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SR 06-15-2021 8A City Council Report City Council Meeting: June 15, 2021 Agenda Item: 8.A 1 of 39 To: Mayor and City Council From: David Martin, Director, Administration Subject: Review and Direction of Draft Housing Element Recommended Action Review the draft Housing Element, as amended by Planning Commission and staff recommended changes in Attachment B, and direct staff to transmit the draft Housing Element to the California Department of Housing and Community Development. Executive Summary This report transmits the draft Housing Element (Attachment A) for the City Council’s review and direction to staff. The draft Housing Element represents a statement of Santa Monica’s housing plan over the next eight years built around four main principles: • Housing Production – provide incentives to increase housing production, especially affordable housing production • Housing Stability – ensure that existing residents are protected from displacement • Location – incentivize and locate housing close to daily services and amenities like parks and schools in addition to places around the city that have historically not accommodated housing, especially affordable housing • Equitable Housing Access – expand access to housing opportunities and overcome patterns of segregation by planning for housing, including affordable housing, in areas that historically excluded diverse housing opportunities A key focus of Housing Element programs is housing production, with substantial emphasis on affordable housing production. Santa Monica’s Regional Housing Needs Allocation (RHNA) mandated by Government Code Section 65584.05 is 8,895 units, of which 69% are to be affordable units. 8.A Packet Pg. 8 2 of 39 The draft Housing Element follows Council direction to produce a compliant Housing Element that addresses historic discrimination and satisfies Affirmatively Furthering Fair Housing (AFFH) requirements. As required, the Suitable Sites Inventory (SSI) and Quantified Objective (QO) capacity calculations are based on feasibility analyses used to demonstrate that proposed development standards can support housing projects. The draft Housing Element consists of five chapters, as well as eight supporting appendices: I. Introduction • Provides a background discussion of Housing Element law, the Housing Element’s relationship to the City’s adopted Land Use and Circulation Element, an introduction to the principles that guide the draft Housing Element, and a summary of outreach efforts. II. Affirmatively Furthering Fair Housing • Provides an assessment of fair housing, including patterns and trends of segregation as well as contributing factors that are barriers to fair housing in the City. • Based on the assessment, provides a summary of fair housing issues, as well as goals and actions to affirmatively further fair housing. III. Goals and Policies • Establishes the Housing Element’s seven primary goals, as well as policies to set the direction as to how goals are to be achieved. IV. Land Available for Housing • Provides a summary of the land available to accommodate housing in the City, including a summary of the Suitable Sites Inventory (an inventory of adequately zoned sites for housing) as well as a discussion of the potential production of Accessory Dwelling Units in the City. V. Programs & Implementation 8.A Packet Pg. 9 3 of 39 • Establishes the programs necessary to achieve the goals and policies set forth in Chapter 3 and describes the objective and implementation schedule for each program. Appendix A – Outreach Summary • Provides a summary of the public outreach that took place during the Housing Element update and includes associated materials such as presentations and staff reports. Appendix B – Housing Needs Assessment • Provides the background data on population, demographics, employment, and housing to assess the City’s housing needs. Appendix C – LUCE Goals and Policies • Identifies the LUCE goals and policies that potentially need amendment following adoption of the Housing Element. Appendix D – Housing Resources • Provides a discussion of the City’s available resources (financial and programmatic) to support housing. Appendix E – Constraints on Housing • Identifies potential constraints on the production of housing and analyzes the extent to which the City can mitigate the negative impacts of these constraints. Appendix F – Report on Suitable Sites Inventory Analysis • Provides details on the methodology used to prepare the Suitable Sites Inventory and includes the supporting data used to identify sites and calculate housing capacity. Appendix G – Review of Past Performance • Describes the prior 5th Cycle Housing Element’s goals, objectives, policies, and programs and summarizes their progress and effectiveness, as well as assessment of whether these remain appropriate or need revision. Appendix H – Opportunities for Energy Conservation 8.A Packet Pg. 10 4 of 39 • Identifies and analyzes opportunities to encourage energy saving features, energy saving materials, and energy efficient systems and design for residential development. The seven goals of the draft Housing Element, which represent desired housing outcomes based on collective feedback from the community, technical working groups, Boards & Commissions, and Council, are as follows: 1. Overall Housing Production: Production of new housing that is sustainable, innovative, safe, and resilient, appropriate with the surrounding neighborhood, offers opportunities for active and healthy living, including walking and biking, and increases equitable housing opportunities. 2. Affordable Housing Production: Housing production for all income categories including for the community’s workforce and most vulnerable communities. 3. Preserve Existing Housing: Preservation of the existing supply of housing and prevent displacement of existing tenants. 4. Equitable Housing Access: A community that provides equitable housing access to all neighborhoods. 5. Address Homelessness: Housing for persons experiencing homelessness. 6. Housing Assistance: Provision of housing assistance and supportive programs and services to extremely low, very low, and moderate-income households with special needs, families, seniors, and the homeless. 7. Anti-Discrimination in Housing: Eliminate housing discrimination on the basis of race, color, religion, sex, gender, gender identity, gender expression, sexual orientation, age, marital status, national origin, ancestry, familial status, income level, source of income, disability, veteran or military status, genetic information, or other such characteristics. A summary table of the Goals and Programs for implementation has been included for ease of reference starting on Page 15 of Chapter 1. 8.A Packet Pg. 11 5 of 39 After consideration of all public comments on the draft concepts presented to City Council on March 30, 2021, including subsequent input from the Planning Commission, Housing Commission, and Rent Control Board, this report provides a summary of the proposals in the draft Housing Element based on City Council’s direction in addition to background information on alternatives that were considered before arriving at the proposals. Once Council has approved a final draft Housing Element, staff will forward that final draft to the California Department of Housing and Community Development (“HCD”) by July 1, 2021, for a 60-day review period for compliance with State law. HCD feedback will then be incorporated into a final Housing Element that will be presented in the Fall for Council adoption along with implementing ordinances (i.e. Code language). Council is required to adopt the Housing Element by October 15, 2021. Background At its March 16, 2021 meeting, the Planning Commission recommended that the City Council endorse the draft concepts for the Housing Element. At its March 30, 2021, meeting, the City Council gave the following direction to staff on the Housing Element: • Prepare a compliant housing element that addresses historic discrimination and satisfies Affirmatively Furthering Fair Housing (AFFH) requirements. • Prioritize 100% affordable housing on City-owned land (with consideration for use by artists or as open space). • Select Option B regarding where housing should be located, from the March 30 City Council staff report, for distribution of potential housing sites, with consideration of zoning changes necessary to support housing in areas where housing has traditionally not occurred. 8.A Packet Pg. 12 6 of 39 • Pursue 100% affordable housing overlay zone with exception of environmental justice1 and previously redlined zones. • Explore diverse opportunities for affordable home ownership and for transitioning from renters to owners by residents. • Explore Accessory Dwelling Unit (ADU) incentives in R1 areas, including potential for deed-restricted ADUs. • Explore options to increase density in areas that historically excluded diverse populations and affordable housing, to increase equitable and affordable housing access, including but not limited to voluntary lot splits/duplexes with affordability covenants. • Promote diversity and inclusion in every neighborhood in Santa Monica. Subsequent to Council direction, staff also met with the Housing Commission on April 1 and the Rent Control Board on April 8. At their April 15 meeting, the Housing Commission largely voted to support the concepts but offered some further refinement to the Council direction: • Incentives for Moderate Income Housing: Consider expanding the incentives in State Density Bonus Law for 100% affordable housing projects to also include Moderate-income projects (up to 120% AMI) with an incentive to allow for unlimited density. This was not unanimous direction with Commissioners who did not support the motion indicating that they would need to further understand the impacts of expanding such allowances on neighborhoods, particularly the Pico neighborhood, and as such, would prefer that these incentives be limited only to commercial boulevards. • Other Metrics for Areas to Exclude from Affordable Housing Overlay (AHO): Council endorsed a proposal that the AHO exclude Environmental Justice areas in addition to formerly redlined areas. Given that those areas include areas of the city where demographics have changed, the Housing Commission instead 1 These areas have been mapped per SB535 Disadvantaged Communities map: https://oehha.maps.arcgis.com/apps/View/index.html?appid=c3e4e4e1d115468390cf61d9db83efc4 8.A Packet Pg. 13 7 of 39 recommends that the City Council consider alternative metrics such as current demographics and concentration of affordable housing. The Rent Control Board also provided the following comments on Council’s direction: • Concern about insufficient enforcement resources devoted to short-term rentals and corporate rentals • Concern about goal of creating home ownership opportunities out of existing permanent rental housing stock • Concern regarding rehab projects particularly with respect to providing landlord support and disruption to tenants • Disagree with providing any incentives for moderate-income housing • Concern regarding whether the language of Goal 6 appropriately captures all protected classes The draft Housing Element reflects Council direction, as well as certain comments provided by the Housing Commission and Rent Control Board. On June 2 and 3, the Planning Commission met and voted to recommend the draft Housing Element to Council with the changes detailed in Attachment B. In recommending the draft Housing Element, the Commission had an extensive discussion regarding the goals, policies, and programs with general emphasis on the following: • Ensuring feasibility for housing projects, • Implementing a robust state density bonus program with a broad menu of frequently requested concessions, • Promoting innovative construction methods and sustainability in new housing, • Updating the development standards to ensure new housing is feasible, • Modifying the proposed affordable housing overlay to apply only to moderate- income projects in targeted areas, 8.A Packet Pg. 14 8 of 39 • Limiting the upzoning of R1 to commercial-adjacent parking lots, and • Initiating an expansive public process that would explore options to redress the impact of historically exclusionary single-unit zoning. Discussion Compliant Housing Element that Addresses Historic Discrimination and Satisfies Affirmatively Furthering Fair Housing Requirements The draft Housing Element addresses Council’s broad direction to prepare a compliant Housing Element by focusing on two key strategies: • Feasible Development Standards to Incentivize Housing Production: Council selected “Option B” for distribution of housing sites with consideration of zoning changes necessary to incentivize housing relative to commercial. Recommended programs propose amending existing development standards to levels that can support the City ‘s minimum inclusionary housing requirements and incentivize housing relative to commercial development • Equitable Housing Access: Recommended programs to incentivize and locate housing in areas that have historically not accommodated housing or have excluded diverse housing opportunities Establish Feasible Development Standards to Incentivize Housing Production (Programs Addressing Feasibility of Housing Projects: 1A, 1B, 1C, 1D, 1E, 1F, 1H, 1I, 2D, 4B) Housing Element law requires that the City establish feasible development standards for housing projects. The proposed programs associated with feasibility of housing projects are intended to address the findings from the housing needs assessment (Appendix B) which highlighted the following: 8.A Packet Pg. 15 9 of 39 • Housing costs are high – more than 42% of Santa Monica households are cost burdened • Lower income households are disproportionately affected by high housing costs • Black and Latino households are predominantly renter households and are severely cost burdened • Only 9% of the Santa Monica workforce lives within the city The need to produce more affordable housing units is addressed in part by the City’s AHPP requirements, which serve as a tool to produce some affordable housing units out of market-rate housing projects. To inform policy making on development standards necessary to support housing production, the City requested that HR&A Advisors conduct feasibility analyses of housing prototypes in every non-residential zone in order to understand the floor area ratio (FAR) necessary to support the City’s minimum AHPP requirements: • On-site option: 10% of total units for 50% AMI households (Very Low Income) • Off-site option: 12.5% of total units for 50% AMI households (Very Low Income) The draft results are included as Attachment E to the staff report. The following is a general summary of findings: • The FARs generally require a minimum of 4-story buildings based on assumption of a double lot and larger site, with the exception of NC (Main Street) at 5 stories. • Most of the proposed FARs are higher than the existing Tier 2 FAR, with the notable exception of the Downtown area. HR&A Advisors’ feasibility analyses demonstrate that in every commercial zone other than Downtown, Tier 1 supportable FAR needs to be set higher than existing Tier 2 FAR in order to support the above minimum AHPP requirements. This effectively negates the need for Tier 2 for housing and therefore, it is proposed that Tier 2 be eliminated for housing projects. 8.A Packet Pg. 16 10 of 39 As detailed in the May 12 Planning Commission report, staff presented 3 possible scenarios for comparison: • Original Draft Concept (presented on March 30) o Tier 1 based on 15% affordable units o Tier 2 based on 20% affordable units • Council Direction “Scenario A” o Tier 1 based on 10% affordable units (same as existing) o Tier 2 unchanged from existing • Council Direction “Scenario B” o Tier 1 based on 10% affordable units (same as existing) o Tier 2 based on 15% affordable units Based on discussion with the Planning Commission and further analysis, staff’s recommended approach to setting supportable FARs in the draft Housing Element is primarily based on Council Direction “Scenario A” with the modification that Tier 2 for housing projects be eliminated. This has the benefit of simplifying the land use system for housing projects and does not preclude further exploration of shifting what are currently Tier 2 community benefits to the new Tier 1 (e.g. enhanced impact fees, Staff’s proposal would result in FAR’s being reset for Tier 1 projects to render production of 10% affordable units. The proposed FARs are shown in HR&A FAR- AHPP analysis (Attachment E) and in Figure 1 below. An example is set forth in Table 1 (note that this is before application of any state density bonuses). Figure 1: Proposed FAR with estimated number of floors and total units (before density bonus) with 10% affordable units 8.A Packet Pg. 17 11 of 39 8.A Packet Pg. 18 12 of 39 The Original Draft Concept is not recommended as it was not part of Council’s direction on March 30 and would result in a greater proportion of market-rate units relative to inclusionary affordable units produced. Similarly, Council Direction “Scenario B” would have necessitated Tier 2 FARs to be set higher than the new Tier 1 recommended FARs. This would also not have been consistent with Council direction to incentivize housing projects relative to commercial projects but not to an extent where it would result in substantially more market-rate units relative to the percentage of affordable inclusionary housing units. Nevertheless, there are alternatives if increasing FARs in all non-residential zones in the City (due to the need to support the minimum AHPP requirements) is not acceptable. For example, Council could consider reducing the minimum AHPP requirements or eliminate the AHPP requirements entirely. In order to provide the Council further understanding of these options, staff requested that HR&A run additional testing generating FARs necessary to support 5% affordable units and market-rate units only, as an understanding of baseline conditions. This analysis is provided in Attachment E and shows relatively minor differences in supportable FARs. The 8.A Packet Pg. 19 13 of 39 consequence of such an approach would be that the City would still be required to allow market-rate housing to proceed and further pressure would be placed on public resources to produce affordable housing (e.g. City, County, State, or Federal funding). In order to inform future policy-making, HR&A was also asked to conduct analyses to understand the FAR necessary to support a variation to the AHPP that would be a 15% on-site requirement with mixed-income units (i.e. 5% VLI, 5% LI, and 5% Moderate). While not the basis of the Suitable Sites Inventory (SSI) calculations, the results of the 15% mixed-income analysis present information to consider for forthcoming revisions to the AHPP. The following table provides one illustrative example of the potential outcomes of the proposal to establish supportable FARs based on 10% affordable units in the Mixed- Use Boulevard Low zone (covers areas of the city like Broadway, Colorado Avenue, eastern end of Santa Monica Boulevard). Table 1: Illustrative Example of resulting FARs in sample MUBL zone (note that this is before any State density bonus) 8.A Packet Pg. 20 14 of 39 Importance of Financial Feasibility for Housing Projects Consistent with Housing Element law, development standards, including FARs, codified in the Zoning Ordinance should support the production of housing projects. Previously, when applicants had the option to satisfy their AHPP requirement through 5% Extremely Low Income (ELI) units, housing projects were proceeding but were producing fewer affordable housing units relative to market-rate housing with all of the units designated for 30% AMI households. To adjust this imbalance and also study the possibility of how to support greater levels of inclusionary housing, the Council enacted a temporary pause on allowing housing projects to select the 5% ELI option. Based on HR&A’s preliminary analysis, the City’s current FAR limits in several zones do not support the City’s current minimum AHPP requirement of 10% Very Low Income (VLI). Implementation of State Density Bonus Law Any allowable State density bonus (Government Code Section 65915)2 would be applied as a percentage increase on the new Tier 1 FAR as shown in Table 2. As required under State density bonus law, applicants would also be entitled to a fixed menu of incentives and concessions to further modify development standards necessary to support the on-site affordable units in the project. Requests for incentives and concessions through this fixed menu would be reviewed through an administrative process. This approach is similar to that taken by peer cities such as West Hollywood and City of Los Angeles. 2 https://leginfo.legislature.ca.gov/faces/codes_displaySection.xhtml?lawCode=GOV&sectionNum=65915 8.A Packet Pg. 21 15 of 39 Table 2: State Density Bonus percentage increase on residential FAR based on provided on-site affordable units Independent of the State density bonus, applicants are also permitted to apply for incentives and concessions to modify development standards, which may include, but not be limited to, increased height, or reduced setbacks as necessary to support the on- site affordable units in the project. In the incentives/concessions review process, the City bears the burden of proof to show that the incentives/concessions are not needed for the proposed project to support production of the affordable units. If the applicant disagrees with the City, the applicant can initiate judicial proceedings and if the City loses, the City is required to pay the applicant’s attorney’s fees. The feasibility analyses provide information about what FARs would result in housing projects that are more likely to develop than commercial projects based on desired AHPP requirements. If the City does not set development standards that would result in housing projects being likely to develop, it opens up the risk for applicants to request incentives and concessions on a case-by-case basis, which reduces transparency and predictability in development for the community and the applicant. Equitable Housing Access (Programs Addressing Equitable Housing Access: 4A, 4B, 4C, 4D) 8.A Packet Pg. 22 16 of 39 As analyzed in the draft Housing Element Chapter 2 and documented in the April 2020 Assessment of Fair Housing, land use and zoning laws were identified as a high priority factor that contributes to housing segregation, disparities in access to opportunity, disproportionate housing needs, publicly supported housing location and occupancy, and disability and access, because multiunit housing opportunities are not equally distributed throughout the city, thereby limiting opportunities for new affordable housing that could foster integration, provide additional opportunities for displaced Santa Monica households, and allow additional opportunities for creation of new affordable units. As a result, Goal 1 from the Assessment of Fair Housing is to increase the supply of affordable housing through several strategies including exploring zoning changes to facilitate the development of affordable housing in areas without publicly supported housing developments. The draft Housing Element’s Goal 4 is intended to build upon the Assessment of Fair Housing’s Goal 1. The adopted LUCE set forth a growth strategy to focus new development in areas proximate to major transportation systems and daily services encompassing approximately 12% of land in Santa Monica while protecting residential neighborhoods from development pressures. In 2020, Santa Monica’s housing stock consists of approximately 52,629 units, 11,572 of which are single-unit dwellings and 40,853 of which are multi-unit dwellings. Nearly all of the existing multi-unit housing is in multi-unit zoned neighborhoods and new housing construction has been in the Downtown and commercial boulevards, consistent with the LUCE strategy.3 While R1 (single-unit) zoning neighborhoods make up approximately 1/3 of land in Santa Monica, they hold only approximately 12% of the housing stock. Decades of discriminatory housing practices have contributed to the segregated housing patterns that exist to this day. A review of demographic and housing data indicate that the concentrations of renter, low-income, and non-White households very much correlate to the historic redlining maps that were used beginning in the 1920s. 3 Santa Monica’s Housing Progress: https://www.santamonica.gov/topic-explainers/santa-monica-s-housing- progress 8.A Packet Pg. 23 17 of 39 In order to meet the AFFH requirement of Housing Element law and break down the patterns of segregation, the draft Housing Element proposes the following programs: • Program 4.A: Allow Multi-Unit Dwellings as a permitted use in all zones where housing is currently prohibited – this would add multi-unit housing as a permitted use in zones where it is currently prohibited (e.g., Office Campus, Industrial Conservation) • Program 4.B: Incentivize housing in non-residential zones that have not previously accommodated housing (Neighborhood Commercial zones like Montana Avenue) – this involves increasing FARs to make housing feasible and more competitive relative to commercial development • Program 4.C: To support the production of affordable housing on surface parking lots owned by religious congregations, standards will be adopted to allow some market-rate units to support the affordable housing • Program 4.D. Expand housing opportunities in the R1 Feasibility Analysis of Program 4.D (Rezoning R1) Staff requested that HR&A, JKA, and Danielian Associates conduct architectural and feasibility analyses to look at (1) how many units could fit within existing R1 envelope and (2) how many units are necessary to support inclusionary on average lot size. The analysis also looked at the effects of minimum lot size of 7,500 sf and 6,500 sf. As shown in Attachment C, the analysis showed that: • High land costs in R1 are a significant factor in determining whether any of the tested scenarios are feasible • Permitting additional units within the existing R1 envelopes is unlikely to produce new multifamily development due to the high cost of R1 parcels and limited sellable area. 8.A Packet Pg. 24 18 of 39 • Permitting three market-rate, for-sale units within a larger envelope (roughly 1.5- times existing R1 lot coverage) could support multi-unit development in some areas of the city but also would necessitate sale price increases. • Requiring one inclusionary unit to be affordable would require more units (approximately 5-6 units) within a larger building envelope that would be akin to R2 standards. Approximately 35% of the City is zoned R1 for single-unit dwellings but contains only 12% of the City’s housing supply and are the least diverse in terms of racial makeup. These results raise a policy question as to whether the desired outcome in considering increasing density in R1 neighborhoods is: (1) producing inclusionary units (that would count for RHNA compliance) or (2) offering units at slightly lower price points (possibly increasing more home ownership housing access to R1 neighborhoods but not at affordable levels). Given Council’s direction to explore equitable and affordable housing access and balancing that with stated desire to also attempt to retain the street character of R1 neighborhoods, the draft Housing Element reflects staff’s original proposal of an approach that attempts to address both goals. Program 4D in the draft Housing element proposes allowing up to 3 units in all R1 parcels of a certain minimum size and proposed rezoning of a limited number of R1 parcels to R2 adjacent to commercial streets (e.g. Montana Avenue) and major north-south routes (e.g. 7P th P Street, 14P th P Street, 26P th P Street). These targeted areas were identified for consideration because of there being appropriate alley access on relatively busier cross-town routes. After significant public comment and consistent with the Planning Commission’s recommendations, staff agrees with a modified recommendation for Program 4D. This is discussed further in the “Alternative Analyzed for Consideration” section below. Research Regarding Pace of Change After R1 Rezoning While the draft Housing Element proposes Program 4D that would increase housing opportunities by rezoning R1, it should be noted that this program is too speculative to enable the City to be able to identify particularly sites for purposes of the SSI. Formal data and studies are scarce with respect to the effects of R1 rezonings that have 8.A Packet Pg. 25 19 of 39 occurred in other cities but staff found some research that addresses the issue, and most of it indicates that the zoning changes have resulted in increased property values but has not produced additional units4. It is also difficult to translate limited housing production in other cities to Santa Monica given how much influence high land costs have on feasibility in Santa Monica. Additional literature indicates that in order to incentivize production of units, cities must take further steps to evaluate development standards that disincentivize housing production such as parking requirements and lot coverage.5 As indicated in the March 30, 2021 staff report presented to Council, staff provided an assessment of the concept of rezoning R1 neighborhoods and found that further assessment would be needed as there may be better strategies available to accomplish the goal of providing equitable housing access. As a result, it can be fairly stated that if Program 4D in the draft Housing Element were implemented, it would not likely result in substantial housing production. Rather, the value of such a program is in providing the opportunity for property owners to increase the number of units, whether through retrofit of existing homes or the addition of more dwelling units that could exceed ADU maximum size limitations. This is another reason why staff no longer recommends Program 4D as set forth in the draft Housing Element. Staff’s modified proposal is discussed in the “Alternatives Analyzed for Consideration” section below. 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. As shown in the below map, the vast majority of new ADUs constructed or under development in the past 3 years have been in R1 neighborhoods, providing a valuable source of rental housing access in otherwise, high cost neighborhoods. If R1 zoning were to be densified, further assessment would need to be done to explore whether an average-size parcel could accommodate a viable deed-restricted affordable housing 4 https://nlihc.org/sites/default/files/AG-2021/06-13_Local-Land-Use.pdf; https://journals.sagepub.com/doi/10.1177/1078087418824672 5 https://www.bloomberg.com/news/articles/2020-07-29/to-add-housing-zoning-code-reform-is-just-a-start 8.A Packet Pg. 26 20 of 39 project. As an alternative, adding capacity to R1 zones could instead be accomplished with additional ADU incentives that may result in units that are affordable by design. Figure 2: Map of ADU projects since 2018 Equitable Housing Access: Alternative Analyzed for Consideration The Planning Commission acknowledged and discussed the City’s past exclusionary zoning practices that have contributed to the housing segregation seen today. However, the Commission expressed concern that Program 4D would not truly achieve AFFH if the resulting 3 units need to be ownership housing that is not affordable and does not open up more equitable housing access. There was also concern that targeted upzoning could inadvertently have the effect of even further increasing land values due to reducing amount of land dedicated to single-unit dwellings, the increased density allowance, and the tradeoff that the 6 market-rate, for-sale units necessary to support one inclusionary unit would not provide broader housing access. Therefore, the Planning Commission recommended that Program 4D be significantly modified in a way that allows the community to continue the discussion on how the City can take 8.A Packet Pg. 27 21 of 39 meaningful steps to address past exclusionary zoning practices in future land use decisions: • Planning Commission Recommended Program 4D • Rezone Selected Portions Of R1-Zone Neighborhoods To Increase Density Explore Options To Address R1 Neighborhoods In order to promote fair access to all neighborhoods in Santa Monica, the City shall rezone selected portions of existing R1-zone neighborhoods to R2. Areas that would be considered include 7th and 14th Streets between Montana Avenue and San Vicente Boulevard and 26th Street between Wilshire and San Vicente Boulevard. The City shall create a program that allows up to 3 units to be constructed in R1-zoned parcels with consideration for establishing a minimum parcel size so as not to further impact areas of the city that already provide diverse housing opportunities. Adjustments to R1 standards such as parcel coverage will be examined but the existing envelope in R1 zones shall be maintained, to the extent feasible. The City shall explore options to address historically exclusionary single unit dwelling zones through future land use decisions. Subsequent to the Planning Commission’s discussion and recommendation on the draft Housing Element in addition to public comments received on the proposal for Program 4D, staff re-assessed how the City could also demonstrate compliance with the AFFH mandate based on the following : • Affordable housing is largely not located in North of Montana (NOMA), Wilshire- Montana (Wilmont), Ocean Park, and Sunset Park. These neighborhoods are more heavily white than Santa Monica as a whole and more so than the diverse neighborhoods of Pico and Downtown. However, high land costs make the production of affordable housing very unlikely in these areas. Much of the HUD- supported affordable housing units are in senior housing, which is less likely to 8.A Packet Pg. 28 22 of 39 contribute to integration of Santa Monica than intergenerational family-occupancy housing, which is a housing type the City has tried to encourage and require. • The City has a strong track record of protecting rental housing stock, producing affordable housing, and housing-assistance programs for existing residents including: o Rent Control has been in place for over 40 years o The City has an ordinance prohibiting source of income discrimination (SMMC 4.28.030(a)), and a division within the City Attorney’s Office that enforces this ordinance o Strong tenant protections including just-cause evictions, tenant harassment regulations, and notice of tenant buyouts o AHPP that requires market-rate projects to provide inclusionary units has been in place for over 30 years o Preserving Our Diversity (POD) program that provides cash-based assistance to low-income seniors • Proposed no net loss ordinance would provide anti-displacement protections particularly for smaller, more vulnerable properties Further, the draft Housing Element proposes the following programs: • Program 4A – adding housing as a permitted use in non-residential zones where it is currently prohibited such as the Office Campus zone • Program 4B – incentivizing housing production on commercial streets of highest resource neighborhoods that have historically not accommodated housing such as Montana Avenue, Ocean Park Boulevard, and Main Street With the Planning Commission’s recommendation that the Affordable Housing Overlay for up to 80% AMI not proceed and that single-unit dwelling upzoning should not occur, staff has proposed a revised Program 1G that would continue to allow one additional 8.A Packet Pg. 29 23 of 39 ADU on single-unit dwelling parcels with the change that the unit would not have to be deed-restricted but perhaps could be restricted to only be permanent rental housing. This revision is being proposed to try and formulate a program that would incentivize R1 homeowners to add an additional ADU to their properties and to increase the supply of rental housing, that would be lower rents than an entire single-unit dwelling due to the sheer difference in size, in R1 neighborhoods. • Revised Program 1G • Promote The Use Of Accessory Dwelling Units Through An ADU Accelerator Program The City shall develop an Accessory Dwelling Unit (ADU) Accelerator Program that will simplify the ADU process by providing property owners interested in building an ADU with a handbook detailing all ADU standards and review procedures, and pre-approved ADU plans that can be selected to reduce time and costs associated with ADU development. The program will also consider further streamlining of the City’s ADU permitting review process. The program will also encourage/incentivize the production of affordable ADUs that will affirmatively further fair housing by providing more affordable rental housing opportunities, that would be affordable by design, within single- unit residential districts, an area of the City with high housing costs that has largely been unaffordable to many. Program 4A, Program 4B, and revised Program 1G in the draft Housing Element would provide increased housing opportunities throughout the City to address the State- mandate to affirmatively further fair housing. However, given this new mandate and the absence of documented Housing Elements that have been deemed to be compliant with this mandate, it is unknown if HCD will view the proposed programs as sufficient enough to address fair housing issues. 8.A Packet Pg. 30 24 of 39 Support for Affordable Housing Production (Programs Addressing Affordable Housing Production: 1G, 2A, 2B, 2C, 2E, 2F, 2G, 2H, 4C) Given the significant RHNA allocation for affordable housing, the draft Housing Element proposes four main strategies to support affordable housing production: 1. City-owned sites: In accordance with Council direction, the draft Housing Element prepared by staff includes a program that City-owned sites be prioritized for 100% affordable housing (Program 2). To analyze the realistic capacity of City-owned sites, staff undertook the following approach: o Prioritize the largest sites for analysis of housing potential: 4th & Arizona, Bergamot Arts Center, and Main Street Parking lots. o Assume that sites would develop at approximately 150 units/acre based on approximate densities of previously approved housing projects in the city and no higher than 80 feet to account for high-rise requirements, prevailing wages, and construction cost increases due to changes in construction type. o Request that HR&A identify financing constraints with respect to 100% affordable housing on City-owned sites to understand how many units could be supported with only public assistance vs. public/private partnership and provide an estimate of possible unit yields on priority sites. o Estimated realistic capacity will be based on assuming public/private partnership similar to methodology used to estimate capacity on other SSI sites, for smaller City-owned sites. As previously listed in the 34TUMay 12, 2021 staff reportU34T, each of the City-owned sites has associated constraints that would need to be considered. Chapter 4 and Appendix F of the draft Housing Element provide more detail regarding allocations for the city-owned 8.A Packet Pg. 31 25 of 39 sites. For reference, the following summarizes HR&A’s findings regarding financing of affordable housing on city-owned sites (Attachment D): o Analysis conducted for the following city-owned sites: ▪ 4P th P/Arizona property (2 properties including parking lot at 1324 5P th St) ▪ Bergamot Arts Center ▪ Main Street surface parking lots o The total physical development capacity of affordable units on city-owned sites over 1 acre available in the next 8 years is 1,693 units. o Top funding sources for affordable housing such as Low-Income Housing Tax Credit (LIHTC) were identified ▪ Even assuming a substantial multiple of historic capture of the top funding sources, affordable housing development capacity is constrained to no more than 1,693 units and would require substantial gap funding over eight years o The funding gap ranges between $50M to $250M and could be closed by either additional public assistance from sources other than the City or would require partnerships with private entities developing revenue- generating uses on city-owned land (e.g. market-rate housing). Article 34 of the California Constitution Article XXXIV, section 1, of the California Constitution (“Article 34”) was adopted as an initiative measure in 1950. Section 1 provides in part: “No low rent housing project shall hereafter be developed, constructed, or acquired in any manner by any state public body until a majority of the qualified electors of the city, town or county, as the case may be, in which it is proposed to develop, construct, or acquire the same, voting upon such issue, approve such project by voting in favor thereof at an election to be held for that purpose, or at any general or special election.” 8.A Packet Pg. 32 26 of 39 Article 34 defines low-rent housing projects as follows: “. . . any development composed of urban or rural dwellings, apartments or other living accommodations for persons of low income, financed in whole or in part by the Federal Government or a state public body or to which the Federal Government or a state public body extends assistance by supplying all or part of the labor, by guaranteeing the payment of liens, or otherwise.” The City participates extensively in providing financial assistance to private affordable housing developers (whether in the form of monetary loans, grants, or conveyance of land) to develop and operate affordable housing projects within the City. Such assistance is considered as development and/or construction within meaning of Article 34 even though the private developers undertake actual development and construction duties. (California Housing Finance Agency v. Elliott (1976) 17 Cal. 3d 575) Proposition I (Article XXI of the Santa Monica City Charter) In 1978, Santa Monica voters authorized the City to develop, finance or rehabilitate a certain amount of low-income housing in order to further its policy goals and avoid any violations of Article 34. The amount of low-income housing was capped at one percent (1 %) of the City's dwelling units, existing as of 1978. In 1998, the City’s voters approved Proposition I, which added Article XXI (Sections 2100-2130) to the City Charter. According to the ballot materials for Proposition I, the intent of Proposition I was to increase the cap limitation adopted by the voters in 1978. Article XXI provides the City with an annual authorization to develop, construct, acquire and finance low income housing units, including senior housing. The City's annual authorization would equal one-half of one percent (½ of 1%) of the total dwelling units existing in the City for the prior fiscal year. To determine starting authorization, the proposition set 48,573 units as the number of 8.A Packet Pg. 33 27 of 39 residential dwelling units existing in the City on June 30, 1998. So, during fiscal year 1998-99, the Proposition I authorized the City to develop, acquire, finance or construct ½ of 1% of 48,573 dwelling units, which equaled 243 low income dwelling units. Proposition I also provided that any portion of an annual authorization which is not used within that fiscal year may be carried over into the future for up to three additional years. Finally, Proposition I required City staff to provide an annual report to the City Council on the implementation of Article XXI, including the number of low-income units authorized, approved for funding, granted planning approval and constructed. According to the last Proposition I report generated, the City’s Proposition I Annual Authority Calculation for Fiscal Year 2019-20 is as follows: FY 2018-19 Authority Authority Used during FY 2018-19: Expired Unused Authority in June 2019: Carryover Authority FY 2016-17 to 2018-19: Plus FY 2019-20 New Authority: 1,055 (220) (43) 792 265 Grand Total 2019-20 Authority: 1,057 To date, the City has never exceeded any annual Proposition I low-rent housing production limits. Proposition I Constraints on the City’s Ability to Plan for Low-Rent Housing on City-owned Property. According to the City’s latest Housing Element analysis (Appendix F), a number of City-owned sites have the highest potential to accommodate the production of affordable housing, including the parcels surrounding the parking lots on Main Street and along Wilshire Boulevard, the Bergamot Arts Center, Parking Structure 3, and the site at 4th Street/Arizona. The 6th Cycle Housing Element proposes to explore means of maximizing housing potential on these sites, subject to a public process. The City engaged with HR&A advisors and local architects to estimate the realistic capacity of these sites with consideration to 8.A Packet Pg. 34 28 of 39 existing constraints (such as lease terms, financial feasibility, etc.). Based on their estimate and applying a density factor of 150 units/acre, City-owned sites have the potential for accommodating for 1,693 units. In light of the development potential for affordable housing on City-owned sites, a question thus arises as to whether Proposition I may act to constrain affordable housing development on City-owned sites. Conveyance of any City-owned site would be subject to the requirements of the Surplus Land Act (California Government Code sections 54220 et seq.). Due to the high cost of construction in Santa Monica, the City’s financial assistance to an affordable housing developer consisting solely of land conveyance is not likely sufficient to construct a 100% affordable housing project without additional sources of government funding (typically federal tax credits), which is typically awarded on a competitive basis. In theory, however, if sufficient funding were available to construct all 1,693 units on City-owned property, the Proposition I limitation on the annual cap of affordable dwelling units that could be produced with each conveyance would need to be considered. This would require coordination to ensure that the conveyances of City-owned property are staggered to fall below the Proposition I limits or, alternatively, the City Council could place a measure on the ballot to increase the cap. However, based upon the current “cushion” of Proposition I authority (due to affordable housing development below the annual Proposition I thresholds in the last three fiscal years), and assuming that government funding remains constrained at historical levels, staff does not think it realistic to assume that Article 34/Proposition I would be a likely constraint on affordable housing development for City-owned sites during the 6th Cycle of the City’s proposed Housing Element. 2. Affordable Housing Overlay (AHO): In accordance with Council direction, the draft Housing Element prepared by staff recommended (Program 2A) a citywide overlay that would augment the incentives provided by AB1763 for affordable housing up to 120% AMI 8.A Packet Pg. 35 29 of 39 o Program for up to 80% AMI affordable housing projects ▪ Applies citywide ▪ Unlimited density ▪ Unlimited height in commercial zones; minimum height of 4 stories in residential zones ▪ No minimum parking requirements o Program for up to 120% AMI affordable housing projects ▪ Apply to targeted areas such as Downtown, Bergamot area and 17P th P Street Metro E Line station ▪ 50% density bonus ▪ Unlimited height ▪ Flexibility in unit size/unit mix in exchange for common area amenities ▪ No minimum parking requirements o Within the overlay would be special regulations for parking lots associated with religious congregations in multi-unit residential zones that would allow some flexibility to include market-rate units as well The AHO was discussed by the Planning Commission at their June 2 and 3, 2021 meeting and the Commission recommended a revision to Program 2A that would eliminate the up to 80% AMI overlay but keep a modified version of the up to 120% AMI overlay. In their discussion, the Commission indicated that the allowances under State density bonus law for 100% affordable housing projects up to 80% AMI already provide enough incentive and since it was unlikely for affordable housing projects to be feasible in R1 neighborhoods, the AHO was unnecessary. However, the Commission supported the up to 120% AMI AHO in targeted areas (e.g. Downtown, Bergamot, 17th Street Station) in order to provide support to moderate-income units, which currently have no dedicated funding source or incentives under local or State law. As a result, the Commission recommended the 120% AMI AHO mirror the allowances under State density bonus law for 100% affordable housing projects. The following table provides a comparison between staff’s proposed program 2A in the draft Housing Element and that recommended by the Commission: 8.A Packet Pg. 36 30 of 39 Table 3: Comparison between Staff and Planning Commission Recommendation for Moderate-Income Affordable Housing Overlay Staff Recommendation Planning Commission Recommendation Applicability Housing project where 100% of the units are affordable to 120% AMI households Housing project where a feasible percentage of units are affordable to 120% AMI households Height Allowance Additional 3 stories or 33 feet Additional 3 stories or 33 feet Density Allowance 50% density bonus Unlimited density Incentives/Concessions from development standards Up to 4 Up to 4 Flexibility in unit size/unit mix in exchange for common area amenities Yes Yes Given interest expressed about 100 percent moderate income projects, and whether they may be feasible in Santa Monica without subsidy or tax credit financing, staff requested that HR&A conduct additional feasibility testing for 100% moderate-income projects but would not recommend that the moderate-income AHO apply to projects that have anything less than 100% of the units affordable to 120% AMI households.. Moderate-income rents are typically determined on a per unit basis in local government affordable rent schedules. But by developing smaller-than-average units, 100 percent moderate income projects can generate higher per-square foot rents that can justify the cost of construction. These projects sometimes also benefit from lower operating expenses, including exemption from property tax if the building is owned by a qualifying non-profit entity or a public agency and the units are deed-restricted. HR&A tested the financial feasibility of a 3-story (2.1 FAR) 100 percent moderate-income housing project and found that it would be unlikely to develop with 440 square foot studio units (440 square feet is the average size of a studio unit in Santa Monica and assumed in HR&A's other recent analysis). A 100 percent moderate income project could be feasible in currently industrial areas near the 17th Street Metro Station or near Bergamot, where land values are less 8.A Packet Pg. 37 31 of 39 costly (i.e., approximately $420 per square foot); this would require additional height, FAR and density (at least with 5 stories and 3.0 FAR), and unit sizes between 300 and 350 square feet per unit in order to be feasible. In Downtown, where land is much more expensive, unit sizes smaller than 250 square feet would be required for the project to be feasible, but units this small might not meet ADA or other basic habitability requirements. Building height and FAR also have a modest impact on feasibility on 100 percent moderate projects with small unit sizes: at roughly 250 square feet per unit, a 3-story building would be feasible outside of Downtown, while a 300-350 square feet per unit average would require a 4- or 5-story building. Additional costs due to high rise/fire code requirements make it unlikely that additional FAR or density beyond that height would support feasibility of a 100 percent moderate income project. 3. Accessory Dwelling Units: Remove barriers to producing ADUs including establishing an “ADU Accelerator” program that is anticipated to include pre- approved plans and review of fees and process for ADUs. 4. Increase opportunities to preserve existing housing units for long-term affordability: While this strategy would not count towards the RHNA, the City has always maintained an acquisition/rehabilitation program for existing units whereby they are deed-restricted for long-term affordability. Expansion in the AHPP off-site option to allow acquisition/rehabilitation as a way to satisfy the requirement is also being proposed. These strategies are in addition to the recommended FAR increases for market-rate housing projects at levels that can support minimum AHPP requirements. Housing Stability (Programs Addressing Housing Stability: 3A, 3B, 3C, 3D, 3E, 3F, 3G, 3H, 3I, 6A, 6B, 6C, 6D, 6E, 6F, 6G, 6H, 7A, 7B, 7C, 7D) 8.A Packet Pg. 38 32 of 39 The City operates many housing programs intended to preserve housing stock and provide assistance to existing tenants including acquisition/rehabilitation, financial assistance, and supportive services. These are detailed in Chapter 5 of the draft Housing Element and listed in Appendix D. A new recommended program is for the City to enact a local version of SB330 tenant protections since that State law sunsets in 2025. This would allow those protections to continue with the City’s local ordinance that would prevent the net loss of units as the result of redevelopment of existing multi-unit residential properties. Suitable Sites Inventory Government Code Section 65583(a)(3) requires local governments to prepare an inventory of land suitable for residential development, including vacant sites and sites having the potential for redevelopment, and an analysis of the relationship of zoning and public facilities and services to these sites. This inventory of land suitable for residential development, otherwise known as the Suitable Sites Inventory (SSI), is used to demonstrate that there is sufficient land at appropriate densities and development standards to accommodate the RHNA at the income levels specified within the planning period. The draft SSI was prepared in accordance with State Housing Element law and HCD’s Housing Element Sites Inventory Guidebook. The draft Housing Element Chapter 4 provides a summary of the SSI and Appendix F provides a report of the methodology used to prepare the SSI. To prepare the SSI, the City’s land use inventory was comprehensively reviewed to identify sites that are available for housing development within the Housing Element planning period, 2021-2029. The City focused the inventory to underutilized commercial sites since these sites are most likely to be redeveloped based on evidence of past development trends. Approximately 312 commercially zoned sites and 23 residentially zoned sites have been identified that have the highest potential to accommodate housing. These are shown on Figure 3. Sites may be viewed interactively on the City’s 8.A Packet Pg. 39 33 of 39 Housing Element Update webpage at https://www.santamonica.gov/housing-element- update-draft-concepts 34TThe sites in the SSI are categorized into twelve categories. Figure 3: Map of draft Suitable Sites for 6P th P Cycle Housing Element Update Capacity to Accommodate RHNA Allocation Per Government Code Section 65583.2(c), the SSI must include a calculation of the realistic residential development capacity of the sites. To ensure that sufficient capacity exists in the housing element to accommodate the RHNA throughout the planning period, HCD recommends that a jurisdiction create a buffer in the housing element inventory of at least 15 to 30 percent more capacity than required, especially for capacity to accommodate the lower income RHNA. With the programs identified in this Housing Element, the sites identified for the SSI combined with anticipated ADU production have the capacity to accommodate at least 8.A Packet Pg. 40 34 of 39 11,025 units providing a 24 percent buffer above the City’s RHNA of 8,895 units. This number is based on application of proposed new development standards for Tier 1 base housing projects. The buffer accounts for the likelihood that not all identified SSI sites may be necessarily developed by a property owner for housing. Approximately 150 additional units could be added to the total capacity if housing projects on these sites provided on-site affordable housing, rather than off-site. The example capacity calculation table on Page 14 of Appendix F to the draft Housing Element shows the methodology of how floor area was converted to capacity estimates for each suitable site. Table 4: Suitable Sites Capacity Summary Table – Base Tier 1 Housing (note that this is a revision to Table F-7, Appendix F – Report of Suitable Sites Inventory Analysis due to an inadvertent error in calculating the capacity of City sites) Total Capacity Capacity for Affordable Units # Units # Affordable Units ELI 30% AMI VLI 50% AMI LI 80% AMI Moderate 120% AMI Category 1 Approved 1,503 416 104 104 104 104 Category 1 Pending 680 165 42 42 42 42 Category 4 City Sites 1,884 1,696 424 424 424 424 Category 11 Religious Sites 257 193 48 48 48 48 Category 12 Parking Lots 94 47 12 12 12 12 All Remaining Categories 6,007 3,805 855 855 855 1,239 ADUs 600 396 90 12 258 36 Total 11,025 6,718 1,575 1,497 1,743 1,905 RHNA Targets 8,895 6,168 1,397 1,397 1,672 1702 Buffer +2,130 550 178 100 71 203 24% Table 5: Example Capacity Calculation Site Attribute Zoning MUB Site Area (SF) 10,000 Typical Density Tier 1 Max Proposed FAR 2.25 Max SF 22,500 Realistic Capacity Building Coverage (% of Site Area) 80% Land Use Controls Ground Floor Area (GSF) 8000 SF Ground Floor Use Retail 8.A Packet Pg. 41 35 of 39 Commercial Floor Area (NSF) 6,960 SF Capacity Upper Floor Uses Residential Residential Floor Area (NSF) 15,540 SF Average SF per Unit based on Unit Mix requirements 700 Max # of Units 22 Alternative Scenarios Analyzed but Not Recommended Interest has also been raised about the capacity if only existing zoning standards were applied. Tables 6 and 7 show the capacity calculations assuming existing Tier 1 and Tier 2 standards, respectively, and assuming that the City also prioritizes City-owned sites for affordable housing (the same as the SSI). At existing Tier 1 standards, the City would not meet the requirement to plan for the RHNA allocation as the estimated total number of units would be 6,600 units – 25% less than the RHNA allocation. In addition, none of the existing Tier 1 FARs have been found to be able to support the minimum AHPP requirements. As a result, this scenario would not produce a compliant Housing Element. Table 6: Existing Tier 1 Standards Capacity # Affordable Units Category 1 Approved 1,503 416 Category 1 Pending 680 165 Category 4 City owned Sites 1,884 1,696 Category 11 Religious Sites 29 22 Category 12 Parking Lots 61 30 All Remaining Categories 1,884 902 ADUs 600 396 Total 6,641 3,628 RHNA Targets 8,895 6,168 Buffer/Shortfall (2,254) (2,540) Buffer/Shortfall % -25% -41% At existing Tier 2 standards, the City would plan for approximately 4% over the RHNA allocation but would not meet the RHNA allocation for affordable units. In addition, feasibility testing for housing has shown that FARs necessary to support existing 8.A Packet Pg. 42 36 of 39 minimum AHPP requirements would need to exceed existing Tier 2 FARs. As a result, this scenario would also not produce a compliant Housing Element. Table 7: Existing Tier 2 Standards Capacity # Affordable Units Category 1 Approved 1,503 416 Category 1 Pending 680 165 Category 4 City owned Sites 1,884 1,696 Category 11 Religious Sites 29 22 Category 12 Parking Lots 61 30 All Remaining Categories 4,511 2,194 ADUs 600 396 Total 9,268 4,919 RHNA Targets 8,895 6,168 Buffer/Shortfall 373 (1248) Buffer/Shortfall % 4% -20% Accessory Dwelling Units Accessory Dwellings Units (ADUs) and Junior Accessory Dwelling Units (JADUs) 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, over the past four years, the State has enacted several laws to help spur the production of housing through the development of ADUs and JADUs. On September 8, 2020, City Council approved an ordinance incorporating State law ADU requirements into a new ADU/JADU Section of the Zoning Ordinance, SMMC Section 9.31.025 Accessory Dwelling Units and Junior Accessory Dwelling Units. The ordinance further expands upon the new requirements by exempting all ADUs and JADUs from parcel coverage or floor area calculations, providing more permissive development of ADUs. Table 8 below and Figure 2 above summarize ADU development and location within the City since 2018, 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 on R1 (Single-Unit Residential) zoned parcels. The City is just now starting to see property 8.A Packet Pg. 43 37 of 39 owners take advantage of the new ability to establish sometimes multiple ADUs within existing multiple-unit and mixed-use developments. Table 8: Santa Monica Historic ADU Production Building Permit Year In-Progress Permit Issued Completed Total 2018 2 13 41 56 2019 32 30 21 83 2020 88 25 2 115 2021 25 2 - 27 TOTAL 147 70 64 281 Average 2018-2020 (56+83+115)/3 = 84.6 units per year Source: Building permit data as of June 1, 2021 Each ADU building permit is only accounted for once across all permit statuses and years. Quantified Objective Pursuant to Government Code Section 65583(b), the draft Housing Element includes quantified objectives for housing production, housing rehabilitation, and housing assistance as required by State law (See Chapter 5). Note that the requirement to prepare quantified objectives does not alter the City’s responsibility to demonstrate compliance with the RHNA for the purpose of preparing a compliant Housing Element. As a result, the quantified objectives are not used for any aspect of RHNA compliance other than a recognition that total housing needs may exceed available resources. The following provides a summary of the quantified objectives for housing production. As one of the required components of a Housing Element, State law [Government Code Section 65583(b)] requires the following: 1. A statement of the community’s goals, quantified objectives, and policies relative to the maintenance, preservation, improvement, and development of housing. 2. It is recognized that the total housing needs identified pursuant to subdivision (a) [i.e., the RHNA] may exceed available resources and the community’s ability to satisfy this need within the content of the general plan requirements. The quantified objectives need not be identical to the total housing needs. The 8.A Packet Pg. 44 38 of 39 quantified objectives shall establish the maximum number of housing units by income category, including extremely low income, that can be constructed, rehabilitated, and conserved over a five-year time period. The City’s success in producing housing units that are deed-restricted to be affordable for the 5P th P Cycle Housing Element has been made possible by public assistance through the City’s Housing Trust Fund, inclusionary units required by the City’s Affordable Housing Production Program, inclusionary units negotiated in development agreements, and pursuit of new funding resources. The lack of a significant and consistent funding source for affordable housing coupled with high land and construction costs in Santa Monica makes achievement of the 6th Cycle RHNA for affordable housing units very challenging. Table 9 presents Santa Monica’s RHNA along with the City’s new construction objectives by income level. The quantified objective represents a level that the City believes is reasonable given the uncertainty of available funding resources from the State and other sources. The City Council has prioritized funding and land use policies to develop affordable housing. Table 9: RHNA vs. Quantified Objective Household Income Category RHNA % of Total Quantified Objective % of Total Very Low 2,794 31% 1,150 22% Low 1,672 19% 572 11% Moderate 1,702 19% 351 7% Above Moderate 2,727 31% 3,180 60% Total 8,895 5,263 The quantified objective of 5,263 units can be achieved based on current approved and pending projects, zoning standards, use of City-owned land, and incentives for ADU production. The lower quantified objective reflects the lack of public financing available for affordable housing. Even with maximizing affordable housing on City- 8.A Packet Pg. 45 39 of 39 owned sites and the City’s inclusionary requirements from the AHPP and DCP, providing 69% of the future units as affordable will be difficult. 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. Prepared By: Beth Rolandson, Administrative Services Officer Approved Forwarded to Council Attachments: A. Draft Housing Element + Appendices A-H (Web Link) B. HR&A, JKA & Danielian Associates R1 Analysis C. Planning Commission and Staff Recommended Changes to Draft Housing Element D. HR&A City-Owned Sites Analysis E. HR&A FAR-AHPP Analysis F. Glossary of Terms & Acronyms G. City Council March 30 Staff Report on Housing Element Draft Concepts (Web Link) H. Planning Commission May 12 Staff Report on Housing Element Progress Update I. Planning Commission June 2 Staff Report on Draft Housing Element (Web Link) J. Written Comments K. PowerPoint Presentation 8.A Packet Pg. 46 HR&A Advisors, Inc.Santa Monica AHPP 2021 Update | 1 R1 DEVELOPMENT STANDARDS ANALYSIS CITY OF SANTA MONICA AFFORDABLE HOUSING PRODUCTION PROGRAM 2020-2021 UPDATE JUNE 2021 8.A.b Packet Pg. 47 Attachment: HR&A, JKA & Danielian Associates R1 Analysis (4568 : Housing Element HR&A Advisors, Inc.Santa Monica AHPP 2021 Update | 2DRAFT RESULTS ANALYTIC APPROACH HR&A, with support from two design firms, tested the feasibility of 1) permitting multifamily units within existing R1 development standards, and 2) requiring an inclusionary unit with these multifamily buildings. Danielian Associates and John Kaliski Architects developed general specifications for the physical parameters of 2 through 6-unit prototypes, aiming to respect existing R1 and/or R2 standards, but noting where flexibility would be needed. Prototype details, feasibility findings and key considerations are included in the following slides. N. of Montana Sunset Park Avg. Underutilized R1 Land Sale Price $2,900,000 ($343/SF) $1,715,000 ($270/SF) Avg. Condo/ Townhouse Sale Price $2,080,000 ($1,190/SF) $1,255,000 ($955/SF) Total Development Cost (excl. Land) $550/SF $455/SF Average Unit Size 1,775 SF 1,350 SF 8.A.b Packet Pg. 48 Attachment: HR&A, JKA & Danielian Associates R1 Analysis (4568 : Housing Element HR&A Advisors, Inc.Santa Monica AHPP 2021 Update | 3DRAFT RESULTS FEASIBILITY IMPLICATIONS* * Based on private developer Profit Margin (12.5%+ = Feasible) MISSING MIDDLE HOUSING | 2 Units within R1 Standards PROS •Maintains existing standards •No costly subterranean parking CONS •Not feasible, even for 100% market rate •Cannot support an inclusionary unit 100% Market 1 MI Unit 1 LI Unit 1 VLI Unit 1 ELI Unit N. of Montana -11%N/A (Market Rate not Feasible) Sunset Park -26%N/A (Market Rate not Feasible) HR&A | JKA | Danielian 8.A.b Packet Pg. 49 Attachment: HR&A, JKA & Danielian Associates R1 Analysis (4568 : Housing Element HR&A Advisors, Inc.Santa Monica AHPP 2021 Update | 4DRAFT RESULTS FEASIBILITY IMPLICATIONS* * Based on private developer Profit Margin (12.5%+ = Feasible) MISSING MIDDLE HOUSING | 3 Units within R1 Standards 100% Market 1 MI Unit 1 LI Unit 1 VLI Unit 1 ELI Unit N. of Montana -12%N/A (Market Rate not Feasible) Sunset Park -26%N/A (Market Rate not Feasible) PROS •Maintains existing R1 zoning standards •No costly subterranean parking CONS •Requires below-market unit sizes •Not feasible, even for 100% market rate •Cannot support an inclusionary unit HR&A | JKA | Danielian 8.A.b Packet Pg. 50 Attachment: HR&A, JKA & Danielian Associates R1 Analysis (4568 : Housing Element HR&A Advisors, Inc.Santa Monica AHPP 2021 Update | 5DRAFT RESULTS MISSING MIDDLE HOUSING | 3 Units w/ flexibility to R1 Standards 100% Market 1 MI Unit 1 LI Unit 1 VLI Unit 1 ELI Unit N. of Montana 11%-24.7%N/A (Mod Income not Feasible) Sunset Park -3%N/A (Market Rate not Feasible) PROS •Larger units may support feasibility North of Montana •Maintains height limits R-1 standards, but not lot coverage CONS •Costly subterranean parking •Cannot support an inclusionary unit •May not be feasible South of the 10 Fwy. (e.g., Sunset Park) HR&A | JKA | Danielian FEASIBILITY IMPLICATIONS* * Based on private developer Profit Margin (12.5%+ = Feasible) 8.A.b Packet Pg. 51 Attachment: HR&A, JKA & Danielian Associates R1 Analysis (4568 : Housing Element HR&A Advisors, Inc.Santa Monica AHPP 2021 Update | 6DRAFT RESULTS MISSING MIDDLE HOUSING | 3 Units w/ flexibility to R1 Standards 100% Market 1 MI Unit 1 LI Unit 1 VLI Unit 1 ELI Unit N. of Montana 15%-19.5%N/A (Mod Income not Feasible) Sunset Park 2.1%N/A (Market Rate not Feasible) PROS •Larger units may support feasibility North of Montana •No costly subterranean parking CONS •Requires adjustments to R1 height limits for part of parcel •Cannot support an inclusionary unit •May not be feasible South of the 10 Fwy. (e.g., Sunset Park) HR&A | JKA | Danielian FEASIBILITY IMPLICATIONS* * Based on private developer Profit Margin (12.5%+ = Feasible) 8.A.b Packet Pg. 52 Attachment: HR&A, JKA & Danielian Associates R1 Analysis (4568 : Housing Element HR&A Advisors, Inc.Santa Monica AHPP 2021 Update | 7DRAFT RESULTS PROS •Feasible for market rate units across the City, as demonstrated by R2 construction CONS •Would require major modification to existing R1 standards •Cannot support an inclusionary unit 100% Market 1 MI Unit 1 LI Unit 1 VLI Unit 1 ELI Unit N. of Montana 28%10%7%7%6% Sunset Park 16%-4.2%N/A (Mod Income not Feasible) HR&A | JKA | Danielian FEASIBILITY IMPLICATIONS* * Based on private developer Profit Margin (12.5%+ = Feasible) INCLUSIONARY HOUSING | 4 Units w/ flexibility to R2 Standards (7,500 SF Lot) 8.A.b Packet Pg. 53 Attachment: HR&A, JKA & Danielian Associates R1 Analysis (4568 : Housing Element HR&A Advisors, Inc.Santa Monica AHPP 2021 Update | 8DRAFT RESULTS INCLUSIONARY HOUSING | 4 Units w/ flexibility to R2 Standards (6,750 SF Lot) 100% Market 1 MI Unit 1 LI Unit 1 VLI Unit 1 ELI Unit N. of Montana 28%10%7%7%6% Sunset Park 16%-4.2%N/A (Mod Income not Feasible) PROS •Feasible for market rate units across the City, as demonstrated by R2 construction CONS •Would require major modification to existing R1 standards •Cannot support an inclusionary unit HR&A | JKA | Danielian FEASIBILITY IMPLICATIONS* * Based on private developer Profit Margin (12.5%+ = Feasible) 8.A.b Packet Pg. 54 Attachment: HR&A, JKA & Danielian Associates R1 Analysis (4568 : Housing Element HR&A Advisors, Inc.Santa Monica AHPP 2021 Update | 9DRAFT RESULTS 100% Market 1 MI Unit 1 LI Unit 1 VLI Unit 1 ELI Unit N. of Montana 31%18%16%15%15% Sunset Park 19%5%2%1%-1% PROS •Feasible for market rate units across the City •May support inclusionary unit in stronger N. of Montana market areas (or potentially Citywide with smaller MI inclusionary unit) CONS •Would require modification to existing R2 standards •Would require additional height, at least for part of lot •Cannot support an inclusionary unit in most casesHR&A | JKA | Danielian INCLUSIONARY HOUSING | 5 Units w/ flexibility to R2 Standards (7,500 SF Lot) FEASIBILITY IMPLICATIONS* * Based on private developer Profit Margin (12.5%+ = Feasible) 8.A.b Packet Pg. 55 Attachment: HR&A, JKA & Danielian Associates R1 Analysis (4568 : Housing Element HR&A Advisors, Inc.Santa Monica AHPP 2021 Update | 10DRAFT RESULTS 100% Market 1 MI Unit 1 LI Unit 1 VLI Unit 1 ELI Unit N. of Montana 36%28%26%26%25% Sunset Park 25%17%14%13%11% PROS •Feasible for market rate units across the City •Would support an inclusionary unit across the City CONS •Would require substantial modification to existing R2 standards, including additional height HR&A | JKA | Danielian INCLUSIONARY HOUSING | 6 Units w/ flexibility to R2 Standards (7,500 SF Lot) FEASIBILITY IMPLICATIONS* * Based on private developer Profit Margin (12.5%+ = Feasible) 8.A.b Packet Pg. 56 Attachment: HR&A, JKA & Danielian Associates R1 Analysis (4568 : Housing Element HR&A Advisors, Inc.Santa Monica AHPP 2021 Update | 11DRAFT RESULTS INCLUSIONARY HOUSING | 6 Units w/ flexibility to R2 Standards (6,750 SF Lot) HR&A | JKA | Danielian PROS •Feasible for market rate units across the City •Would support an inclusionary unit across the City CONS •Would require substantial modification to existing R2 standards, including additional height100% Market 1 MI Unit 1 LI Unit 1 VLI Unit 1 ELI Unit N. of Montana 36%28%26%26%25% Sunset Park 25%17%14%13%11% FEASIBILITY IMPLICATIONS* * Based on private developer Profit Margin (12.5%+ = Feasible) 8.A.b Packet Pg. 57 Attachment: HR&A, JKA & Danielian Associates R1 Analysis (4568 : Housing Element Addenda Sheet Housing Element 2021- 2029 June 2 – 3, 2021 yea HOUSING ELEMENT 2021-2029 ADDENDA SHEET This addenda sheet contains corrections, clarifications, and changes to the published text of the 6th Cycle Housing Element and represents changes recommended by the Planning Commission and staff. The proposed corrections, clarifications, and changes to the Housing Element Update are listed with their locations and their corrections. There may be errors, clarifications and changes that carry over to multiple areas within the plan, all of which will be addressed and amended. The Staff Response column includes explanation where staff does not agree with the Planning Commission recommendation. PLANNING COMMISSION RECOMMENDED CHANGES The following recommended changes to the DRAFT Housing Element Update result from Planning Commission deliberations and further staff analysis. Change No. Page Number Item Description Recommended Redline Staff Response 1. 7 Community Context: The revised version corrects dates and presents facts from a more accurate Santa Monica-specific perspective rather than a regional perspective from which Santa Monica is more of a footnote Santa Monica had simple beginnings in 1875 as an aspiring commercial port. Growth was slow until the City re-imagined itself as a seaside coastal resort and incorporated in 1886. A regional population surge spurred on by the arrival of the Santa Fe Railroad in Los Angeles in 1887, resulted in the City’s population increasing to approximately 2,000 people by 1892, when the Santa Fe completed its line to Santa Monica. The arrival of the first electric street car in 1896 and the completion of major regional roadways in the early 1910s led to further growth of primarily single family homes.1 During the 1920s, the City OK 8.A.c Packet Pg. 58 Attachment: Planning Commission and Staff Recommended Changes to Draft Housing Element (4568 : Housing Element Review and Adoption) Addenda Sheet Housing Element 2021- 2029 June 2 – 3, 2021 Change No. Page Number Item Description Recommended Redline Staff Response witnessed a substantial population and building boom, transforming the City from a recreational destination to a sought- after residential community, that also included significant brick and aircraft industries. During World War II, demand for housing was further spurred on by the rapid growth of Douglas Aircraft resulting in both single- and multi-unit development. 2. 27 A resort at the foot of Pico Boulevard was stopped, and a Jazz Club in the Belmar area was stopped. The original statement above conflates the two, so either chose one, or list both. For example, when Blacks/African Americans tried to build a Jazz Club in the Belmar area in the 1920s OK 3. 49 In Santa Monica, African Americans were never permitted to live in single- family neighborhoods. When the city first established zoning, the prevailing community of African Americans in the city surrounding Phillips Chapel was zoned R2. They petitioned to be rezoned R1 to enjoy the same “protections” as everyone else and were denied. According to census records, no POC ever lived in the city’s R1 districts until the 1950s or 60s. …they were excluded from single-family neighborhoods. OK 8.A.c Packet Pg. 59 Attachment: Planning Commission and Staff Recommended Changes to Draft Housing Element (4568 : Housing Element Review and Adoption) Addenda Sheet Housing Element 2021- 2029 June 2 – 3, 2021 Change No. Page Number Item Description Recommended Redline Staff Response 4. 58 clarify how many units are counted for prior SSI sites and which programs apply to City-Owned sites. The SSI identifies 25 sites that were in the last (5th) Cycle Housing Element with capacity for approximately 1,500 units. OK 5. 66 Program 1.F: Include Tier 3 in the text, not just Tier 2. The City shall also reconsider the feasibility of Tier 2 and Tier 3 project requirements for Downtown housing projects, including the increase in affordable housing requirements relative to building height. OK 6. 28 The area we know today as Pico Neighborhood began in 1904 as a mixed- race area of working-class whites, and Mexicans who worked in the clay pits. Beginning in the 1920s with the Great Migration of African Americans to California, most newly arrived people of color also settled east of 14th Street between Santa Monica and Pico Boulevards that was open to them. The FHA program led to white flight, primarily into the new whites-only Sunset Park neighborhood creating stark segregation in the city. Eminent domain proceedings for the Civic Center and Samohi eliminated most other neighborhoods of color in the city. Many of those families moved to the Pico Neighborhood. In the post-World War II era, the Federal government further intensified segregation 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 in Santa Monica was purposely constructed through the middle of the Pico Neighborhood where most people of color lived instead of using mostly undeveloped land or land with abandoned uses less than two blocks away. The construction of the I-10 freeway in the early OK 8.A.c Packet Pg. 60 Attachment: Planning Commission and Staff Recommended Changes to Draft Housing Element (4568 : Housing Element Review and Adoption) Addenda Sheet Housing Element 2021- 2029 June 2 – 3, 2021 Change No. Page Number Item Description Recommended Redline Staff Response When the I10 freeway was proposed, rather than use less-disruptive corridors such as Olympic Boulevard, undeveloped industrial land, the abandoned railroad right- of-way or abandoned brickyards, a route a block-and-a-half south of all that was chosen that displaced hundreds of families, and many businesses and churches. It divided and disrupted a formerly cohesive community, and led to further displacement when demand for housing resulted in the redevelopment of more family homes into apartment buildings. 1960s demolished hundreds of homes in the Pico neighborhood, resulting in a loss of family wealth through home ownership. With other Santa Monica neighborhoods still not open to the displaced, many more single-unit homes in the Pico Neighborhood were replaced by apartment buildings. 7. Global Change any reference to AB1763, with regards to density bonus consistency, to state law, generally. OK 8. 12 Outreach table mentions meeting with Westside Interfaith Council, but staff met with Santa Monica Area Interfaith Council. Change all references. Staff met with representatives of a variety of religious congregations through the Santa Monica Area Interfaith Council. OK 9. 47 Add clarification that there are only about 6,500 parcels zoned R1 so part of the 11,572 count includes SUDs in MUD zoned properties. In 2020, Santa Monica’s housing stock consisted of approximately 52,629 total units, 11,572 of which are single-unitand 40,853 of which are multi-unit. Although there are over 11,000 single-unit dwellings, there are only around OK 8.A.c Packet Pg. 61 Attachment: Planning Commission and Staff Recommended Changes to Draft Housing Element (4568 : Housing Element Review and Adoption) Addenda Sheet Housing Element 2021- 2029 June 2 – 3, 2021 Change No. Page Number Item Description Recommended Redline Staff Response 6,500 parcels zoned for R1, meaning many are located within multi-unit zones. 10. 60, Figure 4-4 Update Figure 4-4 to reflect most recent ADU data for 2021. 2018: 2, 13, 41, 56 2019: 32, 30, 21 ,83 2020: 88, 25, 2, 115 2021: 25, 2, -, 27 Total: 147, 70, 64, 281 Average 2018-2020: (56+83+115)/3+ 84.6 ADUs per year Source: Building permit data as of June 1, 2021 OK 11. Appendix E, pages 24- 25 and Figure E- 12 Update ADU data to reflect most recent ADU data for 2021. 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 June 1, 2021, Figure E-12 and Map E-6 below summarize ADU development and location within the City since 2018, the start of when State law began to focus on incentivizing ADUs. 2018: 2, 13, 41, 56 2019: 32, 30, 21 ,83 2020: 88, 25, 2, 115 2021: 25, 2, -, 27 Total: 147, 70, 64, 281 OK 12. 60, Figure 4-4 Add note that in Figure 4- 4 each ADU is only accounted for once across all permit statuses and years. Each ADU building permit is only accounted for once across all permit statuses and years. OK 13. 89 Revise the total dollars number and explain what At an estimated $480,000 in total OK 8.A.c Packet Pg. 62 Attachment: Planning Commission and Staff Recommended Changes to Draft Housing Element (4568 : Housing Element Review and Adoption) Addenda Sheet Housing Element 2021- 2029 June 2 – 3, 2021 Change No. Page Number Item Description Recommended Redline Staff Response funding sources are available including private, public, tax credits, fed, state, county, etc. But could also breakdown into range based on possible scenarios. development costs per affordable unit, it would cost approximately $2.9B to produce all of the affordable units in Santa Monica’s RHNA allocation. Funding to produce all of the affordable units in Santa Monica’s RHNA allocation would likely continue to require a mix of inclusionary units and public assistance (i.e. any combination of federal, state, county, and tax credits). Even on City-owned land, the funding gap is estimated at approximately $152,000 that would need to filled by sources other than the City. For privately-funded inclusionary units, the estimated cost to a developer is approximately $480,000. 14. 66 Amend Program 1.F background to breakdown 1,133 units by those projects governed by pre- and post-DCP standards. TBC OK 15. TOC Add page numbers. OK 16. 75 Program 3.C Background: provide more information as to how at-risk these 770 affordable units are. No Change. Nothing more to add. 17. Global Correct parcel size of Bergamot Arts Center to 5 acres throughout. OK 8.A.c Packet Pg. 63 Attachment: Planning Commission and Staff Recommended Changes to Draft Housing Element (4568 : Housing Element Review and Adoption) Addenda Sheet Housing Element 2021- 2029 June 2 – 3, 2021 Change No. Page Number Item Description Recommended Redline Staff Response 18. Appendix F, 15 Add in LUCE baseline capacity as comparison (5,729 units). Add New Section: Comparison of the RHNA with Adopted City Plan Projections: With the adoption of the LUCE in 2010, the City had originally anticipated the addition of 4,955 new housing units in the City by 2030, but that forecast was increased by 2,326 units after adoption of the Downtown Community Plan in 2017. Considering that approximately 2,200 units have been constructed since 2010 and 1,000 units are under construction, the remaining growth anticipated through 2030 under current plans is 4,081 units. The 6th Cycle Housing Element RHNA is more than twice than planned amount of units anticipated under City plans and zoning. OK 19. Table F-7, Appendix F, 15 Assumption for residential unit size seems too high. The Example Capacity Calculation Table should be corrected to reflect average unit size of 700 sf, which was what was actually used. The 1,050 sf was incorrect. Capacity calculations do not change as the 1,050 sf was a typo. OK 8.A.c Packet Pg. 64 Attachment: Planning Commission and Staff Recommended Changes to Draft Housing Element (4568 : Housing Element Review and Adoption) Addenda Sheet Housing Element 2021- 2029 June 2 – 3, 2021 Change No. Page Number Item Description Recommended Redline Staff Response 20. 57 Figure 4-2, Category 10: Incomplete sentence. All remaining City sites with an assessor’s value ratio (AVR) of 0.5 or less have the highest likelihood of redevelopment. OK 21. 62 4th sentence sounds awkward However, there are limited 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. OK 22. 68 Program 2.A: First sentence is repeated. To help make 100% affordable housing projects more competitive against market rate projects and reduce the construction costs of affordable housing, the City shall amend the Zoning Ordinance to establish a citywide 100% Affordable Housing Overlay for up to 80% AMI housing projects that would augment the provisions in AB1763. OK 23. 70 Program 2.D: Second paragraph has an errant “:” At the beginning sentence. On August 25, 2020, the City Council updated Santa Monica Municipal Code Chapter 9.22 which implements State density bonus law, to incorporate updates to the State Density Bonus Law. OK 8.A.c Packet Pg. 65 Attachment: Planning Commission and Staff Recommended Changes to Draft Housing Element (4568 : Housing Element Review and Adoption) Addenda Sheet Housing Element 2021- 2029 June 2 – 3, 2021 Change No. Page Number Item Description Recommended Redline Staff Response 24. 74 Program 3.D: Typo in first sentence As resources are available, the City shall continue to provide loan assistance to nonprofit affordable housing providers and work with providers to identify new funding sources. OK 25. 80 Program 5.A Background: an errant “:” At the beginning sentence. Santa Monica has a long history of investing in housing and supportive services to prevent and address the impacts of homelessness. OK 26. 44 Policy 1.4: The term “context sensitive” may be a barrier to housing projects with greater height and density. Change to “responsive to” Design of Housing. Ensure that the design of new housing development is responsive to the context. OK 27. 45 Policy 1.7: This policy should not just assess constraints to housing, but ensure that City fees/processes do not constrain housing. Review of Housing Constraints. Periodically review City taxes, fees, and regulations to ensure that they do not constrain housing development. OK 28. 46 Policy 2.6: Specifically explore new funding sources for artist housing. New Funding Sources. Work with local nonprofit community organizations to tap into new funding sources and support local capacity to develop affordable housing on an ongoing basis. Explore private arts funding for artist housing. OK 29. 46 Policy 2.5: Employer- provided housing should be permanent. Homeownership Opportunities. Explore ways to encourage the development of ownership housing affordable to moderate- OK 8.A.c Packet Pg. 66 Attachment: Planning Commission and Staff Recommended Changes to Draft Housing Element (4568 : Housing Element Review and Adoption) Addenda Sheet Housing Element 2021- 2029 June 2 – 3, 2021 Change No. Page Number Item Description Recommended Redline Staff Response income households and the City’s workforce, including possibilities for employer- provided permanent housing. 30. 45 Add a few sentences to the Goal 2 background explaining the importance of the arts economy to Santa Monica’s workforce, and the unique housing challenges. The City’s economy is supported by a diverse variety of industry sectors but still remains heavily dependent on the food/accommodation and retail trade sectors. This sector employs approximately 25% of the workforce but has generally lower wages than other sectors. With lower income jobs also in other major employment sectors such as education and healthcare, 91% of workers cannot afford to live in Santa Monica. The artist community of Santa Monica is a unique sector that should be preserved and uplifted through housing opportunities. Artist special housing needs, like live-work units, should also be considered. OK 31. 48 Policy 3.2: Add “rent controlled” after “naturally occurring”, strengthen term “encourage” Preservation of Naturally Occurring and Deed Restricted Affordable Rental Housing. Preserve naturally occurring, rent controlled, and restricted affordable rental housing. OK 8.A.c Packet Pg. 67 Attachment: Planning Commission and Staff Recommended Changes to Draft Housing Element (4568 : Housing Element Review and Adoption) Addenda Sheet Housing Element 2021- 2029 June 2 – 3, 2021 Change No. Page Number Item Description Recommended Redline Staff Response 32. 48 Policy 3.4: Remove reference to State Law. Replacement of Demolished Multi-Unit Housing. The City shall ensure the replacement of multiunit housing that is demolished. OK 33. 50 Policy 4.2: Move “throughout the City.” Equitable Distribution of Housing for All Income Levels. Encourage fair distribution throughout the City of all housing types for extremely low– , very low-, low-, and moderate-income persons including the most vulnerable communities and the housing insecure. OK 34. 50 Policy 4.3: add “zoning change” to after infrastructure investments; change “market opportunities” to “diverse housing types”; add language at the end “as well as programs that would allow for right of return of historically displaced families in Santa Monica” Targeted Investments. Strategically targethousing creation strategies (e.g., public funding, incentives, infrastructure investments, zoning changes, etc) and diverse housing types in locations that will help overcome historic patterns of segregation. as well as programs that will help with the right of return for historically displaced families in Santa Monica. OK, pending City Council discussion on conceptual program in July that would give priority to those displaced (or related to) from the Belmar and 10 frwy areas to the City’s Below Market Rate Housing waitlist 35. 51 Policy 5.2: Remove “those whose last permanent address was in Santa Monica.” Commission expressed concerns that the priority may not be broad enough to address those in need and prior SM residents who’s last Housing and Supportive Services for the Homeless. Match housing and supportive service resources to the needs of priority homeless populations: Santa Monica’s chronically homeless; Staff recommends maintaining this language/ priority as its part of the homelessness strategies adopted by Council. and therefore its necessary to reflect 8.A.c Packet Pg. 68 Attachment: Planning Commission and Staff Recommended Changes to Draft Housing Element (4568 : Housing Element Review and Adoption) Addenda Sheet Housing Element 2021- 2029 June 2 – 3, 2021 Change No. Page Number Item Description Recommended Redline Staff Response permanent address may not have been in SM but still former residents nonetheless. and vulnerable members of Santa Monica’s workforce. this adopted policy in the Housing Element update. 36. 54 Policy 7.1: Add in “including, but not limited to,” before prohibiting Enforce Fair Housing Laws. Continue to enforce fair housing laws including, but not limited to, prohibiting arbitrary discrimination in the building, financing, selling, or renting of housing, on the basis of race, color, religion, sex, gender, gender identity, gender expression, sexual orientation, age, marital status, national origin, ancestry, familial status, income level, source of income, disability, veteran or military status, or genetic information, and to promote racial diversity and equality in housing distribution. OK 37. 15, 63 Program 1.A: Clarify that “the City shall make permanent interim amendments to the LUCE…”; add moderate income units, generalize HAA compliant projects; Elisa’s language; “minimum % of moderate income units”; add the Paula Larmore background statement; reword the minor modification phrase to clarify that it would be subject to ministerial The City shall make permanent interim amendments to the Zoning Ordinance, and make amendments to the LUCE, Downtown Community Plan (DCP), Bergamot Area Plan (BAP) and Zoning Ordinance, as necessary, to allow housing projects that are either 100% affordable, not including manager’s units, subject to HAA, or includes a minimal number of moderate- OK 8.A.c Packet Pg. 69 Attachment: Planning Commission and Staff Recommended Changes to Draft Housing Element (4568 : Housing Element Review and Adoption) Addenda Sheet Housing Element 2021- 2029 June 2 – 3, 2021 Change No. Page Number Item Description Recommended Redline Staff Response process divorced from HAA income units to be reviewed through an administrative process. This program would create a more streamlined application process, providing certainty for housing providers. Amendments shall include clarifications that projects receiving Minor Modifications pursuant to Santa Monica Municipal Code 9.43.020 or by-right density bonus incentives are eligible for this streamlined process. 38. 15, 64 Program 1.B: Remove “certain” The City shall adopt new streamlining procedures to expedite the design review of housing projects. This would include, but not limited to, shifting the design review to be concurrent with entitlement review so as to reduce processing timelines. OK 39. 15, 64 Program 1.C: Expand on list of incentives (Hank Koenig letter). In order to Affirmatively Further Fair Housing, the City shall adopt standards that incentivize housing production on surface parking lots in multi-unit residential zones (i.e. R2, R3, R4) associated with existing commercial uses, including removing the density caps, streamlining parking requirements, removing parking replacement OK 8.A.c Packet Pg. 70 Attachment: Planning Commission and Staff Recommended Changes to Draft Housing Element (4568 : Housing Element Review and Adoption) Addenda Sheet Housing Element 2021- 2029 June 2 – 3, 2021 Change No. Page Number Item Description Recommended Redline Staff Response requirements, removing parking minimums, and restoring underlying maximum allowable density. 40. 15, 65 Program 1.D: Substitute “Transit Priority Areas” to “within ½ mile walking distance of public transit” The City shall explore reducing or eliminating minimum parking requirements for housing projects within ½ mile walking distance of public transit. OK 41. 15, 65 Program 1.E: remove “more” in front of objective standards; add that objective standards would include liberal standards for live/work artists and commercial living situations; reducing minimum parking requirements ; reference eliminate DAs for housing projects citywide; add in language about feasibility. The City shall modify the design guidelines in the BAP to establish objective standards and feasible development standards to support housing production. The revisions to development standards will address at minimum: density (floor area ratio) calculations for housing, height limitations, building modulation, ground floor uses, street frontages/ pedestrian orientation, open space, reduction in parking minimums, live/work artist and commercial living situations, etc. The standards shall be user- friendly with improved clarity and include greater development incentives to build housing. OK 42. 65 Add live/work artist description to the background information of Program 1.E. (See The BAP was initiated to transition 142.5 acres of former industrial land into a walkable, sustainable, and OK 8.A.c Packet Pg. 71 Attachment: Planning Commission and Staff Recommended Changes to Draft Housing Element (4568 : Housing Element Review and Adoption) Addenda Sheet Housing Element 2021- 2029 June 2 – 3, 2021 Change No. Page Number Item Description Recommended Redline Staff Response changes proposed for page 45). innovative complete neighborhood. The BAP encourages affordable/market-rate housing to enable employees to live in the area and offer new lifestyle choices connected to transit. The BAP should also consider the special housing needs of artists, such as live-work units, to promote artist residents in the Bergamot area. 43. 16, 66 Program 1.F: Remove AHPP, replace with Housing Projects. Remover Tier 2 reference, include feasibility language. REVISE THE DOWNTOWN COMMUNITY PLAN DEVELOPMENT STANDARDS TO SUPPORT HOUSING PROJECTS The City shall modify the design standards in the DCP to establish objective standards and feasible development standards to support housing production. The City shall also reconsider the feasibility of project requirements for Downtown housing projects, including the increase in affordable housing requirements relative to building height. OK 44. 16, 67 Program 1.H: Add “Permanent” before “Residential Use”. Add in reference to allow use of ground floor commercial ADAPTIVE REUSE OF EXISTING COMMERCIAL BUILDINGS FOR PERMANENT RESIDENTIAL USE. OK 8.A.c Packet Pg. 72 Attachment: Planning Commission and Staff Recommended Changes to Draft Housing Element (4568 : Housing Element Review and Adoption) Addenda Sheet Housing Element 2021- 2029 June 2 – 3, 2021 Change No. Page Number Item Description Recommended Redline Staff Response space for artist/live-work use. As an alternative to constructing new housing, the City shall encourage and incentivize the adaptive reuse of existing commercial tenant space for residential use and also allow an adaptive reuse of existing ground floor commercial space for artists and live-work use. The City shall also explore policy changes to incentivize the conversion of existing commercial tenant space to residential use, such as relaxing parking, unit mix, open space, and other typical zoning or building code requirements. 45. 16, 67 Program 1.I: Add in outcome oriented permitting benchmarks as a streamlining measure, such as faster processing based on a project’s sustainable performance The City shall support innovative lower-cost and efficient construction techniques for housing. Program shall consider a streamlined building permit review process for housing projects utilizing innovative construction methods and technology, and project-based outcome oriented permitting benchmarks. OK 46. 16, 67 New Program 1.J: Create a new program to encourage sustainable construction to the extent feasible. This would include streamlining Program 1.J: Ensure that local regulations support sustainable construction to the extent technically feasible. 8.A.c Packet Pg. 73 Attachment: Planning Commission and Staff Recommended Changes to Draft Housing Element (4568 : Housing Element Review and Adoption) Addenda Sheet Housing Element 2021- 2029 June 2 – 3, 2021 Change No. Page Number Item Description Recommended Redline Staff Response projects that perform in a sustainable fashion and encourage trees. Program Background: TBD Timeframe: Ongoing Responsible Division: Building and Safety Division, Office of Sustainability and the Environment, City Planning Division Objective: Encourage and incentivize sustainable construction. 47. 17, 68 Program 2.A: remove AB1763 and replace with “State Density Bonus Law”; delete 1st paragraph and keep the 2nd paragraph but with 3 stories or 33 feet and unlimited density; feasibility study to determine the % of moderate income units in the project to qualify The City shall amend the Zoning Ordinance to establish an affordable housing overlay for moderate-income (up to 120% AMI) housing projects in targeted areas of the City such as Downtown area, Bergamot area, and the immediate area around the 17th St station. The moderate-income affordable housing overlay would allow a height increase of up to three additional stories or 33 feet, unlimited density, up to four incentives or concessions, and flexibility in unit size/unit mix in exchange for additional common area amenities. Staff recommends that the moderate- income affordable housing overlay apply only to projects with 100% moderate- income units 48. 18, 69 Program 2.C: Clarify that this includes the AHPP in Downtown; change 15% to 10% (typo); change title to “update the City’s AHPP and development UPDATE THE CITY’S AFFORDABLE HOUSING PRODUCTION PROGRAM AND DEVELOPMENT STANDARDS TO ENSURE OK; Comment to add language for acquisition/conversion of existing units already addressed with current language. 8.A.c Packet Pg. 74 Attachment: Planning Commission and Staff Recommended Changes to Draft Housing Element (4568 : Housing Element Review and Adoption) Addenda Sheet Housing Element 2021- 2029 June 2 – 3, 2021 Change No. Page Number Item Description Recommended Redline Staff Response standards to ensure that housing projects are feasible”; add carve out for acquisition/conversion of existing units THAT HOUSING PROJECTS ARE FEASIBLE In order to increase the number of affordable housing units at all levels, the AHPP, including in the Downtown, shall be revised to eliminate the current “menu” option of affordability requirements and instead establish a desired base affordability percentage of 10% for with the inclusionary units provided equally among all affordable income levels. Additionally, to support increased affordable housing production, the AHPP shall be revised to allow the off-site affordable housing option to be a more viable alternative to on- site affordable units. The revision would allow projects to locate off- site affordable housing to be located anywhere in the City that is not a disadvantaged area, determined through metrics such as overconcentration of lower-income households. The AHPP off-site option shall also be updated to allow market-rate projects to comply with 8.A.c Packet Pg. 75 Attachment: Planning Commission and Staff Recommended Changes to Draft Housing Element (4568 : Housing Element Review and Adoption) Addenda Sheet Housing Element 2021- 2029 June 2 – 3, 2021 Change No. Page Number Item Description Recommended Redline Staff Response the AHPP through the acquisition and rehabilitation of existing rental units and converting those to deed-restricted units. 49. 18, 70 Program 2.D: add Elisa language plus Hank’s specifics (height of ground floor, residential on ground floor, relationship of ground floor to sidewalk) + evaluation of other standards that might an issue; catch all that allows a X% of reduction and/or change to a standard. The City shall update the density bonus ordinance, Santa Monica Municipal Code Chapter 9.22, to ensure consistency with State Density Bonus Law and integration with the City’s land use system, including the Affordable Housing Production Program. The ordinance will clarify how to apply State density bonus law to the City’s development standards in the City’s commercial and mixed-use districts, which are not based on typical measures of density (units/acre) but instead based on Floor Area Ratio (FAR). Per State Density Bonus Law (Gov’t Code § 65915(b)(3)), “total” units” do “not include units added by a density bonus. The applicable percentage density bonus shall be applied to the project’s residential Floor Area (e.g. 50% x residential Floor Area of 1.75). The City shall establish a voluntary ministerial process for consideration of While the Planning Commission recommended language that the City administratively process density bonus applications in the interim, staff does not recommend this change be included in the program as it is procedural in nature and the City will take action in compliance with State density bonus law. Staff is also seeking direction from the City Council on interim procedures for implementing the State density bonus law. 8.A.c Packet Pg. 76 Attachment: Planning Commission and Staff Recommended Changes to Draft Housing Element (4568 : Housing Element Review and Adoption) Addenda Sheet Housing Element 2021- 2029 June 2 – 3, 2021 Change No. Page Number Item Description Recommended Redline Staff Response incentives & concessions and waivers of development standards and a by-right menu of incentives including, but not limited to, one additional story; and relief from: unit mix, open space, setbacks, ground floor heights and finished ground floor elevation relative to adjacent sidewalks, ground floor use requirements; and other requirements provided in Santa Monica Municipal Code 9.43.020. Prior to the ordinance update, the City shall administratively process density bonus applications, including requests for incentives & concessions and waivers of development standards, as required by Government Code Section 65915(a)(1). 50. 18, 71 Program 2.E: Replace “selling” with “the most appropriate disposition”. Expand on development outreach process. The City shall commit City-owned sites for the production of affordable housing. The City shall explore means of maximizing development potential on City-owned sites, including amending the LUCE, Bergamot Area Plan, Downtown Community Plan, and/or Zoning Ordinance to guide development through a public OK 8.A.c Packet Pg. 77 Attachment: Planning Commission and Staff Recommended Changes to Draft Housing Element (4568 : Housing Element Review and Adoption) Addenda Sheet Housing Element 2021- 2029 June 2 – 3, 2021 Change No. Page Number Item Description Recommended Redline Staff Response process, including engagement of community stakeholders, to maximize the production of affordable housing to support a healthy and sustainable environment. To facilitate affordable housing development, the City will continue to assess appropriate City- owned properties for the development of affordable housing, or in some cases may consider the most appropriate disposition of City properties to nonprofit developers for the development of affordable housing. 51. 19, 71 Program 2.F: Add philanthropic sources of funding and add arts housing as another type of affordable housing. The City shall leverage its commitment to use of City-owned land for affordable housing with advocacy for new sources of state, federal, and philanthropic funding that may be used for housing. Once appropriate funding sources are identified, the City will take the necessary steps to move forward. New strategies to provide financial and technical assistance shall be explored and committed to nonprofit housing providers to the greatest extent possible OK 8.A.c Packet Pg. 78 Attachment: Planning Commission and Staff Recommended Changes to Draft Housing Element (4568 : Housing Element Review and Adoption) Addenda Sheet Housing Element 2021- 2029 June 2 – 3, 2021 Change No. Page Number Item Description Recommended Redline Staff Response to support the development of affordable housing, including special needs housing and arts housing. The City will investigate creative financing tools like a regional housing trust fund and infrastructure financing plans to learn how they are used elsewhere and how the City might best leverage these tools to support the construction of affordable housing. 52. 19, 72 Program 2.G: delete “Baby Boomer generation’s” The City shall consider a preference for “aging in place” along with the need for more congregate housing and residential care facilities. OK 53. 21, 76 Program 3.F: Replace “MAINTAIN” with “PRIORITIZE” and “continue to respond” with “maximize its response”. PRIORITIZE CODE ENFORCEMENT RESPONSE TO HOUSING- RELATED VIOLATIONS The City shall maximize its response to residential building code violation complaints. OK 54. 21, 78 Program 4.A: Multi- housing should be permitted in non- residential zones where it is currently not permitted. 3rd sentence change “it” to “housing”. Add at the end “Attention shall be paid to environmental and fair housing considerations”. The City shall amend the Zoning Ordinance, LUCE, and associated specific and area plans to add multi-unit housing as a permitted use in non- residential zones where housing is currently prohibited. To promote the fair and equitable distribution of new housing opportunities across the City, land use regulations shall be OK 8.A.c Packet Pg. 79 Attachment: Planning Commission and Staff Recommended Changes to Draft Housing Element (4568 : Housing Element Review and Adoption) Addenda Sheet Housing Element 2021- 2029 June 2 – 3, 2021 Change No. Page Number Item Description Recommended Redline Staff Response amended to add multi- unit housing as a permitted use in areas where housing is currently prohibited. Land use regulations will be revised to allow housing in areas that currently do not allow housing such as the Office Campus, Industrial Conservation, and Creative Conservation Sector zones. Attention shall be paid to environmental and fair housing considerations. 55. 21, 78 Program 4.B: Add in feasibility language. Consider changing the City’s definition of high- rise outside of seismic and fault zones. The City shall amend the Zoning Ordinance, LUCE, Downtown Community Plan (DCP), and the Bergamot Area Plan (BAP) to establish feasible development standards that can support the City’s minimum inclusionary housing requirements and to create equitable opportunities for housing production throughout the City. To promote the fair and equitable distribution of new housing opportunities across the City, feasible development standards will be amended to incentivize housing production in areas that have historically not permitted or accommodated housing. Staff does not support increasing the height of high-rise: Answer from SMFD: The high- rise requirements are not seismic zone specific. The requirements provide that extra level of occupant safety and fire protection in the event an emergency occurs. What the fire department experienced during the Northridge earthquake was a city wide disaster that effected buildings regardless of the seismic zone. As you may recall, the epicenter for the earthquake was 15 miles north of SM. The findings from that day included multiple 8.A.c Packet Pg. 80 Attachment: Planning Commission and Staff Recommended Changes to Draft Housing Element (4568 : Housing Element Review and Adoption) Addenda Sheet Housing Element 2021- 2029 June 2 – 3, 2021 Change No. Page Number Item Description Recommended Redline Staff Response This would mean increased height and floor area ratios in areas such as the Neighborhood Commercial zones on Main Street, Montana Avenue and the Office Campus zone at the eastern end of Ocean Park Boulevard. building fires and building collapses that left our department strapped for resources. Many of these buildings were not responded to for hours. This ordinance adds a higher level of safety to these building to ensure greater reliance on the built in safety systems so can help the greatest amount of our citizens when the need arises for our services. 56. 22, 79 Program 4.C: Add in priority for affiliates of congregations whose families have been historically displaced. In order to Affirmatively Further Fair Housing, the City shall adopt standards that support the production of affordable housing on surface parking lots owned by religious congregations including allowing some market- rate units to support the affordable housing. To the extent permitted by law, increased priority shall be given to affiliates of those congregations whose direct descendants have been historically displaced. Staff does not support changing this until City Council discussion on conceptual program in July that would give priority to those displaced (or related to) from the Belmar and 10 frwy areas to the City’s Below Market Rate Housing waitlist 57. 22, 79 Program 4.D: Remove first paragraph and add to the end of the second paragraph: “The City shall explore options to address historically exclusionary single unit The City shall explore options to address historically exclusionary single unit dwelling zones through future land use decisions. 8.A.c Packet Pg. 81 Attachment: Planning Commission and Staff Recommended Changes to Draft Housing Element (4568 : Housing Element Review and Adoption) Addenda Sheet Housing Element 2021- 2029 June 2 – 3, 2021 Change No. Page Number Item Description Recommended Redline Staff Response dwelling zones through future land use decisions.” 58. 23, 81 Program 6.B: add in emergency rental assistance programs as an example The City shall continue to explore and identify new funding sources that support rental assistance programs, including emergency rental assistance to the extent feasible. OK 59. 23, 82 Program 6.D: Remove reference to staffing resources and change “provide” to “prioritize”. The City shall prioritize additional education and outreach to tenants and landlords to increase awareness of federal and local housing programs and their rights and legal obligations, including Section 8 housing voucher program and anti-discrimination regarding income source. OK STAFF RECOMMENDED CHANGES The following recommended changes to the DRAFT Housing Element Update result from public comment, correspondence with stakeholders and staff review. Change No. Page Number Item Description Recommended Redline 1. 18, 69 Program 2.c: Remove the 15% minimum AHPP. No specifics at this point. In order to increase the number of affordable housing units at all levels, the AHPP shall be revised to eliminate the current “menu” option of affordability requirements and instead establish a desired base affordability with the inclusionary units provided equally among all affordable income levels. 2. 89 Quantified Objectives Table: the ADU number should be The table in the Quantified Objectives table will be revised accordingly with the correct ADU 8.A.c Packet Pg. 82 Attachment: Planning Commission and Staff Recommended Changes to Draft Housing Element (4568 : Housing Element Review and Adoption) Addenda Sheet Housing Element 2021- 2029 June 2 – 3, 2021 Change No. Page Number Item Description Recommended Redline 600 not 700, which reduces the QO to 5,263 from 5,363. number of 600, which reduces the QO to 5,263 from 5,363. 3. 29 AFFH Maps: Displacement Assessment Map Add new map from the Urban Displacement Project showing displacement vulnerability 4. Appendix F, 28 Infrastructure Constraints: Update language in this section per Public Works staff review. The City’s sewer system consists of approximately 210 miles of sewer pipes, ranging in size from 6 to 36 inches in diameter. Sewer lines are composed of vitrified clay pipes, plastic pipes, or reinforced concrete pipes. The City distributes water to approximately 18,000 customer accounts through a 140-mile network of water lines ranging from 4 to 36 inches in diameter. New housing would be required to comply with the City’s Water Neutrality Ordinance, which requires an offset of new water demand (50% offset of new water demand for 100% affordable housing projects). The City’s primary sources of water supply include groundwater drawn from the Santa Monica Groundwater Basin (SMGB) and imported water supplies provided by the Metropolitan Water District of Southern California (MWD). The City prepared a 2020 Urban Water Management Plan (UWMP) which is slated for adoption in June 2021. The UWMP indicates that sufficient water supply exists to serve the forecasted planned housing in the Housing Element Update. Therefore, water supply is not considered a constraint to housing development. Approximately 75 miles of storm drain pipes are within the city. Of the approximately 1,900 catch basins collecting runoff into the storm drain system, about1,050 are owned and maintained by the County,750 by the City, and 100 by Caltrans. 5. Global “Family” should not be used in any zoning or development descriptions. Change to “unit” throughout Single-unit Multi-unit Etc. 6. 79 Program 4.D Background: Add in commercial versus Historic practices like redlining and restrictive covenants have perpetuated housing 8.A.c Packet Pg. 83 Attachment: Planning Commission and Staff Recommended Changes to Draft Housing Element (4568 : Housing Element Review and Adoption) Addenda Sheet Housing Element 2021- 2029 June 2 – 3, 2021 Change No. Page Number Item Description Recommended Redline residential parcel statistics. Commercial zoning comprises 12%; SUD zoning comprises xx% of the City and xx% of units. Include map. segregation and hindered fair access to housing. Predominantly homeowner neighborhoods have accommodated very little diversity in housing types reducing housing access for even middle-income households and a large percentage of Santa Monica workers. R1-zoned neighborhoods make up approximately 35% of the land area in the city but contain 13% of the housing units in the city. While commercial zoning comprises only 7% of the Cuty’s land area but contains 15% of the housing units in the City. 7. 66 Program 1.F: Move bolded “Program Background” above the program background section of Program 1.F Insert: Program Background 8. Appendix F, 10 Capacity for City-owned sites should be corrected to 1,884 units Based on their estimate and applying a density factor of 150 units/acre, City-owned sites have the potential for accommodating 1,884 units. 9. Appendix F, Figure F-6 Land area for Bergamot Arts Center site does not account for half the site being developed with existing R&D building Site size should be corrected to 205,000 sf and housing capacity should be corrected to 707 units, resulting in total capacity of 1,884 units for City-owned sites 10. Appendix F, 7 Expand explanation on site priority evaluation, specifically on high priority methodology. Sites were given an evaluation of whether they had low, medium, medium high, and high potential for housing redevelopment. In general, high potential sites include those that are adequately sized, are occupied with single tenants, and are located in proximity to other recent housing projects. Sites with known developer interest are also given a high potential. Based on the review of sites, there are 108 parcels approved/pending for residential development and 204 commercially, and mixed used zoned potential parcels in the City identified to have high potential for residential redevelopment. Together these 312 parcels comprise approximately 4.5 million sf of land area. 11. Appendix E, Page 49, Addition of a governmental constraint specific to Santa Monica regarding the 8. Local Ordinance, Propositions, and Rent Control Law a. Santa Monica City Charter Section 615 8.A.c Packet Pg. 84 Attachment: Planning Commission and Staff Recommended Changes to Draft Housing Element (4568 : Housing Element Review and Adoption) Addenda Sheet Housing Element 2021- 2029 June 2 – 3, 2021 Change No. Page Number Item Description Recommended Redline Section A(8) process of potential changes to development standards Santa Monica Charter Section 615 sets forth processes for adoption of ordinances by the City Council. On November 6, 2018, Santa Monica voters approved Measure SM, which amended Charter Section 615 to require five affirmative votes of the City Council in order to adopt or approve an amendment to either the LUCE or the DCP that would increase any maximum height limit or floor area ratio. All members of the City Council that are eligible to vote must be present to vote on an adoption or an amendment to increase height or floor area ratio pursuant to Measure SM. Measure SM includes express exemptions for 100% affordable housing projects and development on property owned by the Santa Monica-Malibu Unified School District or successor school district in the City. he provisions of Measure SM are set to expire on November 6, 2028. The City Council has not considered any adoptions or amendments to the LUCE or DCP that would be subject to the provisions of Measure SM since it was adopted in November 2018. Program 4.B proposes to revise the City’s development standards to incentivize housing projects over commercial development, which will likely result in proposed increases in height or floor area ratio subject to the requirements of Measure SM. However, because the amendments to Charter Section 615 enacted by Measure SM expressly exempt 100% affordable housing projects, the provisions of Measure SM will not serve as a constraint on the development of 100% affordable housing projects. 12. Appendix E, Page 21 Expanded explanation of State of California, Article 34 and moving the subsection from Section A(1) to Section A(8) for consistency c. State of California, Article 34 Article 34 of the State Constitution requires local jurisdictions to obtain voter approval for specified “low rent” housing projects that involve certain types of public agency participation. Generally, a project is subject to 8.A.c Packet Pg. 85 Attachment: Planning Commission and Staff Recommended Changes to Draft Housing Element (4568 : Housing Element Review and Adoption) Addenda Sheet Housing Element 2021- 2029 June 2 – 3, 2021 Change No. Page Number Item Description Recommended Redline Article 34 if more than 49% of its units will be rented to low-income persons. If a project is subject to Article 34, it will require an approval from the local electorate. This can constrain the production of affordable housing, since the process to seek ballot approval for affordable housing projects can be costly and time consuming, with no guarantee of success. Local jurisdictions typically place a measure or referendum on the local ballot that seeks “general authority” to develop a certain number of low-income units during a given period of time. If the electorate approves general parameters for certain types of affordable housing development, the local jurisdiction will be able to move more quickly in response to housing opportunities that fall within those parameters. In compliance with this article, the City of Santa Monica put a referendum (Proposition N) before the voters in 1978 in order to win approval to “develop, finance, or rehabilitate, but not own or operate within the city, housing for rental to low- and moderate-income persons, no less than 50% of which shall be reserved for persons age 60 or older, not to exceed in total throughout the city, 1% of the dwelling units in the city.” On November 3, 1998, Santa Monica’s voters approved Proposition I, which provides the City with an annual authorization to develop, construct, acquire, and finance low- income housing units, including senior housing. The City’s annual authorization is equal to 1/2 of 1% of the total dwelling units existing in the city at the end of the prior fiscal year. Any portion of an annual authorization that is not used may be carried over into the future for up to the three additional years. To date, the City has never exceeded any annual Proposition I low-rent housing production limits. The Suitable Sites Inventory includes a number of City-owned sites that are considered to have the highest potential to accommodate 8.A.c Packet Pg. 86 Attachment: Planning Commission and Staff Recommended Changes to Draft Housing Element (4568 : Housing Element Review and Adoption) Addenda Sheet Housing Element 2021- 2029 June 2 – 3, 2021 Change No. Page Number Item Description Recommended Redline the production of affordable housing. Program 2 E proposes to explore means of maximizing housing potential on these sites, subject to a public process. The City estimated the realistic capacity of these sites with consideration to existing constraints (such as lease terms, financial feasibility, etc.). Based on this estimate and applying a density factor of 150 units/acre, the City estimates that these City-owned sites have the potential for accommodating for 1,693 units. Due to the high cost of construction in Santa Monica, the City’s financial assistance to an affordable housing developer consisting solely of land conveyance is not likely sufficient to construct a 100% affordable housing project without additional sources of government funding (typically federal tax credits), which is typically awarded on a competitive basis. In theory, however, if sufficient funding were available to construct all 1,693 units on City- owned property, the Proposition I limitation on the annual cap of affordable dwelling units that could be produced with each conveyance would need to be considered. This would require coordination to ensure that the conveyances of City-owned property are staggered to fall below the Proposition I limits or, alternatively, the City Council could place a measure on the ballot to increase the cap. However, based upon the current “cushion” of Proposition I authority (due to affordable housing development below the annual Proposition I thresholds in the last three fiscal years), and assuming that government funding remains constrained at historical levels, it does not appear realistic to assume that Article 34/Proposition I would be a likely constraint on affordable housing development for City-owned sites during the 6th Cycle of the City’s proposed Housing Element. 13. Appendix E, Page 49, Reorganization and revised lettering with the addition of two subsections described 8. Local Measures, Propositions, Rent Control law, and Ordinances a. Santa Monica City Charter Section 615 8.A.c Packet Pg. 87 Attachment: Planning Commission and Staff Recommended Changes to Draft Housing Element (4568 : Housing Element Review and Adoption) Addenda Sheet Housing Element 2021- 2029 June 2 – 3, 2021 Change No. Page Number Item Description Recommended Redline Section A(8) above. No changes Rent Control Law subsection. b. Rent Control c. State of California, Article 34 d. Home Sharing (Short-Term Rental) Ordinance e. Residential Leasing Requirements Ordinance f. City Anti-Discrimination Ordinances g. Rent Control Bootleg Unit Ordinance 14. Appendix E, Pages 23-30, Section A(2) Revised lettering a. Accessory Dwelling Units/Junior Accessory Dwelling Units b. Emergency Shelters c. Group Residential d. Low Barrier Navigation Centers e. Manufactured Homes and Mobile Home Parks f. Single-Room Occupancy Housing g. Supportive/Transitional Housing 8.A.c Packet Pg. 88 Attachment: Planning Commission and Staff Recommended Changes to Draft Housing Element (4568 : Housing Element Review and Adoption) HR&A Advisors, Inc.Santa Monica AHPP 2021 Update | 12 AFFORDABLE HOUSING YIELD FROM CITY-OWNED SITES CITY OF SANTA MONICA AFFORDABLE HOUSING PRODUCTION PROGRAM (AHPP) 2020-2021 UPDATE JUNE 2021 8.A.d Packet Pg. 89 Attachment: HR&A City-Owned Sites Analysis (4568 : Housing Element Review and HR&A Advisors, Inc.Santa Monica AHPP 2021 Update | 13DRAFT RESULTS CITY-OWNED SITES |Development Potential for 100% Affordable Housing Key Assumptions: •100% Affordable Housing Multifamily Rental •Qualified for Low-Income Housing Tax Credit program (LIHTC)* •Affordability Level: LIHTC rents (higher than AHPP)affordable to households with 30-80% Area Median Income (AMI), average ~60% AMI •Typical Building Type : 3+ stories •Building Size: ~35-80 units •Density: ~150 dwelling units/acre •Unit Size: larger family units to maximize LIHTC scoring, but still smaller than AHPP requirements, i.e., 700 SF 2-BR (LIHTC) vs. 800 SF 2-BR (AHPP) Greenway Meadows The Arroyo Pacific Landing Example Projects: *May or may not use Santa Monica Affordable Housing Trust Fund AHPP: Santa Monica’s Affordable Housing Production Program 8.A.d Packet Pg. 90 Attachment: HR&A City-Owned Sites Analysis (4568 : Housing Element Review and HR&A Advisors, Inc.Santa Monica AHPP 2021 Update | 14DRAFT RESULTS CITY-OWNED SITES | Development Potential for 100% Affordable Housing Four City-owned sites of 11.28 total acres could theoretically accommodate about 1,693 new affordable units. But even assuming that the City contributes all sites for affordable housing, developers would still need to secure significant gap funding to deliver all units. 100% Affordable Housing Production in SaMo Key constraints: •Lack of affordable land to support projects at scale •Limited funding sources for land acquisition, construction and ongoing operation (e.g., vouchers) Key funding sources: •Low-Income Housing Tax Credit program (LIHTC) •City Affordable Housing Trust Fund (AHPP in-lieu fees; commercial linkage fees sales tax share, other misc. sources) •Developer public benefit payments negotiated through Development Agreements Land (Ac) DU/Ac.Total Units Main St Parking Lots 4.03 150 605 Units 4th and Arizona 1.02 150 154 Units 1324 5th St Santa Monica 1.22 150 184 Units 3500 Olympic Boulevard 5.00 150 750 Units TOTAL 11.28 150 1,693 Units Potential Development Capacity on City-owned sites* * Selected sites over 1-acre with development potential in the next 8 years 8.A.d Packet Pg. 91 Attachment: HR&A City-Owned Sites Analysis (4568 : Housing Element Review and HR&A Advisors, Inc.Santa Monica AHPP 2021 Update | 15DRAFT RESULTS CITY-OWNED SITES | Development Potential for 100% Affordable Housing Even assuming a substantial multiple of the historic capture rate of top funding sources (e.g., LIHTC), affordable housing development capacity on City-owned sites is likely to be constrained at under 1,700 total units and would require about $250M of City and other gap funding over 8 years. Illustrative Development Capacity and Gap Funding Requirement * Based on historic City’s share of total CA units funded by 9% tax credit ** Based on historic non-TCAC funding gap excluding land cost at $152,000 per unit *** Based on the City’s current In-Lieu Fee requirements at ~$30,300 per unit Historic LIHTC Santa Monica Capture 5x Historic LIHTC Santa Monica Capture LIHTC Capture Rate*1.26%6.31% Estimated LIHTC Funding Capture $14.7 M $73.3 M Historic Average LIHTC Funding per Unit $353,288 $353,288 Total Units Funded through LIHTC (Year 1)41 Units 207 Units Total Remaining non-LIHTC Funding Gap (Year 1)**$6.3 M $31.5 M Total Units Funded through LIHTC (Over 8 Years)332 Units 1,660 Units Total Remaining non-LIHTC Funding Gap (Over 8 Years) **$50 M $252 M Assuming the Funding Gap is subsidized solely by AHPP In-lieu Fees*** Number of Market Rate Units Required (Year 1)208 Units 1,041 Units Number of Market Rate Units Required (Over 8 Years)1,665 Units 8,326 Units 8.A.d Packet Pg. 92 Attachment: HR&A City-Owned Sites Analysis (4568 : Housing Element Review and HR&A Advisors, Inc.Santa Monica AHPP 2020 Update | 1 FAR FEASIBILITY MODELING RESULTS CITY OF SANTA MONICA AFFORDABLE HOUSING PRODUCTION PROGRAM 2020-2021 UPDATE JUNE 9, 2021DRAFT RESULTS 8.A.e Packet Pg. 93 Attachment: HR&A FAR-AHPP Analysis (4568 : Housing Element Review and Adoption) HR&A Advisors, Inc.Santa Monica AHPP 2020 Update | 2CONFIDENTIAL DRAFT –NOT FOR DISTRIBUTION FINANCIAL FEASIBILITY FINDINGS Feasibility Modeling Findings: Note:All FAR,number of floors,and number of units are excluding any applicable Density Bonus. •The minimum supportable building heights and FARs reported here are based on HR&A’s financial feasibility model results when they exceeded minimum thresholds for developer profit and return on total development cost,and therefore are deemed “likely to proceed”to project completion. •The FAR differences between 10%VLI and 15%mixed-income scenarios range between 0 and 0.20,except for IC- Industrial Conservation. •The FARs generally require a maximum 4-story building based on the assumed double lot and large site assumptions,with the exception of NC (Main Street)and IC –Industrial Conservation at 5-stories. •Most of the proposed FARs are higher than the current Tier 2 FAR ,with the notable exception of Downtown. •Higher land remediation costs and lower rents in IC-Industrial Conservation may require a relatively higher FAR than other areas to support higher inclusionary requirements. •For most zones,the 12.5%off-site option1 would be feasible with roughly 0.25 less FAR than the 15%VLI option,because choosing to pay an in-lieu fee is less expensive than constructing an affordable unit,and also allows developers to build more market rate units.For certain zones (MUBL,MUB,GC/SMB,HMU,IC),both options have the same FAR requirements. •The minimum supportable FAR for 100%market rate and 5%ELI inclusionary exceeds the existing zoning standards by at least 1.0 FAR in GC (Santa Monica Boulevard)and IC-Industrial Conservation. 1 The analysis assumes the City’s current in-lieu fee of $30,300 per market rate unit.DRAFT RESULTS 8.A.e Packet Pg. 94 Attachment: HR&A FAR-AHPP Analysis (4568 : Housing Element Review and Adoption) HR&A Advisors, Inc.Santa Monica AHPP 2020 Update | 3CONFIDENTIAL DRAFT –NOT FOR DISTRIBUTION 0.0 1.0 2.0 3.0 MUBL MUB GC (SMB)GC (Pico)GC (Lincoln)NC NC (Main)NC (Ocean Park)NC (Montana)HMU FEASIBILITY FINDINGS –Boulevards | Minimum supportable height and FAR for market rate apartment development with 100% market rate units.Floor Area Ratio2.00 FAR 2.50 FAR 2.50 FAR 2.25 FAR 2.00 FAR 2.25 FAR 2.50 FAR 2.25 FAR 1.75 FAR 2.50 FAR 3 Floors 4 Floors 4 Floors 4 Floors 3 Floors 4 Floors 4 Floors 4 Floors 3 Floors 4 Floors 25 Units 35 Units 35 Units 32 Units 25 Units 32 Units 35 Units 32 Units 21 Units 35 Units Note: All FAR, number of floors, and number of units are excluding any applicable Density Bonus.DRAFT RESULTS 8.A.e Packet Pg. 95 Attachment: HR&A FAR-AHPP Analysis (4568 : Housing Element Review and Adoption) HR&A Advisors, Inc.Santa Monica AHPP 2020 Update | 4CONFIDENTIAL DRAFT –NOT FOR DISTRIBUTION 0.0 1.0 2.0 3.0 MUBL MUB GC (SMB)GC (Pico)GC (Lincoln)NC NC (Main)NC (Ocean Park)NC (Montana)HMU FEASIBILITY FINDINGS –Boulevards | Minimum supportable height and FAR for market rate apartment development with 5% ELI.Floor Area Ratio2.25 FAR 2.75 FAR 2.75 FAR 2.50 FAR 2.00 FAR 2.50 FAR 2.75 FAR 2.50 FAR 2.00 FAR 2.75 FAR 3 Floors 4 Floors 4 Floors 4 Floors 3 Floors 4 Floors 4 Floors 4 Floors 3 Floors 4 Floors 28 Units 39 Units 39 Units 35 Units 25 Units 35 Units 39 Units 35 Units 24 Units 39 Units Note: All FAR, number of floors, and number of units are excluding any applicable Density Bonus.DRAFT RESULTS 8.A.e Packet Pg. 96 Attachment: HR&A FAR-AHPP Analysis (4568 : Housing Element Review and Adoption) HR&A Advisors, Inc.Santa Monica AHPP 2020 Update | 5CONFIDENTIAL DRAFT –NOT FOR DISTRIBUTION 0.0 1.0 2.0 3.0 MUBL MUB GC (SMB)GC (Pico)GC (Lincoln)NC NC (Main)NC (Ocean Park)NC (Montana)HMU FEASIBILITY FINDINGS –Boulevards | Minimum supportable height and FAR for market rate apartment development with 10% VLI.Floor Area Ratio2.25 FAR 2.75 FAR 2.75 FAR 2.75 FAR 2.25 FAR 2.75 FAR 2.75 FAR 2.75 FAR 2.00 FAR 2.75 FAR 4 Floors 4 Floors 4 Floors 4 Floors 4 Floors 4 Floors 4 Floors 4 Floors 3 Floors 4 Floors 32 Units 39 Units 39 Units 39 Units 32 Units 39 Units 42 Units 39 Units 24 Units 39 Units Note: All FAR, number of floors, and number of units are excluding any applicable Density Bonus.DRAFT RESULTS 8.A.e Packet Pg. 97 Attachment: HR&A FAR-AHPP Analysis (4568 : Housing Element Review and Adoption) HR&A Advisors, Inc.Santa Monica AHPP 2020 Update | 6CONFIDENTIAL DRAFT –NOT FOR DISTRIBUTION 0.0 1.0 2.0 3.0 MUBL MUB GC (SMB)GC (Pico)GC (Lincoln)NC NC (Main)NC (Ocean Park)NC (Montana)HMU FEASIBILITY FINDINGS –Boulevards| Minimum supportable height and FAR for market rate apartment development with 15% affordable, evenly split between ELI, VLI, LI, and MI. 2.25 FAR 2.75 FAR 2.75 FAR 2.75 FAR 2.25 FAR 2.75 FAR 3.00 FAR 2.75 FAR 2.25 FAR 2.75 FAR 4 Floors 4 Floors 4 Floors 4 Floors 4 Floors 4 Floors 5 Floors 4 Floors 3 Floors 4 Floors 32 Units 42 Units 42 Units 43 Units 32 Units 43 Units 46 Units 43 Units 28 Units 42 UnitsFloor Area RatioNote: All FAR, number of floors, and number of units are excluding any applicable Density Bonus.DRAFT RESULTS 8.A.e Packet Pg. 98 Attachment: HR&A FAR-AHPP Analysis (4568 : Housing Element Review and Adoption) HR&A Advisors, Inc.Santa Monica AHPP 2020 Update | 7CONFIDENTIAL DRAFT –NOT FOR DISTRIBUTION 0.0 1.0 2.0 3.0 MUBL MUB GC (SMB)GC (Pico)GC (Lincoln)NC NC (Main)NC (Ocean Park)NC (Montana)HMU FEASIBILITY FINDINGS –Boulevards | Minimum supportable height and FAR for market rate apartment development with 12.5% off-site affordable. 2.25 FAR 2.75 FAR 2.75 FAR 2.50 FAR 2.25 FAR 2.50 FAR 2.75 FAR 2.50 FAR 2.25 FAR 2.75 FAR 3 Floors 4 Floors 4 Floors 4 Floors 3 Floors 4 Floors 4 Floors 4 Floors 3 Floors 4 Floors 28 Units 39 Units 39 Units 35 Units 28 Units 35 Units 39 Units 35 Units 28 Units 39 UnitsFloor Area RatioNote: All FAR, number of floors, and number of units are excluding any applicable Density Bonus.DRAFT RESULTS 8.A.e Packet Pg. 99 Attachment: HR&A FAR-AHPP Analysis (4568 : Housing Element Review and Adoption) HR&A Advisors, Inc.Santa Monica AHPP 2020 Update | 8CONFIDENTIAL DRAFT –NOT FOR DISTRIBUTION 0.0 1.0 2.0 3.0 LT (East)LT (West)NV BC (Promenade)BC (2nd/4th)TA OT WT FEASIBILITY FINDINGS –Downtown | Minimum supportable height and FAR for market rate apartment development with 100% market rate units. 2.25 FAR 2.25 FAR 2.25 FAR 2.25 FAR 2.25 FAR 2.25 FAR 2.25 FAR 2.25 FAR 4 Floors 4 Floors 4 Floors 4 Floors 4 Floors 4 Floors 4 Floors 4 Floors 18 Units 18 Units 18 Units 18 Units 18 Units 18 Units 18 Units 18 UnitsFloor Area RatioNote: All FAR, number of floors, and number of units are excluding any applicable Density Bonus.DRAFT RESULTS 8.A.e Packet Pg. 100 Attachment: HR&A FAR-AHPP Analysis (4568 : Housing Element Review and Adoption) HR&A Advisors, Inc.Santa Monica AHPP 2020 Update | 9CONFIDENTIAL DRAFT –NOT FOR DISTRIBUTION 0.0 1.0 2.0 3.0 LT (East)LT (West)NV BC (Promenade)BC (2nd/4th)TA OT WT FEASIBILITY FINDINGS –Downtown | Minimum supportable height and FAR for market rate apartment development with 5% ELI. 2.50 FAR 2.50 FAR 2.50 FAR 2.50 FAR 2.50 FAR 2.50 FAR 2.50 FAR 2.50 FAR 4 Floors 4 Floors 4 Floors 4 Floors 4 Floors 4 Floors 4 Floors 4 Floors 21 Units 21 Units 21 Units 21 Units 21 Units 21 Units 21 Units 21 UnitsFloor Area RatioNote: All FAR, number of floors, and number of units are excluding any applicable Density Bonus.DRAFT RESULTS 8.A.e Packet Pg. 101 Attachment: HR&A FAR-AHPP Analysis (4568 : Housing Element Review and Adoption) HR&A Advisors, Inc.Santa Monica AHPP 2020 Update | 10CONFIDENTIAL DRAFT –NOT FOR DISTRIBUTION 0.0 1.0 2.0 3.0 LT (East)LT (West)NV BC (Promenade)BC (2nd/4th)TA OT WT FEASIBILITY FINDINGS –Downtown | Minimum supportable height and FAR for market rate apartment development with 10% VLI. 2.75 FAR 2.75 FAR 2.75 FAR 2.75 FAR 2.75 FAR 2.75 FAR 2.75 FAR 2.75 FAR 4 Floors 4 Floors 4 Floors 4 Floors 4 Floors 4 Floors 4 Floors 4 Floors 39 Units 39 Units 39 Units 39 Units 39 Units 39 Units 39 Units 39 UnitsFloor Area RatioNote: All FAR, number of floors, and number of units are excluding any applicable Density Bonus.DRAFT RESULTS 8.A.e Packet Pg. 102 Attachment: HR&A FAR-AHPP Analysis (4568 : Housing Element Review and Adoption) HR&A Advisors, Inc.Santa Monica AHPP 2020 Update | 11CONFIDENTIAL DRAFT –NOT FOR DISTRIBUTION 0.0 1.0 2.0 3.0 LT (East)LT (West)NV BC (Promenade)BC (2nd/4th)TA OT WT FEASIBILITY FINDINGS –Downtown| Minimum supportable height and FAR for market rate apartment development with 15% affordable, evenly split between ELI, VLI, LI, and MI. 2.75 FAR 2.75 FAR 2.75 FAR 2.75 FAR 2.75 FAR 2.75 FAR 2.75 FAR 2.75 FAR 4 Floors 4 Floors 4 Floors 4 Floors 4 Floors 4 Floors 4 Floors 4 Floors 39 Units 39 Units 39 Units 39 Units 39 Units 39 Units 39 Units 39 UnitsFloor Area RatioNote: All FAR, number of floors, and number of units are excluding any applicable Density Bonus.DRAFT RESULTS 8.A.e Packet Pg. 103 Attachment: HR&A FAR-AHPP Analysis (4568 : Housing Element Review and Adoption) HR&A Advisors, Inc.Santa Monica AHPP 2020 Update | 12CONFIDENTIAL DRAFT –NOT FOR DISTRIBUTION 0.0 1.0 2.0 3.0 LT (East)LT (West)NV BC (Promenade)BC (2nd/4th)TA OT WT FEASIBILITY FINDINGS –Downtown| Minimum supportable height and FAR for market rate apartment development with 12.5% off-site affordable. 2.50 FAR 2.50 FAR 2.50 FAR 2.50 FAR 2.50 FAR 2.50 FAR 2.50 FAR 2.50 FAR 4 Floors 4 Floors 4 Floors 4 Floors 4 Floors 4 Floors 4 Floors 4 Floors 39 Units 39 Units 39 Units 39 Units 39 Units 39 Units 39 Units 39 UnitsFloor Area RatioNote: All FAR, number of floors, and number of units are excluding any applicable Density Bonus.DRAFT RESULTS 8.A.e Packet Pg. 104 Attachment: HR&A FAR-AHPP Analysis (4568 : Housing Element Review and Adoption) HR&A Advisors, Inc.Santa Monica AHPP 2020 Update | 13CONFIDENTIAL DRAFT –NOT FOR DISTRIBUTION 0.0 1.0 2.0 3.0 BTV CAC MUC OC IC FEASIBILITY FINDINGS –Bergamot, OC and IC | Minimum supportable height and FAR for market rate apartment development with 100% market rate units. 2.00 FAR 2.00 FAR 2.00 FAR 2.25 FAR 2.50 FAR 3 Floors 3 Floors 3 Floors 4 Floors 4 Floors 60 Units 60 Units 60 Units 32 Units 35 UnitsFloor Area RatioNote: All FAR, number of floors, and number of units are excluding any applicable Density Bonus.DRAFT RESULTS 8.A.e Packet Pg. 105 Attachment: HR&A FAR-AHPP Analysis (4568 : Housing Element Review and Adoption) HR&A Advisors, Inc.Santa Monica AHPP 2020 Update | 14CONFIDENTIAL DRAFT –NOT FOR DISTRIBUTION 0.0 1.0 2.0 3.0 BTV CAC MUC OC IC FEASIBILITY FINDINGS –Bergamot, OC and IC | Minimum supportable height and FAR for market rate apartment development with 5% ELI. 2.25 FAR 2.25 FAR 2.25 FAR 2.50 FAR 2.75 FAR 3 Floors 3 Floors 3 Floors 4 Floors 4 Floors 67 Units 67 Units 67 Units 35 Units 39 UnitsFloor Area RatioNote: All FAR, number of floors, and number of units are excluding any applicable Density Bonus.DRAFT RESULTS 8.A.e Packet Pg. 106 Attachment: HR&A FAR-AHPP Analysis (4568 : Housing Element Review and Adoption) HR&A Advisors, Inc.Santa Monica AHPP 2020 Update | 15CONFIDENTIAL DRAFT –NOT FOR DISTRIBUTION 0.0 1.0 2.0 3.0 BTV CAC MUC OC IC FEASIBILITY FINDINGS –Bergamot, OC and IC | Minimum supportable height and FAR for market rate apartment development with 10% VLI. 2.50 FAR 2.50 FAR 2.50 FAR 2.75 FAR 2.75 FAR 4 Floors 4 Floors 4 Floors 4 Floors 4 Floors 74 Units 74 Units 74 Units 39 Units 42 UnitsFloor Area RatioNote: All FAR, number of floors, and number of units are excluding any applicable Density Bonus.DRAFT RESULTS 8.A.e Packet Pg. 107 Attachment: HR&A FAR-AHPP Analysis (4568 : Housing Element Review and Adoption) HR&A Advisors, Inc.Santa Monica AHPP 2020 Update | 16CONFIDENTIAL DRAFT –NOT FOR DISTRIBUTION 0.0 1.0 2.0 3.0 4.0 BTV CAC MUC OC IC FEASIBILITY FINDINGS –Bergamot, OC and IC | Minimum supportable height and FAR for market rate apartment development with 15% Affordable, evenly split between ELI, VLI, LI, and MI. 2.50 FAR 2.50 FAR 2.50 FAR 2.75 FAR 3.25 FAR 4 Floors 4 Floors 4 Floors 4 Floors 5 Floors 81 Units 81 Units 81 Units 43 Units 49 UnitsFloor Area RatioNote: All FAR, number of floors, and number of units are excluding any applicable Density Bonus.DRAFT RESULTS 8.A.e Packet Pg. 108 Attachment: HR&A FAR-AHPP Analysis (4568 : Housing Element Review and Adoption) HR&A Advisors, Inc.Santa Monica AHPP 2020 Update | 17CONFIDENTIAL DRAFT –NOT FOR DISTRIBUTION 0.0 1.0 2.0 3.0 BTV CAC MUC OC IC FEASIBILITY FINDINGS –Bergamot, OC and IC | Minimum supportable height and FAR for market rate apartment development with 12.5% off-site affordable. 2.25 FAR 2.25 FAR 2.25 FAR 2.50 FAR 2.75 FAR 4 Floors 4 Floors 4 Floors 4 Floors 4 Floors 71 Units 71 Units 71 Units 35 Units 42 UnitsFloor Area RatioNote: All FAR, number of floors, and number of units are excluding any applicable Density Bonus.DRAFT RESULTS 8.A.e Packet Pg. 109 Attachment: HR&A FAR-AHPP Analysis (4568 : Housing Element Review and Adoption) Glossary of Terms and Acronyms 1. ADU: Accessory Dwelling Unit An attached or detached residential dwelling unit that provides complete independent living facilities for one or more persons and that is located on a parcel with a proposed or existing primary single-unit or multi-unit dwelling. JADU: Junior Accessory Dwelling Unit A dwelling unit that is no more than 500 square feet in size and is contained entirely within an existing or proposed single-unit dwelling. 2. AFFH: Affirmatively Furthering Fair Housing Taking meaningful actions that, taken together, address significant disparities in housing needs and in access to opportunity, replacing segregated living patterns with truly integrated and balanced living patterns, transforming racially and ethnically concentrated areas of poverty into areas of opportunity, and fostering and maintaining compliance with civil rights and fair housing laws. 3. AHO: Affordable Housing Overlay Program 2.A that would amend the Zoning Ordinance to establish a 100% affordable housing overlay for moderate-income (up to 120% AMI) housing projects in targeted areas of the City such as the Downtown, Bergamot area, and the immediate area around the 17th Street station. 4. AHPP: Affordable Housing Production Program (SMMC 9.64) Requires developers of market rate multi-family developments to contribute to affordable housing production and thereby help the City meet its affordable housing need. 5. FAR: Floor Area Ratio The ratio of the total floor area of all buildings on a parcel to the total area of the parcel. 6. HCD: California Department of Housing and Community Development 8.A.f Packet Pg. 110 Attachment: Glossary of Terms & Acronyms (4568 : Housing Element Review and Adoption) 7. HUD: U.S. Department of Housing and Urban Development 8. LUCE: Land Use and Circulation Element Key components of the City’s General Plan establishing the City’s vision, goals, and long-term framework for the City’s future physical development. 9. QO: Quantified Objective Estimated number of units likely to be constructed, rehabilitated, or conserved/preserved by income level during the upcoming 6th housing cycle. After the City identifies housing needs, surveys land and financial resources, analyzes constraints, and develops appropriate programmatic and policy responses that reflect the community’s unique needs and circumstances, it then sets quantified objectives, a target goal for the City to achieve based on needs, resources, and constraints. 10. RHNA: Reginal Housing Needs Assessment RHNA is mandated by State Housing Law as part of the periodic process of updating local housing elements of the General Plan. RHNA quantifies the need for housing within each jurisdiction during the upcoming 6th housing cycle between October 2021 through October 2029. 11. SDB: State Density Bonus State law that allows a density increase of residential units based on a specified percentage of affordable units provided in a proposed project. 12. SSI: Suitable Sites Inventory An inventory of land suitable and available for residential development to meet the locality’s regional housing need by income level. Affordability Levels 13. ELI: Extremely-Low Income (30% of Average Median Income or AMI) A household whose gross income does not exceed 30% of the area median income. 14. VLI: Very-Low Income (50% of Average Median Income or AMI) A household whose gross income does not exceed 50% of the area median income. 8.A.f Packet Pg. 111 Attachment: Glossary of Terms & Acronyms (4568 : Housing Element Review and Adoption) 15. LI: Low-Income (80% of Average Median Income or AMI) A household whose gross income does not exceed 80% of the area median income. 16. Moderate-Income ( Up to 120% Average Median Income or AMI) A household whose gross income exceeds the maximum income for an 80% income household and whose gross income does not exceed 120% of the area median income. Zoning Districts, Area Plans, and Neighborhoods 17. R 1 - Single-Unit Residential District Areas for single-unit housing on individual parcels at densities of one unit plus one accessory dwelling unit (ADU) and one junior accessory dwelling unit (JADU) per parcel. 18. R2 - Low Density Residential District Areas for a variety of low-density housing types. These include single-unit housing, duplexes, triplexes, low-scale multi-unit housing, ADUs, etc. 19. MUBL - Mixed-Use Boulevard Low District 20. MUB - Mixed-Use Boulevard District 21. GC: - General Commercial 22. NC - Neighborhood Commercial District (Main Street, Ocean Park Blvd, Pico Blvd, Montana Ave) 23. IC – Industrial Conservation 24. OC – Office Campus 25. HMU – Healthcare Mixed Use 26. OF – Oceanfront District 8.A.f Packet Pg. 112 Attachment: Glossary of Terms & Acronyms (4568 : Housing Element Review and Adoption) 27. DCP - Downtown Community Plan  LT - Lincoln Transition  NV - Neighborhood Village  BC – Bayside Conservation (Promenade)  BC – Bayside Conservation (2nd & 4th Streets)  TA – Transit Adjacent  OT - Ocean Transition  WT - Wilshire Transition 28. BAP: Bergamot Area Plan  BTV - Bergamot Transit Village  MUC – Mixed-Use Creative  CAC – Conservation: Arts Center  CSC – Conservation: Creative Sector 29. NOMA: North of Montana Neighborhood 30. Wilmont: Wilshire-Montana Neighborhood 8.A.f Packet Pg. 113 Attachment: Glossary of Terms & Acronyms (4568 : Housing Element Review and Adoption) 1 Vernice Hankins From:DiaryofTieira Ryder <tie.ryder@gmail.com> Sent:Monday, June 14, 2021 1:01 PM To:councilmtgitems Cc:Housing@scag.ca.gov; Housing Update; HousingElements@hcd.ca.gov Subject:Draft housing element- council meeting 06/15; general comment EXTERNAL      Hello,     We love duplexes and townhomes, please put them in all single family zoned neighborhoods and require a set number  be affordable. All residents deserve housing they can afford including the working class, seniors, students, veterans,  those with low or no income, and many others in need!     There are over 60,000+ unhoused residents in LA county and local NIMBYS who are upholding illegal segregation as it  relates to race and class are partly responsible for the housing crisis!     Lastly, please close the Santa Monica airport in this housing cycle and partner with LA city to create a walkable  community that is majority affordable housing at the airport and Penmar golf course. As a reminder affordable housing  is both rent and homeownership.     Thank You for all your hard work regarding the matter, I know you all will do the right thing by ending single family  zoning and challenging the FAA to close the airport in this housing cycle.     https://htwws.org/santamonicaairport/    Best,  Tieira  www.HTWWS.org   “Contempt for poverty is violence” Denying residents housing they can afford is violence!     Item 8.A 06/15/21 1 of 61 Item 8.A 06/15/21 8.A.j Packet Pg. 114 Attachment: Written Comments [Revision 1] (4568 : Housing Element Review and Adoption) 2 Item 8.A 06/15/21 2 of 61 Item 8.A 06/15/21 8.A.j Packet Pg. 115 Attachment: Written Comments [Revision 1] (4568 : Housing Element Review and Adoption) 3   Item 8.A 06/15/21 3 of 61 Item 8.A 06/15/21 8.A.j Packet Pg. 116 Attachment: Written Comments [Revision 1] (4568 : Housing Element Review and Adoption) 4 Item 8.A 06/15/21 4 of 61 Item 8.A 06/15/21 8.A.j Packet Pg. 117 Attachment: Written Comments [Revision 1] (4568 : Housing Element Review and Adoption) 5 Item 8.A 06/15/21 5 of 61 Item 8.A 06/15/21 8.A.j Packet Pg. 118 Attachment: Written Comments [Revision 1] (4568 : Housing Element Review and Adoption) 6 Item 8.A 06/15/21 6 of 61 Item 8.A 06/15/21 8.A.j Packet Pg. 119 Attachment: Written Comments [Revision 1] (4568 : Housing Element Review and Adoption) 1 Vernice Hankins From:Anthony Dedousis <anthony@abundanthousingla.org> Sent:Thursday, June 10, 2021 10:11 AM To:Council Mailbox; Housing Update Cc:Sonja Trauss; Jon Wizard; Jes McBride; councilmtgitems Subject:Comment Letter - Santa Monica Housing Element EXTERNAL    Dear Councilmembers,    I'm reaching out to share a letter from Abundant Housing LA and YIMBY Law regarding Santa Monica's draft housing  element.  We have major concerns about the City's intended approach to updating the housing element.  We believe  that the City's intended approach does not satisfy the intent of state law, which is to expand housing availability at all  income levels.    The attached letter contains a detailed explanation of where we view this effort as having fallen short of HCD's  standards and state law.  I've also included a link to AHLA's letter to the City Council from March, expressing concerns  about many of the same issues.    We respectfully request the opportunity to discuss the issues raised in this letter.  Thank you for your consideration.    Regards,    Anthony Dedousis      ‐‐   Anthony Dedousis  Director, Policy and Research  Abundant Housing LA  515 S Flower Street, 18th Floor  Los Angeles, CA 90071  516‐660‐7402  Item 8.A 06/15/21 8 of 61 Item 8.A 06/15/21 8.A.j Packet Pg. 120 Attachment: Written Comments [Revision 1] (4568 : Housing Element Review and Adoption) Item 8.A 06/15/21 9 of 61 Item 8.A 06/15/21 8.A.j Packet Pg. 121 Attachment: Written Comments [Revision 1] (4568 : Housing Element Review and Adoption) Item 8.A 06/15/21 10 of 61 Item 8.A 06/15/21 8.A.j Packet Pg. 122 Attachment: Written Comments [Revision 1] (4568 : Housing Element Review and Adoption) Item 8.A 06/15/21 11 of 61 Item 8.A 06/15/21 8.A.j Packet Pg. 123 Attachment: Written Comments [Revision 1] (4568 : Housing Element Review and Adoption) Item 8.A 06/15/21 12 of 61 Item 8.A 06/15/21 8.A.j Packet Pg. 124 Attachment: Written Comments [Revision 1] (4568 : Housing Element Review and Adoption) Item 8.A 06/15/21 13 of 61 Item 8.A 06/15/21 8.A.j Packet Pg. 125 Attachment: Written Comments [Revision 1] (4568 : Housing Element Review and Adoption) Item 8.A 06/15/21 14 of 61 Item 8.A 06/15/21 8.A.j Packet Pg. 126 Attachment: Written Comments [Revision 1] (4568 : Housing Element Review and Adoption) Item 8.A 06/15/21 15 of 61 Item 8.A 06/15/21 8.A.j Packet Pg. 127 Attachment: Written Comments [Revision 1] (4568 : Housing Element Review and Adoption) Item 8.A 06/15/21 16 of 61 Item 8.A 06/15/21 8.A.j Packet Pg. 128 Attachment: Written Comments [Revision 1] (4568 : Housing Element Review and Adoption) Item 8.A 06/15/21 17 of 61 Item 8.A 06/15/21 8.A.j Packet Pg. 129 Attachment: Written Comments [Revision 1] (4568 : Housing Element Review and Adoption) Item 8.A 06/15/21 18 of 61 Item 8.A 06/15/21 8.A.j Packet Pg. 130 Attachment: Written Comments [Revision 1] (4568 : Housing Element Review and Adoption) Item 8.A 06/15/21 19 of 61 Item 8.A 06/15/21 8.A.j Packet Pg. 131 Attachment: Written Comments [Revision 1] (4568 : Housing Element Review and Adoption) Item 8.A 06/15/21 20 of 61 Item 8.A 06/15/21 8.A.j Packet Pg. 132 Attachment: Written Comments [Revision 1] (4568 : Housing Element Review and Adoption) Item 8.A 06/15/21 21 of 61 Item 8.A 06/15/21 8.A.j Packet Pg. 133 Attachment: Written Comments [Revision 1] (4568 : Housing Element Review and Adoption) Item 8.A 06/15/21 22 of 61 Item 8.A 06/15/21 8.A.j Packet Pg. 134 Attachment: Written Comments [Revision 1] (4568 : Housing Element Review and Adoption) Item 8.A 06/15/21 23 of 61 Item 8.A 06/15/21 8.A.j Packet Pg. 135 Attachment: Written Comments [Revision 1] (4568 : Housing Element Review and Adoption) Item 8.A 06/15/21 24 of 61 Item 8.A 06/15/21 8.A.j Packet Pg. 136 Attachment: Written Comments [Revision 1] (4568 : Housing Element Review and Adoption) 1 Vernice Hankins From:T GROSSMAN <tina.grossman@gmail.com> Sent:Monday, June 14, 2021 11:50 PM To:councilmtgitems; Gleam Davis; Kristin McCowan; Phil Brock; Sue Himmelrich; Oscar de la Torre; Christine Parra; Council Mailbox Subject:2021/06/15 meeting item 8a - objecting to overlay zones in SFR areas and objecting to housing projects of up to four stories in R1 zones EXTERNAL    Hello coucilmembers,  Please note my objection to the proposed overlay zones and housing projects of up to four stories in the overlay zones that cover all R1 areas (except in Ocean Park and the Pico Neighborhood). Truly unacceptable for innumerable reasons.   Thank you,  Tina Grossman  42 year resident  90405  Item 8.A 06/15/21 25 of 61 Item 8.A 06/15/21 8.A.j Packet Pg. 137 Attachment: Written Comments [Revision 1] (4568 : Housing Element Review and Adoption) 2 Vernice Hankins From:Mike <michaelclarke9861@gmail.com> Sent:Monday, June 14, 2021 10:57 PM To:councilmtgitems Subject:Agenda Item 8A EXTERNAL    Santa Monica Housing Policy!         Item 8.A 06/15/21 26 of 61 Item 8.A 06/15/21 8.A.j Packet Pg. 138 Attachment: Written Comments [Revision 1] (4568 : Housing Element Review and Adoption) 3 Vernice Hankins From:Amy Anderson <ananderson27@outlook.com> Sent:Monday, June 14, 2021 7:30 PM To:councilmtgitems; Sue Himmelrich; Gleam Davis; Councilmember Kevin McKeown; Phil Brock; Christine Parra; Kristin McCowan; Oscar de la Torre Subject:Comments to Item 8.A. Draft Housing Element EXTERNAL    Councilmembers,  Thank you for your firm commitment to expanding the supply of affordable housing (AH) in Santa Monica. In your effort  to prepare an impactful and fully compliant Housing Element, I appreciate your willingness to explore new and creative  strategies for producing more affordable units. Affordable homes are a uniquely effective way to reduce greenhouse gas  emissions, to mitigate traffic, and to offer members of our city community the opportunity to prosper.    City Staff and the Planning Commission are recommending to the City Council a strong draft Housing Element. I urge the  Council to approve it as‐is for submission to State HCD. I am strongly supportive of the following policies in particular:    ‐ Ministerial approval for 100% AH projects (up to 120% AMI) and HAA‐eligible projects, as recommended by the  Planning Commission  ‐ Elimination of parking minimums for housing near transit  ‐ Revision of the BAP and DCP to more effectively incentivize housing production  ‐ ADU Accelerator  ‐ AH Overlay, including in R1 zones, and inclusion of 120% AMI AH projects as part of the AH Overlay. Had this  overlay previously existed the former YWCA off of Pico, zoned R1, could have been redeveloped as AH.  ‐ Update to density bonus implementation, as recommended by the Planning Commission  ‐ Incentivizing housing over commercial uses and expanding residential as a by‐right use to new zones    To strengthen the commitment and accountability related to developing affordable housing on City land, which I  strongly support, I urge you to add the following to the program description: Within one month of HE adoption,  staff will provide to City Council projected development timelines for each property for review and approval by  Council.    Lastly, I urge you to maintain the inclusionary housing requirement at 15%; spread the affordability levels across  multiple categories; and adjust density and development standards to improve project feasibility. I am a non‐ profit affordable housing development professional with more than two decades experience. There are not  sufficient public funds available in California for Santa Monica to meet its AH production obligations through  publicly financed projects, even with its commitment to contribute land. The City’s commitment to increasing  affordable housing opportunities needs to include strong and effective policies, like inclusionary housing, that  produce AH through other means.    Thank you for your engaged and thoughtful work on this very important policy document that has the power to  demonstrate Santa Monica’s leadership in tackling the dual crisis of housing supply and affordability.    Amy Anderson  Item 8.A 06/15/21 27 of 61 Item 8.A 06/15/21 8.A.j Packet Pg. 139 Attachment: Written Comments [Revision 1] (4568 : Housing Element Review and Adoption) 1 Vernice Hankins From:zinajosephs@aol.com Sent:Tuesday, June 15, 2021 10:30 AM To:councilmtgitems; Gleam Davis; Kristin McCowan; Sue Himmelrich; Christine Parra; Oscar de la Torre; Phil Brock Cc:zinajosephs@aol.com Subject:City Council 6/15/21 agenda item 7-A: Draft Housing Element EXTERNAL    June 15, 2021 To: Mayor Himmelrich and City Council members From: Zina Josephs RE: 6/15/21 agenda item 7-A: Draft Housing Element Speaking only for myself: 1) I oppose rezoning R1 to multi-family. The state already allows 3 housing units per R1 lot (original home, ADU, and Jr. ADU). 2) I oppose the 100% affordable overlay proposed for north of Montana, northeast Santa Monica, and Sunset Park. 3) I oppose an overlay that would allow 4-story housing projects all over the city. The LUCE focused housing in downtown and along the major boulevards, not all over the city. 4) I oppose changes to the minimum percentage of inclusionary affordable housing in market rate projects. It should remain at 20%. 5) I oppose eliminating parking requirements for housing projects. Forcing families to take the bus to shop for groceries, or to commute to jobs that are not along bus routes is neither practical nor fair. 6) I support the revised quantified objective of round 5,500 units, with 40% affordable and 60% above moderate, but I would like to know where the funding would come from. Item 8.A 06/15/21 28 of 61 Item 8.A 06/15/21 8.A.j Packet Pg. 140 Attachment: Written Comments [Revision 1] (4568 : Housing Element Review and Adoption) 2 7) I hope the City of Santa Monica is getting credit for the previous Housing Element when the city exceeded the SCAG/RHNA allotment by 236%. Thank you for your consideration. Zina Josephs __________________________________________________________ Below are my earlier comments to the Planning Commission: June 2, 2021 Chair Landres and members of the Planning Commission, Speaking only for myself, I oppose the residential up-zoning recommendations in the draft Housing Element. I also oppose having the affordable units generated through inclusionary housing. With 6,300 affordable units required by RHNA, that would require planning for more than 30,000 market rate units, which is obviously unsustainable in Santa Monica. The City of Santa Monica exceeded one of its recent SCAG allocations by 236%, so I don’t understand why the City Council refused to challenge the punitive allocation of nearly 9,000 housing units this time around. The SCAG allocation is an unfunded mandate by the state. Why pretend that Santa Monica can afford to meet it? Regarding the assumption that Densification will create more Diversity in Santa Monica, here is some data that seems to refute that: Santa Monica diversity Item 8.A 06/15/21 29 of 61 Item 8.A 06/15/21 8.A.j Packet Pg. 141 Attachment: Written Comments [Revision 1] (4568 : Housing Element Review and Adoption) 3 65% White, `15% Hispanic, 10% Asian, 5% 2 or more races, 4% African American, 1% other races https://www.niche.com/places-to-live/santa-monica-los-angeles-ca/residents/ _______________________________________________________________________ Does density = diversity? Apparently not. Density by neighborhood: Statistical Atlas #1 – Wilshire/Montana -- #6 in diversity #2 – Ocean Park -- #3 in diversity #3 – Downtown/City Center -- #5 in diversity #4 – Mid-City -- #4 in diversity #5 – Pico -- #1 in diversity #6 – Northeast -- #7 in diversity #7 – Sunset Park -- #2 in diversity #8 – North of Montana -- #8 in diversity Diversity by neighborhood: https://www.niche.com/places-to-live/search/most-diverse- neighborhoods/t/santa-monica-los-angeles-ca/ #1 – Pico -- #5 in density #2 – Sunset Park -- #7 in density #3 – Ocean Park -- #2 in density #4 – Mid-City -- #4 in density #5 – City Center/Downtown -- #3 in density #6 – Wilshire/Montana -- #1 in density #7 – Northeast -- #6 in density #8 – North of Montana -- #8 in density Item 8.A 06/15/21 30 of 61 Item 8.A 06/15/21 8.A.j Packet Pg. 142 Attachment: Written Comments [Revision 1] (4568 : Housing Element Review and Adoption) 4 _________________________________________________________________________________ Center City (downtown): 4,659 total residents – 96% rent, 4% own https://www.niche.com/places-to-live/n/city-center-santa-monica-ca/ 66% white, 13% African American, 8% Hispanic, 6% Asian, 6% 2 or more races https://www.niche.com/places-to-live/n/city-center-santa-monica-ca/residents/ Mid-City: 23,540 total residents – 80% rent, 20% own https://www.niche.com/places-to-live/n/mid-city-santa-monica-ca/ 68% White, 11% Hispanic, 10% Asian, 6% 2 or more races, 3% African American https://www.niche.com/places-to-live/n/mid-city-santa-monica-ca/residents/ North of Montana: 10,300 total residents – 36% rent, 64% own https://www.niche.com/places-to-live/n/north-of-montana-santa-monica-ca/ 77% White, 10% Asian, 9% Hispanic, 3% 2 or more races, 1% African American https://www.niche.com/places-to-live/n/north-of-montana-santa-monica-ca/residents/ Northeast: 5,677 total residents – 49% rent, 51% own https://www.niche.com/places-to-live/n/northeast-santa-monica-ca/ 75% White, 10% Asian, 7% Hispanic, 6% 2 or more races, 1% African American https://www.niche.com/places-to-live/n/northeast-santa-monica-ca/residents/ Ocean Park: 13,379 total residents – 77% rent, 23% own https://www.niche.com/places-to-live/n/ocean-park-santa-monica-ca/ 68% White, `6% Hispanic, 6% 2 or more races, 5% Asian, 5% African American, 1% other https://www.niche.com/places-to-live/n/ocean-park-santa-monica-ca/residents/ Item 8.A 06/15/21 31 of 61 Item 8.A 06/15/21 8.A.j Packet Pg. 143 Attachment: Written Comments [Revision 1] (4568 : Housing Element Review and Adoption) 5 Pico neighborhood: 16,943 total residents – 82% rent, 18% own https://www.niche.com/places-to-live/n/pico-santa-monica-ca/ 42% White, 32% Hispanic, 14% Asian, 8% African American, 4% 2 or more races https://www.niche.com/places-to-live/n/pico-santa-monica-ca/residents/ Sunset Park: 17,678 total residents -- 57% rent, 43% own https://www.niche.com/places-to-live/n/sunset-park-santa-monica-ca/ 62% White, 18% Hispanic, 9% Asian, 7% 2 or more races, 3% African American, 1% other https://www.niche.com/places-to-live/n/pico-santa-monica-ca/residents/ Wilshire/Montana: 20,100 total residents – 81% rent, 19% own https://www.niche.com/places-to-live/n/wilshire-montana-santa-monica-ca/ 75% white, 9% Asian, 8% Hispanic, 5% 2 or more races, 5% African American https://www.niche.com/places-to-live/n/wilshire-montana-santa-monica-ca/residents/ Item 8.A 06/15/21 32 of 61 Item 8.A 06/15/21 8.A.j Packet Pg. 144 Attachment: Written Comments [Revision 1] (4568 : Housing Element Review and Adoption) 6 Vernice Hankins From:Mary Marlow <mmarlow7@icloud.com> Sent:Tuesday, June 15, 2021 9:04 AM To:councilmtgitems Cc:Mary Marlow; Phil Brock; Gleam Davis; Oscar de la Torre; Sue Himmelrich; Kristin McCowan; Christine Parra Subject:June 15, 2021 Agenda Item 7A Housing Element EXTERNAL    Dear Mayor Himmelrich and Councilmembers,   I write to comment on the proposed Housing Element on the agenda of June 15, 2021, city council meeting.  I served on  the Housing Production Sub Committee along with other interested residents, businesses, and developer  representatives.  We struggled to figure out how to build almost 9000 new units with 6000 affordable to low‐ and  moderate‐income renters.  We looked at how much inclusionary housing would be required to generate 6000 affordable  units at different percentage levels.  For example, 10% inclusionary would require 60,0000 units; 15% equals 40,000  units; and 20% would equal 30,000 units.  These are unattainable numbers given the history of Santa Monica generating  around 200 affordable units per year over the last 20 years.  In addition, depending on thousands of market rate units  would overwhelm the infrastructure of the city.  Water, power, sewer and roads cannot handle an increase of people  and traffic without millions of dollars of upgrades.  Money that is simply not available.   Many options were studied, and I object to the following as untenable and in conflict with the General Plan, LUCE  ,which was adopted after seven years of community input:  1) No rezoning of R1 to multifamily.  The zoning already allows for two additional units on R1 lots, an ADU and a Jr.  ADU.  Subdividing R1 lots will only increase wealth of homeowners and likely result in more expensive homes and  apartments.   2) No Housing overlay that would allow up to four stories of 100% affordable housing in all zones in the city.  This idea  is in direct conflict with the LUCE General Plan (focus on building housing in the downtown, Bergamot Transit Village and  Mixed‐use creative areas and the Major Boulevards.     3) No changes to market rate inclusionary housing percentages.  A minimum of 20% affordable units must remain  throughout the city.  Looking at the pipeline of projects, twice as many market rate units are planned as called for in the  Housing Element.   4) No parking elimination for housing projects.  A minimum of one parking per space per unit is required. Until mass  transportation is readily available, cars will continue to dominate during this eight‐year housing cycle.   5) No more than 100 affordable housing units on public land at Bergamot Art Center and 4th and Arizona.  Overbuilding  on public land leaves insufficient open space given the increase in population and lack of community process on public  land decisions.      In conclusion, Santa Monica is making a Good Faith effort to calculate how much housing we can realistically build given  the economy, water, infrastructure limits, and lack of affordable housing funding.  The most likely number of total units  is around 5000 with almost half affordable units.  Item 8.A 06/15/21 33 of 61 Item 8.A 06/15/21 8.A.j Packet Pg. 145 Attachment: Written Comments [Revision 1] (4568 : Housing Element Review and Adoption) 7  Santa Monican’s have worked together on a plan that builds market rate, affordable and homeless units during the next  Housing Element cycle that fits our city’s General Plan, Values and Budget while continuing our years long commitment  to fair and equitable housing for all residents.     Sincerely,  Mary Marlow  Former Ocean Park Association President  Bergamot Advisory Committee Co‐chair  Member of Housing Production Sub‐Committee        Item 8.A 06/15/21 34 of 61 Item 8.A 06/15/21 8.A.j Packet Pg. 146 Attachment: Written Comments [Revision 1] (4568 : Housing Element Review and Adoption) 8 Vernice Hankins From:Elizabeth Van Denburgh <emvandenburgh@gmail.com> Sent:Tuesday, June 15, 2021 8:20 AM To:Sue Himmelrich; Kristin McCowan; Christine Parra; Oscar de la Torre; Phil Brock; Gleam Davis; councilmtgitems Cc:Lane Dilg; Susan Cline; Anuj Gupta; David Martin Subject:6/15/21 City Council Mtg. - Item 8A - Wilmont comments on Draft Housing Element EXTERNAL        June 15, 2021 Mayor Himmelrich and City Council Members, The Wilmont (Wilshire Montana Neighborhood Coalition) Board has the following comments on the draft Housing Element you will review on June 15th:  The Board does not support the residential up-zoning recommendations throughout the draft Housing Element or the application of a 100% affordable housing overlay  The Board supports the LUCE and the recommendations and structure that came with it for housing through 2030. o We expect to see analysis of whether the LUCE does or does not support the availability of complying with zoning and approved/planned development that supports the 9,000 RHNA housing units before the City Council votes on the Housing Element. We have yet to see that analysis completed and/or made public.  The Board has not seen the evidence that densification creates more diversity or affordability which is what we need. o The RHNA affordable units continue to be an unfunded mandate by the state.  The Board rejects a model of having the affordable units be generated through inclusionary housing. With 6,300 affordable units required by RHNA, that would require that 31,500 market rate housing would have to be planned/built at a ratio of 20% inclusionary housing and would be cost prohibitive from a city ecosystem framework for our residents  The Board applauds the residents of the city for passing Prop R on 30% affordable housing in 1990 and applauds the city for generating 37% of housing over the last 25 years to be affordable. Item 8.A 06/15/21 35 of 61 Item 8.A 06/15/21 8.A.j Packet Pg. 147 Attachment: Written Comments [Revision 1] (4568 : Housing Element Review and Adoption) 9 o This draft Housing Element brings to mind the phrase "that no good deed goes unpunished"  The Board strongly supports the city's principles around Housing Stability - ensure that existing residents are protected from displacement as well as continuing to guide, monitor and support earthquake retrofitting to ensure our housing stock survives a significant earthquake.  Specifically in the Wilmont neighborhood, the Board is very concerned regarding the development proposal for 1101 Wilshire (just east across from El Chollo). Developer is asking for a six-story building where SM zoning only approves a four-story building based on a State Density Bonus Law (CA GC Section 65915). We strongly encourage the city to fight this expanded height based on the existing tier and community benefit framework in the LUCE. We have many issues to deal with in the city. Let's use the LUCE as our housing guide and continue to work together to make progress in homelessness and health and safety of public spaces as prioritized by the City Council. Thank-you, Board of Wilshire Montana Neighborhood Coalition (Wilmont) Item 8.A 06/15/21 36 of 61 Item 8.A 06/15/21 8.A.j Packet Pg. 148 Attachment: Written Comments [Revision 1] (4568 : Housing Element Review and Adoption) 2 Vernice Hankins From:Noma Boardmember <nomaboard@gmail.com> Sent:Tuesday, June 15, 2021 11:56 AM To:councilmtgitems; Kristin McCowan; Sue Himmelrich; Christine Parra; Oscar de la Torre; Phil Brock; Gleam Davis Subject:Subject: Agenda Item 7-A Draft Housing Element EXTERNAL        To help protect your privacy, Microsoft Office prevented automatic download of this picture from the Internet.       June 15, 2021 To: Mayor Himmelrich and City Council members From: NOMA Board RE: 6/15/21 agenda item 7-A: Draft Housing Element 1) We oppose rezoning R1 to multi-family. The state already allows 3 housing units per R1 lot (original home, ADU, and Jr. ADU). 2) We oppose the 100% affordable overlay proposed for north of Montana, northeast Santa Monica, and Sunset Park. 3) We oppose an overlay that would allow 4-story housing projects all over the city. The LUCE focused housing in downtown and along the major boulevards, not all over the city. 4) We oppose changes to the minimum percentage of inclusionary affordable housing in market rate projects. It should remain at 20%. 5) We oppose eliminating parking requirements for housing projects. Forcing families to take the bus to shop for groceries, or to commute to jobs that are not along bus routes is neither practical nor fair. Item 8.A 06/15/21 38 of 61 Item 8.A 06/15/21 8.A.j Packet Pg. 149 Attachment: Written Comments [Revision 1] (4568 : Housing Element Review and Adoption) 3 Thank you for your consideration.     smnoma.org  NOMAboard@gmail.com      Item 8.A 06/15/21 39 of 61 Item 8.A 06/15/21 8.A.j Packet Pg. 150 Attachment: Written Comments [Revision 1] (4568 : Housing Element Review and Adoption) 1 Vernice Hankins From:Tricia Crane <1triciacrane@gmail.com> Sent:Tuesday, June 15, 2021 12:03 PM To:councilmtgitems; Sue Himmelrich; Kristin McCowan; Christine Parra; Phil Brock; Oscar de la Torre; Gleam Davis; Lane Dilg; George S. Cardona; Clerk Mailbox; Denise Anderson-Warren Subject:City Council Agenda Item 7-A Draft Housing Element Attachments:OCCOG+PressRelease_HCD_060121.pdf EXTERNAL    To: City Council  From: Tricia Crane  Re: 6/15/21 agenda item 7-A: Draft Housing Element    Dear Mayor Himmelrich and City Council members,  I would like to be sure you are aware of the announcement – below and attached - that the Orange County Council of Governments is challenging the State over the RHNA Housing Allocations.  Thank you  Tricia Crane  The board of the Orange County Council of Governments (OCCOG) voted, 15-0, to sue the Department of Housing and Community Development over its most recent Regional Determination under the Regional Housing Needs Assessment. In its statement on the legal action, the board maintains that the HCD did not follow the statutes outlined in state law to develop the projected number of units needed in the next eight years to adequately house Orange County’s population. Though Orange County continues to adhere to the state’s housing requirements, the OCCOG believes that the latest state-determined zoning quotas will be unfair to local taxpayers.  https://www.cp-dr.com/articles/cpdr-news-briefs-june-8-2021  ==  PRESS RELEASE June 1, 2021 Orange County Council of Governments  SUMMARY OF OCCOG BOARD ACTION   Following a closed session at its May 27, 2021, Board of Directors meeting, the Orange County Council of Governments (OCCOG) Board authorized legal counsel to file a petition for writ of Item 8.A 06/15/21 40 of 61 Item 8.A 06/15/21 8.A.j Packet Pg. 151 Attachment: Written Comments [Revision 1] (4568 : Housing Element Review and Adoption) 2 mandate against the California Department of Housing and Community Development (HCD) challenging HCD’s application of Regional Housing Needs Assessment (RHNA) statutes.   Board Vote: • Support – 15 • Oppose – 0 • Absent – 3   -----     STATEMENT: Attribute to OCCOG Chair, Trevor O’Neil   Orange County Council of Governments (OCCOG) members are responsible for adequately planning new housing for the current and future residents that will live and work in their communities. Orange County recognizes that its high-quality transit and job centers make its communities desirable places for many people to live, work and play. Orange County jurisdictions are currently following the state’s housing statutes and are working hard to update housing elements to meet the number of housing units assigned to them via the 6th Cycle Regional Housing Needs Assessment (RHNA) methodology. However, OCCOG recognizes that Orange County’s citizens and taxpayers deserve to be treated fairly under the law. Therefore, on behalf of its members, OCCOG is challenging the Regional Determination established by the California Department of Housing and Community Development (HCD). Simply, HCD did not follow the statutes outlined in state law to develop the projected number of units needed in the next eight years to adequately house Orange County’s population.   Item 8.A 06/15/21 41 of 61 Item 8.A 06/15/21 8.A.j Packet Pg. 152 Attachment: Written Comments [Revision 1] (4568 : Housing Element Review and Adoption) 1 Vernice Hankins From:Kathy Knight <kathyknight66@gmail.com> Sent:Tuesday, June 15, 2021 12:13 PM To:councilmtgitems; Gleam Davis; Kristin McCowan; Sue Himmelrich; Christine Parra; Oscar de la Torre; Phil Brock Subject:City Council Agenda Item 8-A Draft Housing Element EXTERNAL    Please use this letter from me.   I accidentally put agenda Item 7‐A on my first letter.  It is Agenda Item 8‐A Draft Housing  Element.  Thank you,  Kathy Knight   >   > June 15, 2021  >   > To:   Mayor Himmelrich and City Council Members  >   > From:  Kathy Knight  > 30 year resident of Santa Monica  >   > Re:  6/15/21 Agenda Item 8‐A ‐ Draft Housing Element  >   > Dear Council Members:  >   > 1.  I oppose rezoning R‐1 to multi‐family.  The state already allows 3 housing units per R‐1 lot (original home, ADU, and  Jr. ADU).  >   > 2.  I oppose the 100% affordable overlay proposed for north of Montana, northeast Santa Monica and Sunset Park.  >   > 3.  I oppose an overlay that would allow 4‐story housing projects all over the city.  The LUCE focused housing in  downtown and along   > our major boulevards.   That is where new housing should be.     >   > 4.  Minimum percentage of inclusionary affordable housing should REMAIN at 20% or higher.   As of now too much  housing built is luxury housing that sits empty.  I have been told that there are about 4,000 market rate apts./condos in  Santa Monica that are empty.    > That is ridiculous.    They should be rehabbed into affordable units.   That would solve our housing issue.  >   > 5.  I hope the City of Santa Monica is getting CREDIT for the previous   > Housing Element when the City exceeded the SCAG/RHNA allotment by 23%.  >   > Thank you for your consideration of these comments.  >   > Kathy Knight  > (310) 613‐1175    Item 8.A 06/15/21 42 of 61 Item 8.A 06/15/21 8.A.j Packet Pg. 153 Attachment: Written Comments [Revision 1] (4568 : Housing Element Review and Adoption) 1 Vernice Hankins From:Nikki Kolhoff <nhkolhoff@yahoo.com> Sent:Tuesday, June 15, 2021 12:42 PM To:Council Mailbox; councilmtgitems Subject:6/15/21 agenda item 7-A: Draft Housing Element EXTERNAL    Dear City Council - With respect to the draft Housing Element: 1) I oppose rezoning R1 to multi-family. The state already allows 3 housing units per R1 lot (original home, ADU, and Jr. ADU). 2) I oppose the 100% affordable overlay proposed for north of Montana, northeast Santa Monica, and Sunset Park. 3) I oppose an overlay that would allow 4-story housing projects all over the city. The LUCE focused housing in downtown and along the major boulevards, not all over the city. 4) I oppose changes to the minimum percentage of inclusionary affordable housing in market rate projects. It should remain at 20%. 5) I oppose eliminating parking requirements for housing projects. Forcing families to take the bus to shop for groceries, or to commute to jobs that are not along bus routes is neither practical nor fair. 7) I hope the City of Santa Monica is getting credit for the previous Housing Element when the city exceeded the SCAG/RHNA allotment by 236%. 8) I OPPOSE ANY MODIFICATION TO THE HOUSING ELEMENT TO MEET THE SCAG GOAL. THE GOAL IS BASELESS AND SHOULD BE CHALLENGED. Thanks, Nikki Kolhoff Santa Monica Resident Item 8.A 06/15/21 43 of 61 Item 8.A 06/15/21 8.A.j Packet Pg. 154 Attachment: Written Comments [Revision 1] (4568 : Housing Element Review and Adoption) 1 Vernice Hankins From:Jacob Wessel <jacobkatzwessel@gmail.com> Sent:Tuesday, June 15, 2021 2:00 PM To:councilmtgitems Cc:Gleam Davis; Phil Brock; Christine Parra; Sue Himmelrich; Kristin McCowan; Oscar de la Torre Subject:8.A. Review and Direction of Draft Housing Element EXTERNAL    Members of the Santa Monica City Council,    I would like to commend City staff for their diligent work preparing the Draft Housing Element and urge you to send a  Housing Element to CA HCD that aggressively supports increased housing production and simpler processes for allowing  more housing across Santa Monica.    I am disappointed to see a change in recommendation from the Planning Commission and staff as part of Program 4D  that no longer explicitly calls for up to three units to be allowed to be built in R1 zones. I know first hand the character of  those neighborhoods ‐ I was born and raised in the R1 zone North of Montana ‐ and I would like the City of Santa Monica  to allow more residents and families to live there in units larger than ADUs. Especially since the proposal largely stayed  within the existing building envelopes, it would simply allow multiple units in similar buildings. Please reinstate this  component.    I am also disappointed to see that Program 4D no longer recommends R2 zones for 7th St and 14th St between Montana  and San Vicente and 26th between Wilshire and San Vicente. The two blocks that surround Roosevelt Elementary School  (Lincoln Blvd and 9th St between Montana and Alta) are zoned for R2 and located North of Montana and they fit into the  neighborhood quite nicely and allow more families to access the nearby shopping district, public schools, and green  spaces. I think this original recommendation was wise to allow for more incremental housing production and should be  reinstated.    It is exciting to see a commitment to changing zoning across Santa Monica to allow for more housing production, and I  hope to one day walk down the GC zone of Santa Monica Blvd and have the properties filled not with the car dealerships  of today, but of multistory apartment buildings with ground floor retail. I would also urge evaluating whether most  MUBL zones would be best served converted to MUB zones.    I also hope that as this Housing Element is carried out by City staff and the Council, consideration is given to eliminating  minimum parking requirements for all buildings citywide as has been done recently in other municipalities to enable  cheaper naturally‐occuring housing should developers see tenants not wanting parking.    I have spent the last six years working in city government in Boston on projects related to housing, zoning and  transportation and know how contentious these decisions can be. I urge you to act with courage to allow more dense  housing in the wonderful seaside community that I was fortunate to grow up in and I hope many, many more will be  able to in future generations.    Thank you for your service,    Jacob Wessel  353 19th St Santa Monica, CA 90402  Item 8.A 06/15/21 44 of 61 Item 8.A 06/15/21 8.A.j Packet Pg. 155 Attachment: Written Comments [Revision 1] (4568 : Housing Element Review and Adoption) 2 Vernice Hankins From:OZ <zurawska@yahoo.com> Sent:Tuesday, June 15, 2021 1:58 PM To:councilmtgitems; Lori Gentles Cc:Sue Himmelrich; Kristin McCowan; Christine Parra; Phil Brock; Oscar de la Torre; Gleam Davis; ADACoordinator; Oles Gordeev; mike.soloff@mto.com; Rene Buchanan; Todd Flora; Josh Hamilton; Carl Hansen; Leonora Camner; June Hagen; Nanci Linke-Ellis; Lauri Ringer; Delbert Whetter; Kathryn Kosmeya-Dodge; Alex Elliott; tjhill@dcrc.co; Marielle Kriesel; Anna Topolewski Subject:public input 8A - Housing Element (fair housing - ADA) EXTERNAL    It sure is nice to have goals like advancing fair housing. And here is the reality of how city staff is advancing fair housing – by ignoring the recommendations by Diane Glauber who produced a Fair Housing Assessment report in January 2020, and by ignoring residents' and advocates' emails: From: oz <zurawska@yahoo.com> To: Lori Gentles <lori.gentles@smgov.net> Cc: "lane.dilg@smgov.net" <lane.dilg@smgov.net>; ADACoordinator <adacoordinator@smgov.net>; James Kemper <james.kemper@smgov.net>; S Bavan Meena <meena.s.bavan@hud.gov>; Chin Woo Choi <chinwoo.choi@hud.gov>; Andy Agle <andy.agle@smgov.net>; Phil Brock <phil.brock@smgov.net>; Christine Parra <christine.parra@smgov.net>; Oles Gordeev <oles.gordeev@smgov.net>; Michael Soloff <mike.soloff@mto.com>; Buchanan Rene <rene.buchanan@smgov.net>; Todd Flora <todd.flora@smgov.net>; "josh.hamilton@smgov.net" <josh.hamilton@smgov.net>; Carl Hansen <carl.hansen@smgov.net>; Camner Leonora <leonora.camner@smgov.net>; "june.hagen@smgov.net" <june.hagen@smgov.net>; "nanci.linke- ellis@smgov.net" <nanci.linke-ellis@smgov.net>; "lauri.ringer@smgov.net" <lauri.ringer@smgov.net>; "delbert.whetter@smgov.net" <delbert.whetter@smgov.net>; "kathryn.kosmeya-dodge@smgov.net" <kathryn.kosmeya-dodge@smgov.net>; "alex.elliott@smgov.net" <alex.elliott@smgov.net>; "tjhill@dcrc.co" <tjhill@dcrc.co>; Marielle Kriesel <marielle.kriesel@smgov.net>; Anna Topolewski <anna.topolewski@smgov.net> Sent: Monday, June 14, 2021, 12:24:28 PM PDT Subject: Fwd: ADA-compliant process for locating modified units in the City of Santa Monica Hello Ms. Gentles, Perhaps you could assist me in obtaining a response to the May 13, 2021 email City staff has neglected to respond to. As you probably can see by now, there is a pattern of ignoring residents’ inquiries regarding SMHA related issues. Please know that I was prompted to write the May 13 email upon a request from a SAMHA client who was previously given no choice but to accept a housing unit that does not accommodate their disabilities. Now this SAMHA client would like to finally locate an accommodated unit. The lack of Item 8.A 06/15/21 45 of 61 Item 8.A 06/15/21 8.A.j Packet Pg. 156 Attachment: Written Comments [Revision 1] (4568 : Housing Element Review and Adoption) 3 response from the City is affecting this person’s life and their civil rights, as well as the lives and civil rights of other similarly situated individuals. Thank you for your assistance. Regards, Olga Zurawska Begin forwarded message: From: OZ <zurawska@yahoo.com> Date: May 13, 2021 at 18:20:08 PDT To: lane.dilg@smgov.net, ADACoordinator <ADACoordinator@smgov.net>, James Kemper <James.Kemper@smgov.net> Cc: S Bavan Meena <Meena.S.Bavan@hud.gov>, Chin Woo Choi <chinwoo.choi@hud.gov>, Andy Agle <Andy.Agle@smgov.net>, Phil Brock <phil.brock@smgov.net>, Christine Parra <Christine.Parra@smgov.net>, Oles Gordeev <Oles.Gordeev@smgov.net>, Lori Gentles <Lori.Gentles@smgov.net>, Michael Soloff <mike.soloff@mto.com>, Buchanan Rene <rene.buchanan@smgov.net>, Todd Flora <Todd.Flora@smgov.net>, josh.hamilton@smgov.net, Carl Hansen <Carl.Hansen@smgov.net>, Camner Leonora <leonora.camner@smgov.net>, june.hagen@smgov.net, nanci.linke-ellis@smgov.net, lauri.ringer@smgov.net, delbert.whetter@smgov.net, kathryn.kosmeya-dodge@smgov.net, alex.elliott@smgov.net, tjhill@dcrc.co, Marielle Kriesel <Marielle.Kriesel@smgov.net>, Anna Topolewski <anna.topolewski@smgov.net> Subject: ADA-compliant process for locating modified units in the City of Santa Monica Hello Ms. Dilg, Ms. Medina and Mr. Kemper, I am writing to you in your respective positions as the Executive Director of the Santa Monica Housing Authority, the City’s ADA Coordinator and the Housing Program Manager. This is to request information on the process the City offers in compliance with the Americans with Disabilities Act to Santa Monica voucher program participants who need to locate a modified unit that would accommodate a physical, sensory or other disability. As you might remember, the January 2020 Assessment of Fair Housing in Santa Monica resulted in a report that lists the following recommendation under Goal 4. Increase community integration for persons with disabilities: 3. Provide a point of contact for a dedicated ADA Coordinator to track and maintain a list of ADA accessible housing units and coordinate the housing needs of people with disabilities. Additional responsibilities would include assessing risk of violations, coordinating with City departments, and providing education and instruction. Additionally, the Santa Monica Housing Authority's current 5-Year Housing Plan lists the following goal: Increase community integration for persons with disabilities. Item 8.A 06/15/21 46 of 61 Item 8.A 06/15/21 8.A.j Packet Pg. 157 Attachment: Written Comments [Revision 1] (4568 : Housing Element Review and Adoption) 4 Thank you for your assistance. Regards, Olga Zurawska Item 8.A 06/15/21 47 of 61 Item 8.A 06/15/21 8.A.j Packet Pg. 158 Attachment: Written Comments [Revision 1] (4568 : Housing Element Review and Adoption) EXHIBIT A Below is a list of standards in the DCP and Zoning Ordinance (other than height/FAR) that have proven problematic for housing projects and/or have forced additional discretion/delay for housing projects:  Minimum and maximum ground-floor floor-to-floor heights in the Zoning Ordinance and DCP (generally 11 feet minimum and 16 feet maximum) o Problematic for sloping sites to comply with both the maximum and minimum o Problematic for housing projects that include grocery stores, which are an important neighborhood serving use  Active commercial design standards in the Zoning Ordinance, including: o the requirement that the finished ground floor level be within 18 inches above and below the adjacent commercial boulevard sidewalk level (or for sloping sites 3 feet above and 18 inches below) o the requirement that active commercial design standards apply along both commercial boulevards for a corner lot fronting two commercial boulevards  Active commercial use requirements in the Zoning Ordinance and DCP that limit ground floor uses to specified retail uses on the ground floor and/or prohibit ground floor residential uses. This is particularly problematic for corner lots where the requirement applies along two street frontages.  The restriction on continued use of an R-zoned lot with a 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));  The requirement that parking for any addition on a 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)  The requirement that vehicular access for any redevelopment be on the commercially-zoned lot (SMMC Section 9.16.080(D)). Item 8.A 06/15/21 48 of 61 Item 8.A 06/15/21 8.A.j Packet Pg. 159 Attachment: Written Comments [Revision 1] (4568 : Housing Element Review and Adoption) June 15, 2021 Re: Agenda Item 8A - Housing Element Dear Mayor Himmelrich, Mayor Pro Tem McCowan, and members of the Santa Monica City Council, The penalty for failing to adopt a compliant housing element is not the status quo. The penalties are litigation, fines & fees, loss of state funding, and (most severely) the loss of local zoning control.1 Pursuant to the Housing Accountability Act, cities without a compliant housing element lose the ability to deny 20% below-market-rate (BMR) projects on the basis of local zoning. Almost any 20% BMR project, of any size, on any parcel in the city would become legal.2 Developers could build skyscrapers on streets like Georgina and there is not a thing the city could do to stop them. This is not a penalty way off in the future - it could happen this fall if we fail to adopt a compliant housing element by the deadline. Multiple cities in the San Diego region are already staring down these penalties. Chula Vista, El Cajon, Escondido, Coronado, and others failed to adopt compliant housing elements by SANDAG’s deadline in April. The most common issue: Affirmatively Furthering Fair Housing (AFFH) compliance. We believe the same fate awaits Santa Monica if we do not take meaningful steps to address the very real segregation and exclusion that exists in our city. In our view, the current draft of the Housing Element is woefully insufficient. Santa Monica is a city that was segregated by design. In the first half of the 20th century, deed restrictions, redlining, and other discriminatory government policies determined who could live in the city and where. White people in certain neighborhoods, people of color, religious minorities, and others elsewhere. These policies have since been rendered illegal but the segregation they engineered persists. Today, Santa Monica, despite its progressive reputation, has made very little progress unwinding the segregation the city created many decades ago. Our land use rules – rules which Council controls – 1 http://yimby.cc/consequences 2 See “pro-housing default rule” at https://escholarship.org/uc/item/45g8b2pv Item 8.A 06/15/21 49 of 61 Item 8.A 06/15/21 8.A.j Packet Pg. 160 Attachment: Written Comments [Revision 1] (4568 : Housing Element Review and Adoption) continue to prevent anyone except the wealthiest few from having the opportunity to move into our most exclusive neighborhoods. AFFH requires us to take proactive measures. Not just talk, with vague hints at future action, but concrete commitments on defined timelines. Per HCD, AFFH “means taking 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 protected characteristics.”3 We believe Council was on the right track in March. With the push of Kevin McKeown, a majority of Council decided to explore new housing opportunities in our most exclusive neighborhoods. Not with skyscrapers, or large block apartments, but “missing middle” type density like duplexes, townhomes, or courtyard apartments. These types of homes, which are more affordable by design, would have provided less expensive, more accessible housing opportunities in neighborhoods that are currently out of reach for most. Paired with R2 zoning, which creates the possibility of deed-restricted affordable housing, Santa Monica seemed to be on a path toward meaningfully addressing AFFH requirements.4 Yet despite this bold direction in March, it appears you may soon reverse yourselves. Santa Monica will proclaim – once again – that our most exclusive neighborhoods must remain exclusive. These neighborhoods will not be asked to do their fair share and instead most new housing, as has long been the case in Santa Monica, will be restricted to the car-choked boulevards, near the polluted freeway, and in Downtown. Not because of physical or economic constraints, but because of politics. The aesthetic desires of the most privileged coming before the needs of everyone else. We urge you to stay the course and distribute our RHNA equitably throughout the city. If you reverse yourselves, Santa Monica risks not meeting AFFH requirements, which would lead to a non-compliant housing element. Beyond AFFH, there are other issues in the Housing Element which we believe require further review. These issues, in no particular order, include the following: - Unrealistic plan for city owned land. Except for Parking Structure 3, Santa Monica has no active RFPs, no active development agreements, and no identified sources of funding for housing on city owned parcels. Without any of the foregoing, it’s very hard to fathom how these sites will accommodate 1,884 new housing units by 2029. 3 https://www.hcd.ca.gov/community-development/affh/docs/affh_document_final_4-27-2021.pdf 4 HCD identifies numerous barriers to fair housing which cities should seek to address. Barriers include “predominance of single family uses … in racially concentrated areas of affluence.” Other barriers that HCD identifies, which we encourage City Council to consider more broadly, including multifamily height limits, minimum unit size requirements, and minimum parking requirements. Item 8.A 06/15/21 50 of 61 Item 8.A 06/15/21 8.A.j Packet Pg. 161 Attachment: Written Comments [Revision 1] (4568 : Housing Element Review and Adoption) - Unrealistic assumptions for pipeline projects. During the 5th Cycle, only 77% of pipeline units were built. However, the Housing Element now assumes that 90% of pipeline units will be built. This is unrealistic. As a comparison, City of Los Angeles takes credit for 79% of permitted projects and 45% of entitled projects. Our assumptions should match City of LA’s. - Incorrect capacity calculations. HCD requires a likelihood of residential development calculation for mixed-use and commercial sites. The Housing Element does not appear to make this calculation correctly which would mean the realistic capacity of the suitable sites inventory is overstated. Staff should verify with HCD that all capacity calculations are made correctly.5 - Excessive Constraints. The Housing Element identifies numerous constraints on new housing production but then leaves many of these constraints unaddressed. For example – new condos must pay approximately $125,000 in fees whereas new single-family homes pay only $36,000. This is a needless burden on new condos, which makes condo ownership more expensive. Condo development standards must be revised if Santa Monica is serious about creating new homeownership opportunities. - Vague Programs. Many of the Housing Element programs lack specific commitments. For example, Programs 1.E and 1.F propose revising development standards in Bergamont and Downtown to incentivize housing development but no specific standards are proposed. More concrete language is needed (e.g. “Revise development standards to make 15% inclusionary projects economically feasible”). - Incomplete AFFH Assessment. HCD requires a thorough assessment of fair housing issues in Santa Monica. Much of what HCD requires is still missing from the Housing Element. The Housing Element should be revised to include all relevant HCD requirements.6 We look forward to your discussion tomorrow. Sincerely, Abby Arnold and Carl Hansen Co-chairs, Santa Monica Forward 5 See “Requisite Analysis” at https://www.hcd.ca.gov/community-development/building-blocks/site-inventory- analysis/analysis-of-sites-and-zoning.shtml#realistic 6 See “Assessment of Fair Housing” at https://www.hcd.ca.gov/community- development/affh/docs/affh_document_final_4-27-2021.pdf Item 8.A 06/15/21 51 of 61 Item 8.A 06/15/21 8.A.j Packet Pg. 162 Attachment: Written Comments [Revision 1] (4568 : Housing Element Review and Adoption) AFFH Considerations The following maps, available from HCD’s AFFH Data Viewer, illustrate some of Santa Monica’s fair housing considerations.7 We hope this data is incorporated into the Housing Element’s AFFH analysis. The draft Suitable Site Inventory concentrates new housing in Santa Monica’s least advantaged neighborhoods. Santa Monica Forward believes that new housing should be equitably distributed throughout the city, including in high resource neighborhoods, in accordance with HCD guidance. Suitable Site Inventory Map 7 https://affh-data-resources-cahcd.hub.arcgis.com/ Item 8.A 06/15/21 52 of 61 Item 8.A 06/15/21 8.A.j Packet Pg. 163 Attachment: Written Comments [Revision 1] (4568 : Housing Element Review and Adoption) HOLC Redlining Map (1930s) Percent of Population Non-White (2018) Item 8.A 06/15/21 53 of 61 Item 8.A 06/15/21 8.A.j Packet Pg. 164 Attachment: Written Comments [Revision 1] (4568 : Housing Element Review and Adoption) CalEnviroScreen 4.0 – Measures pollution burden by neighborhood HUD Low to Moderate Income Population Item 8.A 06/15/21 54 of 61 Item 8.A 06/15/21 8.A.j Packet Pg. 165 Attachment: Written Comments [Revision 1] (4568 : Housing Element Review and Adoption) 69102043v1 A Limited Liability Law Partnership Including Corporations / Los Angeles • San Francisco • Orange County Daniel Freedman dff@jmbm.com 1900 Avenue of the Stars, 7th Floor Los Angeles, California 90067-4308 (310) 203-8080 (310) 203-0567 Fax www.jmbm.com June 15, 2021 BY EMAIL ONLY Honorable Members of the Santa Monica City Council City of Santa Monica 1685 Main St #102 Santa Monica, CA 90401 E-Mail: councilmtgitems@smgov.net Re: Review of Draft Housing Element Support Conversion of Ground Floor Commercial to Residential Uses Hearing Date: June 15, 2021; 5:30 pm. Agenda Item 8-A Dear Honorable Members of the Santa Monica City Council: We write to urge the City Council to prioritize code amendments in the Housing Element that permit the conversion of ground-floor commercial spaces within existing mixed-use buildings to residential uses. Our client's and many other property owners in the downtown area have been exploring the concept of converting vacant ground-floor retail/office within existing multi-family buildings to additional residential units. This would not only help to add additional housing in transit-rich multi-family neighborhoods, but would also help the City remodel and improve the existing ground-floor spaces that have struggled with commercial vacancies for many years. Unfortunately, our client's efforts to perform this work has been stymied by the Santa Monica Municipal Code's ("SMMC") blanket and inflexible prohibition on ground floor residential uses in the Transit Adjacent zone. Based on our review of the building and the streetscape, this prohibition is unnecessarily restrictive. It also fails provide for any means for a building owner to repurpose underutilized ground floor spaces into residential uses that would activate sidewalks and ground floor areas. The need for flexibility to permit the conversion of vacant ground-floor commercial to residential is particularly significant at this moment, as long-term commercial vacancies are becoming more and more common in certain parts of the downtown area, and as the need to expand our city's housing supply has never been so great. Accordingly, we ask the City Council encourage the Department of City Planning to prioritize this concept further as part of the Housing Element and to amend the SMMC Item 8.A 06/15/21 55 of 61 Item 8.A 06/15/21 8.A.j Packet Pg. 166 Attachment: Written Comments [Revision 1] (4568 : Housing Element Review and Adoption) June 15, 2021 Page 2 69102043v1 accordingly. This will help the entire City repurpose ground floor spaces that have struggled with vacancies for many years, beautify streetscapes and sidewalks, while adding much needed housing units into transit-adjacent buildings that already maintain residential amenities. This would be a win-win for the City, and so we ask for the City Council's support to Thank you in advance for your consideration, and we look forward to appearing at tonight's hearing on this item. Very truly yours, BENJAMIN M. REZNIK and DANIEL F. FREEDMAN of Jeffer Mangels Butler & Mitchell LLP DF:df CC: Jing Yeo, Planning Manager, Department of City Planning (Jing.Yeo@smgov.net) Item 8.A 06/15/21 56 of 61 Item 8.A 06/15/21 8.A.j Packet Pg. 167 Attachment: Written Comments [Revision 1] (4568 : Housing Element Review and Adoption) 1 Vernice Hankins From:janedempsey@earthlink.net Sent:Tuesday, June 15, 2021 11:21 AM To:councilmtgitems; Gleam Davis; Kristin McCowan; Sue Himmelrich; Christine Parra; Oscar de la Torre; Phil Brock Subject:RE: City Council 6/15/21 agenda item 7-A: Draft Housing Element EXTERNAL    Dear Councilmembers, I fully agree with the below letters from Zina Josephs. Please consider all the points mentioned carefully – your decision will have consequences for the residents of Santa Monica for years to come. Currently, two of my neighbors in R1 single family homes on Wilson Place live next to a soon to be 4 story building. I know they are very unhappy and just wishing they had sold their homes and moved 5 years ago. Jane Dempsey 820 Wilson Place Santa Monica, CA 90405 ------- Sent: 6/15/2021 10:30:07 AM Pacific Standard Time Subject: City Council 6/15/21 agenda item 7-A: Draft Housing Element June 15, 2021 To: Mayor Himmelrich and City Council members From: Zina Josephs RE: 6/15/21 agenda item 7-A: Draft Housing Element Speaking only for myself: Item 8.A 06/15/21 57 of 61 Item 8.A 06/15/21 8.A.j Packet Pg. 168 Attachment: Written Comments [Revision 1] (4568 : Housing Element Review and Adoption) 2 1) I oppose rezoning R1 to multi-family. The state already allows 3 housing units per R1 lot (original home, ADU, and Jr. ADU). 2) I oppose the 100% affordable overlay proposed for north of Montana, northeast Santa Monica, and Sunset Park. 3) I oppose an overlay that would allow 4-story housing projects all over the city. The LUCE focused housing in downtown and along the major boulevards, not all over the city. 4) I oppose changes to the minimum percentage of inclusionary affordable housing in market rate projects. It should remain at 20%. 5) I oppose eliminating parking requirements for housing projects. Forcing families to take the bus to shop for groceries, or to commute to jobs that are not along bus routes is neither practical nor fair. 6) I support the revised quantified objective of round 5,500 units, with 40% affordable and 60% above moderate, but I would like to know where the funding would come from. 7) I hope the City of Santa Monica is getting credit for the previous Housing Element when the city exceeded the SCAG/RHNA allotment by 236%. Thank you for your consideration. Zina Josephs __________________________________________________________ Below are my earlier comments to the Planning Commission: June 2, 2021 Chair Landres and members of the Planning Commission, Speaking only for myself, I oppose the residential up-zoning recommendations in the draft Housing Element. I also oppose having the affordable units generated through inclusionary housing. With 6,300 affordable units required by RHNA, that would require planning for more than 30,000 market rate units, which is obviously unsustainable in Santa Monica. Item 8.A 06/15/21 58 of 61 Item 8.A 06/15/21 8.A.j Packet Pg. 169 Attachment: Written Comments [Revision 1] (4568 : Housing Element Review and Adoption) 3 The City of Santa Monica exceeded one of its recent SCAG allocations by 236%, so I don’t understand why the City Council refused to challenge the punitive allocation of nearly 9,000 housing units this time around. The SCAG allocation is an unfunded mandate by the state. Why pretend that Santa Monica can afford to meet it? Regarding the assumption that Densification will create more Diversity in Santa Monica, here is some data that seems to refute that: Santa Monica diversity 65% White, `15% Hispanic, 10% Asian, 5% 2 or more races, 4% African American, 1% other races https://www.niche.com/places-to-live/santa-monica-los-angeles-ca/residents/ _______________________________________________________________________ Does density = diversity? Apparently not. Density by neighborhood: Statistical Atlas #1 – Wilshire/Montana -- #6 in diversity #2 – Ocean Park -- #3 in diversity #3 – Downtown/City Center -- #5 in diversity #4 – Mid-City -- #4 in diversity #5 – Pico -- #1 in diversity #6 – Northeast -- #7 in diversity #7 – Sunset Park -- #2 in diversity #8 – North of Montana -- #8 in diversity Item 8.A 06/15/21 59 of 61 Item 8.A 06/15/21 8.A.j Packet Pg. 170 Attachment: Written Comments [Revision 1] (4568 : Housing Element Review and Adoption) 4 Diversity by neighborhood: https://www.niche.com/places-to-live/search/most-diverse- neighborhoods/t/santa-monica-los-angeles-ca/ #1 – Pico -- #5 in density #2 – Sunset Park -- #7 in density #3 – Ocean Park -- #2 in density #4 – Mid-City -- #4 in density #5 – City Center/Downtown -- #3 in density #6 – Wilshire/Montana -- #1 in density #7 – Northeast -- #6 in density #8 – North of Montana -- #8 in density _________________________________________________________________________________ Center City (downtown): 4,659 total residents – 96% rent, 4% own https://www.niche.com/places-to-live/n/city-center-santa-monica-ca/ 66% white, 13% African American, 8% Hispanic, 6% Asian, 6% 2 or more races https://www.niche.com/places-to-live/n/city-center-santa-monica-ca/residents/ Mid-City: 23,540 total residents – 80% rent, 20% own https://www.niche.com/places-to-live/n/mid-city-santa-monica-ca/ 68% White, 11% Hispanic, 10% Asian, 6% 2 or more races, 3% African American https://www.niche.com/places-to-live/n/mid-city-santa-monica-ca/residents/ North of Montana: 10,300 total residents – 36% rent, 64% own https://www.niche.com/places-to-live/n/north-of-montana-santa-monica-ca/ 77% White, 10% Asian, 9% Hispanic, 3% 2 or more races, 1% African American https://www.niche.com/places-to-live/n/north-of-montana-santa-monica-ca/residents/ Item 8.A 06/15/21 60 of 61 Item 8.A 06/15/21 8.A.j Packet Pg. 171 Attachment: Written Comments [Revision 1] (4568 : Housing Element Review and Adoption) 5 Northeast: 5,677 total residents – 49% rent, 51% own https://www.niche.com/places-to-live/n/northeast-santa-monica-ca/ 75% White, 10% Asian, 7% Hispanic, 6% 2 or more races, 1% African American https://www.niche.com/places-to-live/n/northeast-santa-monica-ca/residents/ Ocean Park: 13,379 total residents – 77% rent, 23% own https://www.niche.com/places-to-live/n/ocean-park-santa-monica-ca/ 68% White, `6% Hispanic, 6% 2 or more races, 5% Asian, 5% African American, 1% other https://www.niche.com/places-to-live/n/ocean-park-santa-monica-ca/residents/ Pico neighborhood: 16,943 total residents – 82% rent, 18% own https://www.niche.com/places-to-live/n/pico-santa-monica-ca/ 42% White, 32% Hispanic, 14% Asian, 8% African American, 4% 2 or more races https://www.niche.com/places-to-live/n/pico-santa-monica-ca/residents/ Sunset Park: 17,678 total residents -- 57% rent, 43% own https://www.niche.com/places-to-live/n/sunset-park-santa-monica-ca/ 62% White, 18% Hispanic, 9% Asian, 7% 2 or more races, 3% African American, 1% other https://www.niche.com/places-to-live/n/pico-santa-monica-ca/residents/ Wilshire/Montana: 20,100 total residents – 81% rent, 19% own https://www.niche.com/places-to-live/n/wilshire-montana-santa-monica-ca/ 75% white, 9% Asian, 8% Hispanic, 5% 2 or more races, 5% African American https://www.niche.com/places-to-live/n/wilshire-montana-santa-monica-ca/residents/ Item 8.A 06/15/21 61 of 61 Item 8.A 06/15/21 8.A.j Packet Pg. 172 Attachment: Written Comments [Revision 1] (4568 : Housing Element Review and Adoption) 1 Vernice Hankins From:Council Mailbox Sent:Tuesday, June 15, 2021 2:51 PM To:councilmtgitems Subject:FW: Voice of citizen of SM     From: Helene Rosenzweig <hr2md@me.com>   Sent: Thursday, June 3, 2021 6:30 AM  To: Council Mailbox <Council.Mailbox@SMGOV.NET>  Subject: Voice of citizen of SM    EXTERNAL    Dear Member,     I am writing to you to STRONGLY OPPOSE the proposal to change or remove Single Family Residential (SFR) R‐1 zoning in  ANY part of Santa Monica.     On March 30, 2021, Council members Gleam Davis, Kevin McKeown, Kristin McCowan, and Sue Himmelrich voted to  consider changing the SFR zoning to allow developers to build at least 4 units on SFR lots, and to dramatically change  Montana Avenue, Main Street, and Ocean Park Boulevard to build nearly 9,000 housing units (6000 of which would be  classified as “affordable” low‐income units). This 9,000 number was NOT contested by the council, and should be closer  to 3,300 as per previous studies. Pro‐developer groups have pushed for these 9,000 additional units and have even  brazenly advocated to accept this number and pass this proposal WITHOUT public input.    This misguided upzoning proposal will destroy the desirability of Santa Monica as an attractive city. Property values will  decrease as the neighborhoods become less desirable when traffic, noise, density, and construction increase  dramatically. Schools will become overcrowded and city infrastructure will not be able to support this radical upzoning.     This proposal is extremely advantageous and extremely profitable to the developers and unions who are eager to  upzone and develop SFR parcels and the commercial corridors that provide the charm and desirability of our small city.      Homeowners in Santa Monica invest their savings and/or retirement funds to be able to purchase, maintain, and  upgrade their home. Homeowners are financially tied into their homes and their neighborhoods/communities.     There is NO homeowner who buys into a single family neighborhood hoping that a dense 4‐unit apartment building is  built next to them, across from them, or throughout the SFR zoned neighborhood that they believed they had bought  into.     Destroying our SFR neighborhoods will destroy the character of our city. Here are key points:     Upzoning will destroy desirable neighborhoods in the city. No single family homeowner dreams of becoming surrounded  by multi‐unit housing. Families have purchased their homes because of the zoning and neighborhoods. SFR families will  choose to leave and property values will decrease as the neighborhoods become less desirable.      Traffic, noise, density, construction, will increase dramatically. Current SFR neighborhoods do not have the  infrastructure to handle the increased density.   8.A.j Packet Pg. 173 Attachment: Written Comments [Revision 1] (4568 : Housing Element Review and Adoption) 2 Schools will be overcrowded. Less desirable school systems will result in less desirable neighborhoods. It will become a  race to the bottom.     FAMILIES BUY INTO NEIGHBORHOODS THEY CAN AFFORD. This has NOTHING to do with race, equity, social justice, or  minority advancement. Our neighborhoods are already ethnically and religiously diverse.     SFR families have their equity literally invested in their homes, neighborhoods, schools. Homeowners are not transient.  They are the anchors of the communities you wish to destroy.     Overlaying low income housing on Montana, Main, or Ocean Park Blvds, is unnecessary. Studies have shown that  downtown can accommodate the need for extra housing. There are numerous underutilized areas downtown that can  be built up to accommodate both retail + residential.     Please view the following articles:     https://www.smobserved.com/story/2021/04/05/opinion/time‐to‐move‐out‐santa‐monica‐is‐coming‐for‐your‐home‐ with‐upzoning‐plans‐for‐r‐1‐neighborhoods‐and‐putting‐public‐housing‐in‐your‐backyard/5492.html   https://smmirror.com/2020/08/where‐oh‐where‐is‐our‐city‐council/   https://www.smdp.com/the‐downsides‐of‐upzoning/200599   https://www.smobserved.com/story/2020/11/21/politics/surprise‐city‐does‐not‐actually‐want‐your‐input‐on‐upzoning‐ for‐additional‐8874‐units/5052.html   https://santamonicaarch.wordpress.com/2020/08/21/losing‐our‐city/   https://brentwoodnewsla.com/response‐to‐opinion‐of‐toby‐muresianu/     My question to the members are the following:     Would YOU like a 4‐unit next to your house on both sides? Across the street, too?     If you live in a condo or apartment, how would you feel if all of the other apartments in your building were subdivided  into 4 units so you can have at least 4x as many people in each unit? Would you stay in your apartment/condo if this  happened? What would happen to the noise in your building? Your parking? Your ability to use the pool? Your desire to  enjoy the unit as you rented/bought it when you rented/bought it?     Is your goal the destruction of Santa Monica’s neighborhoods in order to benefit developers, and your own interests?     Do you believe that eliminating homeowners is in the best interest of the city, traffic, infrastructure, and long term allure  of neighborhoods?     Do you believe it is in Santa Monica’s interest to decrease desirability and property values while overcrowding our  streets, neighborhoods, parks, schools, and public areas?      Finally, the people who love Santa Monica the most are the ones who have invested their finances and futures to buy a  family home in Santa Monica. You are voting to crush the the families who have actually vested in those neighborhood  to sell out to developers and special interests.     VOTE NO ON ALL UPZONING PROPROSALS.    In addition, please DEMAND that SCAG revise their numbers of units to a manageable number that is in line with the  preservation of our beautiful, inclusive city and way of life.    Thank you  Helene Rosenzweig   8.A.j Packet Pg. 174 Attachment: Written Comments [Revision 1] (4568 : Housing Element Review and Adoption) 3 Sent from my iPhone  8.A.j Packet Pg. 175 Attachment: Written Comments [Revision 1] (4568 : Housing Element Review and Adoption) 4 Vernice Hankins From:Council Mailbox Sent:Tuesday, June 15, 2021 2:36 PM To:councilmtgitems Subject:FW: Agenda item 7-A: Draft Housing Element     From: Alex Novakovich <alexnovak@verizon.net>   Sent: Tuesday, June 15, 2021 11:35 AM  To: Council Mailbox <Council.Mailbox@SMGOV.NET>  Subject: Agenda item 7‐A: Draft Housing Element    EXTERNAL    To: Mayor Himmelrich and City Council members:  I oppose rezoning R1 to multi‐family. The state already allows 3 housing units per R1 lot (original home, ADU,  and Jr. ADU).   I oppose the 100% affordable overlay proposed for north of Montana, northeast Santa Monica, and Sunset  Park.  I oppose an overlay that would allow 4‐story housing projects throughout the city. The LUCE focused housing in  downtown and along the major boulevards, not all over the city.   I oppose changes to the minimum percentage of inclusionary affordable housing in market rate projects. It  should remain at 20%.  I oppose eliminating parking requirements for housing projects. Forcing families to take the bus to shop for  groceries, or to commute to jobs that are not along bus routes is neither practical nor fair.   I support the revised quantified objective of round 5,500 units, with 40% affordable and 60% above moderate,  but I would like to know where the funding would come from.  The City of Santa Monica should be getting credit for the previous Housing Element when the city exceeded the  SCAG/RHNA allotment by 236%.  Thank you for your consideration.    Alex Novakovich  2607 26th St.  Santa Monica  8.A.j Packet Pg. 176 Attachment: Written Comments [Revision 1] (4568 : Housing Element Review and Adoption) 1 Vernice Hankins From:Council Mailbox Sent:Tuesday, June 15, 2021 2:18 PM To:councilmtgitems Subject:FW: Santa Monicans deserve a fully compliant Housing Element Attachments:Santa Monica Housing Element Petition.docx     From: Haley Feng <haley@abundanthousingla.org>   Sent: Tuesday, June 15, 2021 1:50 PM  To: Council Mailbox <Council.Mailbox@SMGOV.NET>  Subject: Santa Monicans deserve a fully compliant Housing Element    EXTERNAL    Dear Councilmembers,     Please find attached a petition for a fully compliant Santa Monica Housing Element, signed by 23 individuals who care  about the future of our community.       Respectfully,   Haley Feng  Communications Manager  Abundant Housing LA  8.A.j Packet Pg. 177 Attachment: Written Comments [Revision 1] (4568 : Housing Element Review and Adoption) Dear Councilmembers, The City of Santa Monica must use the Housing Element update process to meaningfully address the housing shortage crisis and to erase the continued legacy of redlining and other racist and classist housing policies. Redlining and restrictive covenants, which restricted where Black, Latino, and Asian Americans could live, were once common in Santa Monica and throughout Los Angeles County. Discrimination in housing takes other forms today: even after de jure segregation was banned, opponents of neighborhood change in prosperous areas weaponized zoning policy to make apartment construction illegal in much of Los Angeles County, especially in high-income areas. In the Planning Department's own words, “single family zoning originated as a form of exclusionary zoning to economically and racially segregate neighborhoods.” Even today, affordable housing opportunities tend to be located in formerly redlined areas. Santa Monica needs a housing element update that encourages strong housing growth at all levels of income, while promoting fair housing opportunities and undoing patterns of discrimination in housing. However, the draft site inventory runs counter to this goal and is inconsistent with state law, particularly the requirement that housing element updates affirmatively further fair housing. Most of the sites proposed fall within historically redlined neighborhoods, while bluelined neighborhoods see little if any new housing. We are concerned with the potential for fiscal and other negative impacts to the City if it does not submit a fully compliant Housing Element. In addition to the potential loss of local control over land use, potential loss of state and federal funding for affordable housing and other resources, if a court finds a city to be out of compliance, the court can order the city to pay fines to the California state housing trust fund, attorney's fees to the plaintiff, or both. Cal. Gov. Code § 65585(l)(1) defines an escalating structure of fines with a minimum amount of $10,000 per month and a maximum of $100,000 per month. Continued failure to achieve a certified Housing Element allows the court to multiply the fines by a factor of three per month and later a factor of six per month. As a City that has lost a great deal of its revenue and will be recovering from the fiscal impacts of COVID-19 for an undetermined period of time, the risk of a noncompliant housing element is one that we cannot afford to bear. We urge you to make major revisions to the draft housing element, in order to create a transformative, high-quality housing element that creates the housing we desperately need and distributes it across the city in order to end continued systemic segregation. This plan must: 8.A.j Packet Pg. 178 Attachment: Written Comments [Revision 1] (4568 : Housing Element Review and Adoption) • Include a well-designed density bonus program that applies to all residentially-zoned and commercially-zoned parcels, in order to incentivize affordable housing production. • Legalize multifamily housing in all neighborhoods. • Incorporate accurate estimates of the likelihood of development of suitable sites, and propose specific parcels for rezoning if the site inventory alone cannot achieve the RHNA goal. • Rezone high-opportunity census tracts and well-resourced areas (e.g. near transit, jobs, schools, parks, etc.) in order to accommodate lower-income housing opportunities. • Adjust zoning to ensure that affordable homes are also produced outside of historically redlined neighborhoods. • Eliminate all parking minimums citywide. • Put the City at the forefront of safe and efficient construction innovation, such as pre-fabrication, mass timber, and other emerging technologies to control the cost of housing, and streamline approval of code-compliant housing projects. Santa Monica must solve its housing affordability crisis and create a city where everyone can thrive. The time for action on housing is now! Respectfully, Joe Antognini Jeremy Bamberger Stephen Bergauer Logan Cimino Alexander Copulsky Sandra Gruner-Domic Ryan Hass Mark Larson Gil Leib Charlie McNulty Eduardo Mendoza Babak Mozaffari Alex Olivares Gwynne Pugh Randolph Ruiz Tieira Ryder Lorraine Shimahara Matt Stauffer Matthew Stevens Lauren Wrenn Sean Youssefi Natalya Zernitskaya 8.A.j Packet Pg. 179 Attachment: Written Comments [Revision 1] (4568 : Housing Element Review and Adoption) City Council Draft 6th Cycle Housing Element Update June 15, 2021 8.A.k Packet Pg. 180 Attachment: PowerPoint Presentation (4568 : Housing Element Review and Adoption) Agenda 1.Components of a Compliant Housing Element 2.Goals & Policies 3.Housing Programs A.RHNA Compliance: Housing Production & Suitable Sites Inventory B.AFFH Compliance: Equitable Housing Access C.Housing Stability 4.Discussion and direction to staff A.Transmit draft Housing Element as amended to HCD B.State density bonus application to pending housing projects 8.A.k Packet Pg. 181 Attachment: PowerPoint Presentation (4568 : Housing Element Review and Adoption) Why Plan for Housing? 2021-2029 6th Cycle Housing Element guided by community vision and adopted policy •State law requires the City to plan for the community’s housing needs every eight years •Final RHNA allocation of 8,895 units was adopted by the SCAG Regional Council on March 4, 2020. With COVID19 pandemic, thousands face threat of evictions and homelessness •Pandemic has highlighted racial and socioeconomic inequities •Provide housing stability for existing residents and create housing opportunities for all 8.A.k Packet Pg. 182 Attachment: PowerPoint Presentation (4568 : Housing Element Review and Adoption) Mandated by State Housing Element Law •Encourage Housing Production •65583.2(c)(3) -zoning must be appropriate to accommodate the RHNA (8,895 units) which includes lower income housing •Demonstrate through Suitable Sites Inventory •Account for financial feasibility •AFFH –Established by AB686 (2018) •Public agencies required to take, “…deliberate action to explicitly address, combat, and relieve disparities resulting from past and current patterns of segregation to foster more inclusive communities.” 8.A.k Packet Pg. 183 Attachment: PowerPoint Presentation (4568 : Housing Element Review and Adoption) Council Direction From March 30 •Compliant housing element that addresses historic discrimination and satisfies Affirmatively Furthering Fair Housing requirements. •Prioritize 100% affordable housing on City-owned land (with consideration for use by artists or as open space). •Select Option B for distribution of potential housing sites, with consideration of zoning changes necessary to incentivize housing relative to commercial. •Pursue 100% affordable housing overlay zone with exception of environmental justice and previously redlined zones. •Explore •Diverse opportunities for affordable home ownership and transition from renters to owners by residents. •ADU incentives in R1 areas, including potential for deed-restricted ADUs. •Options to densify areas that historically excluded diverse populations and affordable housing, to increase equitable and affordable housing access, including but not limited to voluntary lot splits/duplexes with affordability covenants. •Promote diversity and inclusion in every neighborhood in Santa Monica. 8.A.k Packet Pg. 184 Attachment: PowerPoint Presentation (4568 : Housing Element Review and Adoption) June 2/3 -Planning Commission Discussion •Ensuring feasibility for housing projects; •Implementing a robust state density bonus program with a broad menu of frequently requested concessions; •Promoting innovative construction methods and sustainability in new housing; •Updating the development standards to ensure new housing is feasible; •Modifying the proposed affordable housing overlay to apply only to moderate-income projects in targeted areas; •Limiting the upzoning of R1 to commercial-adjacent parking lots; and •Initiating an expansive public process that would explore options to redress the impact of historically exclusionary single-unit zoning. Detailed changes in Attachment B 8.A.k Packet Pg. 185 Attachment: PowerPoint Presentation (4568 : Housing Element Review and Adoption) Proposed Goals & Policies 1 8.A.k Packet Pg. 186 Attachment: PowerPoint Presentation (4568 : Housing Element Review and Adoption) Santa Monica’s Draft Housing Element Divided into 5 Chapters: I.Introduction II.AFFH III.Goals & Policies IV.Land Available for Housing V.Implementation Programs Technical Appendices Focus on 4 principles 8.A.k Packet Pg. 187 Attachment: PowerPoint Presentation (4568 : Housing Element Review and Adoption) Production of new housing that is sustainable, innovative, safe and resilient, appropriate with the surrounding neighborhood, offers opportunities for active and healthy living, including walking and biking, and increases equitable housing opportunities Policies: •1.1 -Adequate Land •1.2 -Housing Production Incentives •1.3 -Adaptive Reuse •1.4 -Design of Housing •1.5 -Innovative and Sustainable Housing •1.6 -Housing for Special Needs •1.7 -Review of Housing Constraints •1.8 -Streamlined Housing Process Goal 1: Overall Housing Production 8.A.k Packet Pg. 188 Attachment: PowerPoint Presentation (4568 : Housing Element Review and Adoption) Goal 2: Affordable Housing Production Housing production for all income categories including for the community’s workforce and most vulnerable communities Policies •2.1 -Affordable Housing Financing •2.2 -Local Assistance for Affordable Housing •2.3 -Advocacy for Legislative Changes •2.4 -Local Incentives and Streamlining for Affordable Housing •2.5 -Explore Homeownership Opportunities •2.6 -New Funding Sources 8.A.k Packet Pg. 189 Attachment: PowerPoint Presentation (4568 : Housing Element Review and Adoption) Goal 3: Preserve Existing Housing Preservation of the existing supply of housing and prevent displacement of existing tenants Policies •3.1 -Support Rent Control Law •3.2 -Preserve Naturally Occurring and Deed-Restricted Affordable Housing •3.3 -Protection of Rental Units •3.4 -Replacement of Demolished Multi-Unit Housing •3.5 -Availability of Affordable Housing •3.6 -Rehabilitation Assistance •3.7 -Public and Private Funding for Rehab & Preservation •3.8 -Continued Maintenance of Existing Housing •3.9 -Resident Protections During Rehabilitation 8.A.k Packet Pg. 190 Attachment: PowerPoint Presentation (4568 : Housing Element Review and Adoption) Goal 4: Equitable Housing Access A community that provides equitable housing access to all neighborhoods Policies •4.1 -Equitable Distribution of Housing for All Income Levels •4.2 -Access to Opportunities •4.3 -Targeted Investments 8.A.k Packet Pg. 191 Attachment: PowerPoint Presentation (4568 : Housing Element Review and Adoption) Goal 5: Address Homelessness Housing for persons experiencing homelessness Policies •5.1 -Regional Fair Share Approach •5.2 -Housing and Supportive Services for the Homeless •5.3 -Removal of Barriers to Supportive Housing 8.A.k Packet Pg. 192 Attachment: PowerPoint Presentation (4568 : Housing Element Review and Adoption) Goal 6: Housing Assistance Provision of housing assistance and supportive programs and services to extremely low, very low, and, moderate income households with special needs, families, seniors, and the homeless Policies •6.1 -Financial Assistance for Residents •6.2 -Technical Housing Assistance •6.3 -Funding for Supportive Services 8.A.k Packet Pg. 193 Attachment: PowerPoint Presentation (4568 : Housing Element Review and Adoption) Goal 7: Anti-Discrimination in Housing Eliminate housing discrimination on the basis of race, color, religion, sex, gender, gender identity, gender expression, sexual orientation, age, marital status, national origin, ancestry, familial status, income level, source of income, disability, veteran or military status, genetic information, or other such characteristics. Policies •7.1 -Enforce Fair Housing Laws •7.2 -Legal Support for Residents •7.3 -Fair Housing Community Outreach •7.4 -Reasonable Accommodations 8.A.k Packet Pg. 194 Attachment: PowerPoint Presentation (4568 : Housing Element Review and Adoption) RHNA Compliance: Housing Production 2 8.A.k Packet Pg. 195 Attachment: PowerPoint Presentation (4568 : Housing Element Review and Adoption) Housing Production Strategies Programs for Housing Production •Program 2C -Revise Affordable Housing Production Program (AHPP) •Program 4B -Establish FARs at levels that can support minimum AHPP requirements •Program 1E & 1F -Revisit DCP and Bergamot Area Plan development standards •Program 2D -Layer on density bonus •Program 2E & 2F -Commit City-owned sites for 100% affordable housing •Program 4C -Parking lots of religious congregations •Program 1C –Surface parking lots •Program 1G -ADU Accelerator Program •Program 1H -Adaptive Reuse of existing commercial space to residential •Program 1A -Process Streamlining •Program 2G, 5A, 5B, 6A, 6B, 6C –Special Needs Housing and Housing for Homeless 8.A.k Packet Pg. 196 Attachment: PowerPoint Presentation (4568 : Housing Element Review and Adoption) Housing Production Programs Revise AHPP •Establish minimum affordability percentage of 10% Very Low Income Feasibility testing for housing projects •Propose height and FAR based on feasibility testing •Need to increase FARs in all commercial zones over existing Tier 2 except Downtown •New Tier 1 housing FARs are higher than existing commercial FAR •Eliminate Tier 2 for housing projects 8.A.k Packet Pg. 197 Attachment: PowerPoint Presentation (4568 : Housing Element Review and Adoption) Illustrative Example of Proposed FAR MUBL Example to Illustrate –Preliminary FAR estimates & # of units based on 10% VLI (before State Density Bonus) Existing FAR Estimated Units based on Existing FAR Proposed FAR Estimated Units based on Proposed FAR # of Affordable Units (10% of base units) Tier 1 1.25 17 1.25 17 2 Tier 1 with on-site affordable housing 1.5 (3 stories)21 2.25 (4 stories)32 3 Tier 2 (voluntary)1.75 (3 stories)25 ------ 100% Affordable Housing 2.0 28 Unlimited 28 28 100% Affordable Housing Augmented by AB1763 Unlimited 51 Unlimited 51 51 8.A.k Packet Pg. 198 Attachment: PowerPoint Presentation (4568 : Housing Element Review and Adoption) Plan Area Revisions •Bergamot & Downtown •Revise development standards to levels that can support minimum AHPP requirements and incentivize housing •Bergamot •Improve design standards to be more user- friendly •Downtown •Reconsider height/inclusionary requirement relationship Bergamot & Downtown Note: Five votes needed to increase height and FAR in LUCE and DCP 8.A.k Packet Pg. 199 Attachment: PowerPoint Presentation (4568 : Housing Element Review and Adoption) Layering on State Density Bonus •Housing Element law directs establishing supportable FARs absent State density bonus •Projects entitled to % increase in density bonus over established FAR •Applicants can still request “incentives and concessions” to request relief to any development standard Percentage Very Low Income Units Percentage Density Bonus 5 20 6 22.5 7 25 8 27.5 9 30 10 32.5 11 35 12 38.75 13 42.5 14 46.25 15 50 Current AHPP 8.A.k Packet Pg. 200 Attachment: PowerPoint Presentation (4568 : Housing Element Review and Adoption) Interim State Density Bonus Approach Applies to pending projects before ordinance update •Approach similar to West Hollywood model •Apply density bonus as percentage increase to current Tier 1 FAR standards •Process incentives and concessions for relief from development standards administratively 8.A.k Packet Pg. 201 Attachment: PowerPoint Presentation (4568 : Housing Element Review and Adoption) Prioritizing City Sites for Affordable Housing Assessment of Capacity •Estimated capacity yield of 1,884 units •Priority sites over 1 acre •4th/Arizona •Bergamot Arts Center (retain artists) •Main Street parking lots •Assume that all sites could develop at approx. 150 units/acre •Financing gap ranges of $50 -$250M to be filled by other public or private funding source 8.A.k Packet Pg. 202 Attachment: PowerPoint Presentation (4568 : Housing Element Review and Adoption) Parking Lots of Religious Congregations Support for Affordable Housing but Need Flexibility for Market Rate •Presents unique opportunity to further equitable access to all residential neighborhoods •Significant interest in pursuing housing and replacement parking •Need to consider financial feasibility and possibility of market-rate housing to support affordable housing 8.A.k Packet Pg. 203 Attachment: PowerPoint Presentation (4568 : Housing Element Review and Adoption) Surface Parking Lots of Existing Commercial Use Incentivize Housing Production on Parking Lots Associated with Existing Commercial Uses •Remove density caps •Flexibility in “A-lot” rules to allow opportunity for replacement parking •Opportunity to increase housing opportunities in some high resource residential neighborhoods without displacing existing residents 8.A.k Packet Pg. 204 Attachment: PowerPoint Presentation (4568 : Housing Element Review and Adoption) ADU Accelerator Program •Pre-approved plans •User-friendly guidebooks •Streamline city review •Review applicable fees Simplify and streamline ADU approval process 8.A.k Packet Pg. 205 Attachment: PowerPoint Presentation (4568 : Housing Element Review and Adoption) ADU Accelerator Program Revised Recommended ADU Incentive Program within the R1 Zone District •Existing: maximum number of units on R1 parcel is three •One additional ADU if the property owner is willing to deed restrict one of the ADUs as a rental unit •Explore other incentives such as larger size to enhance likelihood of program •Program helps achieve affirmatively furthering fair housing by providing more affordable rental housing opportunities within the R1 zone district Existing: 1 SUD + 1 JADU + 1 ADU Proposed: 1 SUD + 1 JADU + 1 ADU + 1 deed-restricted ADU 8.A.k Packet Pg. 206 Attachment: PowerPoint Presentation (4568 : Housing Element Review and Adoption) Adaptive Reuse •Explore policy changes to incentivize conversion of existing commercial space •Identify potential barriers •Cost of conversion •Parking •Unit mix •Open space •Technical Code adjustments Encourage Adaptive Reuse of Existing Commercial Buildings for Housing Source: https://www.forbes.com/sites/axiometrics/2017/03/29/how-commercial-real-estate-use-is- changing-5-adaptive-reuse-success-stories/?sh=62a28e1a5576 8.A.k Packet Pg. 207 Attachment: PowerPoint Presentation (4568 : Housing Element Review and Adoption) Streamlined Process •Make process thresholds IZO permanent •Administrative process based on objective standards for •100% affordable housing projects – including moderate-income projects •Housing projects subject to the Housing Accountability Act Streamline the permit approval process for Code-compliant housing projects 8.A.k Packet Pg. 208 Attachment: PowerPoint Presentation (4568 : Housing Element Review and Adoption) Housing for Special Needs & Homeless •Housing for seniors, persons with disabilities •Consider new housing types to serve persons with disabilities •Support Permanent Supportive Housing – already a permitted use in all zones •Seek regional cooperation •Add Low Barrier Navigation Centers as by- right use Support Special Needs Housing and Permanent Supportive Housing 8.A.k Packet Pg. 209 Attachment: PowerPoint Presentation (4568 : Housing Element Review and Adoption) Land for Housing: Suitable Sites Inventory 3 8.A.k Packet Pg. 210 Attachment: PowerPoint Presentation (4568 : Housing Element Review and Adoption) Suitable Sites Inventory (SSI) SSI purpose •Identify whether sites can accommodate housing •Helps determine whether there are sufficient adequately zoned sites to accommodate the RHNA by income category •Is not prediction or guarantee of the future nor does it obligate a property owner to do anything Methodology •Identify objective qualities of properties that have redeveloped into housing •Follows HCD’s Housing Element Site Inventory Guidebook •HCD recommends a buffer of 15 to 30 percent 8.A.k Packet Pg. 211 Attachment: PowerPoint Presentation (4568 : Housing Element Review and Adoption) SSI Summary Summary of Total Land Capacity •Total of 11,025 units (includes 24% buffer) Capacity # Affordable Units ELI VLI LI Moderate Category 1 Approved 1,503 416 104 104 104 104 Category 1 Pending 680 165 42 42 42 42 Category 4 City owned Sites 1,884 1,696 424 424 424 424 Category 11 Religious Sites 257 193 48 48 48 48 Category 12 Parking Lots 94 47 12 12 12 12 All Remaining Categories 6,007 3,805 855 855 855 1,239 ADUs 600 396 90 12 258 36 Total 11,025 6,718 1,575 1,497 1,743 1,905 RHNA Targets 8,895 6,168 1,397 1,397 1,672 1,702 Buffer/Shortfall 2,130 550 178 100 71 203 24% 8.A.k Packet Pg. 212 Attachment: PowerPoint Presentation (4568 : Housing Element Review and Adoption) SSI –Other Scenarios SSI capacity of other scenarios modeled •Alternative Scenarios •Existing Tier 1 FARs –below RHNA allocation •5,729 units •FARs cannot support housing project with City’s existing minimum AHPP requirements •Existing Tier 2 FARs –can meet RHNA but potentially not compliant with Housing Element Law •Tier 2 is voluntary tier that requires community benefits –may not be permitted to use as the basis of SSI calculations •Does not account for feasibility 8.A.k Packet Pg. 213 Attachment: PowerPoint Presentation (4568 : Housing Element Review and Adoption) Programs to Affirmatively Furthering Fair Housing 4 8.A.k Packet Pg. 214 Attachment: PowerPoint Presentation (4568 : Housing Element Review and Adoption) Affirmatively Furthering Fair Housing What is Affirmatively Further Fair Housing (AFFH)? •State law requires cities to ensure that their laws, programs and activities affirmatively further fair housing •Per AB 686, Housing Elements must include a discussion of the following related to AFFH ✓Outreach efforts to all segments of the community ✓Assessment of Fair Housing, including patterns and trends, local data and knowledge, and summary of fair housing issues ✓Site Inventory to not only accommodate the RHNA, but also serve the purpose of replacing segregated living patterns with truly integrated and balanced living patterns ✓Identification and Prioritization of Contributing Factors to fair housing ✓Goals and Actions to affirmatively further fair housing opportunities and promote housing throughout the community for all 8.A.k Packet Pg. 215 Attachment: PowerPoint Presentation (4568 : Housing Element Review and Adoption) Affirmatively Furthering Fair Housing •Santa Monica’s established neighborhoods today were influenced by discriminatory policies of the past, including exclusionary zoning and redlining •Location of renters/owner households, Non-Whites, and areas with the lowest opportunity indices correlate with patterns of housing segregation 8.A.k Packet Pg. 216 Attachment: PowerPoint Presentation (4568 : Housing Element Review and Adoption) City’s Leadership in Housing The City has a strong track record of protecting rental housing stock, producing affordable housing, and housing-assistance programs for existing residents •Rent Control has been in place for over 40 years •The City has an ordinance prohibiting source of income discrimination (SMMC 4.28.030(a)), and a division within the City Attorney’s Office that enforces this ordinance •Strong tenant protections including just-cause evictions, tenant harassment regulations, and notice of tenant buyouts •AHPP that requires market-rate projects to provide inclusionary units has been in place for over 30 years •Preserving Our Diversity (POD) program that provides cash-based assistance to low-income seniors •Housing Choice Voucher program 8.A.k Packet Pg. 217 Attachment: PowerPoint Presentation (4568 : Housing Element Review and Adoption) Assessing AFFH: High Resource Areas Santa Monica is a high-resource area •2020 Assessment of Fair Housing Goal 1 -Increase the supply of affordable housing: •Allocate city-owned land for affordable housing •Explore reduction in costs of permits for nonprofit housing developers •Reduce parking requirements for supportive housing developments •Explore zoning changes to facilitate the development of affordable housing in areas without publicly supported housing developments •Further leverage City funds in the development of affordable housing https://www.treasurer.ca.gov/ctcac/opportunity.asp 8.A.k Packet Pg. 218 Attachment: PowerPoint Presentation (4568 : Housing Element Review and Adoption) Affirmatively Furthering Fair Housing Programs for Affirmatively Furthering Fair Housing (AFFH) •Program 2.A -100% Affordable Housing Overlay •Program 2.B –Right of First Offer to Buy Land •Program 4.A -Allow housing as a permitted use in areas formerly prohibiting housing •Program 4.B -Modify development standards to increase the likelihood of housing projects in areas where such housing has not formerly occurred •Program 4.D -Eliminate Single Family Zoning to increase equitable housing access to all neighborhoods 8.A.k Packet Pg. 219 Attachment: PowerPoint Presentation (4568 : Housing Element Review and Adoption) Lower Income Affordable Housing Overlay “Filling in the gaps” (Not recommended by Planning Commission) •AB1763 applies to areas within ½ mile of major transit stop and only for projects up to 80% AMI •Extra 3 stories or 33 feet •Unlimited density •No minimum parking requirements •Apply these standards to the remainder of the city •Difference is to allow unlimited height 8.A.k Packet Pg. 220 Attachment: PowerPoint Presentation (4568 : Housing Element Review and Adoption) Moderate Income Affordable Housing Overlay 120% AMI Targeted to certain areas (e.g. around major transit stops) •Must be 100% moderate-income units •Apply AB1763 •Extra 3 stories or 33 feet •Change:50% density bonus above base FARs •No minimum parking requirements •Flexibility to allow micro units with significant common area amenities Planning Commission Recommendation (Not recommended by staff) •Project does not need to be all moderate-income units •Unlimited density instead of 50% bonus 8.A.k Packet Pg. 221 Attachment: PowerPoint Presentation (4568 : Housing Element Review and Adoption) Support 100% Affordable Housing Explore Right of First Offer to Buy Land •Modelled after San Francisco’s COPA ordinance •Allows non-profit affordable housing providers to receive advanced notice and submit offer when land goes on sale 8.A.k Packet Pg. 222 Attachment: PowerPoint Presentation (4568 : Housing Element Review and Adoption) Housing as Permitted Use & Incentives Dispersed Housing Adding Housing as Permitted Use in Areas where it has been prohibited •Office Campus, and Industrial Conservation Upzone for Housing Potential in Areas that Have Not Accommodated Housing in the Past •Main Street, Montana, Ocean Park Boulevard, Office Campus, and Industrial Conservation 8.A.k Packet Pg. 223 Attachment: PowerPoint Presentation (4568 : Housing Element Review and Adoption) Fair Housing Access to R1 Zones Approach •Analysis of North of Montana and Sunset Park R1 neighborhoods •Will only apply to lots of a minimum size •Key Policy Goals & Questions •Increase Housing Access •How many units can fit within the existing R1 envelope accounting for architectural and financial feasibility? •Produce Inclusionary Units •How many units are needed to support at least one inclusionary affordable housing unit on an average 7,500 sf lot? Neighborhood # R1/OP1 Parcels # Total Parcels % Single Unit Zoning NE Neighbors 891 1224 73% NOMA 2684 3933 68% FOSP 2714 4355 62% PNA 219 3049 7% OPA 161 3157 5% Mid City 0 3374 0% Wilmont 0 4487 0% Measuring Diverse Housing Opportunities by Neighborhood 8.A.k Packet Pg. 224 Attachment: PowerPoint Presentation (4568 : Housing Element Review and Adoption) Fair Housing Access to R1 Zones Findings of what fits in R1 envelope •Within existing R1 envelope •Unlikely to produce multi-unit development •Only North of Montana would be likely to proceed with multi-unit development (3 units) •Needs increase to parcel coverage 8.A.k Packet Pg. 225 Attachment: PowerPoint Presentation (4568 : Housing Element Review and Adoption) Fair Housing Access to R1 Zones Findings of what’s needed to support one inclusionary unit •5 units including 1 inclusionary unit supportable in NOMA •Sunset Park would need 6 units to be supportable •Need more height 8.A.k Packet Pg. 226 Attachment: PowerPoint Presentation (4568 : Housing Element Review and Adoption) Fair Housing Access to R1 Zones Previously Proposed Program •Allow up to 3 units in R1 zones with minimum lot size •Upzone R1 to R2 in certain cross-town routes •Possible Alternative for consideration •Commercial adjacent parcels 8.A.k Packet Pg. 227 Attachment: PowerPoint Presentation (4568 : Housing Element Review and Adoption) Revised Recommendation Increasing Rental Units in R1 Zone District •Revised Program 4D language: Program 4.D: Explore Options to Address R1 Neighborhoods •The City shall explore options to address historically exclusionary single unit dwelling zones through future land use decisions. •Staff recommended alternative for equitable housing access: Program 1.G: Promote The Use Of Accessory Dwelling Units Through An ADU Accelerator Program •The program will also encourage/incentivize the production of affordable ADUs that will affirmatively further fair housing by providing more affordable rental housing opportunities, that would be affordable by design,within single-unit residential districts, an area of the City with high housing costs that has largely been unaffordable to many. 8.A.k Packet Pg. 228 Attachment: PowerPoint Presentation (4568 : Housing Element Review and Adoption) 5 Housing Stability Programs 8.A.k Packet Pg. 229 Attachment: PowerPoint Presentation (4568 : Housing Element Review and Adoption) Housing Stability Housing Stability | Rehabilitation + Assistance/Support Programs 1.Housing Preservation Programs Rehabilitation assistance to maintain, improve, and extend use / livability of aging residential buildings. 2.Housing Assistance Programs + Services Financial & technical support to all income groups and household types including families, seniors, persons with disabilities, others w/special needs. 8.A.k Packet Pg. 230 Attachment: PowerPoint Presentation (4568 : Housing Element Review and Adoption) 1.Rental Assistance Need for financial support for seniors, families, persons with disabilities, etc 2.Resident Services / Tenant Protections Need for continued tenant protection/assistance 3.Support Services Programs that Serve Homeless/At-Risk Individuals Continued support services, case management 4.Preserve Housing Affordability Rehabilitating existing housing including covenant and non-covenant units Resident Needs 8.A.k Packet Pg. 231 Attachment: PowerPoint Presentation (4568 : Housing Element Review and Adoption) Goals | Implementing Programs Goal 3.0 Preservation of the Existing Supply of Housing and Prevent Displacement of Existing Tenants Programs •3.A Restrict Removal of Existing Rental Units for Site Dev. & Req. Protected Units are Replaced •3.B Develop Programs to Address State and Federal Legislative Mandates •3.C Facilitate the Conservation of Restricted and Non-Restricted At-Risk Housing •3.D Maintain an Acquisition and Rehabilitation Program •3.E Maintain a Low-Income Residential Repair Program •3.F Maintain Code Enforcement Response to Housing-Related Violations •3.G Maintain a Mandatory Seismic Retrofit Program •3.H Information & Outreach for Property Owners on Rehab and Maintenance of Housing Units 8.A.k Packet Pg. 232 Attachment: PowerPoint Presentation (4568 : Housing Element Review and Adoption) Goals | Implementing Programs Goal 5.0 Housing for Persons Experiencing Homelessness Programs •5.A -Reduce the Number of Homeless Individuals Living on the Streets of Santa Monica through the Provision of a Range of Housing Options w/an Emphasis on Affordable, Permanent, and Supportive Housing •5.B -Low Barrier Navigation Centers as By-Right Use 8.A.k Packet Pg. 233 Attachment: PowerPoint Presentation (4568 : Housing Element Review and Adoption) Goals | Implementing Programs Goal 6.0 Provision of Housing Assistance and Supportive Programs and Services to Extremely Low-, Very Low-, Low-, and Moderate-Income Households and Households with Special Needs, Families, Seniors, and the Homeless Programs: •6.A -Maintain Rental Housing Voucher Programs & Expand to Assist All Persons w/Disabilities •6.B -Seek Funding Sources to Support Rental Assist. for Vulnerable At-Risk of Displacement •6.C -Maintain & Expand the Preserving Our Diversity (POD) Program •6.D -Information & Outreach for Tenants + Landlords on Housing Programs/Resources •6.E -Maintain a Community Development Grant Program •6.F -Provide Tenant Relocation Assistance •6.G -Maintain a Temporary Relocation Program •6.H -Maintain Reasonable Accommodations to Ensure Equal Opportunity for Housing 8.A.k Packet Pg. 234 Attachment: PowerPoint Presentation (4568 : Housing Element Review and Adoption) Goals | Implementing Programs Goal 7.0 Eliminate Housing Discrimination on the Basis of Race, Color, Religion, Sex, Gender, Gender Identity, Gender Expression, Sexual Orientation, Age, Marital Status, National Origin, Ancestry, Familial Status, Income Level, Source of Income, Disability, Veteran or Military Status, Genetic Information, or other such Characteristics. Programs: •7.A -Maintain Fair Housing Programs •7.B -Provide Tenant / Landlord Mediation & Legal Services •7.C -Right to Counsel Program •7.D -Maintain a Tenant Eviction Protection Program 8.A.k Packet Pg. 235 Attachment: PowerPoint Presentation (4568 : Housing Element Review and Adoption) 6 Discussion Guide 8.A.k Packet Pg. 236 Attachment: PowerPoint Presentation (4568 : Housing Element Review and Adoption) What’s Needed from Council 1.Direct staff to transmit Draft Housing Element, including review of changes in addenda (Attachment B) and any other changes directed by Council 2.Direction on Interim State Density Bonus approach 8.A.k Packet Pg. 237 Attachment: PowerPoint Presentation (4568 : Housing Element Review and Adoption) 8.A.k Packet Pg. 238 Attachment: PowerPoint Presentation (4568 : Housing Element Review and Adoption) ADUs SCAG’s Pre-Approved Affordability Levels: •Extremely Low –15% •Very Low –2% •Low –43% •Moderate –6% •Above Moderate –34% 8.A.k Packet Pg. 239 Attachment: PowerPoint Presentation (4568 : Housing Element Review and Adoption) SSI 8.A.k Packet Pg. 240 Attachment: PowerPoint Presentation (4568 : Housing Element Review and Adoption) 8.A.k Packet Pg. 241 Attachment: PowerPoint Presentation (4568 : Housing Element Review and Adoption)