SR 06-15-2021 8A
City Council Report
City Council Meeting: June 15, 2021
Agenda Item: 8.A
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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.
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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
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• 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
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• 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.
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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.
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• 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
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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,
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• 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:
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• 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.
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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
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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
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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)
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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§ionNum=65915
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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)
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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
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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.
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• 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
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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
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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
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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
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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
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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.
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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
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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.”
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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
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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
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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
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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:
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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
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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)
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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
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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
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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
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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
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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
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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
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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-
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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
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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.
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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.
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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.
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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.
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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.
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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
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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
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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
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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
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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
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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
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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
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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
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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
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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
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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
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June 2 – 3, 2021
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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
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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
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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
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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
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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)
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Housing Element 2021- 2029
June 2 – 3, 2021
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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)
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Housing Element 2021- 2029
June 2 – 3, 2021
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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.
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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
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June 2 – 3, 2021
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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
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June 2 – 3, 2021
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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
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Section
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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
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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
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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
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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
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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
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Packet Pg. 89 Attachment: HR&A City-Owned Sites Analysis (4568 : Housing Element Review and
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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
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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
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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
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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
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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
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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
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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
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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
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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
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Packet Pg. 97 Attachment: HR&A FAR-AHPP Analysis (4568 : Housing Element Review and Adoption)
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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
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Packet Pg. 98 Attachment: HR&A FAR-AHPP Analysis (4568 : Housing Element Review and Adoption)
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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
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Packet Pg. 99 Attachment: HR&A FAR-AHPP Analysis (4568 : Housing Element Review and Adoption)
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0.0
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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
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Packet Pg. 100 Attachment: HR&A FAR-AHPP Analysis (4568 : Housing Element Review and Adoption)
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0.0
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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
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Packet Pg. 101 Attachment: HR&A FAR-AHPP Analysis (4568 : Housing Element Review and Adoption)
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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
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0.0
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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
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Packet Pg. 103 Attachment: HR&A FAR-AHPP Analysis (4568 : Housing Element Review and Adoption)
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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
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0.0
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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
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0.0
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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
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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
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Packet Pg. 107 Attachment: HR&A FAR-AHPP Analysis (4568 : Housing Element Review and Adoption)
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0.0
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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
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Packet Pg. 108 Attachment: HR&A FAR-AHPP Analysis (4568 : Housing Element Review and Adoption)
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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
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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
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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.
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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
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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
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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!
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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
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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
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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!
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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
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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.
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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
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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
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_________________________________________________________________________________
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/
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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/
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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.
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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
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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.
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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)
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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.
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Thank you for your consideration.
smnoma.org
NOMAboard@gmail.com
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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
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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.
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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
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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
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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
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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
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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.
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Thank you for your assistance.
Regards,
Olga Zurawska
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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)).
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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
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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.
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- 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
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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/
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HOLC Redlining Map (1930s)
Percent of Population Non-White (2018)
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CalEnviroScreen 4.0 – Measures pollution burden by neighborhood
HUD Low to Moderate Income Population
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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
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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)
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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:
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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.
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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
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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/
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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/
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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.
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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
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Sent from my iPhone
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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
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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
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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:
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• 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
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City Council
Draft 6th Cycle Housing Element Update
June 15, 2021
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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
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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
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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.”
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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.
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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
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Proposed Goals & Policies
1
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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
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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
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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
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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
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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
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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
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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
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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
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Packet Pg. 194 Attachment: PowerPoint Presentation (4568 : Housing Element Review and Adoption)
RHNA Compliance: Housing Production
2
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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
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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
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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
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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
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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
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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
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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
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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
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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
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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
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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
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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
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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
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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
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Packet Pg. 209 Attachment: PowerPoint Presentation (4568 : Housing Element Review and Adoption)
Land for Housing: Suitable Sites Inventory
3
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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
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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%
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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
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Packet Pg. 213 Attachment: PowerPoint Presentation (4568 : Housing Element Review and Adoption)
Programs to Affirmatively Furthering Fair Housing
4
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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
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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
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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
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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
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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
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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
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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
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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
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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
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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
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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
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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
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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
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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.
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Packet Pg. 228 Attachment: PowerPoint Presentation (4568 : Housing Element Review and Adoption)
5
Housing Stability Programs
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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.
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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
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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
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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
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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
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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
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Packet Pg. 235 Attachment: PowerPoint Presentation (4568 : Housing Element Review and Adoption)
6
Discussion Guide
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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
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Packet Pg. 237 Attachment: PowerPoint Presentation (4568 : Housing Element Review and Adoption)
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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%
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Packet Pg. 239 Attachment: PowerPoint Presentation (4568 : Housing Element Review and Adoption)
SSI
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Packet Pg. 240 Attachment: PowerPoint Presentation (4568 : Housing Element Review and Adoption)
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Packet Pg. 241 Attachment: PowerPoint Presentation (4568 : Housing Element Review and Adoption)