessary, challenge the
rule that states no person can live at the airport while it's operating. There is
plenty of open space that can be utilized now. (To begin building affordable
housing in June 2021; full airport closure by January 2022)
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5. Possibility of toxic air space needs that would require a remedy to keep water
and air space clean for the community and surrounding neighborhoods.
Affordable Rentals
1.Reasonably priced affordable apartments for lower and middle income earners.
The recommended height for apartment buildings is 4-5 stories. Rent would need
to match the average wage of the essential worker in mentioned cities. Rent
should not take more than 30% of an essential workers income; (if market rate
set takes more, renter could potentially get part of rent subsidized)
2.Set an “affordability market rental rate”based off of this income bracket
(about); $20,000-$100,000, but priority should** be given to those that fall
within the lower to middle income bracket, as well as workers that have
established residency from mentioned cities.(income bracket $20,000-$75,000)
No income restrictions once residents are housed.
https://www.nhlp.org/resources/lihtc-admissions-rents-grievance-procedures/
For those with limited to no income and/or displaced minors
1.Offer portion of the housing for residents with limited or no income,
to be partnered with westside chapters of HUD/HCID-LA etc.We can
set a market rate, but it is understood that some residents may have limited or no
income. If we set bachelor apartments at $600 but a potential renter couldn’t
afford that market rate we set because they had limited or no income, then the
funds from HUD would subsidize whatever costs the renter couldn’t afford.
This would likely be for seniors, single parents, students, those living with
disabilities, veterans, and/or chronically homeless but self functioning. This
project for rental units, let's call it “District 11 airport”, could possibly**
“request from HUD the actual market rate cost of a rental unit
apartment”(EX: We set a market rate of $600, but maybe* a bachelor
should**cost $1,200 in Los Angeles, HUD would cover the difference in the
housing projects trust fund. Money to be used for expenses related to rent,
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including admin, onsite safety & security if necessary as well as maintenance for
rental units.)
2. Consider large home space for displaced minors within the community aka a
"group home" to provide stability.
Affordable homeownership
1. Public bank that offers low financing to potential homeowner(s)
2.Set a market rate for the total cost of a home that the homeowner would
pay. When it comes to restorative justice & equity, the city would
offset any cost that went above the actual inflation rate of what a
home should be for the income bracket listed above.
3. Home types can be single bungalows or attached/detached townhomes.
The homes could**function similar to that of homes that are in HOA’s.
(TBD)
4. There would be resell requirements for said homes to protect affordability.
5.Income limits should be set for the working class, residents in Mar Vista
and Venice get priority.30% of the housing should be offered to
African Americans as a restorative, affordable housing initiative
that returns homeownership opportunities to black displaced
families on the westside, as a right to return.This would not
replace any federal reparation payment. I do believe that restorative
justice & equity as a whole should include homes that are not required to
follow resell requirements, that can be done as a larger restorative housing
program but likely would not be part of this specific proposed project.
TBD.
6.Request consideration of affordable homeownership for the
millennial generation, or a percentage of the core group, as they own less
than 18 percent of the real estate in Los Angeles. (EQUITY)
“Equity is defined as “the state, quality or ideal of being just, impartial and
fair.” The concept of equity is synonymous with fairness and justice.”
To our elected officials, I ask that you please consider this request to close
the Santa Monica airport in order to begin the process of building
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affordable housing that belongs to the working class, seniors, students, and
others in need of said housing as early as June 2021.We cannot wait 8 more
years for the airport space to close as the wealthy in that area occupy too much of the
open space in comparison to surrounding cities and they also use the space to drag their
cars over in the airport area while we are all in desperate need of housing, housing that
we needed 10 years ago! No resident should have to beg for housing that they can afford,
no elected official or Gov’t should have that type of power that can deny the basic need
for housing.Thank you for taking the time to read this request from a
community housing advocate in Mar Vista that has been displaced, I’m
looking forward to your response! As a courtesy, I’ve sent this letter to
officials in the city of Santa Monica.
Best,
Tieira Ryder
https://htwws.org/santamonicaairport/
tie.ryder@gmail.com
Links
https://www.surfsantamonica.com/ssm_site/the_lookout/news/News-20
20/August-2020/08_28_2020_Santa_Monica_Names_New_Sports_Field
_After_Once_Thriving_Black_Neighborhood.html
https://www.latimes.com/opinion/livable-city/la-oe-sharp-santa-monica-
airport-housing-20190331-story.html
“Santa Monica’s estimated population of 92,478 residents in 2019 was only a blip
above what it was in 1970, when 88,289 people called the city home. This growing
imbalance between jobs and housing has created a massive influx of daily commuters
into Santa Monica (even well-compensated tech employees) who either can’t find or
can’t afford housing near these job centers. Meanwhile, the population in neighboring
jurisdictions has swelled, displacing lower-income residents.”
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